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The South Coast Air Quality Management District (SCAQMD)
Letter from Manuel Lopez to David Gardiner
October 10, 1995
David Gardiner
United States Environmental Protection
Agency
Regulatory Reinvention Pilot Projects
401 M. Street, S.W.
Washington D.C. 20460
Dear Mr. Gardiner:
The Ventura County Air
Pollution Control District (APCD) is extremely interested in implementing
an emission equivalence program under Project XL as a replacement for
APCD Rule 210, Employee Commute Options. This request is in direct response
to Mary Nichol's June 28, 1995 memorandum which states that emissions
equivalence may have merit as a supplement to trip reduction options,
and that the Environmental Protection Agency (EPA) could implement this
recommendation in the context of the Project XL program.
Ventura County APCD adopted an Employee
Commute Options (ECO) Rule, rule 210, in 1989. Since that time, Average
Vehicle Occupancy, for employers subject to the rule, has increased
significantly from 1.12 to 1.35. However, many employers have had difficulty
complying with the Rule. These employers frequently inquire about alternatives
to the District's Rule 210.
The South Coast Air Quality Management
District (SCAQMD) recently submitted an application requesting approval
of Rule 1501.1 under Project XL. Rule 1501.1 was adopted by the SCAQMD
in April 1995 and allows employers subject to the Rule 1501, Work Trip
Reduction Plans, to achieve emissions equivalence in lieu of complying
with Rule 1501. The exact details for Ventura County's emissions equivalence
alternative have not been finalized at this time. However, it is expected
that the program will be very similar to SCAQMD Rule 1501.1. If rule
1501.1 is approved by EPA under Project XL, we request that you allow
us to adopt a similar rule as a substitute for Rule 210.
Ventura County has been a leader in implementing
stringent and innovative solutions to our air quality problem. An emission
equivalence program as a substitute for Rule 210 can achieve greater
environmental benefits more quickly and at a lower cost than Rule 210.
We look forward to your approval of this request. If you have any questions,
please call Richard Baldwin at 805/645-1440
Sincerely,
Manuel Lopez, Chair
Ventura County Air Pollution Control Board