&EPA
         Office of Transportation
United States    and Air Quality
Environmental Protection	
Agency
EPA420-S-06-004
December 2006
            Motor Coach Idling Field
            Observation Study for
            Washington,  DC, Metro Area

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                                               EPA420-S-06-004
                                                December 2006
Motor Coach Idling  Field Observation Study
        for Washington, DC, Metro Area
          Transportation and Regional Programs Division

                         and

             SmartWay Transport Partnership Group

             Office of Transportation and Air Quality
             U.S. Environmental Protection Agency

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                             Table of Contents




OVERVIEW	1




METHODOLOGY	2




RESULTS	3




CONCLUSION	11




Appendix A: General Results	12




Appendix B: Results by Shift	16




Appendix D: Results by Individual Site	23




Appendix E: Data	32




Appendix F: Sample Observation Form	35




Appendix G Washington, DC Department of Environment Comments	36

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                            ACKOWLEDGEMENT

The Environmental Protection Agency would like to acknowledgement the efforts of
Sarabeth G. Craig of the University of New Hampshire and Aaron R. Wright of the Ohio
State University, as part of The Washington Center Internship Program, without whom
this study would not have been possible.
                                       11

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OVERVIEW

Motor coaches idle their main propulsion engine for long periods, primarily to maintain a
comfortable interior compartment for their passengers (heat or air conditioning). Another
often cited reason for bus idling is to maintain air brake pressure.  Due to the cavernous
interior compartment of motor coaches, maintaining a comfortable interior temperature
requires substantially more time than the typical long-haul truck cab or personal
passenger vehicle.  In fact, it can take hours to bring the interior of a standing bus from
20 degrees Fahrenheit to 60 degrees Fahrenheit. Long-duration idling waste a
considerable amount of fuel (up to a gallon per hour) and exposes the driver, passengers,
and the general public to harmful diesel air emissions, such as particulate matter and
other air toxics.1

Unlike long haul trucks idling at truck stops which are largely hidden from public view,
motor coach idling is highly visible. Motor coaches transport passengers to popular
public destinations. Consequently, many state and local jurisdictions have received
complaints about idling buses, and many of these states and local jurisdictions have
promulgated laws that restrict vehicle idling.  The city of Washington, DC is one
jurisdiction that has passed an anti-idling law. In 1999, the DC Department of Health
amended a municipal regulation (Title 20,  §900.1) that applies to both gasoline and diesel
engines. The DC idling law, which applies to buses with a seating capacity of twelve or
more, restricts idling to three minutes. The law exempts private passenger vehicles,
idling to power on-board equipment (e.g., cement mixers), and idling when the
temperature is thirty-two degrees Fahrenheit or below (5 minutes only).  Fines can be up
to $5,000.  See Appendix G for more information on DC's anti-idling law.

In an effort to better understand motor coach  idling, the Environmental Protection
Agency (EPA) conducted a field observation of motor coaches in and around the
Washington, DC metro area. The purpose  of this study was to observe and report idling
behavior of motor  coaches in various zones.  The ultimate goal of this study is to begin a
dialogue that will reduce idling emissions through education, communication, and
strategies and technologies; and maintain the needs of motor coach buses, and their
drivers and passengers.

This study was conducted in the summer months of 2005, which generally have warmer
temperatures and more tourists visiting the nation's capital than other months.
Consequently, the  findings from this study may reflect increased idling behavior during
the summer season as compared to other seasons. Because Washington, DC has enacted
an idling restriction law, this law also may  have effected idling times.  It should be noted
that this study was limited to observations in the Washington, DC metro area only.  Other
jurisdictions may experience different results.
  The terms "motor coach" and "bus" are used interchangeably throughout this document.

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METHODOLOGY

Ten public zones were initially selected as locations to regularly monitor motor coach
idling behavior. These zones were selected based on preliminary observations made
around the major tourist attractions in Washington,  DC. While other tourist attractions
exist, initial observations confirmed that motor coaches regularly visit these locations.
The original locations are as follows:

       1.  North National Mall - Madison Dr. NW
       2.  South National Mall - Jefferson Dr. SW
       3.  Lincoln/F.D.R. Memorials - Ohio Dr. SW
       4.  National Cathedral
       5.  Waterfront
       6.  Arlington National Cemetery (in Virginia)
       7.  Union Station
       8.  US Capital/Supreme Court/Library of Congress
       9.  Ford's Theatre/Hard Rock Cafe/FBI Building
       10. National Zoo

Observations  occurred over a nine-week period, beginning on June 10, 2005 and ending
on August 9, 2005. After a two-week trial observation period, zones 8, 9, and 10 above
were removed.  These three zones did not have sufficient numbers of buses to continue
observations,  and had ongoing construction activities that limited the amount of parking
or had no parking at all for buses. Finally, the Lincoln/FDR Memorials site was
determined to be too large for one zone observation, so the site was split into two
different zones. The final zones for observation were as follows:

       1.  North National Mall - Madison Dr. NW
       2.  South National Mall - Jefferson Dr. SW
       3.  Lincoln Memorial
       4.  F.D.R. Memorial - Ohio Dr. SW
       5.  National Cathedral
       6.  Waterfront
       7.  Arlington National Cemetery
       8.  Union Station

These remaining eight zones were each visited a total of four times (with the exception of
the South National  Mall and F.D.R Memorial zones, which were visited 3 times),
resulting in 30 full  days of observations. Using a rotating schedule, each zone was
visited on  different days of the work week.  Observations occurred in two shifts per
location: from lOam-lpm and from lpm-4pm. Each morning shift was viewed as
independent from each afternoon  shift,  and information from one shift was shared with
the second shift to avoid overlapping. In the end, the results from both shifts where
combined  into the results for the day.

