March 14, 1973
Page 7914
FEDERAL AID HIGHWAY ACT OF 1973
The Senate resumed the consideration of the bill (S. 502) to authorize appropriations for the construction of certain highways in accordance with title 23 of the United States Code, and for other purposes.
Mr. MUSKIE. Mr. President, I yield myself 10 minutes at this time.
This amendment is cosponsored by Senators BAKER, BIDEN, BROOKE, BUCKLEY, CASE, CRANSTON, HART, HATFIELD, HATHAWAY, HUMPHREY, JAVITS, PASTORE, PELL, PERCY, PROXMIRE, RIBICOFF, STAFFORD, STEVENSON, and TUNNEY.
The Muskie-Baker amendment is a sensible proposal. It simply would give cities and States the flexibility to decide for themselves whether their allocations from the urban systems authorization of the highway trust fund should be spent for roads, or for alternative transportation systems.
This amendment would not provide mass transit facilities in rural areas; it would apply only to the urban systems section.
This amendment would not force cities or states to substitute mass transit facilities for highways; it merely would give the people of urban America a choice they are now denied.
This amendment would not divert trust funds from highways that ought to be built; it would allow cities to substitute alternatives for highways that should not be built.
Nor, Mr. President, is this amendment supported only by narrow interest groups; the Senate passed a similar version last year, the Nixon administration supports it, and a broad coalition of citizen groups including a majority of the Nation's Governors, the National League of Cities-U.S. Conference of Mayors, the United Auto Workers, and Common Cause has worked for its passage.
It has become clear to these and many other Americans that our current national transportation policies are badly out of step with our needs. Although we have set difficult goals for ourselves in conserving our fuel resources, protecting our environment, and improving the quality of urban life, we have preserved at the same time a closed-circle transportation policy which perpetuates highway construction as virtually the only solution to transportation problems that most cities and States can afford to choose.
Every year our metropolitan transportation problems multiply. Whether the problem involves moving workers to and from their jobs, moving goods and people around the city, or bringing essential goods and services to the urban population, more highways and more cars have become the only answer – even when they are obviously not the right answer. Before it is too late, we should take a hard look at the consequences of this policy and decide whether those consequences should be an inevitable part of our future. Before it is too late we should seek ways in which we can all move freely about our cities without endangering our health, destroying our communities, and wasting our resources in the process.
Highways and automobiles have revolutionized life in urban America; but they now threaten in several ways to destroy the urban life they helped to create.
First, highways and the cars that use them pollute the air of our cities and menace the health of the people who live there. This statement should come as no surprise to Members of this body, Mr. President. We were aware of the danger 3 years ago when we unanimously approved the Clean Air Act of 1970. We resolved then that protection of the public health was of primary and overriding importance. We explicitly excluded considerations of economic and technological feasibility in setting ambient air quality standards under that act. And for the same reasons we set a statutory deadline for the development of a clean car.
That was 3 years ago. Now the deadline for meeting the air quality standards is only 2 years away; but as of today the air quality in 67 metropolitan areas constitutes a health hazard because of one or more auto-related air pollutants.
We were also aware in 1970 what the provisions of the Clean Air Act meant in terms of urban transportation systems. The Public Works Committee report forecast the kinds of changes that the new law would require:
As much as seventy-five percent of the traffic may have to be restricted in certain large metropolitan areas if health standards are to be achieved within the time required by this bill.
The committee report warned that–
Construction of urban highways and freeways may be required to take second place to rapid and mass transit and other public transportation systems. Central city use of motor vehicles may have to be restricted.
If cities could make the switch from automobiles to electric rail systems, one calculation estimates that for every 100,000 passenger-miles there would be net decreases of 8,000 tons of carbon monoxide, 1,600 tons of hydrocarbons, and 320 tons of nitrogen oxides.
