Smart Way SIP and Transportation
Conformity Guidance:
Accounting for NOx Reductions
from Trailer Aerodynamic Kits and
Low Rolling Resistance Tires
Guidance for State and Local
Air and Transportation Agencies
&EPA
United States
Environmental Protection
Agency
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Smart Way SIP and Transportation
Conformity Guidance:
Accounting for NOx Reductions
from Trailer Aerodynamic Kits and
Low Rolling Resistance Tires
Guidance for State and Local
Air and Transportation Agencies
Transportation and Regional Programs Division
Office of Transportation and Air Quality
U.S. Environmental Protection Agency
v>EPA
United States EPA420-B-07-004
Environmental Protection , „„.,
Agency June 2007
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TABLE OF CONTENTS
CHAPTER 1 Introduction 5
1.1 What is the purpose of this guidance? 5
1.2 Which SmartWay technologies are addressed by this guidance? 6
1.3 What trucks can be part of a SmartWay project? 7
1.4 How can NOx emission reductions from SmartWay projects be used to
meet SIP and conformity needs? 8
1.5 How does this guidance relate to the Voluntary Mobile Source Emission
Reduction Program SIP guidance? 9
1.6 How does this guidance relate to existing Clean Air Act requirements? 9
1.7 Who should I contact for additional information? 10
CHAPTER 2 Quantifying Retrofit Emission Reductions 13
2.1 How do I quantify emission reductions from SmartWay projects? 13
2.2 What is NMIM and why does EPA recommend its use to quantify
emission reductions from SmartWay projects? 13
2.3 What are the uses and limitations of NMIM? 15
2.4 Can I use NMIM to quantify emission reductions from SmartWay projects
even if I am not using it to generate the local inventory? 16
2.5 Can I use NMIM to estimate emission reductions from SmartWay projects
for uses other than SIPs or conformity determinations? 16
2.6 Where would I get estimates of specific SmartWay project information
needed to quantify emissions reductions from a SmartWay project? 17
2.7 How do I use NMIM to quantify emission reductions from SmartWay
projects? 17
CHAPTERS Using Emission Reductions in SIPs 25
3.1 What are the basic requirements for using emission reductions in SIPs? 25
3.2 How can the estimated NOx emission reductions be used for SIP
purposes? 29
3.3 What would a state submit to EPA to meet the requirements for
incorporating a SmartWay project in a SIP? 29
3.4 What monitoring and record keeping should occur to document NOx
emission reductions from SmartWay projects? 30
3.5 What validation and reconciliation should occur for emission reductions in
SIPs approved under the VMEP guidance? 31
3.6 What penalties can EPA impose for not complying with Clean Air Act
requirements? 31
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CHAPTER 4 Using Emission Reductions in Transportation Conformity
Determinations 33
4.1 What is transportation conformity? 33
4.2 How can NOx emission reductions from SmartWay projects be included
in transportation conformity determinations? 34
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CHAPTER 1
INTRODUCTION
(Note: As used in this document, the terms "we," "us," and "our" refer to the
Environmental Protection Agency (EPA). The terms "you" and "your" refer to a state or
local air pollution control agency or state or local transportation agency or other federal
agency, as appropriate.)
1.1 What is the purpose of this guidance?
Economic prosperity in the United States is inextricably tied to the commercial
movement of goods by truck. Trucks carry three-fourths of the value of freight shipped
in the United States and two-thirds of the weight, according to the U.S. Department of
Transportation's Bureau of Transportation Statistics.1 While essential to business and
consumers, transporting goods by truck also consumes energy and produces pollution.
Recognizing the importance of trucking to both the economy and to the environment,
EPA has developed the SmartWay Transport program to reduce greenhouse gas
emissions and air pollution from the ground freight transport industry, including long-
haul diesel trucks.
The purpose of this guidance is to describe how to quantify and use reductions in
nitrogen oxides (NOx) that result when trucks are outfitted with two specific SmartWay
fuel efficient technologies: low rolling resistance tires and trailer aerodynamic kits. This
guidance describes how to apply these NOx reductions in state implementation plans
(SIPs) and in transportation conformity determinations. Therefore, this guidance could
be of interest primarily to ozone and particulate matter (PM2.5 and PMio) nonattainment
and maintenance areas that are considering additional ways to reduce NOx for reasonable
further progress (RFP) SIPs, attainment demonstrations, or maintenance plans, or in
transportation conformity determinations. EPA's intent in producing this guidance is to
facilitate the adoption of SmartWay projects as a cost-effective way to achieve needed
NOx emission reductions while ensuring that these projects meet SIP and conformity
requirements.
The SIP and conformity policy elements of this guidance in Chapters 1, 3, and 4
are applicable to all states that have nonattainment or maintenance areas. However, the
methodology that is described in Chapter 2 specifically applies to states that use EPA's
MOBILE and NONROAD models. State and local agencies developing SIPs and
conformity analyses for California should consult EPA Region 9 for information on the
http://www.bts.gov/press_releases/2005/bts003_05/html/bts003_05.html
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current version of EMFAC approved for use in California and for information on how to
quantify NOx reductions from the SmartWay technologies addressed by this guidance.
This guidance is focused on quantifying NOx reductions for SIP and conformity
purposes and therefore has an intended audience of air quality and transportation
planners. Other audiences may wish to use this guidance for quantifying NOx reductions
for non-SIP or conformity purposes by reading Chapter 1 for background and referring to
Chapter 2's Questions 2.4 through 2.7 of the guidance for quantifying emission
reductions.
1.2 Which SmartWay technologies are addressed by this guidance?
This guidance pertains to a truck or truck fleet that is outfitted with both of the
following two technologies:
A. Trailer aerodynamic kits,2 which would include the following:
• air deflecting fairings on the bottom of each trailer side ("side skirts"), and
• an air deflecting fairing on the front of the trailer ("gap reducer"); and
B. Low rolling resistance tires,3 e.g., single-wide tires with aluminum or low-weight
steel wheels on:
• all trailer axles, and
• all tractor drive axles. It is optional to also install low rolling resistance tires on
the tractor steer axle.
These technologies would typically be applied to long-haul trucks that are used to move
freight long distances, rather than trucks used for freight movement within a single
nonattainment or maintenance area.
For the purposes of this guidance only, a project that includes these two
technologies together will be referred to as a "SmartWay project." A SmartWay project
is defined as the purchase and installation of both the trailer aerodynamic kits and low
rolling resistance tires on a truck or fleet of trucks, as described above. According to
EPA's SmartWay Technology Package Savings Calculator, the cost of adding the
aerodynamic kits and low rolling resistance tires to a truck would be recuperated in fuel
savings in about two years.4
2 Please refer to EPA's SmartWay website for more information, including a fact sheet on aerodynamics:
http://www.epa.gov/otaq/smartwav/smartwav fleets strategies.htm#aero.
3 EPA will include on its SmartWay website a list of low rolling resistance tires that could be used to meet
the terms of this guidance.
4 The SmartWay Technology Package Savings Calculator can be found at:
http://www.epa.gov/otaq/smartwav/calculator/loancalc.htm
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This combination of aerodynamic kits and low rolling resistance tires is the only
package of SmartWay fuel efficient technologies that has been evaluated for NOx
reductions thus far.5 SmartWay projects could be undertaken by a truck or truck fleet
owner, or by state or local governments who are seeking to reduce NOx for SIP or
transportation conformity purposes.