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RESULTS

General Results

Of the 1,173 observed buses, 618 buses (53%) were idling and 555 buses (47%) were not
idling. As demonstrated in Figures 1 and 2, most of the idling trucks were in violation of
the 3-minute Washington, DC idling law.  The median idling time was 11 minutes and
the average idling time was 16 minutes.
             Figure 1
  Idling Buses vs Non-Idling Buses
            Figure 2
    Idling Times for 618 Buses
   D Number of Idling Buses
   D Number of Non-Idling Buses
• Idled 3 minutes or less
• Idled between 4 and 10 minutes
D Idled between 11 and 20 minutes
D Idled more than 20 minutes
Results by Shift

As would be expected during the summer months, more buses were observed idling
during the afternoon hours than in the morning when the temperatures are higher.  In
addition, a larger proportion of these trucks were idling for over 3 minutes in the
afternoon than in the morning.

Morning Observations (10am - 1pm):

Of 465 observed buses, 155 buses (33%) were idling and 310 buses (67%) were not
idling. The maximum idling time was 38 minutes, and the median idling time was 17
minutes.  The average idling time was 19 minutes. Figure 3 provides a breakdown of the
number of buses idling for various time intervals.

Afternoon Observations (1pm - 4pm):

Of 708 observed buses, 463 buses (65%) were idling and 245 buses (35%) were not
idling. The maximum idling time was 1 hour 4 minutes, and the median idling time was
17 minutes.  The average idling time was also 17 minutes. Figure 4 provides a
breakdown of the number of buses idling for various time intervals.

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                  Figure 3
             10am - 1pm Idling
     D Idled 3 minutes or less
     • Idled between 4 and 10 minutes
     D Idled between 11 and 20 minutes
     D Idled more than 20 minutes
              Figure 4
           1pm-4pm Idling
                      73
                     16%
   D Idled 3 minutes or less
   • Idled between 4 and 10 minutes
   D Idled between 11 and 20 minutes
   D Idled more than 20 minutes
Results by Daily Temperature

Temperature - below 80°F

Of the 66 observed buses, 53 (80%) were idling and 13 buses (20%) were not idling. The
maximum idling time was 29.5 minutes, and the median idling time was 5 minutes.  The
average idling time was 7 minutes.
Of the 53 buses that were observed
idling, the majority of them were
idling for over 3 minutes, in violation
of the Washington, DC law.  Figure 5
provides a breakdown of the number
of trucks idling for various time
intervals.
        Figure 5
Idling Times at below 80°F
         2
        4%
                    14
                   26%
                                                     D Idled 3 minutes or less
                                                     • Idled between 4 and 10 minutes
                                                     D Idled between 11 and 20 minutes
                                                     D Idled more than 20 minutes

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Temperature - between 80°F and 90°F

Of the 758 buses observed, 373 buses
(49%) were idling and 385 buses (51%)
were not idling. The maximum idling
time was 1 hour 11 minutes, and the
median idling time was 11 minutes.  The
average idling time was 16 minutes.

Of the 373 buses that idled, only 61 buses
(16%) idled for 3 minutes or less.  The
remaining 312 buses (84%) idled for over
3 minutes and were in violation of the
idling law for Washington, DC.
Continuing with the idling times
breakdown:  122 buses (30%) idled for
somewhere between 4 and 10 minutes, 108
buses (29%) idled for somewhere between
11 and 20 minutes, and 82 buses (22%)
idled for more than 20 minutes. (Figure 6)

Temperature - above 90°F

Of the 349 buses observed, 192 buses (55%) were
idling and 157 buses (45%) were not idling.  The
maximum idling time was 1 hour 11 minutes, and
the median idling time was 12 minutes. The overall
average idling time was 18 minutes.

Of the 192 buses that idled, only 34 buses (18%)
idled for 3 minutes or less. The remaining 158
buses (82%) idled for over 3 minutes and were in
violation of the idling law Washington, DC.
Continuing with the idling times breakdown:  45
buses (23%) idled for somewhere between 4 and 10
minutes, 53 buses (28%) idled between 11 and 20
minutes, and 60 buses (31%) idled for more than 20
minutes. (Figure 7)
           Figure 6
Idling Times at between 80°F and 90°F
D Idled 3 minutes or less
• Idled between 4 and 10 minutes
D Idled between 11 and 20 minutes
D Idled more than 20 minutes
             Figure 7
     Idling Times at above 90°F
 D Idled 3 minutes or less
 • Idled between 4 and 10 minutes
 D Idled between 11  and 20 minutes
 D Idled more than 20 minutes

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Results by Individual Sites

North National Mall - Madison Dr. NW

The area observed was Madison Dr. NW between 14th Ave. NW and 7th Ave. NW.