On one hand, Mr. President, we have told the cities they must make changes in their transportation systems to protect the public health. But on the other hand we have withheld the funding flexibility that would make those changes possible. This is not consistent policy on our part, and it is a disservice to the cities and to the national policies we ourselves established. By finally granting that long-sought flexibility, this amendment would make it possible for the cities to fulfill both their responsibilities: protection of the public health and assurance of adequate transportation facilities.
Our second concern is that highways and automobiles have had as destructive an effect on our cities themselves as they have had on the health of the people who live in them. Highway construction divides our urban areas with ribbons of concrete – separating people from their jobs and from each other, destroying the integrity of communities, and encouraging suburban sprawl and other questionable land uses. As places of urban and suburban employment have become more and more dispersed, with access to them provided only by highways, more and more workers have been forced to rely on cars to get to their jobs. The available highways have in turn become more congested, forcing us to build more and more roads. We have now devoted so much of our urban living and working space to the automobile that up to 60 percent of the land area in our major cities is required for the circulation and servicing of our cars. The New Jersey Planning Department has predicted that within 30 years, transportation will consume one-third of the State's entire land area.
The heedless construction of urban freeways has run roughshod over the real transportation needs of city residents, displacing literally hundreds of thousands of people and businesses in the process.
On one hand, Mr. President, we have expressed our concern over the fate of our cities as places where people can live and work, and we have created programs and spent money to restore the urban environment. But, on the other hand we have forced those same cities to build highways which defeat that objective.
By allowing the cities to build mass transit systems they do need instead of highways they do not need, the Muskie-Baker amendment would restore good faith and good sense to our efforts to save our cities.
Our third concern, Mr. President, is that highways and automobiles which ravage our cities are at the same time helping to lead us to an energy crisis from which there may be no road back. Automobiles are the most wasteful common means of surface transportation; they use 5 times more fuel to transport a person 1 mile than does a bus, and 10 times more than a train or subway. In fact, automobiles effectively utilize only 5 percent of the potential energy from the fuel they burn.
At the current rate, transportation from the fuel they burn could deplete the entire proven Alaskan oil reserves in 7 years. But the Highway Action Coalition has estimated that if the automobile's use in urban areas alone was reduced by merely 25 percent, we could save 1 million barrels of petroleum per day – the equivalent of the full operating capacity of the proposed Trans-Alaska Pipeline. In light of the energy and fuels crisis of which we are all aware, our present extravagance is unacceptable.
On one hand, Mr. President, we have rung the alarm concerning the energy crisis, and we are seeking ways to reduce our fuels consumption and increase our reserves. But on the other hand, our policies have the effect of pressing upon our cities the most wasteful and inefficient form of transportation that exists. The Muskie-Baker amendment would give the cities a choice, and begin to bring our transportation policies in line with our energy concerns.
In light of all these concerns, it is clear that Americans are paying a price for urban highways that we cannot afford. And many Americans who pay the price get nothing in return. For these citizens of urban America, the highway trust fund and the transportation systems it creates rob Peter to pay Paul.
In many American cities – including Baltimore, Milwaukee, Richmond, and Columbia, S.C. – nearly one out of every four dwellings have no car. Fifty-seven percent of households with incomes below $3,000 have no cars; 14 percent of those households reporting incomes between $3,000 and $10,000 have no car. Most of the 20 percent of Americans who have no car are poor, handicapped, young, or old people who need mobility the most to gain access to adequate education, health care, job opportunities, and other necessities of life. The unemployment of at least one-half of the 1 million jobless handicapped is attributable to a lack of adequate transportation. In five Ohio cities, 54 percent of the households whose head is over 65 have no car, and 42 percent of those households reported a need for transportation beyond any available to them.
The Muskie-Baker amendment would help correct these inequities by amending the highway trust fund to make it more flexible and more sensible, to bring it up to date, and to revitalize it as a useful funding mechanism to meet our transportation needs.
In 1956, Mr. President, the job of building the interstate defense highway system was considered to be so big and so urgent that it was decided to provide annual revenues earmarked for that job from a fund with assured revenues. Therefore, the highway trust fund was established to focus revenues raised from highway-related taxes on specific highway purposes for a 16-year period.