EPA notes that a SmartWay project may be part of a larger Agency effort to
provide incentives for private and public agencies or truck owners to apply "SmartWay
Upgrade Kits" to a truck or fleet of trucks. A SmartWay Upgrade Kit can include idle
reduction devices, retrofits for particulate matter, low rolling resistance tires, and trailer
aerodynamic kits. EPA has issued previous SIP and conformity guidance for quantifying
and using the benefits of idle reduction devices and retrofit projects.6 This document
provides the remaining guidance needed for agencies to quantify and use the NOx
reductions from SmartWay Upgrade Kits in SIPs and conformity. Additional general
information about the SmartWay Transport program can be found at:
http://www.epa.gov/smartwav/swresources.htm
This guidance document is based on the most current scientific information
available on NOx emission reductions from fuel efficient technologies on long-haul
trucks. EPA's Office of Transportation and Air Quality (OTAQ) intends to make
available in the future a formal list of EPA-approved technologies that achieve fuel
efficiency and produce NOx emission reductions, including the technologies addressed
by today's guidance. It is possible that additional fuel efficient technologies which may
evolve in the future could provide additional NOx reductions. Please contact OTAQ if
you have further technical information regarding fuel efficient technologies that may
demonstrate additional NOx reductions. EPA will review such information on a case-by-
case basis. See Question 1.7 of this guidance document for OTAQ contact information.
1.3 What trucks can be part of a SmartWay project?
New emission standards will affect all 2007 and future model year on-road heavy-
duty highway vehicles and engines. In general, this guidance applies to trucks
manufactured before those standards take effect and that will not have to comply with
EPA's regulations for heavy duty trucks (i.e., pre-2007 model years). EPA does not
believe that the SmartWay technologies described in Section 1.2 will result in significant
5 For more information regarding the testing program used to establish that the SmartWay aerodynamic
fairings and low rolling resistance tires reduce NOx, please see Bachman, L. Joseph, Anthony Erb, and
Cheryl L. Bynum, "Effect of Single Wide Tires and Trailer Aerodynamics on Fuel Economy and NOx
Emissions of Class 8 Line-Haul Tractor-Trailers," SAE Paper Number 05CV-45, 2005, found at the
website: http://www.epa.gov/smartwav/documents/sae-05cv045-110105.pdf
6 These two guidance documents, "Guidance for Quantifying Long Duration Truck Idling Emission
Reductions in State Implementation Plans and Transportation Conformity" (EPA420-B-04-001, January
2004), and "Diesel Retrofits: Quantifying and Using Their Benefits in SIPs and Conformity - Guidance for
State and Local Air and Transportation Agencies" (EPA420-B-06-005, June 2006), can both be found at
EPA's website: http://www.epa.gov/otaq/stateresources/transcorf/policv.htnrfsips .
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additional NOx reductions for 2007 and later vehicles because of the NOx control
strategies that will apply to them. However, you might be able to apply this guidance to
some trucks with model years for 2007-2009, because the 2007 standard will be phased
in and therefore not every truck manufactured in 2007, 2008, or 2009 will be required to
meet the 2007 standard initially. Please check with EPA before including any trucks with
model years for 2007-2009 in a project.
1.4 How can NOx emission reductions from SmartWay projects be used to meet
SIP and conformity needs?
This document describes two options for using NOx emission reductions from
these projects to meet both near term and longer term SIP and conformity needs.
1.4.1 SIPs
One option is to use NOx reductions from SmartWay projects to help demonstrate
RFP, attainment, or maintenance in upcoming SIP submissions. To be included in a SIP,
NOx reductions from SmartWay projects must meet the same SIP requirements as any
other control measures. This guidance document provides the necessary information to
include NOx reductions from SmartWay projects in a SIP7, including a calculation
method that ensures that emission reductions calculated for the SmartWay project are
consistent with the rest of the SIP.
State and local agencies can consider including NOx reductions from SmartWay
projects especially in SIPs being developed to meet current ozone and PM2 5 air quality
standards. General SIP requirements are described in Chapter 3 of this document.8
1.4.2 Transportation conformity
Alternatively, state and local agencies could use NOx reductions from SmartWay
projects to meet transportation conformity requirements now or in the future, with little
additional effort beyond what is required to properly implement the project and quantify
the emission reductions. These reductions could be incorporated into a transportation
7 In this guidance, the term "SIP" could mean an initial SIP developed to show RFP, attainment, or
maintenance, or a revision to such a SIP.
o
Note that if a SmartWay project is included in a SIP, it would not be considered a transportation control
measure (TCM) for the purposes of demonstrating timely implementation for transportation conformity,
because the definition of TCM in the transportation conformity regulation at 40 CFR 93.101 specifically
excludes it: "Notwithstanding the first sentence of this definition, vehicle technology-based, fuel based,
and maintenance-based measures which control the emissions from vehicles under fixed traffic conditions
are not TCMs for the purposes of this subpart." Therefore, the regulations at 40 CFR 93.113 do not apply
to SmartWay projects, and SmartWay projects are not covered by Clean Air Act 176(c)(8) which allows
TCMs to be added or replaced in an approved SIP.
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conformity determination without making any change in the SIP. Chapter 4 of this
document explains transportation conformity requirements.
1.5 How does this guidance relate to the Voluntary Mobile Source Emission
Reduction Program SIP guidance?
In October 1997, EPA issued its "Guidance on Incorporating Voluntary Mobile
Source Emission Reduction Programs in State Implementation Plans (SIPs)" (the VMEP
guidance).9 The purpose of the 1997 VMEP guidance is to support innovative methods
in achieving emission reductions for SIPs. The VMEP guidance applies to SIP emission
reduction measures that rely on voluntary actions of individuals and other parties,
including non-governmental parties. EPA anticipates that many SmartWay projects will
fall into the voluntary category, e.g., projects undertaken by fleet owners or operators.
However, a state-funded SmartWay project included in a SIP may not fall under the
VMEP guidance if it has well-defined requirements to ensure its full implementation as a
SIP program. For example, a state program to adopt a SmartWay project for state owned
trucks would not be subject to the VMEP guidance. Please consult your EPA Region
early in the development of a SmartWay project to determine the appropriate use of the
VMEP guidance.
Under the VMEP guidance, the amount of emission reductions allowed for
voluntary mobile measures in a SIP is presumptively capped at three percent of the total
projected future year emission reductions required to attain the applicable air quality
standards. EPA acknowledges that some areas may be able to demonstrate that voluntary
measures may achieve credible reductions higher than the three percent cap. In that case,
EPA will re-evaluate that cap on a case-by-case basis and allow the cap to be exceeded if
the cap hinders the implementation of effective voluntary control measures, subject to
notice and comment during SIP approval. Today's guidance relies on EPA's 1997
VMEP guidance for voluntary SmartWay projects. Interested parties should refer to that
guidance at the time a specific SmartWay project is under development.
1.6 How does this guidance relate to existing Clean Air Act requirements?
This document provides guidance to state and local air pollution control agencies,
transportation agencies, metropolitan planning organizations (MPOs), and the general
public on quantifying and using SmartWay projects to reduce NOx emissions in SIPs and
transportation conformity determinations. SIP requirements can be found in Clean Air
Act sections 110(a)(2) and 172(c). Transportation conformity requirements can be found
in Clean Air Act section 176(c) and 40 CFR Parts 51 and 93. This guidance document
9This guidance is found at: http://www.epa.gov/otaq/stateresources/policv/pag guidance.htm. EPA notes
that the VMEP guidance pertains to SIP measures, rather than transportation or general conformity
determinations. Control measures for conformity determinations must meet the relevant criteria in the
transportation conformity regulation (40 CFR Parts 51 and 93).
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does not substitute for those provisions, nor is it a regulation itself. It does not by itself
impose binding, enforceable requirements on any party. Further, it does not assure that
EPA will approve all instances of its application, and thus the guidance may not apply to
a particular situation based upon the circumstances. The EPA and state decision makers
retain the discretion to adopt approaches on a case-by-case basis that differ from this
guidance where appropriate and consistent with the statute and applicable regulations.