Overall, of the 1,173 total buses observed, 175 buses (15%) were observed at this zone,
the 3rd highest out of the 8 sites. Of the 618 total idling buses observed, 109 idling buses
(17%) were observed in this zone, which was the highest overall (tied with Arlington
National Cemetery).

For the site, of the 175 buses observed, 109 buses (62%) were observed idling and 66
buses (38%) were not idling. The maximum idling time was 1 hour 6 minutes, and the
median idling time was 13 minutes. The average idling time was 16.

Overall, of the 109 buses that idled, only 34 buses (31%) idled for 3 minutes or less. The
remaining 75 buses (69%) idled for over 3 minutes and were in violation of the
Washington, DC idling law. Continuing with the idling times breakdown: 43 buses
(40%) idled for somewhere between 4 and 10 minutes, 22 buses (20%) idled for
somewhere between 11 and 20 minutes, and  10 buses (9%) idled for more than 20
minutes.

South National Mall-Jefferson Dr. SW

The area observed was Jefferson Dr. SW between 7th Ave. SW and 3rd Ave. SW.

Overall, of the 1,173 total buses observed, 196 buses (17%) were observed in this zone,
the 2nd highest out of the 8 sites. Out of the 618 total idling buses observed, 94 idling
buses (15%) were observed in this zone, which was 2nd highest out of 8.

For the site, of the 196 buses observed, 94 buses (48%) were observed idling and 102
buses (52%) were not idling. The maximum idling time was 2 hours 7 minutes, and the
median idling time was 11 minutes. The overall average idling time was 19 minutes.

Overall, of the 94 buses that idled, only 36 buses (36%) idled for 3 minutes or less. The
remaining 58 buses (64%) idled for over 3 minutes and were in violation of the
Washington, DC idling law. Continuing with the idling times breakdown: 25 buses
(27%) idled for somewhere between 4 and 10 minutes, 22 buses (23%) idled for
somewhere between 11 and 20 minutes, and  11 buses (12%) idled for more than 20
minutes.

Lincoln Memorial

The area observed was Daniel C. French Dr.  SW between Lincoln Memorial Circle SW
and Independence Ave. SW.

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Overall, of the 1,173 total buses observed, 118 buses (10%) were observed in this zone,
the 6th highest out of the 8 sites. Of the 618 total idling buses observed, 72 idling buses
(12%) were observed at this zone, which was 4th highest out of 8.

For the site, of thel 18 buses observed, 72 buses (61%) were observed idling and 46 buses
(39%) were not idling. The maximum idling time was 37 minutes, and the median idling
time was 8.5 minutes. The average idling time was 12 minutes.

Overall, of the 72 buses that idled, only 21 buses (29%) idled for 3 minutes or less.  The
remaining 51  buses (71%) idled for over 3 minutes and were in violation of the
Washington, DC idling law.  Continuing with the idling times breakdown: 21 buses
(29%) idled for somewhere between 4 and 10 minutes, 15 buses (21%) idled for
somewhere between  11 and 20 minutes, and 15 buses (21%) idled for more than 20
minutes.

F.D.R Memorial- Ohio Dr. SW

The area observed was W. Basin Dr. SW between Independence Ave. SW and Ohio Dr.
SW and Ohio Dr. SW between W. Basin Dr. SW and the bridge over the Tidal Basin.
Overall, of the 1,173 total buses observed, 82 buses (7%) were observed in this zone, the
7th highest out of the 8 sites.  Of the 618 total idling bi
were observed at this zone, which was lowest overall.
7th highest out of the 8 sites.  Of the 618 total idling buses observed, 30 idling buses (5%)
For the site, of the 82 buses observed, 30 buses (37%) were observed idling and 52 buses
(63%) were not idling.  The maximum idling time was 50 minutes, and the median idling
time was 12 minutes. The average idling time was 19 minutes.

Overall, of the 30 buses that idled, only 5 buses (17%) idled for 3 minutes or less. The
remaining 25 buses (83%) idled for over 3 minutes and were in violation of the
Washington, DC idling law.  Continuing with the idling times breakdown: 10 buses
(33%) idled for somewhere between 4 and 10 minutes, 8 buses (27%) idled for between
11 and 20 minutes, and 7 buses (23%) idled for more than 20 minutes.

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National Cathedral

The area observed was the bus drop-off zone in front of the National Cathedral.

Overall, of the 1,173 total buses observed, 72 buses (6%) were observed in this zone, the
lowest overall. Out of the 618 total idling buses observed, 58 idling buses (9%) were
observed at this zone, which was 7th highest out of the 8 sites.

For the site, of the 72 buses observed, 58 buses (81%) were observed idling and 14 buses
(19%) were not idling. The maximum idling time was 22 minutes, and the median idling
time was 3.5 minutes. The overall average idling time was 7 minutes.

Overall, of the 58 buses that idled, only 17 buses (29%) idled for 3 minutes  or less.  The
remaining 41 buses (71%) idled for over 3 minutes and were in violation of the
Washington, DC idling law.  Continuing with the idling times breakdown: 31 buses
(54%) idled for somewhere between 4 and 10 minutes, 7 buses (12%) idled  for
somewhere between 11 and 20 minutes, and 3 buses (5%) idled for more than 20
minutes.