The primary purpose of the trust fund was the construction of the Interstate System, and the trust fund was to be terminated at the same time that the Interstate System was completed.
To establish the trust fund, the Congress drew on two sources of revenues: First, receipts from then-existing highway-related taxes, such as the gasoline tax which had been on the books and contributing revenues to the General Treasury since 1932; and second, receipts from new highway-related taxes, such as the tread rubber tax. Prior to 1956, the receipts from those existing highway-related taxes – those in the first group had been in the General Treasury and had been used to fund a broad variety of Federal activities – even including foreign aid.
The Congress directed the receipts from all of these taxes, including those which had been in the General Treasury, to the new trust fund. The importance of the contribution to the trust fund from those existing tax revenues is illustrated by the fact that 92 percent of last year's trust fund receipts were derived from tax categories which had been on the books long before 1956, and which before 1956 had provided general revenue funds.
These General Treasury revenues were diverted in 1956 primarily to serve a specific purpose – building the Interstate System. Now, 80 percent of the Interstate System has been completed.
Certain portions of it planned for urban areas will never be built due to many factors – new environmental regulations, revised local determinations as to transportation needs, and citizen pressure against new highway construction. No one questions that the remainder of the system should be completed as soon as possible.
The question now before us is whether – the original purpose being nearly completed – those General Treasury revenues presently in the trust fund should be applied to a broader purpose. Our responsibility in 1973 is to determine how those revenues should be spent in the future.
One option is to build only more roads, regardless of whether they are wanted or needed.
Certainly with respect to the urban portion of the fund, Mr. President, the choice of that option would perpetuate the most glaring flaw in our transportation policy. It would make us the victims of the trust fund rather than the beneficiaries.
A second option is to return some of the trust funds to the General Treasury and to create a new public transit trust fund. This option has some arguments in its favor; we have identified the need for mass transit funds for our cities, and this approach might help to provide those funds. But the arguments against this course of action are also compelling. This would be an arduous and risky approach; the competition for funds from the General Treasury is severe, and there is little likelihood that sufficient money to create a viable fund could be appropriated. Furthermore, this approach would not give the cities the kind of discretion and flexibility they need. We do not want to force the cities to build subways any more than we want to restrict them to highways. On the contrary, we want to give them the opportunity to build the transportation systems that best meet their needs.
And that, Mr. President, is our third option: Amending the highway trust fund in the manner we propose and thereby giving the cities the opportunity to build the transportation systems they think are best suited to their needs.
In 1965, Congress established this trust fund with General Treasury revenues and identified its primary purpose. The Congress never made that trust fund irrevocable, nor has the Congress ever waived the right to modify its purposes. In fact, the Congress has modified the trust fund's purposes in the past by using money from it for billboard removal and the relocation of junkyards. And this year, S. 502 would authorize trust funds for the relocation of railroad lines in Lincoln, Nebr., Elko, Nev., and Brownsville, Tex. The argument that the trust fund is sacrosanct fails in light of these precedents.
And if the trust fund were sacrosanct, Mr. President, areas of the Nation that do not need or cannot accommodate new highways – our cities, in particular – would not share in the benefits of the fund. That result would not be one that was intended by the Congress that created the trust fund in 1956.
In sum, Mr. President, Congress in 1956 brought together tax revenues from many existing sources and some new ones, and focused them through the highway trust fund on a particular problem of national proportion – building the Interstate Defense Highway System. Solving that problem, more than any other factor, was the primary purpose of the new trust fund.
Now, we are faced with another transportation problem that is national in scope. We have identified the dimensions of the urban transportation problem, and it is clear that those dimensions justify the Muskie-Baker amendment.
No trust will be violated. No money will be wasted. And no transportation project – highways or subways – will be built that does not make sense from the point of view of the people who must live with it.