Any decisions by EPA regarding a particular SIP demonstration will only be made based
on the statute and applicable regulations, and following notice and opportunity for public
review and comment.
Where specific recommendations are provided, you should consider whether or
not such recommendations are appropriate for your particular project or situation. This
guidance may be revised periodically without public notice. EPA welcomes public
comments on this document at any time and will consider those comments in any future
revisions of this guidance document.
Readers of this document are cautioned not to regard statements recommending
the use of certain procedures as either precluding other procedures or information or
providing guarantees that using these procedures will result in actions that are fully
approvable. As noted above, EPA cannot assure that actions based upon this guidance
will be fully approvable in all instances, and all final SIP actions may only be taken
following notice and opportunity for public comment.
1.7 Who should I contact for additional information?
If this guidance document does not answer a specific question, please contact the
appropriate EPA Regional Office with responsibility for air quality planning and/or
transportation conformity in the area where the SmartWay project is located. A contact
list of the EPA Regions is available at the following web address:
http://www.epa.gov/epahome/locate2.htm. In addition, contact information for EPA
regional transportation conformity staff can be found at the following website:
http://www.epa.gov/otaq/stateresources/transconf/contacts.htm.
For additional information about the SmartWay Transport program, please contact
Cheryl Bynum of EPA's Office of Transportation and Air Quality at (734) 214-4844,
bynum.cheryl@epa.gov.
For technical questions regarding the use of the National Mobile Inventory Model
(NMIM) for calculating emission reductions from SmartWay projects, please contact
EPA's Office of Transportation and Air Quality at mobile@epa.gov.
For general questions concerning the use of NOx reductions from SmartWay
projects in SIPs or in transportation conformity, please contact Laura Berry of EPA's
Office of Transportation and Air Quality at (734) 214-4858, berry.laura@epa.gov: or
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Gary Dolce also at EPA's Office of Transportation and Air Quality at (734) 214-4414,
dolce.gary@epa.gov.
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CHAPTER 2
QUANTIFYING EMISSION REDUCTIONS FROM SMARTWAY PROJECTS
2.1 How do I— quantify emission reductions from SmartWay projects?
For states other than California, EPA recommends the use of the National Mobile
Inventory Model (NMIM) to estimate emission reductions from SmartWay projects for
SIPs and for transportation conformity analyses. NMIM is the recommended method
because it estimates the impact of a SmartWay project for the particular model years that
it applies to under local conditions. Due to the nature of the aerodynamic kits and low
rolling resistance tires, emission reductions from SmartWay projects will vary based on
the average speed of the vehicles. The method described here accounts for the variable
impacts of the SmartWay equipment described in Section 1.2 based on average speeds of
vehicles on different roadway types.
The NOx reductions by speed provided in the table in Section 2.7.1.6 of this
Chapter should be applied to class 8 tractor-trailer (combination) trucks with the
SmartWay aerodynamic fairings and low rolling resistance tires described in Section 1.2
of the model years specified in Section 1.3 in any state, including California. However,
NMIM may not be appropriate to derive emission factors for fleets of trucks in
California. State and local agencies developing SIPs and conformity analyses for
California should consult with EPA Region 9 for information on the current version of
EMFAC approved for use in California and for information on how to apply the emission
reductions given in Section 2.7.1.6 to EMFAC emission factors.
2.2 What is NMIM and why does EPA recommend its use to quantify emission
reductions from SmartWay projects?
NMEVI is a graphical user interface that contains the MOBILE6.2 and
NONROAD2005 models and a database of county-level input information, the National
County Database (NCD) (note cautions about the use of the NCD in Question 2.3).
NMIM2005 is capable of producing monthly inventories by source classification code
(SCC) and county for every state, but should not be used for California, which has its
own modeling tools. NMEVI was created to simplify the process of developing county -
by-county emissions inventories for multi-county areas, states, or the entire nation.
When using NMIM, users can simply select the year, months, and county or counties
they wish to evaluate. Since NMIM includes county-level information, it will
automatically create MOBILE6.2 input files, run MOBILE6.2, and multiply the emission
10 The intended audience for this chapter is state and local air quality and transportation planners who are
already familiar with how SIP inventories and transportation conformity determinations are developed. For
readers less familiar with this subject matter, please note that Section 1.7 contains contact information if
you have additional questions.
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factors by vehicle miles traveled (VMT) to produce highway vehicle emissions
inventories for each county for each month.n NMEVI will also automatically create
NONROAD2005 input files, run NONROAD2005, and produce nonroad equipment
emissions inventories for each county for each month. NMEVI also provides a post-
processing module that will aggregate the months into an annual inventory and produce
tab-delineated output that can be read into database or spreadsheet software applications.
Because NMEVI provides a graphical user interface for MOBILE6.2 and
NONROAD2005, new and past users of these models may find that NMIM is an easier
way to use MOBILE6.2 and NONROAD2005. Input options and output results from
NMEVI will be familiar to air quality and transportation agency professionals who have
used MOBILE6.2 and/or NONROAD2005 in the past to create emissions inventories for
use in SIPs or transportation conformity determinations.
NMEVI2005 includes the capability to model retrofit projects, a capability that
does not exist in MOBILE6.2. The post-processors in NMIM include retrofit modules
that allow you to specify the details of a retrofit project. These retrofit modules take
emission factors generated by MOBILE6.2 and apply adjustments to those emission
factors or inventories to reflect the specifics of the retrofit project as described in a user-
generated input file. The resulting emission factors are used to generate emissions
estimates for the project.
While SmartWay projects are not retrofit projects, the retrofit modules in NMIM
can be adapted to easily calculate emission reductions from SmartWay projects. For
example, if the input file indicates that the SmartWay equipment described in Section 1.2
was installed in 2005 on 1998 model year class 8 trucks and you want to estimate the
emissions of these trucks in 2010, NMEVI will apply the appropriate adjustments to only
the emissions of model year 1998 class 8 trucks in 2010 when generating an emission
estimate. Because NMIM can be run using the same local inputs as used in the SIP,
NMEVI can calculate emission reductions from a SmartWay project based on the same
conditions used to generate the rest of the inventory used in the SIP or conformity
analysis.
EPA recommends NMIM for assessing the emission reductions from SmartWay
projects for SIP and conformity purposes. However, EPA acknowledges that alternative
methods to NMEVI are available and others may be developed. Alternative approaches
will be reviewed by EPA on a case-by-case basis. Please provide EPA with all relevant
technical support documentation, including the assumptions and other relevant
information used to calculate emission reductions so EPA has the information necessary
to make a decision. Also, any alternative approach must use the latest information as
required by applicable SIP and conformity requirements.
11 "EPA's National Mobile Inventory Model (NMIM), a Consolidated Emissions Modeling
System for MOBILE6 and NONROAD," H. Michaels, et al. U.S. EPA,
http://www.epa.gov/otaq/models/nmim/420r05024.pdf.
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2.3 What are the uses and limitations of NMIM?
EPA's current approved model for estimating emissions from highway vehicles
for SIP and conformity purposes in states other than California is MOBILE6.2. NMEVI
incorporates MOBILE6.2 along with pre- and post-processors, similar to those that many
states have developed on their own, that simplify the process of inventory preparation.
NMEVI is not considered a new emissions model and does not start a new transportation
conformity grace period pursuant to 40 CFR 93.111. Because NMIM incorporates
MOBILE6.2 and NONROAD2005, it may be used to generate emissions inventories for
SIPs and conformity analyses or it may just be used to estimate emission reductions from
retrofit or SmartWay projects, as discussed in Section 2.4. For general SIP and
conformity inventory preparation, the pre- and post-processors in NMIM may have
advantages or disadvantages in various areas or applications compared to pre-existing
methods. Therefore, before using NMIM for general SIP and conformity inventory
preparation, state and local air quality and transportation agencies should work together
with EPA and DOT to determine whether NMIM is appropriate given local conditions
and modeling methods, and to determine what modifications are needed to the NMIM
database to accurately model local conditions.
