Agenda Alamo Area Council of Governments Air Improvement Resources Advisory Committee Thursday, July 16th, 2015 – 1:30 p.m. Al J. Notzon, III Board Room 8700 Tesoro Drive, Suite 100 San Antonio, TX 78217-6228

1. Meeting Called to Order

2. Roll Call

3. Citizens to be Heard

4. Consider and Act upon Approval of the April 16th, 2015 Minutes.

5. Air Quality Outreach and Education Report

6. Ozone Report

A. Updates on the Proposed Ozone Standard

7. Consider and Act upon 2015 Path Forward Plan

8. Consider and Act upon AIR Advisory Committee Schedule

9. Ozone Monitoring Subcommittee

10. Bi-annual Air Quality Funding and State Legislative Update

11. Photochemical Modeling Update

A. Anthropogenic Precursor Culpability Assessment (APCA) results for each regulatory monitor in the San Antonio-New Braunfels MSA

12. Potential Cost of Non-attainment

13. Next Meeting, Oct. 15th, 2015 or Sept. 17th, 2015

14. Adjournment

This meeting is accessible to people with disabilities. The accessible entrance is located at the front entrance of 8700 Tesoro Drive. Accessible parking spaces are also available. Please contact AACOG for auxiliary aids and services for the hearing impaired, including interpreters for the deaf, at (210) 362-5200 at least 48 hours prior to the meeting or by calling Texas Relay at 7-1-1 for assistance. 4. Consider and Act upon Approval of the April 16th, 2015 Minutes.

Minutes of the Alamo Area Council of Governments Air Improvement Resources Advisory Committee Meeting Monday – April 16th, 2015 – 1:30 p.m. Al J. Notzon III Board Room 8700 Tesoro Drive, Suite 100 San Antonio, Texas 78217-6228

AIR Advisory Members Guests Kim Stoker, CPS Energy, Vice Chair Nick Page, AAMPO Kyle Cunningham for Vince Nathan, SA Brenda Howard; Dub Smothers Metro Health District

Christopher Ashcraft, STEER Katherine Mehaffey, JBSA Randolph Mark Langford, Mark Langford Photography Mario Bravo, Environmental Defense Fund Brenda Williams, AACOG Citizens to be Heard Russell Seal, Sierra Club Members not present but excused Peter Bella, ImagineSA Forest Mims, Guadalupe County Michael Lewis, Southwest Research Inst.

AACOG Staff Jesse Balleza, VIA Metropolitan Transit Nicholas Jones Andy Quittner, City of Seguin

Parviz Nazem Dean Word III, Word Construction. Chair Maricela Diaz-Wells Paul Detterline, Capitol Cement Dan Titerle, SAWS Frank Dieck, JBSA Lackland William Bushman, Air Force NEPA Center Kathi Harris, HoltCAT Company

1. Meeting called to order Kim Stoker, Committee Vice Chair, called the meeting to order at 1:38 p.m.

2. Roll call A quorum was achieved.

3. Citizens to be heard There were no citizens to be heard.

4. Consider and act upon approval of the January 15th, 2015 minutes 4. Consider and Act upon Approval of the April 16th, 2015 Minutes.

Mr. Mark Langford made a motion to approve the minutes of the January 15th, 2015 AIR Advisory Committee meeting as read. The motion was seconded by Mr. Russell Seal. The minutes were approved unanimously and motion carried. 5. Ozone Report A. Updates on the Proposed Ozone Standard

Ms. Brenda Williams mentioned that since it was in early days of ozone season there was no significant event on local ozone levels to report, then gave a brief slide presentation describing the recent events regarding the EPA’s new proposed ozone standard. She mentioned that the letter that contained 7 recommendations in regards to the proposed ozone standard, which this Committee as well as the Executive Committee had reviewed back in January meeting, has been posted on the EPA’s site on February 11th. According to this site, overall 430,000 responses to the proposed standard have been received by the EPA. Based on the large number of responses, she said, it would be very unlikely that a response to our letter would be sent to us. She also mentioned a US Congress bill known as CASE, which calls for prohibiting the EPA from lowering its national ambient air quality standards until at least 85% of counties that are now in nonattainment areas have attained the current standards. This bill died in the 113th and were reintroduced and referred to Committee in the 114th Congress on March 17, 2015 for another push. Ms. Williams pointed out that, responses from various organizations and agencies, such as TCEQ, TxDOT, and CAPCOG were included in this meeting’s handouts for members review. These responses consistently had emphasized the issue of emission transport that puts Texas counties at a disadvantage, because the majority of these counties are downwind of transported pollutions. TCEQ and TxDOT had proposed to maintain the existing 75 ppb ozone standard, as conformity analysis would be unfeasible for so many projects within Texas metropolitan areas. Since there were no recommendations and comments on this agenda item, the Committee moved to the next item on the agenda.

6. Consider and act upon EPA’s response to the AIR Committee’s Path Forward Letter Ms. Brenda Williams reported on the San Antonio’s Path Forward program and stated that she had received the EPA staff comments on the newest San Antonio’s Path Forward submittal in December 11, 2014 and based on the recommendation from AirExac Committee she will be sending a letter to the EPA emphasizing the Region’s proactive position in adopting voluntary control strategies. The letter had been distributed among the members of the Air Advisory committee and she requested comments or changes to it before its submittal to the EPA. No change to the content of the letter was suggested but comments were made by the committee members as to adopting the EPA’s recommended control strategies would not reduce emissions enough to remain in attainment of national air quality standards and that the EPA did not offer any technical or monetary assistance on identifying the major emission sources inside or outside of the MSA, which influence ozone levels recorded by the regulatory monitors. A motion was made by Mr. Mark Langford to approve the content of the letter, which was seconded by Mr. Peter Bella. The letter was approved unanimously and motion carried.

7. Bi-annual air quality funding and state legislative update 4. Consider and Act upon Approval of the April 16th, 2015 Minutes.

Ms. Brenda Williams reported on the TCEQ-funded technical projects that AACOG Staff perform as part of region’s air quality planning. The funds also enable AACOG to manage a network of air quality monitors spread in the region. Ms. Brenda Williams mentioned that in the beginning the regions that received these funds from TCEQ comprised four metropolitan areas: San Antonio, Austin, Tyler and Longview, and Corpus Christi, but now 9 regions receive funding, which causes the share of each initial four regions to be reduced. She added that this year’s biennium budget for the State air quality planning, has been proposed by TCEQ for the amount of 5,500,000 dollars, but the Senate Finance Committee may increase this funding by $2,074,500, which will be distributed among Waco, El Paso, Beaumont, Austin, Corpus Christi, Granbury, Longview-Tyler-Marshall, San Antonio, and Victoria. In addition, the rider is amended to add the Killeen-Temple area to the list of areas eligible for air quality planning funding included in the rider, and language would be added requiring that each area receive $350,000 in funding, and that remaining funds be allocated based on population in excess of 350,000. Although the Senate’s version of the budget has been approved according to the latest information gathered by AACOG Staff, the AIR Advisory committee will conduct a follow up on this issue for their next meeting.

8. Photochemical Modeling Update

Ms. Brenda Williams reported that 6 out of 7 planned models runs have been completed, and the only remaining one was a run for Area Source emissions with 10 tons reduction in actual NOX emissions so that the affect of this reduction on ozone level could be model and evaluated. She showed a bar chart in her slide presentation that had documented the results of the 6 model runs. According to this chart, the most effective strategy would be to reduce 10 tons of NOX from off-road/non-road emission sources. This control strategy could reduce the ozone level in the region by nearly 1 pbb; reduction of NOX emissions from Point Sources came as second most effective strategy reducing the ozone level by 0.84 ppb.

The next slide showed a bar chart depicting an historical account of emissions by emission sources indicating gradual reduction in on-road emissions, due to stricter regulation of vehicles at federal level, and importance of emissions from point sources in the future, which made them a candidate for stricter air quality regulation. Mr. Russell Seal asked if the closing of Deely power plant has been taken into account for point sources in the 2018, to which no definite answer could be found since Mr. Smeltzer, the photochemical modeler, was not present to answer the question. However, Peter Bella answered that to the best of his knowledge Mr. Smeltzer has never included the closure of Deely power plant in the 2018 emission inventory; rather he has done that for the 2023 emission inventory.

Mr. Mark Langford asked if Steve could provide the Committee with a graph showing the historical biogenic VOC and NOX contribution compared with the various emission sources, and Mr. Peter Bella requested a bar chart that showed historical contribution of individual facilities to the Point Source emissions. It was also mentioned that the Deely power plant will remain as a backup energy generator for the CPS Energy in the future years and will be brought back online if the demand for electricity would dictated so.

Mr. Russell Seal indicated his interest in having access to information as to how the electric cars replace the older gasoline cars in the San Antonio region, and if EPA’s MOVES model had any account of replacement of the older cars. The MOVES model does take into account the fleet vehicle mix and fleet age for each modeling year, which together account for gradual 4. Consider and Act upon Approval of the April 16th, 2015 Minutes.

replacement of older models with newer and cleaner cars in the process of emissions forecasts, but since it considers electric cars zero emission vehicles, it does not generate VOC or NOX emissions for them.

Mr. Christopher Ashcraft asked if the amount of emissions associated with the oil and gas exploration shown on the bar chart indicated the total emissions within the Eagle Ford Shale or exclusively for those areas with the MSA. Ms. Williams answered that the emissions are for the areas within the MSA, but specifically for Wilson and Atascosa counties that were within the Eagle Ford area.

Mr. Russell Seal indicated his interest in having a graph that showed the incoming NOX emissions outside of the MSA for the 3 years (2018, 2020, 2023) shown on the graph. It was decided that Steve would look into feasibility of producing such graph. C

9. Potential Cost of Non-attainment

Ms. Brenda Williams briefly talked about a list of control strategies and their associated costs and emission benefits, which had been prepared by the TCEQ staff and submitted to AACOG for distribution among the Air Quality Improvement committee members for their review. This list will assist the region to choose those that best suit the needs of San Antonio region since now we know reduction of NOX emission causes more ozone reduction at monitors as opposed to the reduction of VOC emissions.

10. Next Meeting

The Committee decided to meet on July 16th, 2015.

11. Adjournment There being no further business to discuss, the meeting was adjourned at 2:53 p.m.

Air Quality Outreach and Education Report for the Air Improvement Resources Advisory Committee 7-16-15

Types of Outreach Conducted by Air Quality Staff

 Exhibits at health, environmental, and community events  Group presentations  News media  Social media  Paid advertising  Air Quality Health Alert notification

Areas of Concern Expressed by AIR Executive Committee

Paid Advertising

Reported: April through September digital billboards highlighting Fresh Air Friday Ozone Actions Campaign: Loop 410 at Bandera, I-10 at Fredericksburg, I-35 at Weidner, and Hwy 281 at Donella. Each spot: 10 seconds. Number of spots each 24 hrs at each location: 480. Estimated number of distinct viewers every week: 1,000,000+. Regular messages can be switched out for Air Quality Health Alerts. Limited funds for advertising come through the Commute Solutions contract.

Additional Information Requested: Budget expenditures for paid advertising (provided below)

Concerns:  The amount of advertising exposure may not be enough for messages to sink in and be effective with those who see them  It is important that people in the entire region are exposed to such messages

Recommended Action:  Leverage available funds to help represented jurisdictions promote the air quality messages in their areas through their own channels  Pursue the assistance of a marketing firm, preferably pro bono, to sharpen the ads’ appeal  Emphasize the saving of money in the ads

News Media

Reported: From Jan-May air quality staff produced 6 air quality-related press releases, which have resulted in at least 10 articles and 9 interviews in outlets such as the San Antonio Business Journal, the Bandera Currier, WOAI TV, and KTSA radio.

Concerns:  It will take more than one press release per month to get the importance of air quality to sink in with the media and draw the public’s attention to the gravity of the issues involved  The media need to better understand the meaning and nature of air quality issues in advance of receiving messages so that they pay more attention to them and can act effectively

Recommended Action:  Integrate air quality messages as much as possible with the larger AACOG communications strategy  Provide a workshop to help media better understand the meaning and importance of AQHAs in advance of notices they receive  Hold a special summit in the region to discuss the various aspects of the new air quality standards  Pen a special letter from the Executive Committee to the media meteorologists so that they better understand the gravity of the situation

Air Quality Health Alert Notification

Reported: In addition to helping the public understand what the meaning of an Air Quality Health Alert for an Ozone Action Day (AQHA/OAD) and what they can do to protect themselves or help prevent an actual exceedance, staff sends an emailed notification to businesses, schools, agencies, and individuals who have requested it, staff emails notification when there is an AQHA/OAD to those requesting it. From January through May there were 123 new requests added to the list. Total notification includes about 18 hundred email addresses.

Recommended Action:  Reach out to physicians’ offices to alert them of the availability of AQHA/OAD notifications so that patients can sign up—possibly providing a brochure  Medical specialists may also benefit from the receipt of a special letter from the Executive Committee

Advertising Expenditures for the Commute Solutions Program in Recent Years

Type Advertising Locations Duration Cost 2012 Ped-Ad, Street Banner, KTFM Fresh Air Friday Downtown San Antonio (and March- Radio, Posters Event beyond with radio) April 4,963 NuRide: Carpool Hwy 90@1604 (W Bexar Co), Hwy Stationary Matching Service / 16@Hwy 46 (Bandera Co), Hwy Billboards Rewards 281@FM311 (Comal Co) June-July 6,330 Radio (KISS, Ozone Season May-Jun/ KTFM) Messages Regional Aug-Sep 8,280 Walk & Roll August- Posters Challenge Various locations Oct 64 Walk & Roll TPR Radio Challenge Regional Aug-Sep 1,999 TOTAL 21,638 2013 I-10@Foster (E Bexar Co), I- NuRide: Carpool 35@SW Military (SW Bexar Co), Stationary Matching Service / US 90@36th (W Bexar Co), I- Billboards Rewards 35@FM 1518 (W Guadalupe Co) Feb-Mar 18,100 Ped-Ad, Street Fresh Air Friday Banner, Posters Event Downtown San Antonio Mar-Apr 1,678 Radio (KCYY, Ozone Season May-Jun/ KISS, KBBT) Messages Regional Aug-Sep 19,168 KSAT App/Mobile Site AQHAs Regional Aug-Oct 1,600 Walk & Roll TPR Radio Challenge Regional Aug-Sep 1,999 TOTAL 42,545 2014 KXXM Radio & I- Pre-Ozone Season Heart Streaming & FAF Event Regional March 4,302 Street Banner, Fresh Air Friday Posters Event Downtown San Antonio Mar-Apr 319 Radio (KCYY, Ozone Season May-Jun/ KISS, KBBT) Messages Regional Aug-Sep 25,200 TOTAL 29,821 2015 Street Banner, Fresh Air Friday Ped-Ad, Posters Event Downtown San Antonio Mar-Apr 1,675 Ozone Season Loop 410@Bandera (NW SA), I- Fresh Air Fridays 10@Fredericksburg (Central Campaign / SA), I-35@Weidner (NE SA), Digital Billboards AQHAs and Hwy 281@Donella (NC SA) Apr-Sep 28,880 TOTAL 30,475 Examples of Digital Billboard Images Used in Ozone Actions Campaign

Billboard Images For Display When There Is an Air Quality Health Alert

Recent Annual Message Sent to All Area TV Meteorologists

From: Annette Prosterman Sent: Thursday, May 07, 2015 4:21 PM To: Annette Prosterman Subject: Ozone Season: Air Quality Health Alerts/Ozone Action Days

Dear San Antonio-based Meteorologists:

On behalf of the Alamo Area Council of Governments (AACOG), the San Antonio area agency that is responsible for monitoring air quality and educating the public regarding ways reduce air pollution, I would like to thank you for your diligence in informing the public when the Texas Commission on Environmental Quality has predicted that the amount of ground-level ozone may be unhealthy and it has therefore issued an Air Quality Health Alert for Ozone (Ozone Action Day).

For the past three consecutive years, as you are likely aware, the greater San Antonio area has violated the federal standard for ozone pollution, which is based on a three- year average of the fourth highest ozone level in an 8-hour period at one of our area’s regulatory monitors, with a threshold of 75 parts per billion (ppb). Although the current “ozone season” is barely underway, the San Antonio area is very close to being non- compliant with the federal standard based on its current three year average, with 71 ppb at the Camp Bullis regulatory monitor. (Click here for more information.) Already this season, regulatory monitors at Camp Bullis and Marshall High School have registered an 8-hour average reading high enough to exceed the daily threshold, rendering the air unhealthy for sensitive groups (such as children, those with respiratory illnesses, and those who work outdoors) on those days (May 1st and May 2nd).

For the sake of public health and economic well-being, AACOG and its government members are eager to get back into compliance with the federal clean air standards for ground-level ozone. Several of you have assisted in this process by not only announcing when an Air Quality Health Alert/ Ozone Action Day has been issued, but also mentioning specific actions that individuals can take to help reduce the buildup of ozone in our air. Knowing that each second on air is precious, we greatly appreciate the time you take to do this.

It is likely you know that ozone is formed when Nitrogen Oxides (NOx), such as those found in vehicle exhaust, combine in sunlight with Volatile Organic Compounds (VOCs), such as those found in gasoline fumes. You may not know, however, that suggesting steps to limit the NOx in our air, such as driving less or not idling in restaurant drive- thrus, is much more effective in reducing ozone than those that limit VOCs in our air, such as waiting until evening to fill one’s gas tank or waiting for another day to paint the house. This is because, as technical analyses conducted by AACOG and the state indicate, we are a NOx-limited area. That is, we have an excess of VOCs that can only form ozone if there is more NOx. Conversely, we can limit ozone production by reducing NOx.

Therefore, if and when you do have the time and would be so helpful as to offer examples of what people can do to help improve air quality, we recommend the following:

 Eating in for lunch or walking out—rather than driving out—for lunch  Avoiding congested areas on the roadways—especially during rush hours  Carpooling or taking the bus  Parking and going inside the restaurant, bank, or pharmacy instead of idling one’s vehicle in drive-through lanes  Postponing unnecessary trips on Ozone Action Days

Finally, as your limited time on air permits, we would truly appreciate your assistance in helping viewers to understand the meaning and implications of an Air Quality Health Alert/Ozone Action Day. We have found through surveys that may people in the San Antonio area don’t understand that while it’s good to have ozone as a protective layer in the Earth’s upper atmosphere, it’s harmful in the air we breathe, or that the alerts are being issued not so that sensitive people will apply an extra layer of sunscreen, but will limit their exertion outdoors.

Please feel free to contact me if you would like to discuss air quality further.

Again, thank you so much for all that you do to inform the public about our weather and related issues.

