1000 Friends of Maryland *  Chesapeake Bay Foundation * Environmental Defense

March 28, 2000

Mr. J. Craig Forrest, Chairman                    
Transportation Steering Committee
601 North Howard Street 
Baltimore, MD 21201 

The Honorable C.A. Dutch Ruppersberger, Chair
Baltimore Metropolitan Council
601 North Howard Street
Baltimore, MD 21201 

Re: Assuring All Reasonably Available Transportation Control Measures are Included in TIP/RTP

Dear Mr. Forrest and Mr. Ruppersberger:

We are very concerned that the Transportation Steering Committee has taken little action to address its obligations to identify and implement through the Transportation Improvement Program (TIP) and Regional Transportation Plan (RTP) all reasonably available transportation control measures. The TSC has acknowledged that health-threatening air pollution emissions associated with the Baltimore region’s transportation plan are higher than previously thought as a result of greater use of light duty trucks and sport utility vehicles and continuing growth in vehicle miles of travel that is in large part a result of the region’s transportation and land use policies. The State of Maryland and TSC’s members share responsibility for developing policies, investments, and strategies to curb that excessive pollution in the Baltimore region to protect public health.

We understand that the TSC plans to approve the conformity of the 2000-2004 TIP at its meeting on March 28, 2000. We reiterate our concerns that this conformity finding does not satisfy the requirements of the Clean Air Act, TEA-21 planning requirements, and related regulations, particularly with respect to the need to incorporate all reasonably available transportation control measures.

Now we have new concerns that the TSC intends to continue the patterns of the past by pressing forward prematurely in the proposal of a new TIP for 2001-2005 without any examination of additional TCMs. The TSC has announced plans to hold a hearing on April 26, 2000 on a new set of project submissions for the proposed Transportation Improvement Program for 2001-2005, prior to conducting TSC worksessions dealing with potential new TCMs and traffic or pollution mitigation strategies. In a recent meeting with several members of the TSC, we agreed to cooperate with the TSC in exploring strategies for addressing new TCMs, especially related to Commuter Choice incentives. We feel it is inappropriate for you to engage the public in such an exercise unless the products of that activity will be seriously considered for inclusion in the current planning cycle.

Thus, we urge the TSC to undertake an intensive effort to integrate new TCMs into the 2001-2005 TIP prior to holding a public hearing on a new project list.

Attached are some preliminary thoughts on several high priority TCMs that we believe are reasonably available TCMs for the Baltimore region. There is real urgency to this task as the Maryland Department of the Environment is now working on further defining control measures to meet the emission budget shortfalls of its Attainment SIP. Added transportation measures should be a part of the Baltimore region’s emission control strategy. The TIP revision is the best opportunity at hand to identify and advance such projects to protect public health and assure that the region’s transportation program can be implemented without fear of a transportion conformity lapse.

We note that the Clean Air Act requires State Implementation Plans (SIPs) to provide for implementation of all reasonably available control measures (RACM) as expeditiously as practicable. EPA interprets this requirement as imposing a duty on all nonattainment areas to consider all available control measures, and to adopt and implement any such measures that are reasonably available. 57 Fed. Reg. 13498, 13560 (1992). States must provide a justification, supported on economic or technological grounds, as to why measures within the arena of potentially reasonable measures have not been adopted. Further, to show that RACM are being implemented as expeditiously as practicable, the state must explain why the selected implementation schedule is the earliest schedule based on the specific circumstances of that area. Such claims cannot be general claims that more time is needed but rather should be specifically grounded in evidence of economic or technologic infeasibility.

The Baltimore SIP does not meet these requirements. The plan contains only a limited set of control measures, and fails to offer any justification for the failure to adopt numerous available measures that were specifically identified by EPA, the regional planning agency, the states themselves, and public comment. Further, the SIP contains no demonstration or claim that the implementation schedule is the earliest practicable one. The TIP revision is an important opportunity to advance new TCMs to help address these problems in the SIP.

The Baltimore RTP adopted by TSC has many adopted projects and programs that meet the definition of transportation control measures. Presumptively, these measures are reasonably available since they have already been approved by the metropolitan transportation planning process and have satisfied the requirements for reasonably available funding under TEA-21. These planned TCMs are incorporated into the SIP to the extent that the air quality modeling for the area assumes that the transportation system in the area will, in fact, be the system in the MPO plan. But few projects and programs in the regional transportation plan that would qualify as TCMs are included in the SIP. Plainly, Maryland has not complied with the mandate to adopt all RACM and EPA guidance construing that mandate.