The use of NMIM is not required for general inventory preparation for SIPs or
regional conformity analyses. Some areas may choose not to use NMIM simply because
it does not provide a significant resource advantage compared to pre- and post-processing
methods already being used. In addition, the use of NMIM may not be appropriate to
generate emissions inventories in all areas. For example, some areas may already be
using more sophisticated methods for pre- and post-processing input and emissions data
than NMIM can accommodate. In that case, state and local agencies should not use
NMIM for inventory development, but should continue to use the more appropriate
modeling already being conducted in the area. Those agencies should still use NMEVI for
estimating emission reductions from retrofit or SmartWay projects.
States have provided information for the National County Database (NCD) as part
of the National Emissions Inventory (NEI) development process. However, given the
NEI cycle, this may not be the most recent or best available information at the time a
state initiates modeling. For SIPs and regional conformity analyses, state and local
agencies should review the information in the NCD to evaluate whether it includes the
latest and best information currently available including latest planning assumptions
where applicable. Where more current information is available, you must modify the
database to incorporate that information in your analysis to meet regulatory requirements
for the use of latest planning assumptions in SIPs and conformity determinations. (In
addition to updating the NCD for your project, EPA also encourages states to separately
submit updates to the NCD to EPA so that the most accurate database is available for
both national and local inventory development.) The NCD works at the county level and
will need to be modified to account for areas containing partial counties, if necessary.
The NCD also does not contain VMT estimates for future years, so any use of NMEVI for
a future evaluation year will have to include a projection of future VMT. The
interagency consultation process should be used to evaluate whether the use of NMEVI is
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appropriate in a given area, and to evaluate what changes are needed in the NMEVI
database for the area.
If you are using NMIM to develop inventories for SIPs or conformity, and have
made certain that the appropriate local conditions have been entered in the NMIM
database, entering the appropriate SmartWay project inputs as described below will
ensure that SmartWay project reductions are incorporated in the inventory. In order to
calculate the emission reductions from SmartWay projects, you will have to run NMIM
twice - a base case without the SmartWay project and a control case with the SmartWay
project and with all other NMIM inputs unchanged. You would then calculate the
difference between these two inventories to determine the emission reductions from the
SmartWay project.
2.4 Can I use NMIM to quantify emission reductions from SmartWay projects
even if I am not using it to generate the local inventory?
Yes, even if NMIM is not being used for inventory development, EPA
recommends that you use it for the calculation of emission reductions for SmartWay
projects. Because NMEVI uses MOBILE6.2 to develop estimates of reductions from
SmartWay projects, emission reductions calculated using NMIM should be consistent
with the rest of the local inventory. When using NMIM solely to calculate emission
reductions from SmartWay projects, you should first make sure that all NMIM inputs in
the base case (i.e., the case without the SmartWay project in place) are as consistent as
possible with the MOBILE6.2 inputs being used to generate the inventory used in the SIP
or conformity analysis. You should use those same inputs, along with those needed to
describe the SmartWay project, for the control case. Given that some differences in
inputs and effects of pre- and post-processors may result in differences between
emissions calculated using NMIM compared to other inventory methods, NMIM
SmartWay project reductions should be calculated as a percentage reduction to the
affected fleet, which can then be converted to mass reduction by multiplying by the total
emissions for the affected fleet derived from the local inventory.
2.5 Can I use NMIM to estimate emission reductions from SmartWay projects
for uses other than SIPs or conformity determinations?
Yes. NMIM could also be used to evaluate SmartWay projects for other
purposes, such as the development of proposals for SmartWay projects. For these
purposes, NMIM users could rely more on default data in NMIM or other more
simplified methods for using NMIM than would otherwise be necessary for SIP or
conformity purposes. Other, more simplified approaches that do not rely on NMIM may
also be appropriate for non-SIP or conformity uses. You should be aware that these
simplified methods may result in emission reduction estimates that are not completely
consistent with emission reductions calculated for SIP or conformity purposes using more
rigorous methods. Consultation between organizations developing project proposals and
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state and local air quality and transportation agencies about appropriate methods and
interpretation of results is important to ensure that SmartWay projects are properly
evaluated.
2.6 Where would I get estimates of specific SmartWay project information
needed to quantify emissions reductions from a SmartWay project?
As described in the following sections, in order to quantify emission reductions
from a SmartWay project, you will need specific information about the trucks in the
project and their activity in the nonattainment area. Details of the implementation of the
SmartWay project, such as the first and last years of implementation, the percentage of
the fleet receiving the SmartWay equipment described in Section 1.2 each year, and the
model years of the trucks getting this equipment should be readily available in the project
documentation.
Estimates of VMT needed for quantifying the NOx reductions from SmartWay
projects could come from a variety of sources, including global positioning systems
(GPS) on the trucks themselves, trucker logs, maintenance records, or fuel records. In the
absence of this kind of information, the interagency consultation process12 should be used
to determine the best available information to account for activity in the calculation of
emission reductions from a SmartWay project. In the absence of better information,
agencies could agree to use local average estimates of vehicle VMT for the class and
model year of vehicles included in the SmartWay project.
Estimates of average vehicle speeds needed to determine the appropriate
emissions reduction can be based on average speeds by roadway type for class 8 trucks in
the nonattainment area as used to develop the SIP inventory. If specific speed
information for the SmartWay project trucks operating in the nonattainment area is
available (i.e., through the use of GPS or other similar technology), this information
could be used in place of average speeds for determining the appropriate emission
reduction by roadway type. The interagency consultation process should be used to
determine the best available information to account for activity in the calculation of
emission reductions from a SmartWay project.
2.7 How do I use NMIM to quantify emission reductions from SmartWay
projects?
The NMEVI User Guide (available at http://www.epa.gov/otaq/nmim.htm)
provides details of how to use the retrofit modules within NMEVI. Note that throughout
the NMIM User guide, the term "retrofit" is used to describe the input files and
12 The transportation conformity regulations at 40 CFR 93.105 establish general procedures for interagency
consultation on the development of SIPs, transportation plans and TIPs, and transportation conformity
determinations. Many states have adopted conformity SIPs which further tailor these procedures. Consult
your EPA Regional Office if you are unsure whether your state has a conformity SIP.
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parameters used by the retrofit modules. Since this quantification method for SmartWay
projects relies on the use of the retrofit module in NMIM, the terminology used in this
guidance document will be consistent with the terminology used in the NMIM User
Guide. SmartWay projects should be modeled as "fleet specific" projects, and the rest of
this section indicates what information is necessary.
As discussed in detail in the NMIM User Guide, the specifics of a highway
retrofit project are described in an input file called the "Onroad Retrofit Parameters File."
In addition, you will need a second input file called the "Onroad Fleet Information
Parameters File" to describe in detail the specific fleets affected by the SmartWay
project.
2.7.1 The Onroad Retrofit Parameters File
The Onroad Retrofit Parameters File is used to describe the details of the
SmartWay project. These include inputs that specify:
• the pollutant affected by the SmartWay project,
• the vehicle types affected,
• the calendar years during which the SmartWay equipment described in Section
1.2 is installed,
• the model years of the vehicles that will be part of the SmartWay project,
• the percentage of the fleet that will be part of the SmartWay project per year, and
• the percentage effectiveness of the SmartWay equipment described in Section 1.2.
Details on the use of these inputs are described in the NMIM User Guide. Specific
guidance on these inputs, where applicable, is given below.