Waterfront

The area observed was Maine Ave. SW between M St SW and the Interstate 395
overpass.

Overall, of the 1,173 total buses observed, 229 buses (19%) were observed in this zone,
the highest overall. Out of the 618 total idling buses observed, 66 idling buses (11%)
were observed at this zone, which was 6th highest out of the 8 sites.

For the site, of the 229 buses observed, 66 buses (29%) were observed idling and  163
buses (71%) not idling.  The maximum idling time was 1 hour 49 minutes, and the
median idling time was 12 minutes. The  average idling time was 22 minutes.

Overall, of the 66 buses that idled, only 10 buses (15%) idled for 3 minutes  or less.  The
remaining 56 buses (85%) idled for over 3 minutes and were in violation of the
Washington, DC idling law.  Continuing with the idling times breakdown: 19 buses
(29%) idled for somewhere between 4 and 10 minutes, 19 buses (29%) idled for
somewhere between 11 and 20 minutes, and 18 buses (27%)  idled for more  than 20
minutes.

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Arlington National Cemetery

The area observed was the bus parking lot at the Arlington National Cemetery in
Virginia.

Overall, of the 1,173 total buses observed, 162 buses (14%) were observed at this zone,
the 4th highest out of the 8 sites. Out of the 618 total idling buses observed, 102 idling
buses (11%) were observed at this zone, which was the highest out of 8 (tied with
National Mall-Madison Dr.).

For the site, out of 162 buses observed, 102 buses (63%) were observed idling and 60
buses (37%) were not idling.  The maximum idling time was 1 hour 32 minutes, and the
median idling time was 13 minutes.  The overall average idling time was 20 minutes.

Virginia has an anti-idling law which allows buses to idle for up to 10 minutes during hot
weather in order to maintain power to the air conditioning system.  Of the 102 buses that
idled, only 47 buses (46%) idled for 10 minutes or less. The remaining 55 buses (54%)
idled for over 10 minutes and were in violation of Virginia law. Continuing with the
idling times breakdown:  17 buses (17%) idled for somewhere between 11 and 20
minutes and 38 buses (37%) idled for more than 20 minutes.

Union Station

The area observed was the parking garage behind Union  Station.

Overall, of the 1,173 total buses observed, 139 buses (12%) were observed in this zone,
the 5th highest overall. Out of the 618 total idling buses observed, 87 idling buses (14%)
were observed at this zone, which was 3rd highest out of the 8 sites.

For the site, of the 139 buses observed, 87 buses (63%) were observed idling and 52
buses (37%) were not idling.  The maximum idling time was 1 hour, and the median
idling time was 13 minutes. The average idling time was 18.9 minutes.

Overall, of the 87 buses that idled, only 14 buses (16%) idled for 3 minutes or less. The
remaining 73 buses (84%) idled for over 3 minutes and were in violation of the
Washington, DC idling law. Continuing with the idling times breakdown: 20 buses
(23%) idled for somewhere between 4 and 10 minutes, 34 buses (39%) idled for
somewhere between 11 and 20 minutes, and 19 buses (22%) idled for more than 20
minutes.

Summary of Results for All Sites

For all sites, a total of 1,173 parked buses were observed. Figure 8 demonstrates the
number of buses (and the proportion of the total) that were parked at each site. Of these
1,173 buses, 618 were observed idling. Figure 9 shows the proportion of these buses that
were idling at each site. The largest number of buses observed idling was at the two

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combined National Mall locations. Figure 10 demonstrates the average idling times for
each site.
                Figure 8
     Number of Parked Buses by Site
          Figure 9
Number of Idling Buses by Site
 229
 19%
 66
11%
• National Mall A - Madison Ave.
• National Mall B - Jefferson Ave.
D Lincoln Memorial
DOhio Drive - F.D.R. Memorial
• National Cathedral
• Waterfront
• Arlington National Cemetery
D Union Station
  D National Mall A - Madison Ave.
  • National Mall B - Jefferson Ave.
  DLincoln Memorial
  DOhio Drive - F.D.R. Memorial
  • National Cathedral
  D Waterfront
  • Arlington National Cemetery
  D Union Station
                                               Figure 10
                                      Average Idling Times by Site
                                                                   22
              National Mall National Mall
              A - Madison  B - Jefferson
                 Ave.       Ave.
             Arlington
             National
             Cemetery
                                                                                    Union Station
                                            10

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CONCLUSION

This field observation found that the majority of motor coaches in Washington, DC idle
their engines. Of this majority, over 80% idled beyond Washington, DC's idling law
limit. The average idling time ranged from 15-22 minutes with several instances of
idling greater than one hour.

Motor coaches were found to idle throughout the Washington, DC metropolitan area.
This study focused on observing buses at eight popular tourist sites. However, motor
coaches have been  observed to park and idle at almost any available parking spaces in the
city.