Mobile source emissions are the largest individual components of both the VOC and NOx inventories, but the SIP contains few serious new measures to reduce growth in vehicle travel. The TIP, RTP, and SIP revision activities in the coming year must seriously consider a range of TCMs as discussed in the attachment to this letter, such as major expansion of transit service, deeply discounted transit fares, pricing strategies such as High Occupancy Toll lanes, value pricing, and parking excise fees, trip-reduction ordinances, employer-based transportation management plans, and expanded pedestrian and bicycle facilities. These and other TCMs are listed in section 108(f) of the Act, and in EPA guidance documents that identify more than 70 individual measures within broad TCM categories.

A candidate list of reasonably available TCMs for attainment SIPs might include:

1. Commuter Choice Programs: parking cash out, tax credit and other incentives for employer subsidies of transit fares, and tax incentives for employee purchase of transit and van benefits
2. Discounted pre-paid transit fare instruments designed for effective Commuter Choice promotion (e.g. $65/month regional passes), reduced transit fares and fare free zones
3. Accelerated bicycle and pedestrian improvements and bicycle/pedestrian access to transit
4. Land use transportation control strategies: large scale infill redevelopment with TDM and encouraging accessory apartment development in transit oriented neighborhood and centers
5. Replace diesel fleet vehicles with Compressed Natural Gas (CNG) or electric
6. Transit priority treatment and improved traveler information services
7. Value pricing and road and parking pricing incentives and information services
8. Transit and paratransit service expansion (e.g., to achieve an X% increase in person trips by transit and paratransit)
9. I/M for diesel vehicles and/or roadside pull over testing of diesels
10. California Air Resources Board (CARB) diesel fuel

We appreciate the TSC’s consideration of this request to defer action on a new TIP revision until an expedited and intensive review of reasonably available TCMs has been undertaken and considered as part of that process of project identification and resource allocation.

Sincerely,

Michael Replogle
Transportation Director
Environmental Defense

Lee Epstein
Lands Program
Chesapeake Bay Foundation

Dru Schmidt-Perkins
Executive Director
1000 Friends of Maryland 

cc: Nelson Castellanos, FHWA Division Administrator
Sheldon A. Kinbar, FTA Regional Administrator
Bradley Campbell, EPA Regional 3 Administrator

1. Commuter Choice

Background. For the vast majority of working Americans, a free parking space at work has for decades been the sole commuter benefit offered by employers. If you drive alone to work you gain the benefit. If you take transit, carpool, walk, or bike, you lose the benefit and likely pay your own daily transit fare. With this kind of incentive, its no surprise that on any given day nine out of ten American commuters drive to work¹ and nine out of ten of the cars driven to work have one occupant². Yet the 85 million "free" or subsidized employer parking spaces actually cost American business $36 billion per year.³ By spurring more driving, these subsidies exacerbate traffic congestion and air pollution.

1998 Federal Tax Code Change Makes Commuter Choice Reasonably Available Across America. New federal tax law changes make Commuter Choice incentive strategies universally available as potential Transportation Control Measures to meet Clean Air Act requirements in areas that fail to meet the National Ambient Air Quality Standards to protect public health. The 1998 Federal Transportation Equity Act for the 21^st Century (TEA-21) gives new incentives to reward employees and employers who help reduce traffic and pollution problems. The Commuter Choice provisions in TEA-21, Section 9010, modify the Internal Revenue Code and enable employers to offer employees options for qualified transportation fringe benefits. There are three principal Commuter Choice options: (1) Employees can purchase up to $65 dollars per month in transit benefits using pre-tax income (an amount that increases to $100 in 2002) which slashes the effective cost of transit. (2) Employers can offer tax-free subsidies for their employees' transit costs, with the same limits. And (3) employers can now offer cash in lieu of parking -- "cashing-out" old inflexible parking subsidies.

Emission Reduction Benefits. The most effective Commuter Choice option is the parking cash-out incentive, which helps reduce use of single passenger motor vehicles for those who have the alternative of carpooling, telework, bicycling, walking, or using public transportation. A study of California companies offering this new cash-out option found that one out of eight employees who formerly drove to work chose to leave their car at home so they could instead take a raise in pay.⁴ The share of commuters diverted from solo driving by a cash out option was highest in urban centers with good transit options and lower in suburban fringe areas where transit is not available or very limited and where even carpooling is harder to arrange.