2.7.1.1 Pollutants affected by the retrofit project
While NMIM allows you to enter the entire range of pollutants for which
MOBILE6.2 and NONROAD2005 provide emissions estimates, the only pollutant
affected by SmartWay projects in SIPs and conformity analyses is NOx. Therefore, users
should enter only NOx for this input at this time.13
2.7.1.2 Vehicle types affected
The SmartWay equipment described in Section 1.2 can only be installed on class
8 diesel trucks and their trailers and therefore, this is the only category of vehicles for
which reductions can be taken in a SIP or conformity analysis. Users should enter
HDDVSa and HDDVSb to calculate reductions for these vehicles.
13 Only NOx should be input here because NOx is the only pollutant for which SmartWay projects have
been evaluated for SIP and conformity purposes.
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2.7.1.3 Initial and final calendar years of retrofit implementation
These inputs are used to describe the first and last year of implementation of the
SmartWay project. For example, if the SmartWay equipment described in Section 1.2
was installed on trucks in a fleet over a multi-year period, enter the first and last year the
equipment is installed.
2.7.1.4 Initial and final model years retrofitted
These inputs are used to describe the first and last model years of the trucks in the
SmartWay project. Because the effects of the SmartWay equipment described in Section
1.2 on the emissions of trucks with significant after-treatment controls installed is not yet
known, for SIPs and conformity determinations, reductions would typically not be
applied to trucks with model years later than 2006.
2.7.1.5 Percentage of the fleet retrofit per year
This input is used together with the inputs described in section 2.7.2.3 to describe
the implementation of the SmartWay project. If the SmartWay project is implemented
over a multi-year period, use this input to specify the percentage of the fleet that will get
the SmartWay equipment described in Section 1.2 each year. For example, if the initial
and final calendar years of implementation are 2007 and 2009 and the percentage of the
fleet getting the SmartWay equipment described in Section 1.2 each year is 20%, NMTM
will calculate emissions for a fleet in which 20% of the fleet gets the SmartWay
equipment described in Section 1.2 in 2007, 20% in 2008, and 20% in 2009.
2.7.1.6 Percentage effectiveness of the retrofit
This input is used to specify the percentage emission reduction associated with the
SmartWay project. However, unlike retrofit projects, the emission reductions associated
with SmartWay projects vary by vehicle speed. Based on vehicle testing, EPA has
determined the following relationship between average vehicle speed and NOx reductions
from SmartWay projects. This table should be used to determine the appropriate
emission reduction associated with a particular average speed. NOx reductions for
intermediate average speeds can be rounded to the nearest value in the table or
interpolated.
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NOx Reductions Associated with Average Speeds:
Speed (mph)
5
10
15
20
25
30
35
40
45
50
55
60
65
%NOx
reduction
2.0
2.3
2.6
3.0
3.5
4.0
4.6
5.2
6.0
6.8
7.8
9.0
10.3
NMIM produces output for vehicles on each of twelve roadway types. For SIPs
and conformity determinations, the NOx reductions used should be based on the average
speeds used in the SIP or conformity analysis for class 8 trucks on each of the twelve
roadway types specified by NMIM. For example, if the average speed used in the SIP for
class 8 trucks on rural interstates is 65 mph, the NOx reduction for trucks that are part of
a SmartWay project on rural interstates is 10.3%. Because NMIM only allows a single
percentage effectiveness to be applied in any one run, it may take multiple NMIM runs to
get the appropriate reductions on all roadway types. There are two possible approaches
to doing the NMIM runs:
1. Do separate NMIM runs for each roadway type. For the first run, enter the
appropriate percentage reduction in the retrofit parameter file based on the
average speed of class 8 trucks on rural interstates. In the NMIM output, use
only the total emissions for class 8 trucks on rural interstates. Repeat for rural
principal arterials, using the appropriate percentage reduction based on the
average speed of class 8 trucks on rural principal arterials and taking the
output only for that roadway type. Continue for each of the other roadway
types.
Under this approach, it would take as many as twelve NMIM runs to develop
a new inventory with the SmartWay project in place. It could take fewer if
some of the roadway types have the same average speed.
2. Do two NMIM runs - one base case run with no SmartWay project in place
and a second run with the retrofit parameter file that describes the SmartWay
project and with the percentage effectiveness set to 100%. Take the output
from the two runs for class 8 trucks by roadway type and calculate the
difference for each roadway type (i.e., subtract the class 8 rural interstate
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emissions with 100% effectiveness from the base case class 8 rural interstate
emissions). The result is the total emissions for trucks in the SmartWay
project on rural interstates. Multiply that result by the appropriate percentage
reduction from the table above based on the average speed of class 8 trucks on
rural interstates in the nonattainment area. Repeat for each of the other
roadway types.
Under this approach, only two NMIM runs are required, but additional time
and effort are required to post-process the results.
Properly done, either approach is acceptable for SIPs and conformity analyses.
Regardless of the approach used, speeds used in the analysis should be consistent with
average speeds for class 8 trucks for each roadway type used in the SIP. Within a
nonattainment area, each roadway type might actually have multiple average speeds
based on time of day or location (i.e., some urban interstate links may have different
average speeds than others). For purposes of this analysis, a single average speed for
each roadway type is acceptable as long as it is calculated on a VMT-weighted basis from
the speeds used in the SIP.
Note that under either approach, it is not necessary to know the actual average
speeds of the specific trucks that are in the SmartWay project. The general method
outlined here is based on the assumption that trucks in a SmartWay project have similar
activity to all other class 8 trucks in the nonattainment area, i.e., they travel at the same
average speed on a particular roadway type and their VMT is distributed across the
different roadway types proportionally to the total distribution of class 8 VMT. If you
believe that the trucks in the SmartWay project have different average speeds or VMT
distribution than other class 8 trucks in the nonattainment area and you want to account
for that in a SIP or conformity analysis, you would need to document the methods and
information used to develop alternative speeds and VMT distributions. The interagency
consultation process should be used to determine the best approach for your local area.
2.7.2 The Fleet Information Parameters File
The file for on-road fleet information is used to provide details of specific fleets
of vehicles that are part of a SmartWay project. This file should be used, along with the
retrofit parameter file described above, when quantifying the emission reductions from
SmartWay projects. This file includes inputs for:
• vehicle class,
• model year,
• number of vehicles, and
• annual VMT per vehicle.
Details on the use of these inputs are described in the NMEVI User Guide.
Specific guidance on these inputs where applicable is given below. For any SmartWay
project, you should be able to enter detailed information for all of these inputs. Note that
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these files only describe characteristics of a fleet of vehicles; they do not describe any
details of a SmartWay project. When quantifying the reductions for a SmartWay project,
the fleet information parameter files are used to describe the specific fleet, while the
retrofit parameter files are used to describe the SmartWay project applied to that fleet.
When used without retrofit parameter files, the fleet information files can be used to
simply quantify the emissions for any specific fleet of vehicles or engines.
2.7.2.1 Vehicle class parameters
Users should enter HDDVSa and HDDVSb because SmartWay projects only
apply to class 8 diesel trucks.
2.7.2.2 Modelyear
The fleet information file will have one input line for each model year in the
SmartWay project. Typically, the 2006 model year will be the last model year that can be
part of a SmartWay project.
2.7.2.3 Number of vehicles
The number of vehicles entered for the specific fleet should be based on the
calendar year for which emission estimates are being calculated. When estimating
emissions for a specific fleet of trucks that are part of a SmartWay project in the current
year, this is the current size of the fleet of trucks with the SmartWay equipment described
in Section 1.2. However, in future years the fleet of affected vehicles may become
smaller as some vehicles in the fleet are scrapped while other newer vehicles that are not
part of the SmartWay project may be added to the fleet. MOBILE6.2 includes the effects
of normal attrition when projecting future emissions for the entire fleet (e.g., the model
assumes that the number of 1998 model year vehicles decreases in each future year).