This amendment will not provide automatically the ingenious new transportation systems we need for our cities, nor quick public acceptance of mass transportation as a substitute for the luxury and convenience of the private automobile. But the flexibility of funding must be our starting point, both to signify our willingness to change and to make it financially possible to do so.
In summary, Mr. President, no comments more eloquently describe the absolute need for flexibility than the statements of three of the Nation's mayors: Mayor Kenneth Gibson of Newark; Mayor Wes Uhlman of Seattle; and Mayor John Lindsay of New York.
I ask unanimous consent that their letters and accompanying material be inserted in the RECORD following my remarks.
There being no objection, the material was ordered to be printed in the RECORD, as follows
FEBRUARY 26, 1973.
Hon. EDMUND S. MUSKIE,
U.S. Senate,
Washington, D.C.
DEAR ED: I have read with great interest your recent letter and attached proposed amendments to the pending extension of the Federal Aid Highway Act. I enthusiastically endorse and support your efforts to open up the trust fund for public transportation and increase the Urban System funding to $1-billion.
As you may know, Manuel Carballo, my First Deputy Transportation Administrator, recently appeared before the Roads Subcommittee of the Senate Committee on Public Works. On behalf of New York City and the National League of Cities-U.S. Conference of Mayors, he urged that Urban System monies be made available for rail as well as surface transit at the discretion of the localities. I am attaching a copy of his statement which represents my position on the pending legislation.
Ideally, we would prefer the creation of a general transportation trust fund. However, if such a fund were funded inadequately and thus failed to meet the cities' total mass transit and highway needs, we would be no better off than at present. Therefore, we urge that the Congress recognize the need for localities to be able to exercise discretion in the use of funds sufficient to meet their particular needs. New York City, for example, needs $132-million in FY 1974 alone if we are to do an adequate job in maintaining and rebuilding our street system. However, the best estimate of what we would receive under S. 502 is approximately $50-million, including the State matching share.
Our mass transit needs are even more staggering. We estimate our needs through FY 1977 at $2.3-billion, while we can expect to receive, at best, only $300-million over this same period from the $3-billion increase in UMTA contract authority proposed under S. 386.
Other aspects of the pending highway bill require attention. I urge that the distribution formula be based on "urbanized" rather than "urban" areas. The appendix to Mr. Carballo's statement explains in great detail the difficulties inherent in the distribution formulas as provided under S. 502.
I also ask the Congress to provide a guaranteed passthrough of Urban System funds to municipalities over 250,000; S. 502 provides such a guarantee only to "urbanized areas" of that size.
Further, I support your proposal to authorize the Secretary of Transportation to utilize up to 10% of annual trust fund revenues to provide "emergency" assistance for alternate transportation systems where pollution from autos is certified as a threat to safety. Assuming the opening of the trust fund for mass transit, this provision would enable cities like New York to use such funds in a rational way in order to improve air quality levels. In addition, I agree with the purpose of Section 1 of this amendment which requires the Secretary to withdraw approval of routes on the Interstate, Primary and Secondary Systems in areas where federal EPA finds pollution levels unsafe after 1975 and where the Governor and local governments jointly request such withdrawal.
This section, however, raises the same problem that we found with the guaranteed passthrough to "urbanized areas." A municipality of New York's size which seeks withdrawal of certain routes that run through its jurisdiction may be subject to the determinations made by other municipalities or local areas within its urbanized area through which such routes also run. I suggest this amendment be clarified to provide that municipalities over 250,000 be empowered to request withdrawal of urban routes jointly with the Governor of the State, and not be subject to veto by other member units of its urbanized area.
In addition, I support Section 3 of this amendment which empowers the Secretary to refuse approval of any new highway construction which federal EPA certifies will make the air unsafe under the Clear Air Act.
Finally, I endorse the amendment to the Highway Safety Act which establishes State-run programs for inspection of auto emission control systems.