The other Commuter Choice options are employer-paid transit benefits and employee purchase of transit or vanpool benefits using pre-tax dollars. Both of these reduce the cost of using public transportation or vanpools where these are available. EPA recently made estimates of the emissions benefits of the Transitchek program in New York, a transit subsidy program targeting commuters that takes advantage of this federal law change. EPA estimated reductions of about 85 Tons/Yr VOCs, 73 TPY NOx, and 615 TPY CO in 1999. In correspondence with staff of the Senate Environment and Public Works Committee in 1999, the EPA Office of Mobile Sources estimated that a national commuter choice program assuming a 5-10% employee participation rate would generate:

Effects on Employee/Employer Costs. The savings for employees offered by the federal tax law changes are significant and make a high level of employer and employee participation in the next several years realistic. For example, an employee earning $50,000 per year who spends $1000 annually on transit could realize a tax savings (at 42%) of $420 as a result of paying their transit cost using pre-tax dollars, exercising one of the new Commuter Choice options, while their employer would gain payroll tax savings (at 7.65%) of $76 per employee (Arthur Andersen). Even if the cost to set up and administer the program equals 2% of the transit benefit, the employer will still enjoy payroll savings of $56. Employers are likely to face new costs to offer transit passes or added cash income in lieu of parking, but these can also translate into substantial cost savings of several types. It is much cheaper for an employer to boost non-taxable employee benefits than to offer added taxable income to retain or attract workers, which is an increasing issue in a tight labor market. If the employer is able to expand employment without adding more parking spaces or to otherwise avoid the cost of building, leasing, or maintaining parking spaces for workers, capital cost savings can amount to $5,000 to $20,000 per avoided space and operating costs can amount to $750 to $3,000 or more per year per avoided space. Such savings are often significant enough to more than pay for a cash in lieu of parking or transit pass benefit.

State Commuter Choice Incentives. Several states and local governments have offered added transit tax credits, including Washington, New Jersey, and Georgia. Maryland in 1999 adopted the largest tax credit; a 50 percent state tax credit for employer-provided transit benefits that saves employers up to $30 a month per employee, yet this has not been designated as a TCM in the Baltimore SIP or TIP/RTP, nor recognized for its potential effects on traffic and pollution in conformity analysis. Some governments, like Connecticut and Montgomery County, Maryland, sell discounted transit passes to employers, matching employer contributions dollar for dollar, to stretch federal and state tax benefits even farther. Several years ago California adopted a law requiring large employers who lease parking spaces to offer employees added cash income in lieu of parking, but implementation of the law was impeded until recently when conflicting federal tax laws which had worked against cash-out programs were changed.

Broad Support for Commuter Choice Incentives. Commuter Choice programs have been shown to unite the diverse interests of environmentalists, business, labor and transit and highway advocates. Most realize that Commuter Choice is good for business and for communities. Commuter Choice is a voluntary incentive that boosts travel options and supports more efficient use of the roads and transit we already have. It can provide quick relief to traffic-strained communities and will expand market opportunities for new forms of access to suburban jobs. Low- and moderate-income workers benefit particularly, since commuting costs represent a larger relative burden on them, and they tend to be more reliant on ridesharing and transit. The Alliance for Clean Air and Transportation, a new national group representing a diverse array of sectors, including the road builders, automobile industry, environmentalist and health groups, the American Association of State Highway and Transportation Officials, the National Association of Regional Councils, and the US DOT and EPA, in February 2000 adopted a consensus goal of making Commuter Choice benefit programs a standard part of the American worker benefit program over the next five years.

The Need to Go Beyond Marketing and Generalized Expressions of Support. However, Commuter Choice will have an effect on air pollution only if people know about it and use it, and if the opportunities for cost savings offered by aggressive implementation of these incentives are made evident and available to developers, building owners and tenants, and commuters. Marketing alone has been shown to be inadequate to win widespread adoption of Commuter Choice incentives. Mandates for employers to meet pre-established requirements to reduce employee commuting car trips have evoked resentment and resistance from some businesses. But there are many other strategies that can be taken by states, regional bodies, and local municipalities that can foster rapid and widespread adoption of Commuter Choice incentives so these might become available to the average commuter. Additional financial incentives and support by transportation agencies and other government bodies are essential to rapid adoption of Commuter Choice voluntary incentives and can be highly cost-effective in reducing congestion and pollution.