A companion document to this field observation will discuss potential policy, technical,
and strategic solutions to motor coach idling.
                                        11

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                          Appendix A

                        General Results
Median and Average Idling Times	 15
Breakdown of Number of Parked Buses by Site	16
Breakdown of Number of Idling Buses by Site	17
                              12

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               Median and Average Idling Times
                                                           16.39663191
  10.66666667
Median Idling Time
                                                        Average Idling Time
                                13

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              Breakdown of Number of Parked Buses by Site
                                                                      D National Mall A - Madison Ave.
                                                                      • National Mall B - Jefferson Ave.
                                                                      D Lincoln Memorial
                                                                      DOhio Drive - F.D.R. Memorial
                                                                      • National Cathedral
                                                                      D Waterfront
                                                                      • Arlington National Cemetery
                                                                      D Union Station
229
19%
118
10%
                                  14

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Breakdown of Number of Idling Buses by Site
                                                         D National Mall A - Madison Ave.
                                                         • National Mall B - Jefferson Ave.
                                                         D Lincoln Memorial
                                                         DOhio Drive - F.D.R. Memorial
                                                         • National Cathedral
                                                         DWaterfront
                                                         • Arlington National Cemetery
                                                         D Union Station
                              15

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                          Appendix B

                        Results by Shifts
Idling Buses vs Non-Idling Buses (10 am-lpm Observations)	19
Breakdown of Idling Times (10 am-lpm Observations)	19
Idling Buses vs Non-Idling Buses (lpm-4pm Observations)	19
Breakdown of Idling Times (lpm-4pm Observations)	19
Median and Average Idling Times (10 am-lpm Observations)	20
Median and Average Idling Times (lpm-4pm Observations)	20
                               16

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  Idling Buses vs Non-Idling Buses
     (10am -1pm Observations)
                                                                                                                      Breakdown of Idling Times
                                                                                                                      (10am - 1pm Observations)
                                              • Number of Idling Buses
                                              • Number of Non-Idling Buses
Idling Buses vs Non-Idling Buses
    (1pm - 4pm Observations)
                                                                                                                        Breakdown of Idling Times
                                                                                                                        (1pm -4pm Observations)
                                                 • Number of Idling Buses
                                                 D Number of Non-Idling Buses
• Idled 3 minutes or less
D Idled between 4 and 10 minutes
D Idled between 11 and 20 minutes
• Idledmorethan20minutes
                                                                      17

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                                    Median and Average Idling Times
                                       (10am -1pm Observations)
117.5-
E
                        Median Idling Time
                                                                       Average Idling Time
                                                                                                                               Median and Average Idling Times
                                                                                                                                   (1pm -4pm Observations)
                                                                                                                  Median Idling Time
                                                                                                                                                                    Average Idling Time
                                                                                              18

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                    Appendix C

            Results by Daily Temperature
Idling Buses vs. Non Idling Buses Below 80° F	22
Breakdown of Idling Times Below 80° F	22
Median and Average Idling Times Below 80° F	22
Idling Buses vs. Non Idling Buses Between 80-90° F	23
Breakdown of Idling Times Between 80-90° F	23
Median and Average Idling Times Between 80-90° F	23
Idling Buses vs. Non Idling Buses Above 90 ° F	24
Breakdown of Idling Times Between Above 90 ° F	24
Median and Average Idling Times Above 90° F	24
                        19

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Idling Buses vs Non-Idling Buses
   (Temperatures below 80°F)
                                                                                                                    Breakdown of Idling Times
                                                                                                                    (Temperatures below SOT)
                                                 • Number of Idling Buses
                                                 D Number of Non-Idling Bust
• Idled 3 minutes or less
D Idled between 4 and 10 minutes
D Idled between 11 and 20 minute:
• Idled more than 20 minutes
                                              Median and Average Idling Times
                                                 (Temperatures below 80°F)
                                Median Idling Time
                                                                                  Average Idling Time
                                                               20

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   Idling Buses vs Non-Idling Buses
(Temperatures between 80°F and 90°F)
     Breakdown of Idling Times
(Temperatures between SOT and 90°F)
                                              • Number of Idling Buses
                                              DNumber of Non-Idling Buses
                                        • Idled 3 minutes or less
                                        D Idled between 4 and 10 minutes
                                        D Idled between 11 and 20 minutes
                                        • Idled more than 20 minutes
                                                 Median and Average Idling Times
                                              (Temperatures between 80°F and 90°F)
                                                                                             16.30044454
                                    10.35294118
                                  Median Idling Time
                                                                                          Average Idling Time
                                                                  21

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Idling Buses vs Non-Idling Buses
   (Temperatures above 90°F)
Breakdown of Idling Times
(Temperatures above 90°F)
                                           • Number of Idling Buses
                                           • Number of Non-Idling Buses
                                             Median and Average Idling Times
                                                 (Temperatures above 90°F)
                                   • Idled 3 minutes or less
                                   Q Idled between 4 and 10 minutes
                                   D Idled between 11 and 20 minutes
                                   • Idled more than 20 minutes

,.