Sincerely, Annette

Annette Prosterman, PhD Natural Resources Transportation Coordinator Alamo Area Council of Governments (210) 362-5213 www.aacog.com/air

Agenda Item 6. Ozone Report

Ozone Report Air Improvement Resources Technical Committee July 13, 2015

Description of ozone standard promulgated in 2008: The annual fourth-highest daily maximum 8-hour concentration, averaged over 3 years, measured at each monitor within an area must not exceed 0.075 ppm.1 Table 1 describes current status of San Antonio-New Braunfels MSA in this regards. This standard currently is being reevaluated and the EPA is proposing the 8-hour standard to be set within a range of 65 to 70 ppb.2

Table 1: Status of Compliance with 8-Hour Ozone Standard, San Antonio-New Braunfels MSA, 20153 4th Highest Reading, ppb The 4th highest value in 2015 Current* 3 Year Monitor Site must be below this Average 2013 2014* 2015* value to meet the 75 ppb standard† Camp Bullis C58 83 72 67 74 73 San Antonio NW C23 76 69 66 70 83 Calaveras Lake C59 69 63 60 64 96 * 2015 as of 7/06/2015 * 2014 as of 10/31/2014 † If the three year average is to be in compliance with the 2008 standard, the 4th highest eight-hour average daily reading for each particular monitor must be less than shown value.

During 2014 as the Table 2 indicates, CAMS58 at Camp Bullis recorded an 8-hour average ozone level of 72 ppb. If this number is averaged with the fourth-highest values recorded at the monitor for 2012 and 2013 when these readings are confirmed by TCEQ, then the San Antonio region will have exceeded the current 8-hour average ozone standard.

Table 2: Status of Compliance with 8-Hour Ozone Standard, San Antonio-New Braunfels MSA, 20144 4th Highest Reading, ppb Current 3 Year Monitor Site 2012 2013 2014 Average

Camp Bullis C58 87 83 72 80 San Antonio NW C23 81 76 69 75 Calaveras Lake C59 70 69 63 67

1 Available online: http://www.epa.gov/air/criteria.html 2 Available online: https://www.federalregister.gov/articles/2014/12/17/2014-28674/national-ambient-air-quality-standards-for- ozone 3 Available online: http://www.tceq.state.tx.us/cgi-bin/compliance/monops/8hr_attainment.pl 4 Ibid

Page 1 of 3 Agenda Item 6. Ozone Report

Table 3: Status of Compliance with 8-Hour Ozone Standard, Texas Urban Areas 20145 4th Highest Value, ppb 2014 Design Region 2012 2013 2014 Value Dallas-Fort Worth 81 85 77 81 San Antonio - New Braunfels 87 83 72 80 Houston-Galveston-Brazoria 87 84 71 80 El Paso 74 73 70 72 Temple 78 71 69 72 Longview-Tyler-Marshall 78 71 66 71 Beaumont-Port Arthur 76 67 67 70 Waco 73 72 63 69 Austin-Round Rock-San Marcos 76 70 63 69 Corpus Christi 69 66 65 66 Victoria 66 62 62 63 Lower Rio Grande Valley 58 58 60 58

Figure 1: Number of 8-Hour Ozone Exceedances of 65 ppb at EPA Regulatory CAMS in the San Antonio-New Braunfels MSA, 2005-2014

5 Ibid

Page 2 of 3 Agenda Item 6. Ozone Report

Figure 2: Number of Days with 8-hr Ozone Averages > 65 ppb by Semi-monthly Periods for San Antonio, 2005 – 2014

2009 2010 EPA’s Proposed Ozone Standard Timeline

Nov. 25, 2014: EPA released a proposal to update the NAAQS for ground-level ozone • Court-ordered requirement • EPA proposes the 8-hour standards to be set within a range of 65 to 70 ppb • EPA is seeking comment on levels as low as 60 ppb Dec. 17, 2014: Proposed rule was published in the Federal Register March 17, 2015: Comments on the Proposed Rule were due to the EPA, and the AIR Executive Committee members submitted their comments

Oct. 1, 2015: Court-ordered deadline for EPA to issue the final ozone standard Oct. 1, 2017: EPA determination of attainment or non-attainment for affected areas (maybe based on 2014, 2015, and 2016 3-year average) Oct. 1 2020: SIP elements for non-attainment areas are due

Dec. 31, 2020: Attainment deadline for “Marginal” areas 2011 2012 Dec. 31, 2023: Attainment deadline for “Moderate” areas

Page 3 of 3

2013 2014

Alamo Ozone Advance Program: Regional Sustainability Initiatives

Voluntary Measures for the AACOG Ozone Advance Path Forward

2015 Path Forward Update

To be reviewed by the AIR Advisory Committee July 16, 2015

Updated July 9, 2015

Prepared by

Ozone Advance participation letter from the Air Improvement Resources Committee of the Alamo Area Council of Governments, dated July 25, 2012.

Ozone Advance participation letter from the Air Improvement Resources Committee 2 of the Alamo Area Council of Governments, dated July 25, 2012

Table of Contents

Chapter 1: Introduction ………………………………………………………………… 5

Chapter 2: Background………………………………………………………………… 7 2.1 Ozone Monitoring……………………………………………………………… 8 2.2 Air Quality Trends and Design Values……………………………………….. 9 2.3 Seasonal Variations in Ozone Concentrations……………………………… 10 2.4 Meteorology and Ozone Concentrations…………………………………….. 11 2.5 Emission Sources and Trends………………………………………………… 11 2.6 Photochemical Models…………………………………………………………. 13 2.7 Predicted Ozone Concentration Comparisons: 2006, 2012, and 2018…… 14 2.8 Next Steps……………………………………………………………………….. 16

Chapter 3: Ongoing Strategies…………………………………………………………. 17 3.1 Voluntary Emission Reduction Strategies……………………………………. 17 3.1.1 CPS Energy………………………………………………………………. 17 3.1.2 City of San Antonio………………………………………………………. 18 3.1.3 Local Cement Industry…………………………………………………… 20 3.1.4 Local Oil & Gas Industry: Eagle Ford Shale…………………………… 21 3.1.5 VIA Metropolitan Transit…………………………………………………. 23 3.1.6 Alamo Area Metropolitan Planning Organization……………………… 24 3.1.7 San Antonio Water System……………………………………………… 24 3.1.8 Texas Department of Transportation – San Antonio…………………… 24 3.1.9 Build San Antonio Green……………………………………………… 25 3.2 Air Quality Outreach and Education Programs………………………………. 26

Chapter 4: New/Proposed Strategies…………………………………………………. 34 4.1 City of San Antonio……………………………………………………………… 34 4.2 San Antonio Metropolitan Health District Air Quality Program Proposal….. 34 4.3 Local Oil & Gas Industry: Eagle Ford Shale…………………………………. 35

Chapter 5: Public/Stakeholder Involvement………………………………………….. 36

Appendix A: Major Stationary Sources in the SA-NB MSA, 2012…………………. 37

Appendix B: Potential Control Strategies List………………………………………… 40

3

Table 2-1: 2010, 2013 and 2014 population estimates for the SA-NB MSA, U.S. Census data……………………………………………………………………………… 8

Table 2-2: Ozone-measuring monitors in the San Antonio region with locations, types of data collected, and reporting details………………………………………… 9

Table 2-3: San Antonio design values between 2010 and 2015…………………… 10

Table 2-4: Tons of anthropogenic NOX and VOC emissions per ozone season weekday, San Antonio - New Braunfels MSA, 2012, 2018, 2023…………………. 12

Figure 2-1: Map of the 13-county AACOG region and 8-county San Antonio-New Braunfels Metropolitan Statistical Area………………………………………………. 7

Figure 2-2: Locations of regulatory and non-regulatory ozone monitors in the San Antonio area………………………………………………………………………… 8

Figure 2-3: Annual fourth highest 8-hour average ozone concentrations in ppb recorded at regulatory monitors in the San Antonio area, 2008 – 2015…………… 10

Figure 2-4: Map of the most heavily-traveled roadways in the AACOG region…… 13

Figure 2-5: Change in San Antonio-New Braunfels MSA Eight-Hour Design Values, 2018……………………………………………………………………………… 14

Figure 2-6: Predicted daily maximum 8-hour ozone concentrations in the 4-km subdomain for selected episode days, 2006, 2012 Eagle Ford, and 2018 Eagle Ford moderate scenario………………………………………………………………… 15

Figure 3-1: Annual VMT reductions recorded by NuRide participants…………….. 30

Figure 3-2: Annual VOC and NOx reductions (lbs.) from decreases in VMT, as recorded by NuRide participants………………………………………………………. 30

4

Chapter 1: Introduction

As a “near-nonattainment” area for ozone, the San Antonio region has a long history of air quality planning and voluntary control implementation aimed at keeping the region’s air quality within the thresholds established by the National Ambient Air Quality Standards (NAAQS). As early as 1995, the first air committee was formed by the Alamo Area Council of Governments to address air quality issues. This committee requested the first emissions inventory for the region, for inventory year 1994.

In January 1996, the San Antonio Mayor's Blue Ribbon Committee on Air Quality merged with the Air Quality Committee of the Alamo Area Council of Governments (AACOG) to form the Air Quality Task Force (AQTF). The charge of the AQTF was to develop public education and provide advice to elected officials on air quality issues. The major accomplishment of the early AQTF was the establishment of the Ozone Action Day program. During FY 1996 - 1997, the AQTF provided input on the first Near Non-Attainment grant, authorized by the 1997 Texas Legislature.

However, when the U.S. Environmental Protection Agency (EPA) proposed the new eight-hour ozone NAAQS in the summer of 1996, the focus of the AQTF began to shift, first by providing comments and guidance on the impact of the new eight-hour ozone NAAQS. Monitor results indicated that on high ozone level days, background levels coming into Bexar County were at or near ozone NAAQS threshold levels. Later that year when EPA finalized the eight-hour NAAQS it became apparent that, based on historical data, the San Antonio Metropolitan Statistical Area (SA/MSA) could well be designated non-attainment when the EPA made the first eight-hour non-attainment designations initially scheduled for July 2000.

During July 1998, the City of San Antonio (COSA), San Antonio-Bexar County Metropolitan Planning Organization (MPO), Bexar County, and AACOG staff recommended to elected officials that the AQTF be revised to fit the structure advised by the Texas Commission on Environmental Quality (TCEQ), then known as the Texas Natural Resource Conservation Commission (TNRCC). During January - February 1999, AACOG’s Boards of Directors and other responsible parties representing COSA, Bexar County, and the MPO approved the formation of the Air Improvement Resources (AIR) Committee consortium including the Executive/Advisory, Technical, and Public Education Committees and member appointments. The AIR Committee conducted their first official meeting during April 1999 with the goal to establish an organized, comprehensive, and aggressive plan of action to keep the SA/MSA from slipping into nonattainment of the ozone standard.

In 2002, EPA announced the Early Action Compact (EAC) protocol for helping regions achieve and maintain the 8-hour ozone NAAQS by facilitating early, voluntary ozone reduction plans in a manner consistent with applicable local, state, and federal air

5 quality policies. The protocol outlined specific deliverables and reporting requirements for participation. Later that year, the elected officials serving on the AIR Executive Committee, with the approval of the local municipalities and counties they represented, signed an EAC in partnership with the Chairman of the TNRCC (now the TCEQ) and the Regional Administrator for the EPA.

Although EPA designated the San Antonio region as being nonattainment deferred due to a recorded design value of 89 San Antonio, parts per billion (ppb) during the 2001-2003 averaging period, Texas is the most the EAC agreement allowed the region time to implement populous city in the U.S. that has voluntary strategies that helped to reduce ozone precursor not received a full emissions. By the end of the effective term of the EAC on nonattainment December 31, 2007, regulatory monitors were again showing designation. compliance with the ozone standard. Under the terms of the EAC, the region was re-designated as being in attainment, that is, as being in full compliance with the federal ozone standard.

With the promulgation of a revised 8-hour average ozone standard in 2008, however, the San Antonio region again faced the possibility of a nonattainment designation. In April 2012, EPA designated 46 areas as nonattainment of the 75 ppb threshold established by the 2008 standard. Although the San Antonio region’s ozone values met the standard at the time, within a few months, the three-year average on which attainment is based had climbed above the health-based standard.

The on-going challenge the region faces in meeting the 2008 standard as well as past successes with the EAC program provided local leaders the incentive to participate in EPA’s Ozone Advance program. Although the program does not shield an area from a nonattainment designation, it does facilitate efforts aimed at reducing ozone pollution and maintaining healthy air quality. Therefore, the program has the potential for helping a region avoid a nonattainment designation and the requirements associated with such a designation.

In July 2012, the AIR Executive Committee submitted to EPA a letter of participation in the Ozone Advance program. In 2013 and 2014, the Committee submitted a Path Forward plan for the region that described activities implemented by multiple regional government agencies, industries, and organizations to reduce NOx and VOC emissions.

This document is the 2015 update to the Alamo Ozone Advance plan and describes successes, program enhancements, and new and proposed strategies for improving air quality and community health in the San Antonio region. Differences between the 2014 and 2015 Path Forward are the updates to sections addressing background information and new/proposed control strategies in the 2015 version. Any subsections in the chapter listing ongoing strategies for which AACOG was provided updated information have been identified as updated from the 2014 Path Forward.

6

Chapter 2: Background

San Antonio, located in south-central Texas, is the second largest city in the state and the seventh largest in the nation.1 The U.S. Census Bureau estimates that, among the nation’s municipalities, San Antonio experienced the third largest numeric increase in population from April 1, 2010, to July 1, 2011. Nearby Austin was ranked fourth for numeric increase.

San Antonio is in Bexar County, which is centrally located in the 13-county AACOG region (figure 2-1). The metropolitan statistical area includes Bexar and seven surrounding counties. The second largest city in the MSA is New Braunfels, located in adjacent Comal County. County populations for the SA-NB MSA are listed in table 2-1.

Figure 2-1: Map of the 13-county AACOG region and 8-county San Antonio-New Braunfels Metropolitan Statistical Area (dark green)

1 U.S. Census Bureau Texas Dominates List of Fastest-Growing Large Cities Since 2010 Census, Census Bureau Reports, June 28, 2012, available at: https://www.census.gov/newsroom/releases/archives/population/cb12-117.html

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Table 2-1: 2010, 2013, and 2014 population estimates for the SA-NB MSA, U.S. Census data2 MSA County 2010 Population 2013 Population 2014 Population Atascosa 44,911 47,093 47,774 Bandera 20,485 20,601 20,892 Bexar 1,714,774 1,817,610 1,855,866 Comal 108,472 118,480 123,694 Guadalupe 131,537 143,183 147,250 Kendall 33,410 37,766 38,880 Medina 46,006 47,399 47,894 Wilson 42,913 45,418 46,402

This Path Forward plan covers the eight-county SA-NB MSA, as this is the presumptive boundary for a nonattainment designation under the federal Clean Air Act, should the area be subject to such a designation.

2.1 Ozone Monitoring Ozone concentrations are measured by a network of continuous air monitoring stations in and surrounding San Antonio (figure 2-2). TCEQ operates three regulatory monitors, AACOG operates six non-regulatory monitors, and CPS Energy, the local energy utility in San Antonio, operates two monitors. While other air monitors exist in the region, the common feature of the mapped monitors is that they all measure ambient ozone concentrations. In addition to ozone, several stations measure other chemicals and/or meteorological parameters, as described in table 2-2.

Figure 2-2: Locations of regulatory and non-regulatory ozone monitors in the San Antonio area

2 U.S. Census Bureau, American FactFinder, available at: http://factfinder2.census.gov/bkmk/table/1.0/en/PEP/

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Table 2-2: Ozone-measuring monitors in the San Antonio region with locations, types of data collected, and reporting details First date of reporting Designation / Site Location Description Data Measured (online) / Currently Name maintained by C23 6655 Bluebird Lane O3, meteorology September 17, 1996 Marshall High School San Antonio TCEQ C58 Near Wilderness NOx, O3, August 12, 1998 Camp Bullis Road, San Antonio meteorology TCEQ C59 14620 Laguna Road SO2, NOx, O3, May 13, 1998 CPS Calaveras Lake San Antonio PM2.5, meteorology San Antonio Metropolitan Health District C678 802 Pecan Valley Dr. CO, SO2, NOx, O3, March 4, 1999 CPS Pecan Valley San Antonio PM2.5, meteorology Dios Dado for CPS C501 11535 Pearsall Road O3, meteorology June 17, 2002 Elm Creek ES Bexar County Dios Dado for AACOG C502 7286 Dietz Elkhorn O3, meteorology June 28, 2002 Fair Oaks Ranch Rd, Fair Oaks Ranch Dios Dado for AACOG C503 1715 E. Ammann Rd. O3, meteorology August 26, 2002 Bulverde ES Bulverde, Comal Dios Dado for AACOG County C504 2090 Airport Rd. Ozone August 30, 2002 New Braunfels Airport New Braunfels, Dios Dado for AACOG Guadalupe County C505 21340 FM 3009 Ozone March 26, 2003 Garden Ridge City of Garden Ridge Dios Dado for AACOG C506 1865 Hwy 90 East Ozone March 26, 2003 Seguin Outdoor City of Seguin Dios Dado for AACOG Learning Center C622 7145 Gardner Road CO, SO2, NOx, O3, July 29, 2004 Heritage Middle San Antonio PM2.5, meteorology Dios Dado for CPS School

2.2 Air Quality Trends and Design Values Ground-level ozone is one of the most pervasive air pollutants in the country. Like many areas, San Antonio struggles to remain in compliance with the federal ozone standard. As shown in figure 2-3, the annual fourth highest 8-hour average ozone values, upon which attainment calculations are based, have exceeded the 2008 standard’s 75 ppb threshold (dotted green line) at one or more San Antonio monitors, four of the seven years between 2008 and 2015.

Monitors C23 and C58 in northwest Bexar County typically record the highest ozone concentrations of the three regulatory monitors, as these are located at “downwind” sites. Wind directions during the ozone season are more likely to originate from the northeast, east and southeast quadrants than other directions. Conversely, C59 located in southeast Bexar County is an “upwind” monitor that typically provides data on background ozone concentrations, before air parcels reach San Antonio’s urban core.

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Figure 2-3: Annual fourth highest 8-hour average ozone concentrations in ppb recorded at regulatory monitors in the San Antonio area, 2008 – 2015*

*2015 data as of 7/2/2015. Note: Data validated by TCEQ through May 2015.

While the region experienced generally decreasing ozone levels between 2004 and 2009, based on the rolling three-year averages or design values for that period, local design values began to increase in 2010 and continued that trend through 2013. Table 2-3 lists the design values for regulatory monitors between 2010 and 2015. Exceedances of the NAAQS are distinguished by orange font.

Table 2-3: San Antonio design values between 2010 and 2015 Monitoring Site 2010 2011 2012 2013 2014 2015* San Antonio Northwest C23 75 75 77 78 75 70 Camp Bullis C58 75 75 80 81 78 74 Calaveras Lake C59 67 66 69 70 68 64 *2015 data as of 7/2/2015. Note: Data validated by TCEQ through May 2015.

2.3 Seasonal Variations in Ozone Concentrations In addition to annual trends, AACOG tracks seasonal ozone trends as part of the development of a conceptual model for the region. From April through June, there is a seasonal increase in the number of high ozone days in most Texas cities. This period represents the first and longest high ozone seasonal peak that San Antonio typically experiences. However, by early July the number of high ozone days decline. The next seasonal increase covers a period beginning in August and ending in late October, during which the frequency of high ozone days is slightly lower than the spring period.