SIP Commitments for Commuter Choice TCM. The measures below are a reasonably available set of steps that municipal, regional, and state agencies can take to assure that potential air pollution reduction benefits from Commuter Choice will be realized in a timely manner. The Baltimore region should include the following reasonably available elements as part of its SIP and TIP/RTP:

1. Municipal and state agencies within the non-attainment area should adopt written SIP commitments that they will provide public leadership by offering Commuter Choice options to their own workforce on a rapid implementation timetable, including management, administrative, and budget commitments to make this possible, and
2. Municipal and state agencies within the non-attainment area should adopt written SIP commitments that they will aggressively promote Commuter Choice options to employers and commuters in their region with marketing, technical and administrative assistance, new transit fare products, and new financial incentives for employers and employees that are adjusted annually in an effort to meet stated performance targets.
3. The SIP should include targets and timetables for (a) providing different segments of the labor force with Commuter Choice options of various types and (b) achieving increased levels of use of various Commuter Choice incentives by various portions of the labor force. For example, a non-attainment area could identify the following model targets, which could be used as the basis for estimating SIP credits if accompanied by commitments to reasonably linked funding and policy commitments that could be anticipated to meet these targets:

1. Municipal, regional, and state agencies within the non-attainment area should identify for priority funding in the next Transportation Improvement Program (TIP) and Regional Transportation Plan (RTP) Commuter Choice promotion initiatives and related incentives. This should include funding for:

1. transit, rideshare, and alternative commute program marketing, paid advertising, and transportation management associations,
2. development of new pre-paid discount transit fare instruments and seamless regional transit fare and service coordination designed to facilitate easy marketing (e.g., introducing a new unlimited use $65/month regional transit pass that can be purchased by or through employers),
3. promotion of pre-paid employer-subsidized transit fare instruments to both employers and employees,
4. transit fare buy-down programs that match employer contributions towards employee transit commute benefits with public sector subsidies (e.g., the Montgomery County, MD, Fair Share program) or tax credits (e.g., the Maryland or Washington State Tax Credits for employers who pay for transit benefits or who offer cash in lieu of parking payments)

1. Municipalities should agree to incorporate incentives for adoption and use of Commuter Choice incentives by employees, employers, and developers through additional flexibility in the application of zoning parking requirements, in requiring that leases and property transactions separately identify the cost of parking spaces and offer options for reduced parking in exchange for covenants and agreements to incorporate cash in lieu of parking and employer paid transit benefits in building leases and other real estate transactions. Municipalities should agree to require Commuter Choice strategies to be considered in traffic planning, site plan and development review decisions, zoning and parking ordinance revisions, access-to-jobs programs and local tax policy.

Background. Transportation agencies have begun to program more bicycle and pedestrian transportation improvements in recent years, making these reasonably available in all metropolitan areas. A large share of these projects offer transportation and related air quality benefits by giving travelers expanded travel choices for short and medium length trips within communities and for access to public transportation. Projects that restore or improve walking and biking connections between neighborhoods to schools, for example, may significantly reduce ‘serve passenger’ trips made by parents to drop or pick up their kids at school. Projects that overcome natural or man-made barriers to safe and comfortable bicycle and walk travel to shopping centers, park-and-ride lots, transit stations, employment centers, or recreational areas may significantly reduce motor vehicle use for access to these activities. Especially when combined with improved transit, expanded financial incentives for use of alternatives, land use and urban design strategies that reduce trip lengths and automobile dependence, and social marketing efforts, investments in pedestrian and bicycle facilities can have a major impact on the number of motor vehicle trips in an area, and typically somewhat lesser impacts on vehicle miles of travel.

Emission Reduction Benefits. The reduction of emissions stemming from improved pedestrian and bicycle is often disproportionately higher than the accompanying reduction in motor vehicle trips and vehicle miles of travel. This is because motor vehicle emissions per mile traveled are highest when engines are cold. Regional travel demand models are usually poorly suited to characterizing the nature, attributes, barriers and potential for non-motorized travel modes. The often inadequate and poor quality local data on walking and bicycling has frequently lead to gross misestimation of the potential for non-motorized modes to play a role in travel and even greater misestimates of their potential to reduce air pollution. When well integrated into a community and regional transportation demand management system, bicycle and pedestrian improvements usually have a potential to multiply the effectiveness of other strategies to reduce motor vehicle trips and emissions by enhancing access to public transportation, influencing travelers to choose closer destinations instead of more distant ones, and enhancing the livability and attractiveness of existing communities, supporting infill development, and boosting travel choice.