I/I
o
= 10-
E



n













12.22727273
















18.1835493



















                              Median Idling Time
                                                                                      Average Idling Time
                                                                22

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                     Appendix D

                    Results by Site
North National Mall - Madison Dr. NW	26
South National Mall - Jefferson Dr. SW	27
Lincoln Memorial	28
F.D.R. Memorial - Ohio Dr. SW	29
National Cathedral	30
Waterfront	31
Arlington National  Cemetery	32
Union Station	33
                         23

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   Idling Buses vs Non-Idling Buses
(North National Mall - Madison Dr. NW)
      Breakdown of Idling Times
(North National Mall - Madison Dr. NW)
                                              • Number of Idling Buses
                                              • Number of Non-Idling Buses
                                             • Idled 3 minutes or less
                                             D Idled between 4 and 10 minutes
                                             D Idled between 11 and 20 minutes
                                             • Idled more than 20 minutes
                                                             24

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   Idling Buses vs Non-Idling Buses
(South National Mall -Jefferson Dr. SW)
      Breakdown of Idling Times
(South National Mall -Jefferson Dr. SW)
                                               • Number of Idling Buses
                                               D Number of Non-Idling Buses
                                             • Idled 3 minutes or less
                                             Dldled between 4 and 10 minutes
                                             DIdled between 11 and 20 minutes
                                             • Idled more than 20 minutes
                                                          25

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Idling Buses vs Non-Idling Buses
       (Lincoln Memorial)
Breakdown of Idling Times
    (Lincoln Memorial)
                                                1 Number of Idling Buses
                                                1 Number of Non-Idling Buses
                                      • Idled 3 minutes or less
                                      Dldled between 4 and 10 minutes
                                      D Idled between 11  and 20 minutes
                                      • Idled more than 20 minutes
                                                                 26

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Idling Buses vs Non-Idling Buses
 (F.D.R. Memorial -Ohio Dr. SW)
  Breakdown of Idling Times
(F.D.R. Memorial - Ohio Dr. SW)
                                             • Number of Idling Buses
                                             D Number of Non-Idling Buses
                                        • Idled 3 minutes or less
                                        Dldled between 4 and 10 minutes
                                        D Idled between 11 and  20 minutes
                                        • Idled more than 20 minutes
                                                                                  27%
                                                               27

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Idling Buses vs Non-Idling Buses
      (National Cathedral)
Breakdown of Idling Times
   (National Cathedral)
                                              • Number of Idling Buses
                                              D Number of Non-Idling Buses
                                       • Idled 3 minutes or less
                                       D Idled between 4 and 10 minutes
                                       D Idled between 11 and 20 minutes
                                       • Idled more than 20 minutes
                                                       28

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                     Idling Buses vs Non-Idling Buses
                               (Waterfront)
Breakdown of Idling Times
       (Waterfront)
                                                                  • Number of Idling Buses
                                                                  • Number of Non-Idling Buses
163
71%
                                        • Idled 3 minutes or less
                                        Dldled between 4 and 10 minutes
                                        DIdled between 11 and 20 minutes
                                        • Idled more than 20 minutes
                                                                           29

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Idling Buses vs Non-Idling Buses
  (Arlington National Cemetery)
 Breakdown of Idling Times
(Arlington National Cemetery)
                                            • Number of Idling Buses
                                            D Number of Non-Idling Buses
                                         • Idled 3 minutes or less
                                         Dldled between 4 and 10 minutes
                                         D Idled between 11 and 20 minutes
                                         • Idled more than 20 minutes
                                                         30

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Idling Buses vs Non-Idling Buses
         (Union Station)
Breakdown of Idling Times
      (Union Station)
                                             • Number of Idling Buses
                                             D Number of Non-Idling Buses
                                        • Idled 3 minutes or less
                                        Dldled between 4 and 10 minutes
                                        DIdled between 11  and 20 minutes
                                        • Idled more than 20 minutes
                                                      31

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Appendix E




   Data
    32

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Number of Buses Idling at Each Site, by Temperature and Shift
Sites Temperature
North National Mall -
Madison Dr. NW
South National Mall -
Jefferson Dr. SW
Lincoln Memorial
F.D.R. Memorial - Ohio Dr.
SW
National Cathedral
Waterfront
Arlington National
Cemetery
Union Station
ALL SITES
Less than 80°
80°-90°
More than 90°
Total=175
Less than 80°
80°-90°
More than 90°
Total=196
Less than 80°
80°-90°
More than 90°
Total=118
Less than 80°
80°-90°
More than 90°
Total=82
Less than 80°
80°-90°
More than 90°
Total=72
Less than 80°
80°-90°
More than 90°
Total=229
Less than 80°
80°-90°
More than 90°
Total=162
Less than 80°
80°-90°
More than 90°
Total=139
Less than 80°
80°-90°
More than 90°
Total=1,173
Not
AM
12
8
o
J
23
0
41
0
41
0
19
20
39
0
23
0
23
13
0
0
13
46
16
19
81
36
0
14
50
0
40
0
40
107
147
56
310
Idling
PM
0
27
16
43
18
43
0
61
1
4
2
7
0
29
0
29
0
0
1
1
0
39
43
82
0
9
1
10
0
6
6
12
19
157
69
245
Total
12
35
19
66
31
84
0
102
1
23
22
46
0
52
0
52
13
0
1
14
46
55
62
163
36
9
15
60
0
46
6
52
139
304
125
568
Idling
AM PM
0
8
3
11
0
13
0
13
0
10
20
30
0
10
0
10
15
0
0
15
5
2
6
13
9
0
32
41
0
22
0
22
29
65
61
155
0
71
27
98
32
49
0
81
19
5
18
42
0
20
0
20
0
38
5
43
0
26
27
53
0
35
26
61
0
34
31
65
51
278
134
463
Total
0
79
30
109
32
62
0
94
19
15
38
72
0
30
0
30
15
38
5
58
5
28
33
66
9
35
58
102
0
56
31
87
80
343
195
618
                       33