Ozone concentrations fluctuate by season depending on several factors including variations in transport, meteorology, chemical loss of ozone, and upper stratospheric ozone levels. During the spring and fall ozone season peaks, for example, ozone transport is significant. Ozone transport is lowest in July before increasing again into the late summer and fall.

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2.4 Meteorology and Ozone Concentrations Certain identifiable regional-scale meteorological pressure systems are associated with high ozone events. Prevailing wind directions, wind speeds, mixing, and dispersion conditions are influenced by high-pressure systems. High-pressure systems suppress vertical mixing of pollutants and influence wind direction, and are characterized by clear skies, relatively low wind speeds, and low humidity in San Antonio. These meteorological conditions typically increase ozone formation and transport of pollutants into the San Antonio area and generate elevated concentrations of local ozone.

An analysis between meteorology and ambient ozone indicates a number of local meteorological factors that contribute to elevated ozone concentrations in the San Antonio region. The following summarize the relationship between local meteorology and ozone photochemistry:

Meteorological conditions on days with elevated ozone typically include stagnated winds over Texas, limited frontal movement, lack of precipitation, reduced mixing between layers, and clear skies. High ozone days are typically absent of strong synoptic weather systems. Local meteorological conditions associated with high ozone days include lack of precipitation, low atmospheric moisture content in the afternoon, and clear skies. Wind vectors on high ozone days were more stagnated and often originated from the east and northeast. Mixing heights are typically lower in the early morning hours and experience a rapid rise in the late morning through early afternoon on high ozone days. Low nighttime mixing height can trap nocturnal pollutants from the local area as well as emissions from the previous day. When combined with a rapid rise in mixing height that allows downward mixing of transported pollutants from higher inversion layers, ozone can become significantly elevated.

2.5 Emission Sources and Trends AACOG develops periodic emissions inventories of non-road, off-road, and area sources in the region. Combining AACOG data with point and on-road emissions calculated by other state agencies provides an indication of the daily and annual anthropogenic VOC and NOx emissions generated in the region by sector.

Despite a consistently increasing population in the region and escalating activity in the nearby Eagle Ford Shale play, analyses of emissions trends indicates that regionally- generated NOX emissions should continue a downward trend, in large part due to improvements in vehicle emission standards. Local VOC emissions are expected to remain static (table 2-4).

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Table 2-4: Tons of anthropogenic NOX and VOC emissions per ozone season weekday, San Antonio - New Braunfels MSA, 2012, 2018, 2023 VOC NO Source X 2012 2018 2023 2012 2018 2023 Eagle Ford 3 7 7 4 4 4 Non-Road 27 19 17 20 11 8 Off-Road 3 3 3 8 8 7 Area 151 154 190 16 16 17 Point 6 7 7 66 64 57 On-Road 33 22 19 77 43 32 Total 224 213 244 190 146 125

On-road vehicles have traditionally represented the largest source of NOx in the region. San Antonio is transected by a number of major highways and its proximity to multiple land and ocean ports guarantees an abundance of heavy duty vehicle traffic. Development of the Eagle Ford Shale area has served to further increase the use of heavy-duty vehicles on the region’s roadways. Figure 2-4 highlights the most heavily- traveled roads in the region.

Weekday NOx emissions for 2012 from on-road sources in the SA-NB MSA were estimated at 77 tons per day, followed by point sources at 66 tons per day. By 2018, that trend is expected to reverse, so that point sources are expected to be the largest source of NOx, at 64 tons per day, and on-road sources fall to second largest at 43 tons per day.

The largest point sources for NOx emissions in the region are coal-fired power plants and cement plants. Other point sources include military bases, research facilities, and manufacturing operations. Appendix A lists major stationary sources in the SA-NB MSA.

In terms of anthropogenic emissions, most VOCs generated in the SA-NB MSA are the facilities and activities collectively categorized as area sources. This trend is expected to continue through 2023, the last date for which emissions have been estimated.

Modeling and other analyses indicate the SA-NB MSA is NOx limited. Therefore, air quality planning tends to focus on controls that reduce NOx emissions, although VOC controls are also evaluated.

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Figure 2-4: Map of the most heavily- traveled roadways in the AACOG region. Data courtesy of the Texas Department of Transportation, San Antonio District

2.6 Photochemical Models AACOG conducts analysis of factors influencing local ozone concentrations using photochemical models that simulate actual high ozone episodes in the region. Since photochemical models simulate the atmospheric and meteorological conditions that helped produce high ozone values during a particular episode, an important advantage the models provide is the ability to test various scenarios, such as changes in emission rates, under the same set of meteorological conditions that favor high ozone concentrations.

The most recently completed photochemical modeling project was based on a May 31 – June 2, 2006 episode provided by TCEQ and refined by AACOG with regional emissions inputs.3 The focus of the AACOG work, completed in 2013, was to predict the impact of oil and gas operations in the Eagle Ford Shale on local ozone concentrations.

The June 2006 model was projected to 2012 and 2018 using forecasted changes in anthropogenic emissions. Several emission inventory scenarios were developed for Eagle Ford Shale oil and gas production in 2018 in order to gauge the area’s impact

3 The photochemical model used for this analysis was CAMx version 5.40. Three-dimensional hourly meteorological fields were generated by WRF via the WRF2CAMx interface tool. A complete description of the model’s configurations is provided in AACOG’s report Development of the Extended June 2006 Photochemical Modeling Episode, developed with funding from the Alamo Area MPO.

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An attainment test was conducted on the 2018 modeling results. For the Eagle Ford Shale low production scenario, the 2018 design value was predicted to be 70.9 ppb at C23, 73.8 ppb at C58, and 65.0 ppb at C59. Under the Eagle Ford high scenario, the design values were 71.4 ppb at C23, 74.3 ppb at C58, and 65.6 ppb at C59. Concentrations at all regulatory-sited monitors were predicted to meet the 75 ppb 8- hour ozone standard for every 2018 projection case, although the 2018 design value at C58 was very close to the current 75 ppb 8-hour ozone NAAQS for the high production scenario. Figure 2.5 provides a comparison of 2018 design values by monitor for each of the Eagle Ford growth scenarios.

Figure 2-5: Change in San Antonio-New Braunfels MSA Eight-Hour Design Values, 2018

2.7 Predicted Ozone Concentration Comparisons: 2006, 2012, and 2018 Tile plots were developed from the photochemical modeling results for predicted daily maximum 8-hour ozone concentrations. These plots provide visual depictions of the expected spatial variations in ozone concentrations.

The plots show consistent reductions in ozone concentrations between 2006 and 2018 in the San Antonio-New Braunfels MSA for every exceedance day of the 2006 episode. Figure 2.6 provides tile plots for selected episode days. The outlined regions in the plots represent the four largest MSAs in the state: Houston-The Woodlands-Sugar Land, Dallas-Fort Worth-Arlington, San Antonio-New Braunfels, and Austin-Round Rock.

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Figure 2-6: Predicted daily maximum 8-hour ozone concentrations in the 4-km subdomain for selected episode days, 2006, 2012 Eagle Ford, and 2018 Eagle Ford moderate scenario

June 3: 2006 2012 2018

June 8: 2006 2012 2018

June 14: 2006 2012 2018

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2.8 Next Steps AACOG is in the process of refining the regional emissions inventory, with a focus on updating emissions associated with oil and gas production activities. In addition, the agency has developed a schedule of photochemical modeling runs that will add to the available analytical tools for air quality planning. The completed and scheduled runs are as follows:

Completed Runs • Eagle Ford Shale runs (6 runs – low, moderate, and aggressive scenarios) • Zero out run for the San Antonio MSA • 25% NOX reduction, 2018, 50% NOX reduction, 2018, 75% NOX reduction, 2018, 25% VOC reduction, 2018, 50% VOC reduction, 2018, 75% VOC Reduction, 2018, 25% VOC and NOX reduction, 2018, 50% VOC and NOX reduction, 2018 • Updated 2006 run with the latest emission inventory and meteorological files from TCEQ • Updated 2012 run (AACOG received projected emission inventories from TCEQ) • Updated 2012 Eagle Ford run with local data • Updated 2018 run • Updated 2018 low scenario Eagle Ford run with local data • Hourly on-road source runs (1 ton reduction of NOX – base case, 7am, 9 am, 10 am, 11 am, noon, 1 pm) • Anthropogenic Precursor Culpability Assessment (APCA), 2018 (using existing TCEQ data and local Eagle Ford EI) • NOX emission reductions for Point, On-Road, and Non-Road/Off-Road sources (3 runs for 20 ton) • VOC emission reductions for Area, Point, On-Road, and Non-Road/Off-Road sources (4 runs for 20 ton)

Scheduled Runs • Hourly on-road source runs (1 ton reduction of NOX – 8am) • Runs on individual Point Sources (Capitol, CEMEX, TXI, Spruce1, Deely, San Miguel, Alamo Cement, Chemical Lime) • Control Strategy Runs (5 runs) • Anthropogenic Precursor Culpability Assessment (APCA) run with individual San Antonio New Braunfels MSA Counties as regions , 2018 • Start running the June 2012 photochemical modeling episode • Create projection cases for 2020 • Create projection cases for 2023

Finally, AACOG has compiled a list of potential control strategies that were provided to local governments and elected officials (Appendix B). These may be considered potential contingency measures in the event that current voluntary measures are deemed insufficient for maintaining the ozone NAAQS.

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Chapter 3: Ongoing Strategies

Local agencies and stakeholders have taken actions that will remain ongoing into the future and will have a positive impact on ozone levels in the region. Their actions and willingness to list measures are key leadership features of the Alamo Ozone Advance effort.

3.1 Voluntary Emission Reduction Strategies The ongoing strategies chapter is divided into two major divisions: voluntary emission reduction strategies and air quality outreach and education programs. These strategies and projects are listed by the organization or industry responsible for strategy implementation.

3.1.1 CPS Energy Updated since 2014 Path Forward Submission

Programs: Save For Tomorrow Energy Program, Solar Generation One important source of ozone precursors is power generation when fossil fuel is used. CPS Energy has created as series of consumer-based reduction programs, including: Residential and commercial energy conservation and solar rebate program to help avoid 771 MW of electric load-Save for Tomorrow Energy Program (STEP); 345 MW of savings as of February 2015. For FY2015 the goal is to reduce demand by 142 MW (141,641 kilowatts). Home Area Network (HAN), a NEST thermostat rebate program and Think Eco program for customers to manage energy and provide peak load reductions Commercial demand response program that includes an automated demand response program that opened the door for smaller commercial customers Installing LED street lights with the City of San Antonio to increase lighting energy efficiency; 23,492 lights installed as of 4/28/15. 1500 MW of renewable energy capacity by 2020 (approx. 20% of generation capacity); as of April 28, 2015, 1,207.4 MW in commercial operation which includes 134 MW of utility-scale solar with about 310 MW of utility-scale solar scheduled to come online by 2017; also have about 21.5 MW of rooftop solar as of April, 2015 Reducing emissions by “rebalancing” generation portfolio with additional renewable energy, Summit Texas Clean Energy Project (IGCC technology and 90% carbon capture) and recent purchase of natural gas plant Invested over $253 M in emission control technologies at its coal units since 1997, including Separated Over Fired Air (SOFA), bag houses, NOx combustion

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controls, Selective Catalytic Reduction (SCR) technology, and mercury controls. CPS Energy NOx emissions have been reduced over 70% from 1997 to 2012. Mow Down Smog Program to provide customers rebates for purchasing electric lawn equipment instead of gasoline. In 2014, CPS Energy issued 408 rebates for electric lawn equipment.

Key among these is the STEP program for the reduction in emissions which accompanies the reduction in generation using fossil fuel power. In 2009-2010, with support funding provided by the TCEQ, CPS Energy partnered with the Texas A&M Energy Systems Laboratory (ESL) and AACOG to provide an assessment of the ozone impacts derived from the STEP program. The final4 report, delivered in October of 2010, showed that “according to the TCEQ/ESL, the total annual NOx emissions reductions estimated through 2009 energy savings were 114.03 ton/year.”

However, since that time, the STEP program has continued and CPS Energy has also established a series of solar photovoltaic facilities. Solar PV installations represent a reduction in NOx emissions produced by traditional fossil-fuel power generation. In addition, they have announced a proposal to take the two Deely coal-fired power plants offline in 2018, with replacement generation capacity basically provided by the natural gas fired power generation facilities at Rio Nogales near Seguin and increased generation capacity using renewable energy.

The reductions in oxides of nitrogen (NOx) resulting from this outstanding effort were documented for 2011 and estimated for 2020 by the Energy Systems Laboratory. The latter is the target year for the STEP goals of 771 MW reduction in power consumption through the energy efficiency measures in the program.

Perhaps more critically, the energy savings which might be achieved through the voluntary, cost-efficient program can grow to become 35 times greater by 2020 than the energy savings reductions achieved in 2011, according to the analysis for growth potential noted in the report. This potential represents a tremendous path for involvement by the citizens of the region who are CPS Energy customers. The willingness of the residential, commercial, and industrial sectors to participate and grow the success of the STEP program is targeted for strong support by the AIR Committee.

3.1.2 City of San Antonio Updated since 2014 Path Forward Submission

The City of San Antonio has been a leader in identifying and deploying environmental measures that benefit air quality. Those measures include:

4 "NOx Emissions Reduction from CPS Energy's 'Save For Tomorrow Energy Plan' Within the Alamo Area Council of Governments Report to the Texas Commission on Environmental Quality," Energy Systems Laboratory at the Texas Engineering Experiment Station, Texas A&M University System; October 2010; available online: http://repository.tamu.edu/bitstream/handle/1969.1/93369/ESL-TR-10-10- 01.pdf

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The largest solar power capacity of any city in Texas (in partnership with CPS Energy). The largest wind power portfolio of any municipal utility in the U.S. (in partnership with CPS Energy) Network of over 140 electric vehicle charging stations, many with multiple chargers. The first public utility to purchase power (200 MW) from the Texas Clean Energy Project with 99% carbon dioxide capture. An adopted City goal of meeting the 2030 Challenge of zero net carbon buildings. The State’s largest fleet of CNG-powered refuse trucks.

For the purposes of the Ozone Advance partnership, the City of San Antonio provides a series of programs that benefits the region’s clean air planning process.

Programs: Solar PV Installations, Energy Efficiency Building Retrofits, Clean Transportation The City of San Antonio has created a series of programs5 that result either in reduced power consumption, reduced vehicular travel and congestion, or enabling installation of solar photovoltaic power generation, including:

Municipal Retrofits: Recent (2011 – 2014) Energy Efficiency Projects Avoided Elec. (kWh) EECBG - Municipal Facility Retrofit Program 8,110,693 EECBG - 3 parking garage lighting retrofits 888,000 EECBG - 24 facilities lighting retrofits 874,000 Alamodome and Convention Center PC 11,987,000 Airport PC 5,100,000 Phase 6 Exterior Lighting 1,670,000 Phase 7 Lighting 750,337 CPSE LED Street Lighting Retrofit (25,000) 21,698,000 Pool Pump Retrofits 827,631 Retrocommissioning of 5 large facilities 1,678,900 Total 53,584,561 Energy Efficiency Projects Completed 2015 Est. Avoided Elec. (kWh) Programmable Thermostats – 6 Facilities 212,998 High Efficiency Washing Machines – 2 Fire Stations 468 Solar Window Film – 4 Facilities 73,193 Total 286,659

5 Text from City of San Antonio's "San Antonio ARRA Grants – Project Highlights," online as http://www.sanantonio.gov/oep/pdf/Energy%20and%20Sustainability%20Project%20Highlights.pdf

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Revolving Energy Efficiency Fund: Rebates and energy savings from Municipal Retrofits are being allocated into a revolving Energy Efficiency Fund, which provides a mechanism to finance future energy efficiency projects. This resulted in the creation of a permanent Energy Management program to continue targeting efficiency opportunities throughout City facilities as an alternative to relying on performance contracts. COSA remains the only major municipality in the State of Texas with this type of dedicated revolving energy fund. Transportation Enhancements: San Antonio’s B-Cycle bike share program, with a total of 55 locations, provides opportunities to enhance personal health and provides active transportation choices to residents and visitors. According to program data, riders logged over 295,000 B-Cycle trips - burning 38.6 million calories and offsetting over 1,130,000 pounds of carbon since the program launched in 2011. The City of San Antonio has allocated funds through its City Wide Bond Program from 2012-2017 to complete approximately $337M in congestion mitigation measures for streets, bridges and sidewalks. The 41 projects include improved access management and traffic signalization along with the addition of bike lanes and sidewalks. The City of San Antonio has installed 25 solar trash compactors in city parks to reduce miles driven from reduced need for trips to empty the trash bins. COSA’s measures to regulate development within the inner city were established by the “Inner City Reinvestment and Infill Policy.” This policy establishes priority areas of the City targeted for development to coordinate public incentives in these areas. The incentives include financial assistance, such as fee waivers and tax abatements for eligible projects, and staff support to expedite regulatory and procedural obstacles that sometimes serve as a hindrance to infill development. Other Development measures include the City of San Antonio’s “Tree Ordinance.” On May 6, 2010, San Antonio’s City Council amended Chapter 35 of the City of San Antonio’s Unified Development Code relating to tree preservation and adequate canopy coverage (Ordinance 2010-05-06-0376). The goal of the ordinance is to increase the canopy coverage of the City and its ETJ within residential and commercial development. For example, the required tree canopy coverage for single-family residential construction is 38% of the lot. The final tree canopy requirement will be accomplished after meeting two requirements (1) the tree preservation requirements of 35% of the lot and (2) the canopy shade value of the new two trees required for planting.

3.1.3 Local Cement Industry Programs: in the past, AACOG worked with industrial consultants to gauge effectiveness and reduction totals achievable through implementation of reduction technologies. Strategies implemented voluntarily in 2007 lowered NOx pollution by about 4.5 tons/day, and are likely to have been one of the reasons for our recent history of success.

The cement manufacturing industry in the San Antonio-New Braunfels Metropolitan Statistical Area (SA-NB MSA) consists of four facilities: Alamo Cement, Capitol Aggregates, Inc./Capitol Cement, Cemex Construction Materials South LLC and TXI

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Hunter Cement. To date these facilities have made significant investments in technology and modifications to operational practices which have resulted in emissions reductions.

Nitrogen Oxide (NOX) Control – Selective Non-Catalytic Reduction: Each of the facilities has installed SNCR, which represents the most modern and efficient control technology available for the cement industry for this ozone precursor. Typical reductions can range widely, between 10-50%, based on a variety of test data, but site-specific factors at each plant must be considered. As mentioned above, the addition of SNCR represents a significant capital and operational investment for these facilities, which will cumulatively approach $9.5 million in the next 12 months.

Improvements to Efficiency in Manufacturing Processes: Each of the facilities has made improvements to manufacturing technology to lower emissions and reduce energy consumption in recent years. These plants utilize the most modern dry-process technology available for manufacture of cement, referred to as Preheater-Precalciner. In addition, equipment used in the process includes modern low-NOX firing systems as well as use of feed materials that require significantly lower energy amounts to process. According to the U.S. Portland Cement Association, since 1972 energy consumption has been reduced industry-wide by 37.5% per unit produced, and the producers in the SA-NB MSA region also reflect this continued improvement, which ultimately results in lowered emissions and improvements to ground level ozone.