I think the changes you have suggested will benefit the nation's cities as well as its suburban and rural neighbors. I am pleased to be able to endorse these amendments and urge your support for our proposal for a guaranteed passthrough of Urban System funds to municipalities over 250,000.
My Administration will continue to press strongly for these changes in order to achieve a truly balanced national transportation system. Please feel free to call on me or members of my Administration if we can be of further assistance.
Sincerely,
John V. Lindsay, Mayor.
STATEMENT BY MANUEL CARBALLO
Mr. Chairman, members of the Committee, I am Manuel Carballo, the First Deputy Transportation Administrator and Commissioner of Highways of the City of New York. I am also a member of the Transportation Steering Committee of the National League of Cities and am pleased to come before you today in behalf of the League, the United States Conference of Mayors, and Mayor Lindsay to discuss the pending extension of the Federal-Aid Highway Act, S. 502.
Consideration of this bill is of critical importance at this time, not only because of. the considerable benefits that have resulted throughout the country under the 16-year-old federal Highway Trust Fund program, but also because of the distortions and imbalances that have resulted in a time of rapidly changing transportation needs.
At its best, the range of programs fostered under the Highway Trust Fund have a track record matched in impact and efficiency by few other Federal programs: high concentrations of funds, generated by a simple and equitable tax structure, and expended directly and efficiently to create a nation-wide highway system in a relatively short period of time.
But at its worst, the structure of these programs has tended to create distortions that must be corrected. Traffic congestion chokes many of our highways as mass transit needs have gone unmet. Auto exhaust fouls our air. Urban areas have received a share of the Highway Trust Fund which does not begin to reflect their population, need, or importance to the nation.
Both the mood of the country and the mood of the Congress appear to reflect the realization that this must be the year that the thrust of the federal highway program is re-examined – and rightly so. Our task, then, is to sustain the best elements of the highway program – its efficiency and high concentration of funds – while re-directing its thrust to correct many of the imbalances that it has partly helped to create.
Clearly, the construction of a fast, safe and efficient Interstate System was a necessary and admirable objective and one we have essentially achieved. There is considerable doubt whether this objective would have been achieved had not a Highway Trust Fund been established to finance it. On the other hand, there is also considerable doubt whether the imbalance in our transportation system would exist to the extent it does if mass transit had gotten its fair share of the huge investment of federal dollars over the years and if the cities had had discretion over the use of such funds.
Although it is late, there is certainly time to focus our energies and our resources in bringing our transportation systems into balance. Clearly this means increased funding for mass transit.
To do otherwise threatens the very viability of urban areas. This is not a partisan issue. We can no longer afford to be highway advocates or mass transit advocates. We can only be "balanced transportation" advocates. Failure to redress the current imbalance in our transportation system benefits no one.
Today, new conditions dictate that cities must have greater flexibility with federal assistance programs than now available to enable them to address their particular conditions and priorities.
It is the position of the City of New York, for example, that the best way to correct this imbalance is through the establishment of a General Transportation Fund. Our objective is to provide flexibility for localities regarding the use and distribution of such funds. Who, other than the localities, knows better what the needs are? In some cases this would mean priority for construction of highways; in others, the funds would be allocated for mass transit – subways, buses, people movers.
However, what we have before us today is not legislation to create such a fund but a highway bill.
We do, of course, strongly support the progressive step this Committee has already taken in broadening the uses of Urban System funds to include bus purchases. But the National League of Cities and United States Conference of Mayors urge you to go further and allow rail transit uses as well. Cities must have the ability to choose a mixture of highways, buses, and rail systems to meet their own local conditions. In furtherance of this policy, we most strongly urge S. 502 be amended to allow Urban System funding for rail projects, as well as for buses. This flexibility for local governments in planning and building a balanced transportation program is especially important in the face of limited availability of both highway and mass transit funds.
At the funding level proposed in this bill, however, many cities would be hard pressed to meet even their minimal highway needs, much less make a significant investment in mass transit – NYC is a case in point.