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Number of Buses Idling at Each Site,
Sites Temperature
North National Mall -
Madison Dr. NW
South National Mall -
Jefferson Dr. SW
Lincoln Memorial
F.D.R. Memorial - Ohio Dr.
SW
National Cathedral
Waterfront
Arlington National
Cemetery
Union Station
ALL SITES
Less than 80°
80°-90°
More than 90°
Total=175
Less than 80°
80°-90°
More than 90°
Total=196
Less than 80°
80°-90°
More than 90°
Total=118
Less than 80°
80°-90°
More than 90°
Total=82
Less than 80°
80°-90°
More than 90°
Total=72
Less than 80°
80°-90°
More than 90°
Total=229
Less than 80°
80°-90°
More than 90°
Total=162
Less than 80°
80°-90°
More than 90°
Total=139
Less than 80°
80°-90°
More than 90°
Total=1,173
by Temperature, Shift, and Length
3 minutes or
less
AM PM
0
6
0
6
0
4
0
4
0
2
6
8
0
3
0
3
o
J
0
0
3
1
0
0
1
0
0
7
7
0
4
0
4
4
19
13
36
0
1
o
J
4
2
5
0
7
6
2
5
13
0
2
0
2
0
11
o
3
14
0
5
4
9
0
11
o
J
14
0
4
6
10
8
41
24
73
4 to 10
minutes
AM PM
0
1
1
2
0
5
0
5
0
2
4
6
0
4
0
4
10
0
0
10
o
5
0
1
4
1
0
6
7
0
4
0
4
14
16
12
42
0
22
10
32
18
13
0
31
7
2
6
15
0
6
0
6
0
20
1
21
0
10
5
15
0
15
4
19
0
5
11
16
25
93
37
155
11 to 20
minutes
AM PM
0
1
1
2
0
17
0
17
0
1
4
5
0
7
0
7
1
0
0
1
1
2
5
8
4
0
o
J
7
0
5
0
5
6
33
13
52
0
31
10
41
6
2
0
8
5
0
5
10
0
1
0
1
0
6
0
6
0
4
7
11
0
3
7
10
0
18
11
29
11
65
40
116
of Time
More than
20 minutes
AM PM
0
0
1
1
6
14
0
20
0
5
6
11
0
5
0
5
1
0
0
1
0
0
0
0
4
0
16
20
0
9
0
9
11
33
23
67
0
17
4
21
0
2
0
2
1
1
2
4
0
2
0
2
0
1
1
2
0
7
11
18
0
6
12
18
0
7
3
10
1
43
33
77
Total
0
79
30
109
32
62
0
94
19
15
38
72
0
30
0
30
15
38
5
58
5
28
33
66
9
35
58
102
0
56
31
87
80
343
195
618
34

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                                                 Appendix F

                                            Sample Observation Form
TOD AY'S DATE:
TOD AY'S TEMP. (F):
LOCATION:
OBSERVER (print):
OBSERVER (signature):
NO.




TOTTR RTTS
COMPANY NAME




TJr.FNSF.PT. A TF#





IDLING
START
TIME
(am/pm)




IDLING
STOP
TIME
(am/pm)




TOTAL
IDLING TIME
(MIN/HR)




COMMENTS




Total Buses Parked =
Total Buses Idling =
Min Idling Time =
Max Idling Time =
Median Idling Time =
Mean Idling Time =
xx
XX
xx minutes
xx minutes
xx minutes
xx minutes xx seconds
                                                    35

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                                   Appendix G

           Comments from the District of Columbia Air Quality Division

       Although the District of Columbia Air Quality Division has focused compliance
initiatives on engine idling in the past five years, the United States Environmental
Protection Agency (EPA) Motor Coach Study conducted in the summer of 2005 indicates
that more work still needs to be done.

       The District of Columbia engine idling regulation was originally enacted in 1972.
DC Rules & Regulations, Reg. 72-18. Later, the air quality regulations were reorganized
and the idling regulation was adopted into Section 3 of the District's Air Pollution
Control Act of 1984 (D.C. Law 5-165, effective March 15, 1985; 20 DCMR 900.1, as
amended).  In an effort to curb motor vehicle emissions the District has amended the
engine idling regulation several times since its original inception.  Recent amendments
have targeted limiting the number of exceptions to the three (3) minute time period
allowed for idling, and increasing the penalty amount for violations. These measures
have been necessary to reduce the amount of emissions during warm weather months
when ozone reaches unsafe levels. As a result of these amendments, the District's current
engine idling regulation provides that:

       The engine of a gasoline or diesel powered motor vehicle,  the engine of a
       public vehicle for hire, including buses with a seating capacity of twelve
       (12) or more persons, on public or private space shall not idle for more
       than three (3) minutes while the motor vehicle is parked, stopped, or
       standing, including for the purpose of operating air conditioning
       equipment in those vehicles, except as follows:

              (a) To operate private passenger vehicles;
              (b) To operate power takeoff equipment including,
              dumping, cement mixers, refrigeration systems, content
              delivery, winches, or shredders; or
              (c) To idle the engine for five (5) minutes to operate
              heating equipment when the ambient air temperature is
              thirty-two degrees Fahrenheit (32°F) or below.