Upgrades to Mobile Fleets: Upgrades have been ongoing at all facilities to incorporate use of lower-emitting engines for mobile equipment at the plants. Some facilities have worked through the Texas Emissions Reduction Program (TERP) while others have voluntarily upgraded fleets to further enhance efficiency.

3.1.4 Local Oil & Gas Industry: Eagle Ford Shale Updated since 2013 Path Forward Submission

As the oil and gas industry in the Eagle Ford continues to mature, improvements in infrastructure, operations, and technology provide improvements to regional air quality. These improvements occur through the following practices: Companies are moving to a “pad drilling model” wherein multiple wells are drilled and completed sequentially from a single pad at a single time, eliminating the emissions associated with multiple rig up/rig down activities and the transportation between those events. As technology improves and knowledge of the characteristics of the resource increases, well drilling efficiencies are realized. In general, longer laterals are being drilled in 2/3 the time and with less energy required of an Eagle Ford well just two years previous. Industry continues to focus on long-term advanced planning to ensure timely construction of the required infrastructure, such as processing facilities for initial separation of water, oil, and gas before sending it to pipelines. They rely heavily on pipeline infrastructure as part of the development of this asset, which keeps

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the product in the pipeline and reduces the volume of gas flared. To date, almost $1 billion has been invested in approximately 1,000 miles of pipeline infrastructure to ensure gas is captured and transported to market. The industry continues to increase this investment to further minimize the incidents of flaring in the play. Contracts and coordination with 3rd party midstream (transportation) companies to ensure downstream assets are in place and operational to support production without flaring. Oil and gas production companies depend on pipeline and terminal companies to receive their product and transport to market. As the play matures, more and more operators in the Eagle Ford are choosing to utilize a central processing facility concept, which enables numerous wells to be routed to one facility for processing. This minimizes flaring by ensuring equipment is in place to handle multi-well oil and gas production as opposed to the need for processing equipment at every wellhead. At gas gathering facilities, atmospheric storage tanks are being replaced with pressurized tanks, which reduce gas flashing of volatile liquids, thereby eliminating the need for flaring. Additionally, vapor recovery units are being installed at central processing facilities at the last stage of separation in an attempt to maximize the recovery of gas and direct it to sales, as opposed to flaring the last stage low pressure gas. Companies are improving engineering design and operation to allow production directly from the facility separation equipment to gas (high and low pressure) and liquid pipelines. This improvement reduces the air emissions associated with the storage of condensate in tanks, the use of flares as a control device, and the loading of tucks and subsequent transportation on roadways. The storage tanks, flares, and truck loading are only used during times of maintenance or downtime on the production collection equipment or pipelines. The use of multi stage separation technology (i.e. HLP separators or VRTs) helps to reduce the amount of potential flash gas at the tanks, which in turn reduces the amount of gas flared.

Partnerships with the Oil and Gas Industry The growing development of the Eagle Ford shale play represents an important economic generator in south central Texas, as well as a potentially large source of emissions. AACOG staff is working to address these emissions concerns in three programs. 1) Because the rate of ozone precursors from the Eagle Ford shale play development is very poorly understood, with the support of the TCEQ, AACOG staff and many important stakeholders in the Eagle Ford development have partnered to create an ozone precursor emissions inventory of the development. This is a critical component to understanding the ozone impacts from the development by including them in AACOG’s photochemical modeling analysis. 2) AACOG and the Alamo Area Development Corporation6 have supported the creation of the South Central Texas Natural Gas Vehicle Consortium. The purpose of the South Central Texas Natural Gas Vehicle Consortium is to focus on expanding natural gas transportation markets and refueling

6 The consortium is described on AACOG’s web site at http://www.aacog.com/index.aspx?nid=404

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infrastructure in the Central and South Texas regions (Austin, Corpus Christi, Laredo, San Antonio, and surrounding counties). The Consortium plays a role in addressing emissions from the Eagle Ford shale development since every older diesel-powered vehicle or engine that can be replaced with a cleaner Compressed Natural Gas, Liquefied Natural Gas, or clean diesel vehicle or engine represents an advance in air quality. In addition, Ryder, known for transportation and supply chain management products and its fleet of rental trucks, is now integrating natural gas into their 160,000 truck fleet. They are joining the effort in Texas to increase natural gas fueled transportation by promoting natural gas vehicles, building more fueling stations, and adding maintenance capabilities for natural gas vehicles. 3) Established in 2001 by the State of Texas, the Texas Emissions Reduction Plan (TERP) provides a series of programs to reduce NOx and monitor the reductions, including grants to upgrade or replace on-road vehicles, non-road equipment and other mobile sources in the Emissions Reduction Incentive Grants (ERIG) program (see http://www.terpgrants.org/). The 83rd Regular Session of the Texas Legislature concluded in late May 2013 and provided SB 1727, modifying ERIG to allow the TCEQ to place a priority on programs that include the “reduction of emissions from the operation of drilling, production, completions, and related heavy-duty on-road vehicles or non-road equipment in oil and gas production fields where the commission determines that the programs can help prevent that area or an adjacent area from being in violation of national ambient air quality standards.” This provides another avenue of support for making reductions in the nearby Eagle Ford shale play. AACOG staff is pursuing this possibility by working with industry to understand how this program might best be used.

3.1.5 VIA Metropolitan Transit Updated since 2014 Path Forward Submission VIA staff has implemented a series of transportation fleet projects that include: Diesel repower project provided a 30% certified NOx reduction for some vehicles; A series of replacements of vehicles averaging 4 gr NOx/horsepower-hour down to 0.15 gr NOx/hp-hr; Replacement of 94 diesel-powered paratransit vans with propane-powered vans. Gasoline powered buses that were replaced by propane and compressed natural gas powered buses. A Bus Rapid Transit line powered with 19 compressed natural gas (CNG) articulated vehicles. Three 100% electric battery buses in the downtown area Four 40’ CNG buses Thirty diesel-electric hybrid buses

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3.1.6 Alamo Area Metropolitan Planning Organization Added since 2013 Path Forward Submission The Alamo Area MPO has submitted the 2015-2018 Transportation Improvement Program (TIP) for Mobile Source Emission Reduction Strategies (MOSERS) analysis for tons per day reductions in VOCs and NOx. This analysis is currently being conducted by the Texas Transportation Institute (TTI). The MPO plans to submit these noted projects and associated reductions for inclusion in the next Ozone Advance update.

3.1.7 San Antonio Water System Updated since 2013 Path Forward Submission The San Antonio Water System (SAWS) has implemented numerous energy efficiency measures. These measures include: Ongoing Sponsorship of VIA Bus Pass Program for SAWS employees Commercial and Residential Water Conservation Programs Medio Mixer Project Biogas Reuse at Dos Rios An international reputation in water conservation accommodating a 67% increase in population over the last 25 years without an increase in overall water consumption. o In 2012, SAWS indoor and outdoor conservation rebate programs saved 735 million gallons of water, equivalent to 2,254 acre-feet. The nation’s largest (110 miles) direct recycled water delivery system in the nation for use by golf courses, parks, commercial and industrial customers, as well as San Antonio's famous River Walk. The nation’s second largest Aquifer Storage and Recovery Facility. The only U.S. city in which all three products of wastewater treatment (gas, solids and water) are commercially sold or recycled.

New and Upcoming In-Conduit Hydropower generation Compressed Natural Gas vehicle pilot project

3.1.8 The Texas Department of Transportation - San Antonio District Added since 2014 Path Forward Submission

Since 2005, TxDOT has sponsored an agency-wide Clean Air Program that encourages employees to practice commute reduction activities such as ridesharing, biking, walking, public transportation, as well as reducing other trips during the work day by encouraging employees to brown-bag their lunches. Employees are reminded and encouraged to perform regular maintenance on their vehicles to help reduce vehicle emissions. Employees earn points for participating in these activities from May through September and leave time is granted once enough points are earned, up to 8 hours.

To the extent practical, the district office uses clean business practices such as: Using low-emission diesel fuel;

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Avoiding refueling between the hours of 6-10 am; Limiting the idling of vehicles; Sending ozone action day notifications to district employees; Avoid mowing on TxDOT properties on Ozone Action Days; Encourage contractors to use efficient equipment as well as properly maintain equipment to mow right-of-ways; Continue to purchase solar-powered light and sign boards; Continue to install LED signal bulbs; Purchase energy star products; Encourage contractors to apply for grants such as TERP for highway equipment Continue to allow flexible work schedules and compressed work schedules.

TxDOT also sponsors the “Drive Clean Across Texas” partnership program between TxDOT, TCEQ, and EPA to educate the public about the impact of car emissions on air quality. The program helps to educate the public on ways they can reduce emissions. The program includes educational material for school curriculum, provides vehicle replacement assistance, and information on how to report a smoking vehicle. http://www.drivecleanacrosstexas.org.

In addition to these statewide measures, TxDOT-San Antonio District sponsored a Travel Demand Management Study that aimed to assist the region in managing traffic flow by influencing travel behavior. This study introduced 9 major San Antonio employers to traditional TDM programs and provided them with strategies that emphasize livability, sustainability, transit, walking and biking, transportation and land use planning, systems operations, economic development and improved air quality. This study was completed in early 2015 and detailed summary reports of survey data are being developed with recommendations for each employer. An overall summary report is being compiled as well..

TXDOT also completed a variable speed study (on Loop 1604 between US 281 and IH 10) which looked at the operational and safety impacts of lowered speed limits during times of inclement weather, congestion and road construction to decrease the number of rear end collisions along major corridors. Researchers designed and procured the field equipment for the project and integrated the hardware and software systems that trigger lower speed limits along the VSL corridors. As a result of the study, the legislature could give TxDOT the authority to create permanent speed limit management systems across the state.

3.1.9 Build San Antonio Green Added since 2014 Path Forward Submission Build San Antonio Green (BSAG) is San Antonio’s residential green building program. As a voluntary, third party certification program, BSAG works with the homebuilding community to help create homes with increased efficiency, comfort, and durability. To date, they have certified 5,050 homes, with 1,111 in 2015 alone. The program has also certified 54 retrofits and 5 multifamily homes to date.

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These certifications saved over 74 million kWh, with 9,277 kW of peak demand reduction. This calculates to more than 63 million lbs of CO2 and over 48,000 lbs of NOx prevented. The energy saved equated to the yearly energy of 4,625 homes, and the emissions reduced equal over 5,000 cars removed from the road for one year.

3.2 Air Quality Outreach and Education Programs Alamo Area Council of Governments Updated since 2014 Path Forward Submission

In 1998, AACOG and partnering agencies established the Air Improvement Resources (AIR) Committees to guide the local air quality planning efforts of the region. At the time, AACOG covered a 12-county7 area, making the agency ideally suited for planning activities that cross multiple political boundaries. The committees were led by the AIR Executive Committee, whose membership included elected officials representing the four-county San Antonio MSA. As the MSA region grew, invitations to participate in the AIR Executive Committees were extended to representatives of the entire eight-county San Antonio-New Braunfels Metropolitan Statistical Area (SA-NB MSA).

In addition to the Executive Committee, there are two other AIR Committees that advise and conduct work directed by the Executive Committee. The three AIR committees and their responsibilities are as follows: AIR Executive Committee In addition to guiding the activities of the other AIR Committees and AACOG staff, the Executive Committee facilitates the completion of and updates to local air quality studies and necessary planning activities for attainment under the current 8-hour average ozone NAAQS. The Committee’s mission includes developing a comprehensive emission reduction plan that will guide the region's actions to attain the 8-hour ozone NAAQS. Membership of the Executive committee includes judges or commissioners from county governments and city mayors or council people from municipal governments in the MSA, as follows:

o Bexar County o Pleasanton, City of o Comal County o Bandera, City of o Floresville, City of o Boerne, City of o Guadalupe County o Hondo, City of o New Braunfels, City of o Bandera County o San Antonio, City of o Kendall County o Seguin, City of o Medina County o Wilson County o Atascosa County

The following entities may also appoint a representative to the Executive Committee: o Alamo Area Council of Governments Board of Directors (AACOG) o Greater Bexar County Council of Cities (GBCCC) o Alamo Area Metropolitan Planning Organization (MPO)

7 A thirteenth county – McMullen County – was added in 2013.

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AIR Advisory Committee: The AIR Advisory Committee acts as liaison between the AIR Executive Committee and the greater citizen sectors, both public and private. AIR Advisory Committee membership invitations are extended among the following groups and individuals, and others as determined by the AIR Executive Committee.

o Business representatives o Chambers of Commerce o Environmental groups o Health organizations o Education agencies o Neighborhood o Transportation organizations organizations o Utilities o Other elected officials o Industry representatives o Minority organizations

AIR Technical Committee The Technical Committee provides recommendations and assistance on air quality technical issues to the AIR Executive Committee for the planning meetings held by the AIR Executive Committee. Membership includes state and federal agencies (ex- officio membership) and the following local agencies and organizations:

AACOG Hondo, City of TCEQ (ex-officio) Atascosa County Kendall County Texas Department Of Bandera, City of Medina County Transportation (TxDOT) Bandera County Metropolitan Health District District Office Bexar County Alamo Area Metropolitan EPA (ex-officio) Boerne, City of Planning Organization VIA Metropolitan Transit CPS Energy New Braunfels, City of Wilson County Comal County Pleasanton, City of Floresville, City of San Antonio, City of Guadalupe County Seguin, City of

Public Input Public input on air quality matters is sought through multiple venues including the various AIR Committee meetings. These meetings are open to the public and the agendas are posted on state and county web sites, as well as AACOG’s AIR Committee web pages. The bylaws of the committees are written to encourage public participation by ensuring that time is allotted during each meeting for citizen comments.

Comments can also be submitted to AACOG through some of the agency’s air-related web pages. Contact information listed on several AACOG web pages and the CleanAirDrive.com site, described later in this section, allows readers to ask questions or make comments.

Because public perception and opinion are important considerations for the air quality planning and outreach efforts of the region, AACOG’s Natural Resources staff conducts surveys, at least annually, to gauge public understanding of ozone pollution, knowledge of voluntary strategies, the types of controls residents are willing to adopt on a voluntary

27 basis, and their understanding of terms used in educational messages. The surveys are primarily conducted at outreach events, but may also be available on AACOG’s web site or partners’ sites. Due to the non-random nature of the data collection and the low numbers of surveys gathered, the results cannot be considered representative of the region. However, the information does guide the outreach activities of AACOG’s Natural Resources staff and often helps to identify public concerns and misunderstandings about air quality topics. In addition it provides a feedback mechanism for public opinion that is important to both staff and to the AIR Committees.

Commute Solutions AACOG has administered a Commute Solutions program for more than 16 years. The program focuses on educating people about the connection between air quality and transportation, informing them of what they could do differently to use less gas, and offering them viable alternatives to driving as a single occupant in a vehicle.

Those who commute to work or school may help reduce traffic and save fuel costs through AACOG’s rideshare program. For short commutes, people in the Alamo Region are encouraged to burn calories rather than gasoline by walking or biking instead of driving. Commuters may also consider participating in an alternative work schedule. Employers can help make their workplace commuter-friendly by considering Commute Solutions employer options. Schools can help reduce traffic congestion and harmful pollution around their campuses by adopting one or more of Commute Solutions school programs.

Since the focus of Commute Solutions is air quality outreach and education, advertising is a key component of the program. Advertising campaigns are run during the ozone season and the messages are typically distributed through a combination of media such as radio, television, and billboards. Over the past several years, Commute Solutions messages have encouraged the public to adopt measures that increase fuel economy as a way of saving money. These fuel economy messages seem to appeal to a broader audience than those that link vehicle emission reduction strategies to cleaner air and health benefits.

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Air Quality Health Alert Program When an Ozone Action Alert has been issued by the TCEQ, AACOG’s Air Quality Health Alert (AQHA) program sends an email or a text message to all those in the Greater San Antonio area who are registered for this service that announces the alert, what it means, and how one best responds to avoid associated health risks and help reduce the likelihood that an exceedance will actually occur. The program actively recruits recipients and assists individuals in the registration process, particularly at environmental and health events. As of June 30, 2015, 1,716 individuals, media representatives, school nurses, city officials, and other interested parties were registered to receive these notices. In the coming year, the program plans to target the news media as an ally in assisting to build awareness of the service and increase the number of notification recipients. To increase the number of AQHA recipients by at least 200 within the next year is a program goal.

Air Quality Health Alert Banner Program The AQHA banner program complements the goals of the alert program by providing a visual reminder to the public that an alert is in effect. The program received a substantial boost in 2006 when the City of San Antonio funded banners for all 353 schools in San Antonio, to be placed in a prominent campus location when an AQHA was issued. Since then, banners have also been distributed to new schools in San Antonio upon request and provided, for a replacement fee, new banners to those schools that have lost or misplaced their banners. In addition, banners have been sold (at cost) to schools outside of San Antonio as well as to businesses and agencies. In May 2015, the program was promoted in an email message to all area school nurses, with a reminder that the Ozone Season had begun. In addition, a special pamphlet was designed to explain the meaning of an alert, the health effects of ground-level ozone, and the AQHA program. During August, staff addressed all school nurses in the San Antonio School District on these topics at their annual orientation meeting. Plans for the next year include a request to all school districts to place an article about the meaning of the banners and the implications of AQHAs in newsletters or electronic newsletters designed for parents. Note: Attempts to gauge the actual display of these banners per school have been thwarted by low response rates to surveys conducted to gather such information.

NuRide Carpool Matching and Emissions Reduction Tracking System NuRide is a free, online carpool matching system, contracted to operate in Greater San Antonio by AACOG, through which members who do not have carpool partners can search for them. This service also rewards people who record, at Nuride.com, the trips they take by walking, biking, busing, carpooling, or vanpooling, along with the trips they save through telecommuting and working a compressed schedule, so that we may track emissions savings through these modes of transportation. Over 100 participating businesses are providing those rewards. From July 1, 2014 to June 30, 2015, the number of individuals registered on this site who live within or commute to the San

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Antonio-New Braunfels MSA rose to 11,090. Collectively that year, they recorded 998,513 trips resulting in a savings of 18 million vehicle miles traveled, and a reduction of over 28 tons of ozone-forming chemicals, NOx and VOCs. Plans for the year ahead include exploring the possible use of digital billboard advertising along major commuting corridors to promote the carpool matching program.

Figure 3-1: Annual VMT reductions recorded by NuRide participants Annual VMT reductions recorded by NuRide participants 30,000,000

25,000,000

20,000,000

15,000,000

10,000,000

5,000,000

0 2009 2010 2011 2012 2013 2014

Figure 3-2: Annual VOC and NOx reductions (lbs.) from decreases in VMT, as recorded by NuRide participants 50000 45000 40000 35000 30000 25000 20000 15000 10000 5000 0 2009 2010 2011 2012 2013 2014 Voc Nox

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CARE Program To alleviate a concern that acts as a deterrent to commuting to work by alternative transportation, namely, that an emergency will arise while at work and the commuter will have no immediate way home, AAGOG offers the Certified Auto Ride in case of Emergency (CARE) program. Those who live and work within the MSA, regularly commute by alternative means, and record their trips on NuRide.com are qualified, and are offered reimbursement for up to 4 cab rides home from work per year, of up to $50 each, when an emergency arises for which they must go home. During any given week, approximately 1,500 area NuRide members qualify and have access to this service. While a very small portion of that number actually uses the offer for a ride in the case of an emergency, knowing that it’s there provides a certain sense of security to others, and helps to maintain the emissions reductions reported through NuRide. More promotion of the existence of the program as a way to encourage new users of alternative transportation is needed, however, and a revised pamphlet, along with more public service announcement (PSA) promotion, is in the plan for the coming year.