However, these effects are not applied to the number of vehicles entered in the fleet
information file for a specific fleet (e.g., if your input file indicates that you have twenty
1998 model year vehicles in your SmartWay project fleet in 2005, NMIM will assume
twenty 1998 model year vehicles in any future year that you model).
Unless you have reason to believe that all the trucks that are part of the SmartWay
project would still be in the fleet by the calendar year that is being evaluated, reduce the
input for number of vehicles appropriately.
Example: Trucking Company A will install SmartWay aerodynamic fairings and
low rolling resistance tires as described in Section 1.2 on 100 trucks in the year
2007. Trucking Company A intends to sell half of these trucks to other trucking
firms in 2010, and replace them with brand new model year 2010 trucks.
Suppose the emissions estimates are needed for 2009 and 2015. For this
SmartWay project, you would enter the following information in the Fleet
Information Parameters File input file for Number of Vehicles:
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Number of vehicles in 2009: 100
Number of vehicles in 2015: 50
2.7.2.4 Average annual mileage
The VMT entered for the specific fleet should be based on the activity that
actually occurs within the nonattainment or maintenance area to which the SIP or
conformity analysis applies. For a SmartWay project applied to a fleet of long-haul
trucks, you must not include VMT that occurs outside the nonattainment or maintenance
area.
The activity level (VMT or hours of use) entered for the specific fleet should be
based on the calendar year for which emission estimates are being calculated. When
estimating emissions for a specific fleet in a current year, this is the current activity level
of the fleet. However, in future years, the activity level of the affected vehicles in the
fleet may change as older vehicles are often used less than newer ones. MOBILE6.2
includes the effects of decreased activity with age when projecting future emissions for
the entire fleet (e.g., MOBILE6.2 assumes that the activity of 1998 model year vehicles
decreases in each future year). However, these effects are not applied to the activity
levels entered in the fleet information file for a specific fleet (e.g., if your input file
indicates that 1998 model year vehicles are driven 100,000 miles in 2005, NMIM will
assume that 1998 model year vehicles are driven 100,000 miles in any future year that
you model). Unless you have reason to believe that activity levels of vehicles currently
in the specific fleet would not have changed by the calendar year that is being evaluated,
you should account for this lowered activity by reducing the input for VMT or hours of
use appropriately.
Specific information on the VMT or hours of use of vehicles that are part of a
SmartWay project may be available from maintenance records, user logs, or fuel records.
In the absence of this kind of information, the interagency consultation process should be
used to determine the best available information to account for activity in the calculation
of emission reductions from a SmartWay project. In the absence of better information,
agencies could agree to use local average estimates of vehicle VMT for the class and
model year of vehicles included in the SmartWay project.
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CHAPTER 3
USING EMISSION REDUCTIONS IN SIPS
3.1 What are the basic requirements for using emission reductions in SIPs?
In order to be approved as a control measure that provides NOx emission
reductions in a SIP, a Smart Way project would need to be consistent with SIP RFP,
attainment, or maintenance requirements and other requirements of the Clean Air Act, as
appropriate. The SmartWay project must provide emission reductions that meet the basic
SIP requirements:
• quantifiable,
• surplus,
• federally enforceable,
• permanent, and
• adequately supported.
These requirements are described below. You will notice information under both "SIP
Requirement" and "Specific Recommendations" headings. The "SIP Requirement"
heading refers to requirements under Clean Air Act section 110 concerning SIPs that are
mandatory. The "Specific Recommendations" headings include our recommendations
for implementing a SmartWay project. While these recommendations are not binding,
they may provide appropriate safeguards and considerations for a successful SmartWay
project.
3.1.1. Quantifiable -
SIP Requirement: The NOx emission reductions from a SmartWay project are
quantifiable if they are measured in a reliable manner and can be replicated (e.g., the
assumptions, methods, and results used to quantify emission reductions can be
understood). NOx reductions must be calculated for the time period during which the
reductions will occur and will be used for SIP purposes.
Specific Recommendations:
• In general, quantifying the NOx reductions from installing the SmartWay
equipment described in Section 1.2 on trucks is fairly straightforward. You will
need to document the NOx reductions by providing all relevant data to EPA for
review.
• Chapter 2 of this document provides you with EPA's recommended method for
quantifying NOx reductions from SmartWay projects. You can use this
methodology or you can submit your own methodology. If you submit your own
methodology, we will review it and make a decision as to its appropriateness on a
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case-by-case basis. If you choose to use an alternative method, we encourage
you to engage the applicable EPA Region early.
3.1.2 Surplus -
SIP Requirement: Emission reductions are considered "surplus" if they are not
otherwise relied on to meet other applicable air quality attainment or maintenance
requirements for that particular NAAQS pollutant (i.e., there can be no double-counting
of emission reductions). In the event that the SmartWay project is used to meet such air
quality related program requirements, its NOx reductions are no longer surplus and may
not be used as additional emission reductions. Emissions from the trucks that will be part
of a SmartWay project must be in the applicable mobile source emissions inventory
before the NOx reductions from that SmartWay project can be used for RFP, attainment
or maintenance in a SIP.
3.1.3 Federally Enforceable -
SIP Requirement: A SIP SmartWay project must be enforceable, regardless of
whether it is in the SIP as a voluntary measure or a mandatory one. However, the
requirements for enforceability differ depending on whether the project is voluntary or
mandatory.
Voluntary SmartWay projects. A voluntary SmartWay project is one that relies
on voluntary actions of individuals or other parties for achieving emission reductions,
rather than a required response to a state or local regulation. If your SmartWay project is
a voluntary measure, it would be approved into the SIP under EPA's VMEP guidance,
and the state is responsible for assuring that the reductions quantified in the SIP occur.
The state would need to make an enforceable SIP commitment to monitor, assess, and
report on the emission reductions resulting from the voluntary measure and to remedy
any shortfalls from forecasted emission reductions in a timely manner. Under the current
VMEP guidance, the total of all voluntary mobile source measures (including SmartWay
projects) may not exceed three percent of the total reductions needed to meet any
requirements for RFP, attainment, or maintenance. EPA acknowledges that some areas
may be able to demonstrate that voluntary measures may achieve credible reductions
higher than the three percent cap provided by the VMEP guidance. In that case, EPA will
re-evaluate that cap on a case-by-case basis and allow the cap to be exceeded if the cap
hinders the implementation of effective voluntary control measures, subject to notice and
comment during SIP approval. If you wish to have a SmartWay project approved as a
voluntary measure, consult the 1997 VMEP guidance for further information.
Mandatory SmartWay projects. Where a control measure, such as a SmartWay
project, is implemented as part of a rule or regulation for SIP purposes, it would be a
mandatory measure. In this case, the SmartWay project would be considered federally
enforceable only if it meets all of the following criteria:
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• The emission reductions from the SmartWay project are independently verifiable.
• Violations are defined, as appropriate.
• You and EPA have the ability to enforce the measure if violations occur.
• Those liable for violations can be identified.
• Citizens have access to all the emissions-related information obtained from the
responsible party.
• Citizens can file lawsuits against the responsible party for violations.
• Violations are practicably enforceable in accordance with EPA guidance on
practicable enforceability.
• A complete schedule to implement and enforce the project has been adopted by the
implementing agency or agencies.
If your SmartWay project is mandatory, then there is no cap on the amount of
NOx emission reductions that can be claimed as long as such reductions are supported
and meet standard SIP enforceability requirements for mandatory measures and the
baseline emissions are in the inventory.
3.1.4 Permanent -
SIP Requirement: The NOx emission reductions produced by the SmartWay
project must be permanent throughout the time period that the reductions are used in the
applicable SIP.