For this reason, it is essential that the urban systems authorization be raised to a level that would allow these cities to take advantage of this flexibility and meet their basic transportation needs.
The highway bill before us today, while providing more funds to urban areas than currently available falls far short of the cities' highway needs, particularly since the TOPICS program is now also to be funded from this source. In my own City, for example, our highway needs amount to $132 million in FY 1974 while the best estimate of what NYC can expect to receive under the bill is approximately $50 million (which includes the State matching share).
Similarly, urban mass transit needs are even more desperately under-funded.
As a representative of the National League of Cities and United States Conference of Mayors and the City of New York, I find it impossible to talk about a highway bill without, at least in the first instance, also discussing the Urban Mass Transportation Act and its relation to S. 502.On February 6, testifying on behalf of the National League of Cities and United States Conference of Mayors before your colleagues on the Senate Banking, Housing and Urban Affairs Committee, I strongly endorsed S. 386 which increases UMTA contract authority by$3 billion through FY 1977, and would include an additional $800 million in operating subsidies over two years. I reiterate that support there today.
But it must be observed that even that noteworthy legislation fails to provide sufficient increases in capital funds to meet the mass transit needs of our nation's cities. Nowhere is this fact more evident than in my own City of New York. While our mass transit needs through FY1977 are in excess of $2.3 billion, we can expect to receive at best only $360 million over this same period out of the proposed $3 billion increase in UMTA contract authority. In the face of these kinds of shortages in funds for both urban highway and mass transit programs, it is even more essential that the authorization level for urban systems in S. 502 be increased and that the permissible uses for these funds be broadened to allow localities the option of choosing among highway and mass transit priorities. I would again stress that cities would not be choosing highways or mass transit, but their proper mixture of each.
Accordingly, the National League of Cities and United States Conference of Mayors call for a funding level of $1.5 billion annually for the urban transportation system. The Committee has proposed $650 million for the Urban System and $350 million for Urban Extensions. Secretary Brinegar has testified that the Administration will request $1.1 billion for the urban system in FY 74, then rising to $1.2 billion in FY 75 and to $1.35 billion in FY 76. We commend this strong commitment for urban transportation needs, particularly when the Administration's budget for FY 74 proposes only $800 million for urban system authorization in FY 74. However, we feel that this is not enough. Funds will be available as the nation's current priority, the Interstate System, is completed and the new priority of urban transportation needs is begun to be met.
Let us now look more closely at the specifics of the bill pending before us today. We of course applaud the opening of the Trust Fund for bus purchases, the increase in local control over route designation, urban transportation planning funds, Interstate transfer, the concept of a guaranteed "passthrough" and the increased funding for Urban Systems over current authorizations.
In several significant ways, however, we think that this legislation represents a retreat from the excellent bill reported favorably out of this committee last year.
You will recall that last year's bill, S. 3939, authorized $800 million for Urban Systems and an additional $50 million for a newly-created "Small Urban" System. Even that authorization level fell far short of meeting the pressing transportation needs of our urban areas – indeed we have called for a minimum commitment of $1.5 billion this year for the urban transportation system.
But instead, we regret that the bill we are considering merges the Urban and Small Urban System and cuts the total Urban System authorization level by $200 million at a time when urban transportation systems are dangerously under-funded throughout the nation.
S. 502 would redefine the eligible recipients of Urban System money. Funds would be used for projects in any "urban" area, a municipality or place of 5,000 population or more, rather than the present "urbanized" area, an area with a central city of 50,000 or more. Senator Bentsen stated that this change was made in lieu of creating the "Small Urban System"' in last year's bill and thereby adding another categorical grant. We agree with his concern over proliferating grant-in- aid programs. But we question if expanding the Urban System at this time will be the answer. We also feel earmarking $50 million for small urban systems of the $650 million urban system authorizations, is impossible to administer. We urge retention of the Urban System as a program for urbanized areas. Urbanized areas already have been developing their programs for Urban System projects. Many already have the institutional structures for planning and implementing a transportation program and relating it to other areawide concerns. Urbanized and metropolitan areas are the criteria for eligibility in numerous federal programs. Transportation needs are most acute in urbanized areas, having been deferred for other, non-urban priorities. To suddenly place smaller urban areas into the existing Urban System could cause major disruptions in program administration and funding of current and planned projects.