Green Patrol School Anti-idling Program Green Patrol is an anti-idling vehicle program offered to schools in San Antonio and its eight surrounding counties. As a part of the basic Green Patrol design, which may vary from school to school, “No-Idle Zones” are created on school campuses where school staff deem necessary. Children deliver a letter to their parents asking that they not idle their vehicles in these zones. Attached to the letter is a “No-Idle Pledge” that parents are encouraged to sign and return to the school with their children. To further engage the students, Green Patrol Officers, usually 5th graders, are assigned to observe “No Idle Zones” and remind parents of the pledge they took by wearing green jerseys and holding up “No-Idle” signs.

“Ozzy,” the official mascot of the Green Patrol

program, encourages students to engage in air quality projects and educational activities.

Program enhancements: Redesigned Clean Air Drive to allow easy Patrol Material. Developed a new Green Patrol Logo (at left).

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Goals Increase awareness of vehicle idling and the program through press releases. Have at least two schools participate in the program and have at least two more schools actively pursuing the program for this year or early next school year. Continue to develop the program to make it more marketable to schools. CleanAirDrive.com Although the public may obtain information about AACOG’s technical and educational air quality activities on the agency’s web site, a second site is maintained by AACOG’s Natural Resources staff that is devoted entirely to air quality outreach and education. The site, CleanAirDrive.com, provides basic information about ground-level ozone, its health effects, and measures everyone can adopt to help reduce the chemicals that form ozone. All materials distributed at outreach and educational events refer to this web site.

Fresh Air Friday AACOG’s air quality outreach staff conducts an ozone season kickoff at the beginning of April, referred to as “Fresh Air Friday.” The event is conducted at lunchtime as an environmental fair on a plaza in the heart of San Antonio. Although open to the public, downtown employees are invited to bring a brown bag or carry out from a nearby restaurant instead of driving out to eat—which is emphasized as a way to help improve air quality. Photochemical models developed in the past by AACOG predicted that reduced vehicle trips during the late morning – early afternoon timeframe were associated with greater reductions in peak ozone concentrations than trip reductions in the early morning or late afternoon. Consequently, the event is used to emphasize alternative transportation choices for noon time activities. During Fresh Air Friday, approximately 25 partner organizations set up exhibits along with AACOG’s clean air programs table, each displaying a sign that briefly describes a way in which their organization promotes or contributes to cleaner air. Typically 500 people attend. A consideration for 2015 is extending the Fresh Air Friday concept for several weeks after the kickoff event, by asking the public to collectively focus on one way to help keep the air clean each Friday, such as asking everyone to check their tire pressure that day, or to substitute a short vehicle trip – a mile or less – with walking or biking.

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Walk & Roll Challenge For the past 10 years, AACOG’s air quality staff has conducted the Walk & Roll Challenge, a month-long competition in which businesses, agencies, and other organizations vie with one another to see whose employees can record the most trips taken by walking, biking, carpooling, or busing, as well as trips saved through telecommuting and compressed work schedules, which are referred to as “smart” trips. Organizations with the most alternative trips recorded per employee are the winners. Regardless of whether their employers are officially participating, individuals can also participate in the Walk & Roll Challenge simply by recording the trips they take by alternative means at NuRide.com. This past September, 16 organizations and 1,848 individuals participated, recording 69,196 trips that month, reducing vehicle miles traveled by 786,917, and keeping over a ton of ozone precursors from the air. Instead of September, which is towards the end of the ozone season and typically extremely hot in San Antonio, this challenge will be held in May next year, with the hopes that, if held near the beginning of the ozone season, its effect on new transportation habits will last far into the season, and that the more moderate temperature will encourage more walking and biking. Its timing will also be concurrent with National Bike Month, for which staff plans to leverage the focus on biking activities with their clean air partners.

Air Quality Stewardship Awards AACOG’s Air Quality Stewardship Award annually recognizes businesses, agencies, schools, and other organizations that have made significant voluntary efforts to reduce air pollution. Eligible for an Air Quality Stewardship Award is any organization with a physical presence within San Antonio or one of its eight surrounding counties that has helped to improve air quality in at least one of the following categories; Commuter Assistance, Fleet Management, Energy Efficiency and Sustainable Building, Industrial Process Pollution Reduction, Landscaping and Air Quality Education.

The varying sizes, structures, and missions of nominated organizations are taken into consideration in the selection process. These awards provide an opportunity to acknowledge and showcase the efforts of air quality stewards in the Greater San Antonio area and to inspire others to greater action.

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Chapter 4: New/Proposed Strategies

4.1 City of San Antonio At the request of the City of San Antonio, TCEQ arranged a study that provided the municipality with a list of control strategies they may implement to reduce ozone precursor emissions originating from sources within the City’s boundaries and extra territorial jurisdiction. The study provided an evaluation of potential controls including the estimated NOx and VOC emission reductions and cost per ton of reduction for each strategy. The results were provided to AACOG for use in photochemical model runs to determine their estimated impact on regional ambient ozone concentrations.

Timeline The control strategy report was completed in early 2015. Based on the results of the study, COSA staff developed a draft air quality plan. The plan will be presented to their City Council in August of 2015 for adoption along with recommended air quality ordinances that address viable strategies identified in the study.

4.2 San Antonio Metropolitan Health District Air Quality Program Proposal The San Antonio Metropolitan Health District (SAMHD) proposes to develop an air program that will require the registration of businesses that are sources of air pollution within the city. Registration will provide information that can be used in determining strategies to lower ozone levels. SAMHD would recommend changes to Chapter 26, “Pollution Control”, Article II, of the City Code of the City of San Antonio, Texas pertaining to the regulation of air pollution which will update the references to state law in the current ordinance and require that facilities with sources of air pollution register with Metro Health. The City Council will consider the changes to Chapter 26 during FY15. One position in the program has been identified to address resident complaints and work with small businesses currently considered “minor point sources.” This work will include outreach efforts to these small businesses to address reductions in air pollution emissions. It is believed that many of these small businesses are not aware of operational changes that could be made to improve their businesses and also air quality. There are many of these small businesses that individually are considered minor sources of air pollution but when added together they become a much larger source of air pollution.

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4.3 Local Oil & Gas Industry: Eagle Ford Shale Multiple companies in the oil and gas industry proactively seek measures that will help reduce emissions from their activities and operations. While the number of participants is unknown, the following example describes one such project by a company operating in the Eagle Ford Shale (EFS).

Background The company’s Eagle Ford Shale (EFS) asset team analyzed and improved the standard industry practice of using natural gas in back pressure dump valves on production separators, resulting in significant emissions reductions.

Point of Delivery (POD) locations in EFS have production separators which separate the gas, oil and water into their appropriate flow lines. Both the oil and water are automated with dump valves on their outlet legs. The water leg utilizes a snap-acting dump valve while the oil uses a throttle dump valve; both are intermittent bleed valves. Industry practice is to use natural gas as the medium to hold back pressure on these valves.

Problem: Each time the separator dumps liquid, some portion of the back pressure gas is vented to the atmosphere. Economically feasible solutions were sought to reduce or eliminate air emissions released during this process.

Activity: A pilot project was conducted to test the effectiveness of implementing compressed air as a supply fluid to control the dump valves. The initial installation and operation proved successful, as all natural gas emissions were eliminated from the dump valves at the POD, and production was unaffected by the change. Because of this, a decision was made to switch over as many PODs as economically feasible.

Timeline: By the end of 2014, convert 16 PODs (170 compressors) to use compressed instrument air instead of natural gas. This is equal to 34% of the total separators in the EFS.

Emission Reductions: Using natural gas to control the dump valves, on average, 0.72 mcf was believed to have been potentially emitted per dump, per day on a separator. By utilizing instrument air instead of natural gas, separator dump valve emissions will likely be reduced by approximately 30% in 2014.

No additional emissions will be created in order to eliminate these current emissions, as an electric powered compressor will be used.

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Chapter 5: Public/Stakeholder Involvement

AACOG’s Community Survey AACOG encourages public and stakeholder involvement at the various AIR Committee meetings, as described in earlier sections. Public opinion is obtained by other methods as well, such as through periodic surveys. While AACOG’s Natural Resources staff conducts public surveys on air quality topics at least annually, these surveys represent a very small sample size and limited geographic scope. Neither are the surveys diverse from a demographic standpoint, as the surveys tend to be distributed at similar types of events, typically with a health or environmental focus. AACOG is in the process of developing a community project that proposes to survey a representative sample of those registered to vote in the SA-NB MSA regarding some of their underlying assumptions about air quality, their support for selected ozone emissions strategies, and their willingness to take individual action to help improve air quality, with the ultimate goals of: building community awareness and knowledge of air quality issues in the Greater San Antonio area, providing a channel for public input that may lead to a greater sense of ownership of air quality issues and the desire to help work toward possible solutions, gathering knowledge of public sentiments that may influence community leaders to select, support, and act upon particular strategies to reduce emissions; and Avoiding public resistance that has put other local plans, such as transportation projects, on indefinite hold, and allowing the region to collectively move forward in confidence to effectively reduce ozone pollution.

Timeline The survey design was completed by the end of 2014. AACOG is seeking funding to conduct the study during FY 2016.

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APPENDIX A MAJOR STATIONARY SOURCES IN THE SA-NB MSA, 2012 SOURCE: TEXAS COMMISSION ON ENVIRONMENTAL QUALITY8

COMPANY COUNTY SIC SIC DESCRIPTION NOX TPY VOC TPY SAN MIGUEL ELECTRIC ATASCOSA 4911 ELECTRIC SERVICES 3105.96 71.886 COOPERATIVE INC REGENCY FIELD SERVICES ATASCOSA 1321 NATURAL GAS LIQUIDS 50.8434 26.9658 LLC ENTERPRISE PRODUCTS NATURAL GAS BANDERA 4922 101.4697 14.8674 OPERATING LLC TRANSMISSION CAPITOL AGGREGATES INC BEXAR 3241 CEMENT, HYDRAULIC 912.9059 102.8847 CITY PUBLIC SERVICE BEXAR 4911 ELECTRIC SERVICES 5671.0434 73.3517 CITY PUBLIC SERVICE BEXAR 4911 ELECTRIC SERVICES 12.575 0.6167 PETROLEUM BULK NUSTAR LOGISTICS LP BEXAR 5171 STATIONS & 2.2873 32.2909 TERMINALS ENTERPRISE BEXAR 1321 NATURAL GAS LIQUIDS 47.1849 19.5464 HYDROCARBONS LP SPORTING & ATHLETIC 900 GLOBAL LLC BEXAR 3949 0 0.5622 GOODS NEC US DEPT OF AIR FORCE BEXAR 9711 NATIONAL SECURITY 259.768 37.0018 PETROLEUM BULK EXXONMOBIL CORP BEXAR 5171 STATIONS & 0 21.4334 TERMINALS PETROLEUM BULK CITGO PETROLEUM CORP BEXAR 5171 STATIONS & 0 19.5859 TERMINALS CALUMET SAN ANTONIO BEXAR 2911 PETROLEUM REFINING 27.9787 164.4827 REFINING LLC US DEPT OF AIR FORCE BEXAR 9711 NATIONAL SECURITY 7.4001 13.5123 CITY PUBLIC SERVICE BEXAR 4911 ELECTRIC SERVICES 760.6428 48.8261 PETROLEUM BULK MOTIVA ENTERPRISES LLC BEXAR 5171 STATIONS & 3.4615 37.001 TERMINALS AGGREGATE PLANT BEXAR 3444 SHEET METAL WORK 0.3526 0.8274 PRODUCTS CO PETROLEUM BULK NUSTAR LOGISTICS LP BEXAR 5171 STATIONS & 4.8957 29.1862 TERMINALS ALAMO CEMENT COMPANY BEXAR 3241 CEMENT, HYDRAULIC 2179.3 35.0576 II LTD

8Available at: http://www.tceq.state.tx.us/assets/public/implementation/air/ie/pseisums/2012statesum.xlsx

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NONCOMMERCIAL SOUTHWEST RESEARCH BEXAR 8733 RESEARCH 169.4039 55.8284 INSTITUTE ORGANANIZATIONS WOOD KITCHEN CARDELL CABINETS INC BEXAR 2434 6.896 122.03 CABINETS MAXIM INTEGRATED SEMICONDUCTORS BEXAR 3674 13.6638 23.3646 PRODUCTS INC AND RELATED DEVICES PETROLEUM BULK FLINT HILLS RESOURCES BEXAR 5171 STATIONS & 0.9752 22.4647 CORPUS CHRISTI LLC TERMINALS INTERTEK AUTOMOTIVE TESTING BEXAR 8734 28.6252 5.3795 RESEARCH LABORATORIES ALUMINUM SHEET ALCOA INC BEXAR 3353 31.4252 2.0955 PLATE & FOIL WOOD KITCHEN CARDELL CABINETRY LLC BEXAR 2434 0.13 32.259 CABINETS COMBINATION UTILITY WIN SAM INC BEXAR 4939 13.5871 0.8423 NEC BFI WASTE SYSTEMS OF BEXAR 4953 REFUSE SYSTEMS 3.87 26.4 NORTH AMERICA LLC FLOWERS BAKING CO OF BREAD, CAKE AND BEXAR 2051 5.1914 9.266 SAN ANTONIO LLC RELATED PRODUCTS WASTE MANAGEMENT OF BEXAR 4953 REFUSE SYSTEMS 12.9857 15.5207 TEXAS INC MEN'S FOOTWEAR, SAN ANTONIO SHOE INC BEXAR 3143 0 8.8196 EXCEPT ATHLETIC BOEING COMPANY BEXAR 3721 AIRCRAFT 1.3685 47.3023 AIRCRAFT ENGINES & KELLY AVIATION CENTER LP BEXAR 3724 36.2677 12.174 ENGINE PARTS WOOD KITCHEN ZEE MANUFACTURING LTD BEXAR 2434 0.1996 9.5775 CABINETS BIO ENERGY AUSTIN LLC BEXAR 4911 ELECTRIC SERVICES 79.12 11.644 UNITED SERVICES INSURANCE CARRIERS, BEXAR 6399 14.0567 2.904 AUTOMOBILE ASSOC NEC BIO ENERGY TEXAS LLC BEXAR 4911 ELECTRIC SERVICES 40.23 17.3586 TOYOTA MOTOR MFG MOTOR VEHICLES AND BEXAR 3711 19.1222 388.189 TEXAS INC CAR BODIES TXI OPERATIONS LP COMAL 3241 CEMENT, HYDRAULIC 609.1731 4.7464 CHEMICAL LIME LTD COMAL 3274 LIME 433.18 23.159 CEMEX CONSTRUCTION COMAL 3241 CEMENT, HYDRAULIC 2568.3737 3.1398 MATERIALS SOUTH LLC SYMONS BY DAYTON COMAL 3444 SHEET METAL WORK 0 3.9893 SUPERIOR

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WASTE MANAGEMENT OF COMAL 4953 REFUSE SYSTEMS 24.3873 66.0574 TEXAS INC UNSUPPORTED LEISURE POOLS USA COMAL 3082 PLASTICS PROFILE 0 TRADING INC SHAPE BRICK AND ACME BRICK CO GUADALUPE 3251 0 0 STRUCTURAL CLAY TILE BLAST FURNACES AND STRUCTURAL METALS INC GUADALUPE 3312 125.0553 36.6259 STEEL MILLS TIN INC DBA TEMPLE GUADALUPE 3275 GYPSUM PRODUCTS 15.3991 16.1302 INLAND PLASTICS PRODUCTS, XERXES CORP GUADALUPE 3089 0.0999 80.4377 NEC GUADALUPE POWER GUADALUPE 4911 ELECTRIC SERVICES 277.5859 7.6751 PARTNERS LP REPUBLIC PLASTICS PLASTICS, FOAM GUADALUPE 3086 0 213.1 SERVICES LTD PRODUCTS CITY PUBLIC SERVICE GUADALUPE 4911 ELECTRIC SERVICES 268.462 3.022 LONESTAR FIBERGLASS PLASTICS PRODUCTS, GUADALUPE 3089 0 6.5224 POOLS LLC NEC COATED FABRICS, NOT ARMORTEX INC GUADALUPE 2295 0 3.6 RUBBERIZED INTERNAL CATERPILLAR INC GUADALUPE 3519 COMBUSTION 83.051 5.9257 ENGINES OASIS PIPELINE COMPANY NATURAL GAS KENDALL 4922 0 0 TEXAS LP TRANSMISSION WATCO TANKS INC WILSON 3444 SHEET METAL WORK 0 13.9618 CRUDE PETROLEUM & HUNT OIL COMPANY WILSON 1311 3.2006 18.4402 NATURAL GAS CRUDE PETROLEUM & HUNT OIL COMPANY WILSON 1311 7.982 18.351 NATURAL GAS LAZARUS ENERGY LLC WILSON 2911 PETROLEUM REFINING 21.1607 111.6088

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APPENDIX B POTENTIAL CONTROL STRATEGIES LIST

Source for Emission NO Time Likely Category Strategy X Cost Suggested Description Source Benefit Frame Stakeholders Strategy Local Austin Area Governments Buy Bin 4 or better EPA Tier 2 Bin 4 vehicles have lower than On-road Low Fast Medium Ozone Advance All fleet owners Procurement Light-Duty vehicles fleet average (Bin 5) NO emissions. Program, 2012 X Policy Local Austin Area Purchase any new heavy duty vehicle that Governments Buy CARB-Certified On-road Low Fast Medium Ozone Advance meets California Air Resource Board’s low All fleet owners Procurement Low-NO Idle HDV X Program, 2012 NO idle standard of 30 grams per hour. Policy X Require the use of cleaner equipment, as Clean Contracting well as operational practices, such as time Local Government policies; Austin Area of day equipment will be operated, idling, Governments agencies and landscaping & Non-road Medium Medium Low Ozone Advance and ozone action responses. Clean Procurement large construction Program, 2012 landscaping contracting to encourage the Policy companies contracts use of low-emission equipment and practices in landscaping contracts. Local Government Clean Fuel Austin Area Ensure that any biodiesel or other Governments On-road, agencies and Specifications in Low Fast Low Ozone Advance alternative fuels purchased achieves Procurement Non-road large Contracts Program, 2012 equivalent emission reductions as TxLED. Policy companies Local Government Austin Area Governments Local Sourcing of Ensures elimination of long distance trips agencies and On-road Medium Medium Medium Ozone Advance Procurement Materials and trucking. large Program, 2012 Policy companies Onboard equipment options such as On-Board Idle auxiliary power units (APUs), heaters, and Austin Area Fleet Reduction On-road, coolers can be installed on heavy-duty Medium Fast Low Ozone Advance All fleet owners Management Technologies for Non-road trucks to reduce idle time at truck stops, Program, 2012 HDV roadsides, ports, terminals, and delivery sites Texas Emissions Austin Area Use of TERP funding for upgrade or All fleet owners, Fleet Reduction Plan Non-road High Fast Medium Ozone Advance replacement of older vehicles and small and large Management (TERP) Program, 2012 equipment with Tire 4 equipment. companies Targets trucks, trains, Non-road Retrofit Older Austin Area All fleet owners, Fleet On-road, equipment, and backup diesel generators. Vehicles & High Medium High Ozone Advance small and large Management Non-road TERP and other State's funding can be Equipment Program, 2012 companies applied for to fund these projects.