• For a voluntary SmartWay project, the state would need to commit to monitor,
assess, and report on the emission reductions resulting from a truck owner's
voluntary application of SmartWay equipment. The emission reductions that
result from a voluntary project are available only for the time covered by this
commitment. For example, a state includes a voluntary SmartWay project in its
SIP based on Trucking Firm A's commitment to install SmartWay equipment
described in Section 1.2 on 100 trucks in its fleet. Trucking Firm A is expected to
own these trucks for five years. Precluding any other stipulations or
commitments, the state can only include the emission reductions from this
voluntary SmartWay project for the five years that Trucking Firm A is expected
to have the trucks. The state commits to monitor these 100 trucks while they are
owned by Trucking Firm A. Once Trucking Firm A sells these trucks to Trucking
Firm B, their emission reductions can no longer be included in the SIP, unless
additional commitments can be obtained.
• For a mandatory SmartWay project, the time period that the emission reductions
are used in the SIP can be no longer than the useful life of the trucks that are part
of the SmartWay project, and may be less if the SmartWay equipment described
in Section 1.2 is removed or not maintained over time.
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Specific Recommendations:
• As stated in Chapter 1, SmartWay projects will typically involve truck fleets
operating over long distances and thus only part of their travel occurs in the
nonattainment or maintenance area. NOx emission reductions claimed from
such SmartWay projects should be limited to the fleets' activity (and the
associated NOx emission reductions) expected to occur within the nonattainment
or maintenance area, as well as those accounted for in the inventory. Refer to
Sections 2.6 and 2.7.2.4 for more information.
• If trucks that are part of a SmartWay project operate exclusively within the
nonattainment or maintenance area, NOx reductions from these trucks may be
entirely applied to that area. Trucks that typically operate within a captive area
may include State/local government owned trucks.
• For voluntary or mandatory SmartWay projects, you should demonstrate that the
trucks outfitted with the SmartWay equipment described in Section 1.2 remain in
use within the nonattainment or maintenance area for their useful life to the
extent emission reductions are claimed.
3.1.5 Adequately Supported -
SIP Requirement: The state must demonstrate that it has adequate funding,
personnel, implementation authority, and other resources to implement the SmartWay
project on schedule.
Specific Recommendations:
• The state should ensure it has identified appropriate funds from a reliable funding
source (e.g., a private trucking company submitting a letter to the state committing
to install the SmartWay equipment described in Section 1.2 on a certain number of
trucks).
• The state should ensure that the truck fleet operators correctly install and maintain
the SmartWay equipment described in Section 1.2 according to the kit and tire
manufacturers' recommendations.
o Example: A private company has installed the SmartWay equipment
described in Section 1.2 on 50 long-haul trucks. The state should ensure
that such a company has staff that are properly trained to operate,
maintain, and detect problems with the SmartWay equipment as
appropriate.
• The state should assess and verify the status of the implementation of SmartWay
projects and the associated emission reductions, as applicable for the duration of
the NOx reduction claimed.
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3.2 How can the estimated NOx emission reductions be used for SIP purposes?
For your RFP, attainment, or maintenance SIP strategy, you can use NOx
emission reductions that are expected to be generated from the SmartWay project by
applying the following criteria:
• NOx emission reductions would be calculated as required in the SIP process for a
given pollutant and standard.
o For example, NOx reductions from SmartWay projects would be
calculated in an 8-hour ozone SIP for tons reduced per day for a typical
summer day within the ozone season.
o In contrast, NOx reductions would be calculated on a tons per year basis
for SIP inventories for the annual PM2.5 standard; state and local agencies
should consult on what typical day is appropriate for SIP inventories for
the daily PM2 5 standard.
• Any calculations would consider factors that may affect emission reductions and
their surplus status over time, including changing patterns of operations or use,
vehicle deterioration factors, SmartWay equipment useful life (i.e, useful life of
the SmartWay aerodynamic fairings and low rolling resistance tires described in
Section 1.2), and government emission standards. Note that if you use NMEVI to
quantify the NOx reduced from the project, government emission standards are
automatically taken into account. Furthermore, NMIM gives you the opportunity
to enter information to correctly account for other factors such as changes in the
number and activity of the trucks in the affected fleet in the user input files. See
Chapter 2 for more information about NMIM.
• Emission reductions would be commensurate with the level of activity from
SmartWay project trucks within a given nonattainment or maintenance area as
described in Question 3.1.4. For example, if SmartWay project trucks are operated
partially within the nonattainment or maintenance area, the associated reductions
from the SmartWay project would be limited to the activity that is expected to
occur from such trucks within the nonattainment or maintenance area, as well as
those accounted for in the inventory.
3.3 What would a state submit to EPA to meet the requirements for
incorporating a SmartWay project in a SIP?
You would submit to EPA a written document that:
• Identifies and describes the SmartWay project, i.e., the number and type of trucks
that will receive the SmartWay equipment described in Section 1.2, and the
schedule on which the project will be implemented;
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• Contains estimates of emission reductions attributable to the project, including the
methodology and other technical support documentation used for your estimates.
EPA recommends NMIM for assessing the emission reductions from SmartWay
projects for SIP purposes. Please refer to Chapter 2 for detailed information about
using NMIM for SmartWay projects. However, EPA acknowledges that
alternative methods to NMEVI are available and others may be developed.
Alternative approaches will be reviewed by EPA on a case-by-case basis. Please
provide EPA with all relevant technical support documentation, including the
assumptions and other relevant information used to calculate emission reductions
so EPA has the information necessary to make a decision. Also, any alternative
approach must use the latest information as required by applicable SIP
requirements;
• Contains either:
o an enforceable commitment for the state to monitor, assess and report the
resulting emission reductions if the project is developed under the VMEP
guidance; or
o federally enforceable requirements for the state to implement, track, and
monitor the project.
• If the project is developed under the VMEP guidance, includes an enforceable
commitment to remedy any SIP emission shortfall in a timely manner in the event
that the project does not achieve the estimated emission reductions; and
• Meets all other requirements for SIPs under Clean Air Act sections 110 and 172.
3.4 What monitoring and record keeping should occur to document NOx
emission reductions from SmartWay projects?
3.4.1 What should the state air agency monitor and record?
Clean Air Act section 110(a)(2)(C) requires that submitted SIPs "include a
program to provide for the enforcement of the measures" that the state adopts to reduce
emissions. A state's decision about whether a measure needs to be enforced will depend
on the state's knowledge of the emission reductions achieved by the measure. Therefore,
this Clean Air Act requirement for a program that provides for enforcement makes it
necessary for states to monitor measures that they include in their SIPs, including
SmartWay projects.
EPA recommends that for each truck outfitted with the SmartWay equipment
described in Section 1.2 , the state air agency or another responsible party should monitor
and record the following information, where applicable, for each time period for which
an emission reduction is generated:
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• Actual use and operation of the truck;
• Proper installation of the aerodynamic kit and low rolling resistance tires at project
initiation; and
• Proper training of truck operators and technicians at project initiation.
Monitoring and recording these data is one way to ensure that the statute is met. A state
can propose other methods of monitoring and recording data in its SIP submission, and
EPA would consider whether or not it would be sufficient to meet Clean Air Act
requirements.
3.4.2 How long should the state air agency maintain records?
Under 28 U.S.C. 2462, the government has five years to bring an enforcement
action or suit for the failure to implement a measure in a SIP. Based on this statute of
limitations, all information to be monitored and recorded in accordance with this
guidance for existing SIP requirements should be maintained by the state air agency or
another responsible party for a period of no less than five years, or longer where
appropriate.
3.5 What validation and reconciliation should occur for emission reductions in
SIPs approved under the VMEP guidance?