20 DCMR 900.1. The District of Columbia Department of Motor Vehicles (DMV) has a
synonymous regulation codified in 18 DCMR 2418.3, which is enforced by other District
and federal government agencies.

       Although the District has taken many measures to improve the air quality, the DC
metropolitan area continues to fall below air quality standards established in the federal
Clean Air Act, 42 U.S.C. §7401 et seq. Accordingly, EPA has identified the DC
metropolitan area as a non-attainment area for ozone and particulate matter (PM) ambient
air quality standards. As the District has very few industrial activities, the largest and
most significant sources of the District's air pollution problem are motor vehicles.
                                      36

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       Vehicle exhaust emits nitrogen oxides (NOX), carbon monoxide (CO),
hydrocarbons (HC), including volatile organic compounds (VOCs), and particulate
matter (PM) into the atmosphere. In the presence of heat and sunlight, these pollutants
create ozone. Ozone and some of the other pollutants mentioned above, especially PM,
are the cause of many respiratory illnesses. Vehicles are most inefficient while idling
because the fuel is not completely combusted and pollutants are released in higher level
than when the vehicle is in operation.  Therefore, excessive idling leads not only to many
respiratory illnesses, but also the exhaust fouls the air with various pollutants that erode
buildings and monuments. In short, vehicle exhaust causes damage to personal and real
property.

       After observing an increase of violations in 2002 the District started an aggressive
campaign to eradicate engine idling problems. The Air Quality Division stepped up
enforcement and designed flyers to educate drivers about the engine idling regulation.
Air quality inspectors hand out the flyers in high volume engine idling areas (markets,
warehouses, and certain areas where tour buses  park while waiting out the day), and the
division sends the flyers to busing and trucking  companies for postings in newsletters.  In
addition, the air quality attorney  often settles cases for a lower penalty if the violator
takes action to inform other drivers about the District's engine idling regulation (i.e.
notices in newsletters, notices attached to paychecks, letters to each driver in smaller
companies, etc.).  Due to these compliance and  enforcement efforts,  engine idling has
been reduced in the District.2

       A disconcerting part of the EPA Motor Coach Study is that many of the violations
occurred in areas not patrolled by the Air Quality Division. The federal Park Police and
Capitol Police have primary jurisdiction over zones 3, 4, 5, and 7, and a significant
portion of zones 1 and 2. Therefore, the District's Air Quality Division must make better
efforts to coordinate compliance initiatives with other District and federal agencies. The
Air Quality Division plans to establish an engine idling task force with representatives
from other agencies that have authority to enforce engine idling regulations including: the
Department of Public Work's Parking Enforcement Division; the Department  of Motor
Vehicles; the Metropolitan Police Department's Motor Carrier Division; and federal
agencies,  such as the Park Police and Capitol Police.

       The District needs  cooperation from the  busing industry as well. Tour buses that
idle for cabin temperature  is particularly important for the transportation of senior
citizens who are susceptible to health problems. The District understands that a
comfortable cabin temperature is important for senior citizen health, but so is the impact
 Notices of Infraction (tickets) issued for violations of the District's engine idling regulations:

2000:   AQD99        DMV32       Total =131
2001:   AQD 126       DMV 15       Total =141
2002:   AQD 187       DMV 10       Total = 197
2003:   AQD 44        DMV 20       Total = 64
2004:   AQD 48        DMV 41       Total = 89
                                       37

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of inhalation from bus exhaust.  The District cannot allow buses to idle for excessive
periods of time simply to keep air conditioners running because that would frustrate the
purpose of the idling law.  Seniors who require ambulatory assistance and the wheelchair
lift can take up to five minutes to safely load onto a bus.  The District reasonably enforces
the engine idling regulation and does not issue citations when passengers are loading or
unloading.

       Responsibility for controlling excessive idling must be shared with the
government and the regulated industry. Engine idling can be greatly reduced through
current technologies, such as mobile idle reduction technologies, which provide auxiliary
power to replace or supplement diesel engine idling while the vehicle is stopped. These
units reduce idling, reduce fuel consumption, extend engine maintenance intervals,
reduce wear on engines and help vehicles comply with anti-idling laws.  These
technologies can be safely installed into one luggage space of tour buses, and would
greatly reduce excessive idling.  In addition, other technologies are available, such as
stationary electrified parking spaces, wherein drivers hook up to a metered machine that
provides heating,  air-conditioning, phone service and electricity.  Busing and trucking
companies can install mobile idle reduction technologies on their own vehicles.
However, a stationary electrified parking system would require a coordinated industry
effort due to the necessity to have a convenient area where large vehicles could park and
hook up to the machines.

       The District is committed to reducing engine idling and is willing to work with
the regulated industry and other governmental entities to accomplish this goal.  The
planned task force will help coordinate enforcement initiatives, but education and
assistance with preventative technologies will provide the most benefit for the citizens
and visitors to the District of Columbia.
Kimberly Katzenbarger                   Neil Williams
Counsel to the Air Quality Division        Air Quality Division Environmental Engineer

The District of Columbia Air Quality Division
51 N Street, NE
Washington, DC  20002
202-535-2257
                                      38

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