Source for Emission NO Time Likely Category Strategy X Cost Suggested Description Source Benefit Frame Stakeholders Strategy Replacing or repowering older diesel Repower Older Austin Area vehicles and equipment with Tier 4 All fleet owners, Fleet On-road, Vehicles & High Medium High Ozone Advance engines. Applicable to all pre‐2010 small and large Management Non-road Equipment Program, 2012 vehicles, TERP and other State's funding companies can be used. Replacing or repowering older diesel Replace Older Austin Area vehicles and equipment with Tier 4 All fleet owners, Fleet On-road, Vehicles & High Medium High Ozone Advance engines. Applicable to all pre‐2010 small and large Management Non-road Equipment Program, 2012 vehicles, TERP and other State's funding companies can be used. Determine suitable fleet size and composition in terms of both overall Business Evaluation Austin Area All fleet owners, Fleet On-road, number of vehicles and vehicle type; and Rightsizing of Low Medium Low Ozone Advance small and large Management Non-road "rightsizing" evaluation, locates Fleet Usage Program, 2012 companies underutilized vehicles for reassignment or disposal. Prohibit use of drive through lanes during Regulation & Drive-Thru Service DFW List of On-road Low Fast Low the ozone season or high ozone alert days; All Enforcement Restrictions Controls encourage parking instead. Vehicle Idling Austin Area Regulation & Limitation on idling by all vehicle types in Enforcement & On-road High Fast Low Ozone Advance Cities Enforcement certain parts of cities. Restriction Program, 2012 Cities can pass ordinances that restrict the use of Non‐road equipment by private businesses, such as restricting idling, Regulating Use of Austin Area limiting the time of day certain equipment is Regulation & Unpermitted Non-road, Medium Medium Low Ozone Advance used, or even simply requiring registration Cities Enforcement Combustion Area Program, 2012 and reporting. Such restrictions can be Equipment placed on backup generators, to avoid testing generators during high ozone days. Austin Area Burning construction and demolition debris, Regulation & Open Burning Local Area Low Fast Low Ozone Advance yard wastes, and other natural vegetation Enforcement Restrictions Governments Program, 2012 releases smoke and NOX into the air.

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Source for Emission NO Time Likely Category Strategy X Cost Suggested Description Source Benefit Frame Stakeholders Strategy According to EPA’s definition, these are "Special plans to manage travel demand in effect during special events, defined as destinations for a large number of vehicle On-road, Austin Area Regulation & Special Event trips which occur on a one-time, infrequent, Local Non-road, Varies Fast Low Ozone Advance Enforcement Policies or scheduled basis (such as athletic Governments Area Program, 2012 events, festivals, fairs, political rallies, and major entertainment performances)." e.g. remote parking, shuttle service, parking management, highway improvement. Reduce employee commute vehicle trips Require Trip Austin Area through implementation of rideshare, Regulation & Low- Local Reduction Plans for On-road Medium Low Ozone Advance telecommuting, and flexible work‐hour Enforcement Medium Governments Large Employer Program, 2012 programs, transit pass subsidies, bicycling, and similar strategies. Transportation Austin Area Added capacity and removal of existing Emission Roadway State & Local On-road High Slow High Ozone Advance bottlenecks on the freeway system, e.g. Reduction Improvement Governments Program, 2012 update of ramps@ 410/I-35 North Measures Strategies such as making transit more convenient and reliable through additional light rail and commuter rail lines, exclusive bus lanes, easily understood fare Transportation Expanded and Austin Area structures and transfers, and subsidized Emission Governmental Improved Transit On-road, High Medium High Ozone Advance transit service. In addition, strategies to Reduction entities System Program, 2012 improve transit amenities such as business Measures class service, more comfortable and attractive bus and rail stops, increased security can be used to make travel more pleasant and convenient.

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Source for Emission NO Time Likely Category Strategy X Cost Suggested Description Source Benefit Frame Stakeholders Strategy Targets employees commuting to the work place. This includes: a) provision of alternative commute infrastructure such as bike racks, showers, preferential carpool/vanpool parking; b) carpool or alternative transportation programs, Transportation including a dedicated parking cash‐out Commuter Trip Austin Area Governmental Emission program, subsidized transit passes, or Reduction Programs On-road Medium Fast Low Ozone Advance entities & Large Reduction other incentives (such as administrative (vanpool, carpool) Program, 2012 Employers Measures leave or regular prize drawings) for employees to take alternative commutes; c) compressed work weeks in which an employee does not have to travel to work at least one day every two weeks; d) flexible work schedules; and e) teleworking; among others. Transportation Improved Non- Austin Area Emission Implementation of bicycle and pedestrian State & Local Motorized Travel On-road Low-Medium Medium Medium Ozone Advance Reduction projects with supporting programs. Governments (Pedestrian/Bike) Program, 2012 Measures Emission reductions through the AirCheck Transportation AirCheck Texas Texas Low-Income Vehicle Repair Local Emission Incentives for Old Houston's list of On-road High Fast Medium Assistance, Retrofit, and Accelerated Governments & Reduction Vehicles control strategies Vehicle Retirement Program (LIRAP) to Agencies Measures Replacement repair or replace high emitting vehicles Transportation Emission HOV Medium- TCEQ (Rider 8 Promoting higher vehicle occupancy by State & Local On-road Medium High Reduction Implementation High List) implementing HOV lanes. Governments Measures Transportation Emission Traffic Signal Houston's list of Regional Computerized Traffic Signal State & Local On-road Low-Medium Medium Medium Reduction Improvement control strategies System Governments Measures Would require sponsorship and /or Transportation commitment of significant public funds. Emission Transit Fare Free on TCEQ (Rider 8 This policy should by itself generate State & Local On-road Low-Medium Fast Medium Reduction High Ozone Days List) long‐term increases in ridership. To be Governments Measures effective, this would require expanded transit fleet and possibly support facilities.

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Source for Emission NO Time Likely Category Strategy X Cost Suggested Description Source Benefit Frame Stakeholders Strategy Transportation State & Local Emission Transit Off-Peak TCEQ (Rider 8 Governments, On-road Medium Fast Low Transit incentive Reduction Pass List) Large Measures Employers Transportation Emission Congestion pricing / TCEQ (Rider 8 The goal of congestion pricing policies is to State & Local On-road Medium Fast Medium Reduction Toll Roads List) mitigate congestion and improve air quality Governments Measures Transportation Emission Expansion of State & Local On-road Medium Fast Medium Local Expansion of TransGuide. Reduction TransGuide Governments Measures Development Development Measures to Land use planning incentives for Local On-road Medium-high Slow Low Local Measures Encourage mixed‐use, transit‐oriented projects Governments Reduction in VMT Commitments by local governments to Austin Area reduce electricity consumption at places Development Reduce Electricity Point and Local High Slow Low Ozone Advance such as waste water treatment facilities by Measures Consumption Area Governments Program, 2012 update of pumping or lighting equipment or by use of energy efficient equipment. Austin Area Development Measures to Shade Measures to shade or cool developed State & Local All unknown Slow Medium Ozone Advance Measures or Cool Urban Areas areas (e.g. tree planting, cool roofs) Governments Program, 2012 This can include any set of commitments that would reduce emissions on ozone Austin Area Governmental Outreach & Ozone Action Day action days, such as allowing employees to All Medium Medium Low Ozone Advance Entities & Large Awareness Programs come to work at 10 am, rescheduling Program, 2012 Employers backup generator testing, or delaying construction and landscaping projects. Contracts to Ban Incentives in construction projects to not Construction Outreach & Construction Activity work on air quality health alert days. Could Companies and All Medium Fast Low Local Awareness on Ozone Action be required when contracts are made with Local Days construction companies. Governments Use of TV weather forecasts, radio, Austin Area Local Outreach & Multimedia Public Internet, TransGuide signs to inform public All low Fast Medium Ozone Advance Governments Awareness Education Program of high ozone days and Clean Air Plan and Program, 2012 and Agencies ask for "Do your share for cleaner air". Austin Area Develop school curricula for school Outreach & School Curricula & ISD's and local All low Medium Low Ozone Advance students for early introduction of air quality Awareness Education Program agencies Program, 2012 issues in the region to them.

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Source for Emission NO Time Likely Category Strategy X Cost Suggested Description Source Benefit Frame Stakeholders Strategy Austin Area Encourage local businesses to implement Local Outreach & Business Outreach All Medium-high Medium Medium Ozone Advance emission reduction measures and Governments Awareness Program Program, 2012 participate in adopting regional measures. and Agencies Local N/A (Only Regulation & Cold Cleaning DFW List of Governments Non-road VOC Fast Low Require low VOC solvent Enforcement Regulations Controls and small Reductions) business Replace older combustion ground support equipment and APUs with newer engines City Aviation Regulation & DFW List of Airport Measures Non-road Low Fast Low or with electrified equipment. TERP and Departments, Enforcement Controls DERA funding may be available for some Airlines of these projects. Commute Solutions is a program administrated by AACOG's Natural Promoting the Use Resources Department and offers people Austin Area Local Outreach & of Commute viable alternatives to driving a single On-road High Fast Low Ozone Advance Governments Awareness Solutions Rideshare occupant vehicle. Those who commute to Program, 2012 and Agencies Program work or school may help reduce traffic and save fuel costs through AACOG's rideshare program. This measure doesn’t entail reducing emissions per se, but provides data on small stationary sources of NOX, such as industrial, commercial, or institutional facilities or oil and gas facilities that fall Small Emission Austin Area under TCEQ emission inventory reporting Local Reporting & Source Reporting Area NA Fast Low Ozone Advance requirements individually, but collectively Governments Planning Requirements Program, 2012 can make up a significant amount of NOX and Agencies emissions. Reporting could involve listing of all combustion equipment on the premises, and the quantities of fuel consumed, to allow AACOG staff to calculate emissions.

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Source for Emission NO Time Likely Category Strategy X Cost Suggested Description Source Benefit Frame Stakeholders Strategy Installation of pollution control systems at existing power plants and cement companies. These can include low- NOX burners (LNB), combustion optimization, natural gas reburn (NGR), steam injection, water injection, selective catalytic reduction Encourage use of (SCR), and selective Non-catalytic Austin Area Stationary NO Control reduction, depending on plant X Point High Medium High Ozone Advance Industry Source SNCR/SCR on all configuration. These controls can achieve Program, 2012 Cement kilns 50-80% reductions in NOX from existing sources. Many plants and units already of some of these controls installed, but there are still opportunities to reduce emissions from many of these facilities. These can be multi-million dollar projects, but on cost-per ton basis are very efficient. Replacing older, higher-emitting plants with Early Retirement of Austin Area newer, lower-emitting fossil fuel plants Stationary Coal Burning Power Point High Medium High Ozone Advance equipped with technologies such as Power Plants Source Plants; e.g. Deely Program, 2012 integrated combined cycle turbines with advanced NOX controls such as SCR. Replacing older, higher-emitting plants with Replacing Older Austin Area newer, lower-emitting fossil fuel plants Stationary Gas-Fueled Power Point High Slow High Ozone Advance equipped with technologies such as Power Plants Source Plants Program, 2012 integrated combined cycle turbines with advanced NOX controls such as SCR. Other Stationary Installation of pollution control systems at Austin Area Stationary Source Controls point sources other than power plants Point, Area High Medium High Ozone Advance Industry Source (steel mills, within or near the San Antonio- New Program, 2012 smelters, refineries) Braunfels MSA Geothermal and Solar thermal electricity generation. Geothermal power is considered to be sustainable because the Alternate Source of heat extraction is small compared with the Stationary High/Medi DFW List of Fuel for Electricity Point High Slow Earth's heat content. New plant designs Power Plants Source um Controls Generation require water temperature of only 57 C. The 377 MW Ivanpah Solar Power Facility is the largest solar power plant in the world, located in the Mojave Desert of California.

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Source for Emission NO Time Likely Category Strategy X Cost Suggested Description Source Benefit Frame Stakeholders Strategy NO emission limits on small-scale Stationary Replace Boilers & DFW List of X Oil & Gas Point, Area Medium Fast Medium residential and industrial boilers, process Source Heaters Controls Production heaters, and water heaters Optimizing Glycol circulation and installing flash tank separators on glycol dehydrators Glycol Dehydrators N/A (Only reduce methane, VOC, and HAP Stationary DFW List of Oil & Gas Control or Recycle Point, Area VOC Fast High emissions. Recovered gas can be recycled Source Controls Production Vented VOC Reductions) to the compressor suction and/or used as a fuel for the TEG reboiler and compressor engine. Better identify and N/A (Only Oil and Gas industry should have Stationary DFW List of Oil & Gas repair leaking Point, Area VOC Fast Low procedures in place to continually look for Source Controls Production components Reductions) leaks and repair them. Transportation Emission Commuter and Judge Wolff's AQ Commuter Rail from San Antonio to Austin, State and Local On-road Medium Slow High Reduction Light Rail Strategies light projects. Governments Measures Transportation Transit Multimodal Emission Judge Wolff's AQ Additional bus multimodal sites such as State and Local Park & Ride On-road Medium Fast Medium Reduction Strategies VIA’s Westside Multimodal Facility Governments Facilities Measures Transportation Legislative initiatives to fund the Texas Rail Emission Texas Rail Judge Wolff's AQ State and Local On-road Medium Medium Medium Relocation Fund (created 79th Reduction Relocation Strategies Governments Legislative Session) Measures Transportation Freight rail relocation outside populated State and Local Emission Freight Rail Judge Wolff's AQ On-road Medium Medium Medium areas and adaptive reuse of tracks for Governments; Reduction Relocation Strategies commuter rail Rail Companies Measures Transportation Addition multimodal facilities such as the State and Local Emission Rail Multimodal Judge Wolff's AQ Union Pacific site ‐ Old Pearsall Road to On-road Medium Medium Medium Governments; Reduction Facilities Strategies encourage the transport of freight by rail Rail Companies Measures instead of trucks. Transportation Advanced Expand boundaries of the Advanced Emission Judge Wolff's AQ Local Transportation On-road Low Fast Low Transportation District to include all of Reduction Strategies Governments District Bexar County Measures

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Source for Emission NO Time Likely Category Strategy X Cost Suggested Description Source Benefit Frame Stakeholders Strategy The Mission Verde Sustainability plan is an economic approach to sustainability with a focus on energy conservation. The plan Development Mission Verde Point, Area, Local High Fast Low COSA calls for diversification of energy sources, Measures Sustainability Plan On-road Governments updates to the transportation system, creation of green jobs, and reuse and revitalization of San Antonio’s resources The energy conservation measures providing financial incentives to residential and commercial customers to improve heating, ventilation, insulation, and air Local Save for Tomorrow Development conditioning systems as well as to increase Governments Energy Plan Point, Area High Fast Low COSA Measures the use of energy efficient lamps and and Business (STEP) programmable thermostats, expand lighting Owners retrofits, replacement of existing household appliances with energy efficient appliances, and other commercial programs. Local Require building codes that encourage Development Green Building Medium- Judge Wolff's AQ Governments Point, Area Fast Low energy efficiency and design with the Measures Code High Strategies and Building nature principals Companies Development Advance Low- Judge Wolff's AQ Pass-Thru Financing Projects financed by Local Non-road Low-Medium Fast Measures construction Medium Strategies local governments to advance construction Governments Transportation San Antonio B- Continue funding and support for bike Emission State and Local Cycle Municipal On-road Low Fast Low COSA share alternative transportation system in Reduction Governments Bike Share System and around downtown Measures Development Solar Energy Promote electricity generation and the use State and Local Point, Area High Fast Low COSA Measures Projects of Solar Power Governments Local Development Installation of LED Governments Point, Area Medium Fast Low COSA Reduction of energy consumption Measures Streetlights and Business Owners Lawn Mower Outreach & Medium- Replacement or exchange of residential Replacement Non-road Fast Low CPS/COSA Home Owners Awareness High mowers with electric or Tier 4 mowers Program Outreach & DFW List of Mileage based auto insurance may Pay-As-You-Drive On-road Medium Fast Low Vehicle Owners Awareness Controls encourage less driving.

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Source for Emission NO Time Likely Category Strategy X Cost Suggested Description Source Benefit Frame Stakeholders Strategy Parking cash-out is a program where certain employers who provide subsidized Outreach & DFW List of parking for their employees can offer cash Parking Cash-Out On-road Low Fast Low Employers Awareness Controls allowance in lieu of a free or subsidized parking space. Cash-out for 10% of area employees The program is designed to reduce employee commute vehicle trips through Outreach & Best Workplaces DFW List of implementation of rideshare, On-road Low Fast Low Employers Awareness Program Controls telecommuting, and flexible work-hour programs, transit pass subsidies, bicycling, and similar strategies. Warm mix asphalt is produced at105o to 135o C (220o to 275oF) compared to hot- mix asphalt (284o to 338oF). By reducing Local N/A (Only the temperature at which the asphalt is Governments Regulation & Non-road, Warm Mix Asphalt VOC Fast Low COSA produced, benefits of reduced fumes, and Enforcement Area Reductions) emissions, reduced energy consumption Construction can be realized, as well as better Companies compaction, paving in cold weather, and possibly better cracking resistance.

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Agenda Item 8. Consider and Act upon AIR Advisory Committee Schedule

2015 Calendar AIR Committee Meetings

Current Calendar for AIR Committees

AACOG Board AIR Executive AIR Advisory AIR Technical Month Of Directors Committee Committee Committee 8:30 AM, 10:00 AM, Wednesdays 1:30 PM, 1:30 PM,

Wednesdays (Same Date as Thursdays Mondays AACOG Board) July July 22 July 22 July 16 July 13 Aug. August 26 Sept. September 23 September 14 Oct. October 28 October 28 October 15 Nov. -- November 9 Dec. December 2

Possible Dates for AIR Advisory meetings if the committee votes for a semi monthly schedule  Thursday September 17th, 2015  Thursday November 19th, 2015 (November 26th is Thanksgiving Day)

10. Bi-annual Air Quality Funding and State Legislative Update

Status of 2016-2017 Biennium Budget for Air Quality Planning

The house version of the 2016-2017 biennium budget for TCEQ for air quality assessment and planning shows appropriation of $125,851,942 for 2016 and $119,291,383 for 20171. This represents a decrease of $ 3,814,783, or 1.53 percent, as compared to the 2014–15 biennial spending levels2. For the biennium Rider 7, as one of the budget items for air quality planning in near nonattainment areas, $5,000,500 were appropriated. The areas as shown below in House Bill (HB 1) language included Waco, El Paso, Beaumont, Austin, Corpus Christi, Granbury, Longview-Tyler-Marshall, San Antonio, and Victoria.