SIP Commitments for Pedestrian and Bicycle Improvement TCMs. The Baltimore regional TIP/RTP includes some pedestrian and bicycle improvements, but it is a miniscule percentage of the 20 year plan budget. At this very small level of expenditures on bicycle and pedestrian improvements, there can be little hope of making very much of the region pedestrian and bicycle friendly or to have an appreciable effect on travel demand and emissions from these projects. It is a reasonably available measure to accelerate the rate of project programming and funding commitments for bicycle and pedestrian projects, for example by building out the projected 20-year RTP bicycle and pedestrian program in a period of three to five years. The region is today spending far less than one percent of its RTP capital and operating budget on bicycle and pedestrian projects and programs, it can achieve this SIP objective by increasing spending on these projects to several percent of the total. Funds for this might be found by slipping slightly the timetable for buildout of some other projects in the TIP and RTP that can be expected to increase emissions and thereby delay timely attainment of healthful air quality.

A bicycle and pedestrian SIP commitment might also include funding of a program for community-based bicycle and pedestrian planning and improvements. In a very large share of communities there is significant unmet demand for the retrofit of sidewalks, for pedestrian traffic safety improvements, for enhanced connections of neighborhoods to schools, and for better pedestrian and bicycle access to public transportation. A SIP commitment to fund planning and public involvement to identify, design solutions, and address local needs such as these is a critical part of assuring effective additional efforts in this arena beyond the accelerated funding of TIP and RTP bicycle and pedestrian projects. Because of the difficulty of estimating emission reduction benefits related to many small scale projects, it is important for the SIP emission analysis to aggregate these into a performance-oriented package. In other words, the SIP should set realistic but ambitious mode share objectives and trip reduction objectives related to improving bicycle and pedestrian friendliness of particular areas, fund travel monitoring and planning to evaluate the effectiveness of the overall effort, and not waste time evaluating each individual component of the non-motorized travel investment and service enhancement effort. As the overall package is implemented, the investments, plans, and policies should be actively evaluated together and resources allocations and policies should be refined in response to experience.

Background. There is a growing consensus among land development and real estate experts that some of the best emerging opportunities for market-responsive growth of new housing and employment are in infill redevelopment in existing communities, including urban and inner suburban areas that have been in decline in recent decades. Steps are being taken by some regions to facilitate this shift in development focus. For example, Portland, Oregon, Newark, New Jersey, and Atlanta, Georgia are all taking steps in various phases of progress, towards renewal of brownfields and older neighborhoods. Maryland has passed landmark Smart Growth laws to promote infill development.

Emission Reduction Benefits. There is substantial evidence that significant air quality benefits can be achieved by modifying land development patterns to limit urban sprawl and facilitate transit use. A recent EPA-funded report concludes that careful land use planning can reduce vehicle trip lengths and promote shifts to transit, bicycling and walking modes.⁵ For example, the report cites studies showing that development at infill sites can result in vehicle NOx emissions that are 27% to 42% lower than at more dispersed locations.⁶ The report identifies specific strategies to achieve such results, including planning that promotes transit-oriented development, density transfers, and design elements that encourage pedestrian, bike, transit and ridesharing activity (e.g., narrower streets, sidewalks, bike lanes, traffic calming devices).⁷ The report further identifies a number of cities throughout the nation where such strategies have been adopted and included in air quality plans.⁸ For example, the maintenance SIP for Portland, Oregon identifies several land use TCMs, including an urban growth boundary, requirements for transit-oriented development, and a regional parking policy.⁹ The 1994 Sacramento, CA., ozone SIP contains land use-related TCMs, including a requirement that new developments include mitigation measures to achieve a 15% reduction in vehicle emissions.¹⁰ The San Francisco clean air plan includes land use planning measures, and programs to promote pedestrian travel and traffic calming.¹¹ The EPA report also identifies a number of other land use TCMs that have been adopted in other cities, although not yet included in clean air plans.¹² All of the above-referenced strategies are within the arena of potential RACM that must be considered by the states.¹³

The Atlanta region recently won approval from EPA for a TCM which is composed of a projected 6 million square foot mixed use infill brownfield redevelopment on a 135-acre parcel, together with a regionally significant highway bridge across an interstate road that is needed for site access, and a comprehensive transportation demand management and transit service package for the site and nearby area. This project qualified as a TCM because it was possible to demonstrate that the package of measures, investments, and development would contribute to reduced regional vehicle miles of travel by locating more jobs and housing close to the regional center with appropriate services and incentives.