The SIP submission for a voluntary measure should contain a description of the
evaluation procedures and time frame(s) in which the evaluation of SIP reductions will
take place. Once the voluntary control measure is in place, emission reductions should be
evaluated by you as required to validate the actual emission reductions. You should
submit the results of your evaluation to EPA in accordance with the schedule contained in
the SIP. If the review indicates that the actual emission reductions are not consistent with
the estimated emission reductions in the SIP, then the amount of emission reductions in
the SIP should be adjusted appropriately or applicable remedial measures should be taken
under the VMEP guidance. See EPA's VMEP guidance for further information
regarding validation and reconciliation requirements for such measures.14
3.6 What penalties can EPA impose for not complying with Clean Air Act
requirements?
Use of this guidance does not relieve you of any obligation to comply with all
otherwise applicable Clean Air Act requirements, including those obligations pertaining
to the use of emission reductions in your SIP, such as emission reductions for your
14 This guidance is found at: http://www.epa.gov/otaq/stateresources/policv/pag guidance.htm. EPA notes
that the VMEP guidance pertains to SIP measures, rather than transportation or general conformity
determinations. Control measures for conformity determinations must meet the relevant criteria in the
transportation conformity regulation (40 CFR Parts 51 and 93).
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attainment demonstration or maintenance plan. Violations of Clean Air Act requirements
are subject to administrative, civil, and/or criminal enforcement under Clean Air Act
section 113, as well as to citizen suits under Clean Air Act section 304. The full range of
penalty and injunctive relief options would be available to the federal or state government
(or citizens) bringing the enforcement action.
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CHAPTER 4
USING EMISSION REDUCTIONS IN
TRANSPORTATION CONFORMITY DETERMINATIONS
4.1 What is transportation conformity?
Transportation conformity is required under Clean Air Act section 176(c) (42
U.S.C. 7506(c)) to ensure that federally supported highway and transit project activities
are consistent with ("conform to") the purpose of the SIP. Conformity to the purpose of
the SIP means that transportation activities will not cause new air quality violations,
worsen existing violations, or delay timely attainment of the relevant national ambient air
quality standards (NAAQS or "standards"). EPA's transportation conformity rule (40
CFR Parts 51 and 93) establishes the criteria and procedures for determining whether
transportation plans, transportation improvement programs (TIPs) and projects conform
to the SIP. Transportation conformity applies to areas that are designated nonattainment,
and those redesignated to attainment after 1990 ("maintenance areas" with SIPs
developed under Clean Air Act section 175 A) for transportation-related criteria
pollutants. Some areas that are currently subject to transportation conformity could
benefit from NOx reductions that result from SmartWay projects, including 8-hour
ozone, PM2 5, and PMi0 nonattainment and maintenance areas.15
In urban areas, transportation planning and conformity determinations are the
responsibility of the metropolitan planning organization (MPO). MPOs are responsible
for updating and revising the transportation plan and TIP on a periodic basis, as well as
making transportation plan and TIP conformity determinations. Such a determination
includes a regional emissions analysis that shows that the emissions expected from the
area's planned transportation system do not exceed the motor vehicle emissions target
("budgets") set by the SIP for meeting RFP, attainment, or maintenance requirements. In
cases where an area does not yet have a SIP in place, a different type of emissions test16
is used for conformity. After an MPO's conformity determination, the U.S. Department
of Transportation (DOT) must also determine conformity of the transportation plan
and/or TIP. The interagency consultation process is required to be used when developing
transportation plans, TIPs, conformity determinations, and SIPs, and the process includes
MPOs, state departments of transportation, public transit agencies, other transportation
agencies, state and local air quality agencies, EPA, and DOT (40 CFR 93.105).
15 Note that in a PM25 area, transportation conformity applies with respect to NOx unless both
EPA and the state find it is not a significant contributor and the SIP does not include a NOx motor vehicle
emissions budget. In a PM10 nonattainment or maintenance area, transportation conformity applies with
respect to NOx only if either the EPA or the state air agency has made a finding that this precursor is a
significant contributor to the PM10 nonattainment problem or if the SIP includes a NOx budget. See 40
CFR 93.102(b)(2) for details.
16 In areas without SIP budgets, an interim emissions test(s) must be met. These tests are the
"baseline year test" and the "build/no-build test." See 40 CFR 93.109, 93.118, and 93.119 for specific
requirements in various types of nonattainment and maintenance areas.
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4.2 How can NOx emission reductions from SmartWay projects be included in
transportation conformity determinations?
The transportation conformity rule describes the specific requirements for
including emission reductions from projects in a transportation conformity determination.
If the emission reductions from the SmartWay project have been accounted for in the
SIP's budget, the MPO would also include the reductions from the SmartWay project, to
the extent it is being implemented, when estimating regional emissions for a conformity
determination. Including the emission reductions in both the SIP's budget and in a
conformity determination in this way is not "double-counting," but rather correctly
accounting for all the control measures that are in place in both the SIP and transportation
conformity processes.17
To include NOx emission reductions from SmartWay projects in a regional
emissions analysis, the appropriate jurisdictions must be committed to the measure. The
appropriate level of commitment varies according to the requirements outlined in 40 CFR
93.122(a), which are described as follows:
• If the SmartWay project does not require a regulatory action to be implemented
and it is included in the transportation plan and TIP with sufficient funding and
other resources for its full implementation, it can be included in a transportation
conformity determination.
• If the SmartWay project requires a regulatory action to be implemented, it can be
included in a conformity determination if one of the following has occurred:
o The regulatory action for the SmartWay project is already adopted by the
enforcing jurisdiction (e.g., a state has adopted a rule to require such a
project);
o The SmartWay project has been included in an approved SIP; or
o There is a written commitment to implement the SmartWay project in a
submitted SIP with a motor vehicle emissions budget that EPA has found
adequate.18
• If the SmartWay project is not included in the transportation plan and TIP or the
SIP, and it does not require a regulatory action to be implemented, then it can be
included in the transportation conformity determination's regional emissions
analysis if the determination contains a written commitment from the appropriate
17 See 40 CFR93.122(a)forthe requirements regarding what must be included when estimating
regional emissions in a conformity determination.
18 40 CFR 93.118 describes the process and criteria that EPA considers when determining whether
submitted SIP budgets are appropriate for transportation conformity purposes prior to EPA's SIP approval
action.
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entities to implement the project. An example of a SmartWay project that would
not be included in the transportation plan and TIP would be a state-sponsored loan
or grant program to install SmartWay equipment described in Section 1.2 on local
truck fleets.
Whatever the case, any NOx emission reductions can only be applied in a
transportation conformity determination for the time period or years in which the
SmartWay project will be implemented. Written commitments must come from the
agency with the authority to implement the SmartWay project (as required by 40 CFR
93.122(a)(4)and93.101).
For example, an MPO includes a SmartWay project in its emissions estimates
done for a transportation conformity determination based on Trucking Firm A's
written commitment to install SmartWay equipment described in Section 1.2 on
100 trucks in its fleet in the year 2008. Trucking Company A's written
commitment indicates that these 100 trucks will be sold and replaced with brand
new trucks during the years 2011 - 2015.
Suppose the MPO determines conformity in the year 2008, and it determines that
it needs to analyze emissions for the attainment year of 2010, the last year of the
transportation plan of 2030, and 2020 (an intermediate year). Based on the
written commitment from Trucking Firm A, the MPO would enter the following
information in the Fleet Information Parameters File input file for Number of
Vehicles:
Number of vehicles in 2010: 100
Number of vehicles in 2020: 0
Number of vehicles in 2030: 0
Note that in future conformity determinations, the MPO could include the
emission reductions from these trucks after they are sold if it can obtain similar
written commitments from the new owners of the SmartWay trucks.
The latest emissions model and planning assumptions must also be used when calculating
emission reductions, according to 40 CFR 93.110 and 93.111.
You would utilize the interagency consultation process required by 40 CFR
93.105 to discuss the methods and assumptions used to quantify the NOx reductions from
the SmartWay project. Chapter 2 of this document describes how to quantify emission
reductions.
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