Conference Committee Version of Rider 7 Appropriation: Air Quality Planning. Amounts appropriated above include $6,000,500 for the biennium out of the Clean Air Account No. 151 in Strategy A.1.1, Air Quality Assessment and Planning, for air quality planning activities to reduce ozone in areas not designated as nonattainment areas during the 2016- 17 biennium and as approved by the Texas Commission on Environmental Quality (TCEQ). These areas may include Waco, El Paso, Beaumont, Austin, Corpus Christi, Granbury, Kileen-Temple, Longview-Tyler-Marshall, San Antonio, and Victoria. These activities may be carried out through interlocal agreements and may include: identifying, inventorying, and monitoring of pollution levels; modeling pollution levels; and the identification, quantification, implementation of appropriate locally enforceable pollution reduction controls; and the submission of work plans to be submitted to the TCEQ. The TCEQ shall allocate $350,000 to each area and the remaining funds to each area based on population in excess of 350,000. The grant recipients shall channel the funds to those projects most useful for the State Implementation Plan (SIP).3

The bill passed through the following stages and become law:

Stage 1 Filed 2/09/2015 Stage 2 Out of House Committee 3/24/2015 Stage 3 Voted on by House 4/02/2015 (Passed) Stage 4 Out of Senate Finance Committee 4/08/2015 Stage 5 Voted on by Senate 4/14/2015 (Passed)4 - Conference Committee 4/20/2015 - report prepared for submittal to the house and senate 4/20/2015 - voted in favor by both chambers 5/30/2015 Stage 6 Governor Action 6/20/2015 Stage 7 Bill Becomes Law 6/20/20155

1 Legislative Budget Board Recommendations Senate Version, 84th Legislature, 2015, Page VI-18, online:http://www.lbb.state.tx.us/Documents/Budget/Session_Code_84/2016-17_GAAct_Senate_SB2_Intro.pdf 2 General Appropriations Act, 83rd Texas Legislature, August 30, 2013, Page VI-15, online: http://www.lbb.state.tx.us/Documents/GAA/General_Appropriations_Act_2014-15.pdf 3 Issue Docket, Conference Committee on House Bill 1, 2016-17 General Appropriations Bill, Article VI - Natural Resources, As of May 19, 2015 page 43. Online: http://www.lbb.state.tx.us/Documents/Appropriations_Bills/84/Final/Article06_IssueDoc_05-20- 2015_02_46_27_PM.pdf 4 Senate Journal, 84 Legislature, April 14, 2015, online: http://www.journals.senate.state.tx.us/sjrnl/84r/pdf/84RSJ04- 14-F.PDF#page=4 5 Texas Legislative Guide, available online: http://txlege.texastribune.org/84/bills/HB1/

10. Bi-annual Air Quality Funding and State Legislative Update

Clean Air Account No. 151 “The Clean Air Account No. 151 is a General Revenue-Dedicated account created by Senate Bill 2, Seventy-second Legislature, First Called Session, 1991. Account No. 151 was established to receive Clean Air Act fees which are used to safeguard the air resources of the state, recover the costs of permitting new or modified emission sources, and recover the costs of permit review and renewal. Allowable uses of the account include: 1. the development and administration of the federal air permitting program under Titles IV and V of the Federal Clean Air Act; 2. the Vehicle Emissions Inspection and Maintenance program (VEIMP); and 3, the Low-Income Vehicle Repair Assistance, Retrofit and Accelerated Vehicle Retirement Program (LIRAP). Funds deposited in the Clean Air Account No. 151 come from a variety of permits and fees, with the largest portion from the motor vehicle safety inspection fee.

7/9/2015

Completed Photochemical Modeling Runs

• Hourly On‐Road Emissions

• APCA Run Photochemical Modeling Report • Impact of other regions on regulatory monitors • Impact of local sources Air Improvement Advisory Committee • Hourly impact of VOC and NOX emissions Alamo Area Council of Governments

July 13th, 2015

Hourly 1 Ton NOX Reductions from On‐Road Vehicles APCA Run: Contribution by Region at C58

Emission reductions by source type in the San Antonio‐New Braunfels MSA Design Value days = Days were the predicted 2012 8‐hour ozone > 70 ppb Funding for runs is provided by the Alamo Area MPO Funding for APCA runs are provided by the Alamo Area MPO

San Antonio‐New APCA Run: IQR Plot of the Contribution by Region, 2018 Braunfels MSA Local Contribution to 1‐hour Ozone by Source • CAMS 58 in Camp Bullis Category, C58, Design

• On ozone Value Days Design Value Days (Days when the 2012 predicted ozone is > 70 ppb in 2012)

• Using TCEQ approved Eagle Ford 2018 Emissions Draft Results: Do not Inventory cite, quote, or distribute Moderate development scenario

• BC = Boundary Conditions

IQR = Interquartile range Whiskers = 1.5 x ICQ Funding for APCA runs are provided by the Alamo Area MPO Funding for APCA runs are provided by the Alamo Area MPO

1 7/9/2015

APCA Run: IQR Plot of the Contribution by Local Sources, 2018 Scheduled Runs (3 Linux Workstations) • Updated 2012 run (AACOG received projected emission inventories from TCEQ)

• CAMS 58 in • Updated 2018 run Camp Bullis • Updated 2012 Eagle Ford run with local data • On ozone • Updated 2006 run with the latest emission inventory and meteorological files from TCEQ Design Value Days (Days • Updated 2018 low scenario Eagle Ford run with local data when the 2012 predicted ozone • Runs on individual Point Sources (Alamo Cement) is > 70 ppb in 2012) • Runs on individual Point Sources (Spruce 1, Deely, Capitol Cement, San Miguel, TXI, CEMEX, Chemical Lime) • Control Strategy Runs (3 run+) • Anthropogenic Precursor Culpability Assessment (APCA) run with individual San Antonio New Braunfels MSA Counties as regions , 2018 • Additional APCA run? • Start running the June 2012 photochemical modeling episode

Draft Results: Do not • Create projection cases for 2020 and 2023 cite, quote, or distribute IQR = Interquartile range Whiskers = 1.5 x ICQ Funding for APCA runs are provided by the Alamo Area MPO

San Antonio‐New Braunfels Hourly VOC and NOX Emissions Contribution to 1‐hour Ozone, C58, Design Value Days

Funding for APCA runs are provided by the Alamo Area MPO

NOX Emissions by Source, San Antonio‐New Braunfels Predicted 8‐hour Ozone Design Values MSA, tons/ozone season day Funding is provided by the Alamo Area MPO C58 Ozone Monitor, 2018

• Biogenic Emissions are not available • Oil and Gas Development Emissions are only for the San Antonio-New Braunfels MSA • CPS Energy Deely Power plant is included in 2018 (but not 2023) Funding for 25%, 50%, and 75% reductions is provided by the Alamo Area MPO

2 7/9/2015

10 Tons of NOX or VOC Emission Reductions by Source Category APCA Photochemical Model Run

• Anthropogenic Precursor Culpability Assessment (APCA)

• The ozone reaction tracers allow ozone formation from multiple “source groupings” to be tracked simultaneously

• A source grouping can be defined in terms of: 1. geographical area and 2. emission category

• What is the source of the ozone at each regulatory monitor?

• Run time ~45 days –run not completed yet CAMS 58

Emission reductions by source type in the San Antonio‐New Braunfels MSA Funding for runs is provided by the Alamo Area MPO

APCA Regions and Categories APCA Run, June 2018 Projection Case, May 31st to June 14th, C58 Regions • Dallas‐Fort Worth Nonattainment (NA) Area • Waco‐Temple‐IH35 Region • Austin‐Round Rock Metro Stat Area (MSA) • San Antonio‐New Braunfels MSA • Houston‐Galveston‐Brazoria NA Area • Other Texas Counties • Other US States and Coastal Areas • International (Canada and Mexico) • Initial Conditions • Boundary conditions

Emission Categories • Area • Non‐Road/Off‐Road • On‐Road • Point • Eagle Ford Oil and Gas Development • Biogenic (APCA only attributes ozone production to biogenic emissions when ozone formation is due to the

interaction of biogenic VOC with biogenic NOX) Funding for APCA runs are provided by the Alamo Area MPO

San Antonio‐New APCA Run, June 2018 Projection Case, June 15th to June 30th, C58 Braunfels Local Contribution to 1‐hour Ozone by Source Category, C23, Design Value Days

Draft Results: Do not cite, quote, or distribute

Funding for APCA runs are provided by the Alamo Area MPO Funding for APCA runs are provided by the Alamo Area MPO

3 7/9/2015

APCA Run: Contribution by Local Sources June 2006 Photochemical Modeling Episode • WRF v3.2 Meteorological Model, CAMx 6.0 • Version 6 of the Carbon Bond photochemical mechanism (CB6) • During the episode, 8‐hour ozone exceeded 75 ppb on nine days at C58 and six days at C23 • Modeling Days: ‐Seven ramp‐up days, May 24th ‐ May 30th, ⁻ Thirty ‐one primary episode days, May 31st – June 30th and ⁻ Two ramp‐down days, July 1st and 2nd • Emissions were projected to 2012 and 2018

• TCEQ approved EI and Photochemical Model

Draft Results: Do not cite, quote, or distribute Design Value days = Days were the predicted 2012 8‐hour ozone > 70 ppb Funding for APCA runs are provided by the Alamo Area MPO

Predicted 8‐hour Ozone Design Values, 2018

Based on latest TCEQ approved Eagle Ford Emission Inventory Funding for zero out run is provided by the Alamo Area MPO

4 12. Potential Cost of Non-attainment

Nonattainment Areas’ Required Controls and Associated Costs

The San Antonio area may face a nonattainment designation for the 2015 eight-hour ozone National Ambient Air Quality Standard (NAAQS), and AACOG in this regards asked TCEQ to help analyze the potential costs of this designation for San Antonio region. TCEQ has submitted a list of potential VOC and NOX controls, as well as estimated cost for these controls if/when they are implemented. TCEQ would like to emphasize that it has collected the information from publically available sources, and inclusion of a reference to a cost estimate does not indicate that the TCEQ has reviewed or agreed with the referenced study results. TCEQ’s study reveals that the cost of an ozone nonattainment designation depends on many factors.

General Nonattainment Costs Categories Available studies have widely varying conclusions regarding ozone nonattainment costs. The cost of an ozone nonattainment designation depends on many factors, including:

Costs accruing to regulated entities to comply These stem from requirements to reduce emissions (such as additional point source controls), implement federally-required controls (some for areas sources), and additional procedural requirements, such as nonattainment new source review (NSR) permitting.

Costs accruing to governments State and local governments incur costs for developing and implementing SIPs, implementing more stringent permitting requirements, and monitoring and enforcement.

Costs accruing to individuals Citizens in ozone nonattainment areas may be required to comply with inspection and maintenance (I/M) and fuel requirements for vehicles or face other potential restrictions (on idling, lawn care equipment, etc.). They may also experience indirect costs for goods and services as businesses complying with control requirements raise prices. These costs may be estimated in general equilibrium econometric models that account for behavior changes (“induced” effects).

Indirect costs These include the long-term effects of business decisions to avoid locating or expanding in areas with stricter air quality controls. They may include changes in prices, employment, and consumption patterns.

Negative costs (benefits) Some businesses that build, install, and service pollution control equipment may benefit from increased demand for their products, including engineering design, materials, manufacturing, construction, and vehicle inspection industries. This discussion does not address indirect or negative costs. The only cost to individuals that is assessed is that of complying with vehicle emissions testing (I/M) requirements.

Nonattainment Costs under Marginal and Moderate Classifications

The requirements most likely to influence the potential cost of nonattainment in the San Antonio area are those mandatory controls set aside for Marginal or Moderate nonattainment areas. For Marginal ozone designation, major point sources in the area must begin to comply with emissions inventory reporting requirements and offset proposed new emissions via a nonattainment NSR permit and local authorities must comply with federal general and 12. Potential Cost of Non-attainment transportation conformity requirements. It is challenging to estimate the cost of these requirements; however, the procedural costs, delays, and uncertainty introduced by these permitting and conformity requirements are cited as reasons why companies may prefer not to locate or expand in nonattainment areas. For a Moderate nonattainment designation, citizens would be required to obtain emissions inspections for most vehicles and State to submit a SIP that incorporates all reasonably available control measures (RACM) necessary to achieve or advance attainment, including reasonably available control technology (RACT) requirements. With a Moderate and higher ozone nonattainment designation, the FCAA also requires states to demonstrate reasonable further progress (RFP) toward attainment and at least a 15% reduction in VOC from baseline emissions within six years. Should controls required as RACT or RACM not provide sufficient reductions in ozone precursors to demonstrate RFP, then additional controls may be needed. The vehicle emissions inspection fee, under Moderate scenario, is generally an incremental $14 to $27, on top of the cost for a safety inspection, for all gasoline-fueled light-duty vehicles aged 2 through 24 years old.

If the San Antonio area is designated Moderate nonattainment or above for ozone, the types of controls currently required in the Houston-Galveston-Brazoria or Dallas-Fort Worth areas may be considered for the San Antonio area. Attachment 1: Volatile Organic Compounds (VOC) Source Categories and Estimated Costs and Attachment 2: Nitrogen Oxides (NOX) Source Categories and Estimated Costs provide available cost information on emission sources that are subject to control requirements in other Texas nonattainment areas that are designated as moderate or above. Attachment 1 includes all EPA CTG emission source categories and selected ACT emission source categories for which cost information was available.

Cost of Implementing SIP Strategies If the San Antonio area is designated as nonattainment, local governments will face costs associated with implementing SIP strategies. These costs include coordinating stakeholder involvement in air quality planning decisions, developing local ordinances, outreach, and participation in transportation and general conformity activities. The TCEQ has estimated that the agency’s level of effort is 45,000 to 55,000 hours of staff time, with an estimated cost of over $1 million dollars, per SIP. The cost of implementing SIP strategies at the local government and regional level can also be significant. If the designation classification is marginal instead of moderate, the costs would be lower with the amount varying in relation to the volume of emissions that would need to be reduced. 12. Potential Cost of Non-attainment

Attachment 2: Nitrogen Oxides (NOX) Source Categories and Estimated Costs

Unit/Source TCEQ Estimated Cost Year Information/Source Link Category Estimated Cement Control Kiln Total Capital Total Annual Cost Effectiveness 2006 Assessment of NOx Emissions Kilns/Cement Technology Type Cost (MM $) Cost (MM $) ($/ton NOx reduced) Reduction Strategies for Cement Kilns- Manufacturing 1 SCR Wet 5.0 - 5.7 0.6 - 2.7 5,500 - 96,000 Ellis County: Final Report, ERG, Inc. Dry 6.7 - 8.4 2.0 - 2.2 1,900 - 2,200 (July 14, 2006) SNCR Wet 1.2 - 1.4 0.3 - 0.5 2,400 - 13,000 Revised Final Report with corrected Dry 2.3 1.0 - 1.1 1,500 - 2,900 tables and figures (August 23, 2006) LoTOxTM Wet 2.8 - 5.8 0.5 - 1.6 3,300 - 11,000 Dry 5.2 - 6.7 2.4 - 3.1 2,300 - 2,600 31 TexReg 10538 (pg.10600) Lime Kilns 1 Control Technology Total Capital Cost ($) Total Annual Cost ($) 2006 25 TexReg 8137 (pg. 8290) Staged Combustion 225,000 10,000 Electric Control Size Capital Cost FO&M Cost VO&M Cost 2011 Potential Impacts of Environmental Generating Technology (MW) ($/kW) ($/kW) ($/MWh) (2008 $) Regulation on the U.S. Generation Utilities (EGU) SCR 25 - 900 492 - 270 2.6 - 0.4 1.23 Fleet, Final Report, Prepared by ICF International for the Edison Electric SNCR 25 - 900 33 - 10 0.7 - 0.2 1.235 Institute (January 2011) Control Technology Capital Cost ($/MW) Total Annual Cost ($) 2 2006 31 TexReg 10538 (pg.10600) SCR 125,000 1,362,500 Stationary Control Firing Capital Cost ($) Annual Cost ($) 2006 31 TexReg 10538 (pg.10599 - 10601) Internal Technology Type Installation 2nd Catalyst Equipment 2nd Catalyst Combustion NSCR Rich-Burn 16,667 + 15/hp 2,600 + 5/hp Engines 3 16.67/hp 11/hp EGR + Lean-Burn 39,167 + 15/hp 2,600 + 5/hp NSCR 41.67/hp 11/hp SCR Lean-Burn 310,000 + 72.70/hp 37,300 + 16.30/hp SCR Dual-Fuel 187,000 + 98/hp 37,000 + 16.30/hp LEC Lean-Burn 226,000 + 66.80/hp 57,800 + 14.60/hp Stationary Control Technology Total Capital Cost ($) Total Annual Cost($) 2006 31 TexReg 10538 (pg.10599) Combustion LNB 400,000 52,500 Turbines 2

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12. Potential Cost of Non-attainment

Unit/Source TCEQ Estimated Cost Year Information/Source Link Category Estimated Industrial, Control Technology Capital Cost Annual Cost 2006 31 TexReg 10538 (pg.10597 - 10598) Commercial, ($/MMBtu/hr) ($/MMBtu/hr) Institutional SCR 4,000 - 6,000 700 Boilers LNB 3,100 600 Industrial, Control Capital Cost Total Capital Cost ($) 2 Total Annual Cost ($) 2 2006 31 TexReg 10538 (pg.10599) Commercial, Technology ($/MMBtu/hr) Institutional LNB 3,280 23,640 3,980 Process Heaters Natural Gas-Fired Control Technology Total Capital Cost ($) Total Annual Cost ($) 2006 31 TexReg 10538 (pg.10599) Heaters, Dryers, LNB 37,070 6,370 & Ovens 2 Brick & Ceramic Control Technology Total Capital Cost ($) Total Annual Cost ($) 2006 31 TexReg 10538 (pg.10599) Kilns 2 LNB 159,090 72,730 Glass & Technology Unit Type Total Capital Cost ($) Total Annual Cost ($) 2006 31 TexReg 10538 (pg.10599) Fiberglass Oxy-Fuel Glass Furnace 9.8 (million) 4 0.7 - 4.1 (million) 4 Manufacturing Firing Fiberglass Furnace 1.9 - 5.1 (million) 4 LNB Glass/Fiberglass 65,000 2 11,000 2 Curing Oven Iron & Steel Technology Unit Type Total Capital Cost ($) Total Annual Cost ($) 2006 31 TexReg 10538 (pg.10599) Manufacturing 2 LNB Reheat/Heat Treat 150,000 28,700 Furnaces Incinerators 2 Control Technology Total Capital Cost (MM $) Total Annual Cost ($) 2006 31 TexReg 10538 (pg.10600) SCR 1.2 272,000 CEMS 1 Total Capital Cost ($) Total Annual Cost ($) 2006 31 TexReg 10538 (pg.10599) (general) 148,300 48,000

MM $: million dollars Wet: Long Wet Kiln Dry: Long Dry Kiln SCR: Selective Catalytic Reduction SNCR: Selective Non-Catalytic Reduction LoTOxTM: Low Temperature Oxidation CEMS: Continuous Emissions Monitoring System 2

12. Potential Cost of Non-attainment

MW: Megawatt kW: Kilowatt MWh: Megawatt-hour FO&M: Fixed Operating and Maintenance VO&M: Variable Operating and Maintenance LEC: Low Emissions Combustion LNB: Low-NOx Burner Units may need fuel meters to demonstrate compliance with state rules, thereby incurring additional compliance costs. Fuel metering costs are ~$2,500 per meter. Units may need to conduct initial compliance testing to demonstrate compliance with state rules, thereby incurring additional compliance costs. Initial stack test costs are ~$3,500 per control. Engine owners/operators may need to conduct quarterly testing in addition to initial and periodic testing, thereby incurring additional compliance costs. Quarterly test costs are ~$125 per control. 1 Costs per unit. Costs for units in San Antonio may differ. 2 Costs per unit, reverse calculated from the total costs and total number of units based on the specific units subject to the cited rulemaking. Total costs for the entire unit group may include zero costs for units considered already compliant with the proposed rulemaking. Costs for units in San Antonio may differ. 3 Cost curves for engines apply to only gaseous fuel-fired engines and not to diesel-fired engines. 4 Costs per plant. Costs for plants in San Antonio may differ.