SIP Commitments for Land Use TCMs. The Baltimore region should develop pilot projects that build upon these models for land use TCMs with comprehensive travel demand management, transit services, and appropriate incentives.

To pick one example in the Washington, DC region, a land use TCM could be focused on the New York Ave/NOMA (North of Massachusetts Ave) corridor Metro-oriented redevelopment zone. The DC Government could identify and package a focused redevelopment zone, related transportation improvements, and supportive transportation demand management policies as a comprehensive land use TCM, building on the precedent set by the Atlantic Steel project in Atlanta, which recently qualified as a TCM. In Atlanta, this 135-acre brownfield redevelopment site in Midtown Atlanta required major transportation investment in the form of a highway bridge across I-75/I-85 to connect it to a MARTA metro station an provide needed access for a 6 million square foot mixed use development. The Atlantic Steel project could only proceed if this transportation project was bundled with added transit investments and services, the infill redevelopment project and appropriate urban design guidelines, and supportive transportation demand management to assure that it would reduce total motor vehicle trips and travel in the region. US EPA helped the Atlanta region with technical modeling assistance that helped demonstrate the emission benefits. This innovative packaging of strategies allowed the transportation investments to move forward despite a transportation conformity lapse in metropolitan Atlanta which blocked other new highway funding approvals.

With the DC region facing tight motor vehicle emission budgets, a similar approach could be followed for the NY Ave/NOMA corridor redevelopment, where a new metro station and transit oriented redevelopment proposals are gathering momentum, but have not yet been accounted for in the regional transportation land use, transportation, and air quality planning process. Similar TCMs could be developed in Baltimore to assure priority access to funding for transportation investments needed to support infill development and to safeguard such investments should the region fall into a conformity lapse.

A smaller scale land use TCM would be geared to removing zoning, permitting, building, parking, and site design code barriers that now impede adaptive reuse of existing buildings for accessory apartments, neighborhood serving retail, and environmentally appropriate home-based business uses in residential areas. Many local jurisdictions now prohibit accessory apartments or make it difficult to provide affordable ‘granny flats’ in existing single-family homes in transit-oriented neighborhoods close to employment centers. One reasonably available land use TCM would facilitate such conversions with code changes, technical assistance and financing, for example to help empty nesters age in place while repopulating older neighborhoods back to their historic population levels. By helping more working families live close to jobs, this would cut vehicle miles of travel, congestion and pollution. The SIP could establish targets for creating new housing units in place in existing transit served neighborhoods, for example, for accessory units to provide for a 1% increase in the number of total housing units per year in zones that are within walking distance of designated ‘smart growth’ centers or within walking distance of transit operating at least once every 15 minutes.

Background. Another control measure that has been implemented in an increasing number of areas around the nation is the phase-out of diesel buses and fleet vehicles on an accelerated schedule and replacing them with new buses and fleet vehicles powered by substantially cleaner fuels, such as natural gas or stored electric power.

Emission Reduction Benefits. Studies show that in-use emissions of NOx and VOCs by natural gas buses are about one-third those of diesel buses.¹⁴ A just released report by the National Association of State and Local Air Quality Officials looking at the health impact of particulates concludes that up to 125,000 Americans may contract cancer as a result truck, bus and other diesel engine emissions. Numerous businesses and bus systems around the nation are now using CNG vehicles, and thus it is clearly an established technology.¹⁵ For all these reasons, and given the substantial number of diesel fleet vehicles operating in most regions, a diesel conversion program is clearly a RACM that must be considered for inclusion in the SIP.

SIP Commitments for Diesel Bus Replacement. Although the issue cost of purchasing alternative fuel vehicles is higher than conventional diesel fuel buses, clean fuel buses are a wise investment in the long run. Diesel buses cost 30 to 50 thousand dollars more then standard diesel buses. Natural gas costs average 15 to 40% less than gasoline or diesel and the engines require less maintenance so you get a long term operating cost benefit. The greatest benefit it offers is the reduction of harmful smog to our health. Over its expected lifetime a CNG bus will save approximately 190 thousand gallons of diesel fuel, also decreasing dependency on petroleum. A city in California recently became the first public agency in U.S. to park a fleet of Diesel buses and switch overnight to a fleet of 100% natural gas, reporting few difficulties in making the transition due to extensive training of staff for the change.

A SIP TCM for diesel bus replacement should identify the timetable for bus replacement, the age of buses being replaced, and adequate funding resources for the replacement.