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12. Potential Cost of Non-attainment Attachment 1: Volatile Organic Compounds (VOC) Source Categories and Estimated Costs Source Category CTG/ACT EPA Estimated Cost 30 TAC TCEQ Estimated Year Control Description Information (Year) Cost Estimated Source Bulk Gasoline Plants CTG Top submerged fill balance system §115.211 – $75,000 to 2006 Vapor combustor, or 31 TexReg EPA- -$36/ton of VOC reduced §115.219 $200,000/unit 5558 450/77-2- Top submerged fill system $300,000 to Vapor recovery unit 035 -$118/ton of VOC reduced $1,000,000/unit (1977) Bottom fill -$18/ton of VOC reduced (1977) Cleaning Solvents CTG Parts cleaner §115.460 – -$1840/yr per 2011 Switch to low-VOC or 36 TexReg EPA- $1,666/ton of VOC reduced §115.469 large facility low vapor pressure 3865 Industrial 453/R-06- -$2760/yr per cleaning solvents

001 Other solvent cleaning small facility December (2006) -$1,326/ton of VOC reduced Parts cleaning: 26, 2014 (2002) $2,589/ton of VOC reduced Other cleaning: -$1,590/ton of VOC reduced (2008 dollar) Cutback Asphalt CTG -$14.5/ton of VOC reduced §115.510 – No cost increase 2006 Alternative materials 31 TexReg EPA- (1977) §115.519 are available at 5558 450/2-77- comparable prices. 037 (1977) Fugitive Emissions CTG Model Unit B Net Annualized costs: §115.352 – $0.5 to $1.0 per 2002 Quarterly monitoring 27 TexReg EPA- §115.359 component of blind flanges, caps, 5394 450/3-82- Monitoring: $2,292/yr plugs at pipe or line

010 end; connectors; (1982) §115.780 – heat exchanger §115.789 heads; sight glasses; meters; gauges; connections; bolted manways; hatches; agitators; sump

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12. Potential Cost of Non-attainment Source Category CTG/ACT EPA Estimated Cost 30 TAC TCEQ Estimated Year Control Description Information (Year) Cost Estimated Source Monitoring and leak repair for pump $215,250 to 2002 covers; stormwater seal: $4,674/yr $430,500 per and process drains; quarter junction box vents; Monitoring and leak repair for valves: covers and seals on $5,100/yr water separators

Graphic Arts CTG Carbon Adsorption §115.430 – No recent cost EPA- $46 to $34/ton of VOC recovered §115.439 estimated Rotogravure and 450/2-78- Flexography Incineration System 033 $120 to $1,650/ton of VOC reduced (1978) (depending on VOC input rate, heat recovery, and outlet concentration) (1978) Graphic Arts CTG $1,300 to $2,800/ton of VOC reduced §115.430 – $1,300 to 2011 Add-on control for a 36 TexReg EPA- (2006) §115.439 $2,800/ton VOC press emitting at 3834 Flexible Package 453/R-06- reduced least 25 tons per year Printing 003 $142,000 to Installing a fixed bed (2006) $341,000/unit catalytic oxidizer $26,200 to Annual operating $47,500/yr costs Graphic Arts CTG Control of VOC from heatset inks §115.440 – $27,847/unit 2009 Refrigeration unit for 34 TexReg EPA- $2,010/ton of VOC reduced §115.449 fountain solution 7015 Offset Lithographic 453/R-06- Printing and 002 Letterpress Printing Control of VOC from cleaning solution $1,876/yr Annual operating (2006) $855/ton of VOC reduced cost (2006) Industrial Adhesives CTG $265/ton of VOC reduced §115.470 – $4,480/yr 2011 Switching to low VOC 36 TexReg EPA- §115.479 formulas 3834 453/R-08- $3,356/yr per facility $200 Coating application

005 (2008) system – High (2008) volume/low pressure (HPLV) spray gun $1400 Coating application complete system Natural CTG Monitoring instrument $9,200/site §115.352 – No recent cost Gas/Gasoline EPA- Cap on line installed $61/cap estimated

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12. Potential Cost of Non-attainment Source Category CTG/ACT EPA Estimated Cost 30 TAC TCEQ Estimated Year Control Description Information (Year) Cost Estimated Source Processing 450/3- Compressor vent control §115.359 Piping: $4,020 plus 83-007 Flare: $10,040/site (1983) Initial leak repair $1800 to $18,000/site Annual leak detection and repair $9,800 to $48,000/site Recovered product benefit $6,500 to 65,000/site Net annual cost: $3,300 to -$17,000/site -$67 to $127 $/ton of VOC reduced (1980)

Petroleum Liquid ACT Liquid-mounted seal Internal Floating §115.110 – $10,000/Tank 2006 Guidepoles control 31 TexReg Storage EPA- Roof (IFR): $20/linear (lin) feet (ft) §115.119 10525 Floating and Fixed- 453/R- External Floating Roof (EFR): $80/lin ft $60,000/Flare 2011 New flare, or 36 TexReg Roof Tanks 94-001 3817 (1994) Secondary seals on IFR $26/lin ft $110,000/Unit 2011 Vapor Recovery Unit 36 TexReg 3817 Secondary seal on EFR $54/lin ft Controlled fittings $600 to $680/tank (1994) Install IFR capital $46,970 to $189,040/tank $380 to $1,530/ton VOC reduced

Upgrade IFR fittings $420 to $17,300/ton

Upgrade EFR fittings -$260 to -80/ton (1991) Petroleum Liquid CTG Capital cost for IFR and seals §115.110 – No recent cost Storage EPA- $12,000 for 50 ft diameter tank §115.119 estimated $28,000 for 100 ft diameter Fixed-Roof Tanks 450/2- $53,000 for 150 ft diameter 3

12. Potential Cost of Non-attainment Source Category CTG/ACT EPA Estimated Cost 30 TAC TCEQ Estimated Year Control Description Information (Year) Cost Estimated Source 77-036 Annual operating and maintenance (1977) (O&M), inspection $900 for 50 ft diameter tank $1,800 for 100 ft diameter $3,400 for 150 ft diameter -$136 to $235/ton of VOC reduced (1977) Petroleum Liquid CTG -$60 to $3,582/ton of gasoline lost §115.110 – $10,000/Tank 2006 Guidepoles control 31 TexReg Storage EPA- §115.119 10525 $24 to $4,930/ton of crude oil lost $60,000/Flare 2011 New flare, or 36 TexReg External Floating 450/2- 3817 Roof Tanks 78-047 Secondary seal capital $16,900 for 100 $110,000/Unit 2011 Vapor Recovery Unit 36 TexReg (1978) ft diameter welded & riveted tank 3817 Seal inspection, O&M $1,100/yr for 100 ft diameter tank (1978) Refineries CTG Surface condenser §115.120 – $50,000/unit 2006 Water separator 31 TexReg -$104/ton of VOC reduced §115.129 control unit 5558 Vacuum Producing EPA- Systems, 450/2- Vacuum producing system §115.131 – $15,000/unit 2006 Water separator VOC 31 TexReg Wastewater 77-025 -$96/ton of VOC reduced §115.139 monitoring and 5558 Separators, and operating 1977/10 §115.311 – Process Unit Wastewater separator $500/year 2002 Recordkeeping per 27 TexReg (1977) §115.319 Turnaround -$91/ton of VOC reduced facility 49 Flaring $4.5/ton of VOC reduced Turnaround -$91/ton of VOC recovered (1977) Refineries CTG Monitoring instruments initial cost §115.352 – No recent cost $8,800/site §115.359 estimated Leaks from EPA- Petroleum Refinery 450/2- Annual leak detection and repair cost $112,600/site Equipment 78-036 Optional: Seal oil vent control device (1978) initial cost: $3,700/site

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12. Potential Cost of Non-attainment Source Category CTG/ACT EPA Estimated Cost 30 TAC TCEQ Estimated Year Control Description Information (Year) Cost Estimated Source Annual seal oil control operation cost: $400/site (1977) Rubber Tires CTG $151 to $459/ton of VOC reduced No rubber tire (1978) manufacturer Manufacture of EPA- identified in 2012 EI Pneumatic Rubber 450/2- for San Antonio area Tires 78-030 (1978) Solvent Cleaning CTG §115.412 – There are no EPA- §115.419 requirements from Solvent Metal 450/2-77- this CTG in §115.420 Cleaning §115.420 – 022 – §115.429 that are §115.429 (San Antonio area (1977) expected to cost or already subject to save a source money. the requirement) Surface Coating CTG §115.420 – No magnet wire EPA- §115.429 manufacturer Insulation of 450/2-77- identified in 2012 EI Magnet Wire 033 for San Antonio area (1977) Surface Coating CTG No shipbuilding and 61 FR ship repair operation Shipbuilding and 44050 identified in 2012 EI Ship Repair (1996) for San Antonio area Operations Surface Coating CTG Carbon adsorbers for chemical milling §115.420 – No recent cost EPA- maskants capital: $247,000 §115.429 estimated Coating Operations 453/R-97- at Aerospace Carbon adsorbers for waterborne 004 Manufacturing and milling maskants capital: $143,000 (1997) Rework Operations Dry media blasting for depainting 59 FR capital: $604,000 29216 High transfer efficiency application (1994) equipment capital: $64,200 Spray gun cleaning equipment: $5,000 Spray booth and filter system: $6,400 Hand-wipe and flush cleaning annual cost: $6,900

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12. Potential Cost of Non-attainment Source Category CTG/ACT EPA Estimated Cost 30 TAC TCEQ Estimated Year Control Description Information (Year) Cost Estimated Source Waterborne chemical milling maskants annual cost: $55,000 Blast depainting annual cost: $3,000 (1994) Surface Coating CTG Exterior siding §115.420 – No recent cost EPA- $2,600/ton of VOC reduced §115.429 estimated Flat Wood Paneling 453/R-06- Interior siding Coatings 004 $1,900/ton of VOC reduced (2006) $101,000 per facility (2005) Surface Coating CTG $1,200/ton of VOC reduced §115.450 – $1,200/ton VOC 2011 Add on @ 90% 36 TexReg EPA (2005) §115.459 reduced emission reduction 3834 Paper, Film, and 453/R-07- Capture system and new thermal Foil Coatings 003 oxidizer (TO) (2007) Capital: $2,479,820 to $6,780,733 (2002) annual cost: $857,781 to $2,312,499/yr (2005) Capture system Capital: $290,000 to $1,686,000 (2002) annual cost: $145,013 to $1,049,738/yr (2005) Surface Coating CTG $500/ton of VOC reduced §115.450 – $500/ton of VOC 2011 Switch to low-VOC 36 TexReg EPA (2006) §115.459 reduced solvent 3834 Large Appliance 453/R-07- (2006) Coatings 004 $730/yr Small plant: switch (2007) to low-VOC solvent $25,900/yr Large plant: switch to low-VOC solvent $200 HVLP spray gun, or $1400 Coating application complete system Surface Coating CTG $200/ton of VOC reduced §115.450 – $200/ton VOC 2011 Cost effectiveness 36 TexReg EPA- (2003) reduced 3834

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12. Potential Cost of Non-attainment Source Category CTG/ACT EPA Estimated Cost 30 TAC TCEQ Estimated Year Control Description Information (Year) Cost Estimated Source Metal Furniture 453/R-07- §115.459 $600 to $36,000 Capital: switch to Coatings 005 per facility low-VOC solvent (2007) $1,670/yr per Operating cost: facility switch to low-VOC solvent $200 Coating application system HVLP gun $1400 Coating application complete system $3,500,000 to Capital: enclosure $6,300,000 and thermal oxidizer $575,000 to Annual operating $1,100,000 cost: enclosure and thermal oxidizer Surface Coating CTG $1,758/ton of VOC reduced §115.450 – $9,950/ton of 2012 Use exempted SCAQMD – EPA- §115.459 VOC reduced solvents to meet R1107 Miscellaneous 453/R-08- 2015 standard Metal and Plastic 003 $1,758/ton of 2011 Switch to low-VOC 36 TexReg Parts Coatings (2008) VOC reduced coating cost 3834 effectiveness $2,600 to Switching to low-VOC $11,500/facility solvent for metal per year coating operation $600 to Plastic coating annual $76,000/facility operating cost per year $200 HVLP spray gun $1,400 Complete coating application system Surface Coating CTG No cost implications expected. §115.450 – No recent cost EPA §115.459 estimated Automobile and 453/R-08- Light-Duty Truck 006 Assembly Coatings (2008)

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12. Potential Cost of Non-attainment Source Category CTG/ACT EPA Estimated Cost 30 TAC TCEQ Estimated Year Control Description Information (Year) Cost Estimated Source Synthetic Organic CTG §115.531 – No pharmaceutical Chemical EPA- §115.539 products Manufacturing 450/2-78- manufacturer Industry 029 identified in 2012 EI (1978) for San Antonio area Synthesized Pharmaceutical Products Synthetic Organic CTG Polypropylene plant §115.120 – $600,000 2006 Control device for a 31 TexReg Chemical EPA- Thermal incinerator: $635,900 or §115.129 vent stream 5558 Manufacturing Flare: $90,600 450/3- Industry Polyethylene plant $360,000 2006 Annual operating 83-008 Incinerator: $557,400 or Flare: cost Manufacture of (1983) $54,500 High-Density Polyethylene, Polystyrene plant Condenser: $32,300 Polypropylene, and (1980) Polystyrene Resins Synthetic Organic CTG Cap lines: $5,500 to 67,900/site §115.352 – $500/site per 2002 Recordkeeping 27 TexReg Chemical EPA- §115.359 year 55 Manufacturing 450/3- Monitoring instrument: $9200 Industry 83-006 Polymer and Resin (1983) Initial leak repair: $22,500 to 2002 Startup monitoring 27 TexReg Manufacturing $1,200 to $14,000/site $45,000/yr per after shutdown 5415 Equipment Net annual cost: $2,300 to $5,400/site site @ $0.5 to (1980) $1.0 per component Synthetic Organic CTG capital cost $1,373,000 to $9,988,000 §115.120 – No recent cost Chemical EPA- (1980) §115.129 estimated Manufacturing 450/3-84- Industry 015 annual costs (1984) Air Oxidation $338,000 to $5,294,000

Processes (1980) $100 to $6,849/ton of VOC reduced depending on flow rate, emission rate, and heating value

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12. Potential Cost of Non-attainment Source Category CTG/ACT EPA Estimated Cost 30 TAC TCEQ Estimated Year Control Description Information (Year) Cost Estimated Source Synthetic Organic CTG Incinerator capital costs: $86,203/unit §115.120 – No recent cost Chemical EPA- annual cost: $49,562 §115.129 estimated Manufacturing 450/4- Industry 91-031 Scrubber capital cost: $28,237/unit Reactor Processes (1993) annual cost: $47,130 and Distillation Operations Flare capital cost: $94,502 annual cost: $508,481 Incinerator + scrubber: $241 to $21,405/ton of VOC reduced

Flare: $632 to $6,034/ton of VOC reduced Thermal incinerator: $275 to $12,525/ton of VOC reduced (1993)

Tank Trucks CTG Vapor recovery unit capital: $176,000 §115.211 – $75,000 to 2006 New vapor 31 TexReg EPA- to $194,000 §115.219 $200,000 combustor 5558 Tank Truck Gasoline 450/2-77- annualized: $20,600/yr Loading Terminals §115.221 – $300,000 to New vapor recovery 026 §115.229 $1,000,000 unit (San Antonio area (1977) Incinerator capital: $140,000 $1700 to 1999 Vapor balance 24 TexReg already subject to annualized: $29,800/yr $2700/tank truck system 61 the requirement) $71,350/Bulk Vapor recovery plant equipment Cost effectiveness $19,300 to Ultraviolet beam @251,000 gal/day throughput $22,300/flare sensor or thermocouple $121/ton for refrigeration system

$129/ton for compression- refrigeration-absorption system

$181/ton for TO (1977)

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12. Potential Cost of Non-attainment Source Category CTG/ACT EPA Estimated Cost 30 TAC TCEQ Estimated Year Control Description Information (Year) Cost Estimated Source Tank Trucks CTG Not available §115.211 – $1700 to 2006 Vapor recovery 31 TexReg EPA- §115.219 $2700/tank truck system 5558 Leaks from Gasoline 450/2-78- Tank Trucks and §115.234 – 051 Vapor Collection §115.239 (1978) $360 to Vapor tightness Systems $650/tank truck testing per year (San Antonio area already subject) Vegetable Oil CTG Not available None identified in Manufacturing EPA- 2012 EI for San 450/2-78- Antonio area 035 Wood Furniture CTG 20 foot turbolator oven: $48,600 §115.420 – $21,000/yr Compliance cost 22 TexReg Manufacturing EPA- annual operating cost: $3,500/oven §115.429 12401 453/R-96- Waterborne paint delivery small 007 system: $9,100 (1996) Medium to large system: $34,400 Spray booth modification medium to large system: $3,250 -$818 to $3,272/ton of VOC reduced (1991) Industrial ACT Steam Stripping Unit §115.140 – $194,600 annual 2002 Inspect water seals 27 TexReg Wastewater EPA- capital: $512,000 §115.149 operating cost daily 5394 453/D-93- $500 2001 Recordkeeping cost 26 TexReg 056 4026 (1993) annual cost: $267,900 $347/ton of VOC 1999 For Organic 24 TexReg (1989) reduced Chemicals, Plastics, 5413 and Synthetic Fibers Manufacturing $5,732 to 1995 Based on similar 19 TexReg $420,796/ton of control for benzene 7999 VOC reduced NESHAPS Adsorption initial cost: $246,030 to $971,214/site annual cost: $96,470 to $204,120/site (1988)

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