This is not to say that smaller urban areas do not have their own priority needs. Expansion of eligible uses of Primary and Secondary System funds for public transportation to apply to small urban areas may be the preferable alternative. Or the Committee may create a "small urban system" within the existing rural Primary and Secondary programs.
We thus propose the allocation formulas and "passthrough" mechanisms provided in the bill be modified. The bill provides that states shall receive Urban Systems funds based upon their share of the national "urban" population. Within the states, the formulas for distribution become unclear. Urbanized areas over 250,000 are guaranteed a minimum "passthrough," although Sec. 125, relating to those funds "attributable" to such urbanized areas, fails to clearly define "attributable." Consequently, it is difficult to ascertain the intent of the legislation. Our assumption is that the intent is to guarantee funds to urbanized areas over 250,000 in direct proportion of its share of its state's "urban" population (a highly difficult and confusing calculation to make, since almost 15% of the nation's "urbanized" population is non-"urban." This dilemma is discussed in the appendix to this testimony.) Such funds would be dispensed by a regional transportation agency, or in its absence, the State.
We would recommend several major changes with respect to these provisions: First, as proposed in last year's bill, that funds be distributed to the states on the basis of their urbanized population; and within the states, allocations be made on the same basis. This provides a consistent distribution formula that meet transportation needs throughout the nation. (See Appendix B for more detailed analysis).
Second, I would like to reiterate that the policies of the National League of Cities and United States Conference of Mayors, although supportive of a mandatory passthrough to urbanized areas, do not allow our support for the proposed restriction of passthrough authority of Urban System funds to areas of over 250,000. The League and the Conference are on record that funds should be allocated to all urbanized areas, the only restriction being their capacity to plan and implement projects on the Urban System.
The City of New York agrees with the concept of a guaranteed passthrough. It also agrees with the National League of Cities and United States Conference of Mayors that the provisions of S. 502 creating such a guaranteed passthrough are unacceptable and unworkable. The City of New York differs, however, with the NLC and USCM as to the nature of the changes that need to be made in the bill before us. I have appended to my statement New York City's position on passthrough eligibility.
Other aspects of the bill require attention. We suggest that funds for planning under the Urban System be borne totally by the federal government, consistent with current planning funding on the Interstate System.
To limit red tape in the grant approval process, DOT should limit review of technical details of projects, and allow state and local agencies to certify that such federal standards as are necessary have been complied with. The new Chapter 1-A, Alternative Federal-Aid Highway Procedures, proposed in S. 502, addresses this red tape problem. However, it should not be a device for the states and their highway departments to by-pass the increased local control over Urban System projects that would be effected if S. 502 passed. The procedural and substantive gains and safeguards in present law, and as proposed in S. 502, must be preserved. They must be made explicitly applicable to any alternative procedures available to the states.
I would urge the members of the committee to review technical amendments and analysis submitted in the appendix.
Conclusion: Criteria for a Balanced Transportation Program.
The transportation needs of American's urban areas are indeed great. What kind of a balanced national program then do we require in order to begin to meet these needs?
We have thought a great deal about this question in the City of New York and we have consulted with officials of other cities at great length through our participation in the National League of Cities and United States Conference of Mayors.
Our position – which is supported by a great number of my colleagues across the country, through their national organizations on whose behalf we appear, and is embodied in the recommendations I have made today – is that Federal-Aid Highway legislation aimed at creation of a balanced transportation system should meet at least the following minimum criteria:
1. Increased funding for urban transportation systems, giving proper weight to the mass transit and highway needs of urban areas, thereby correcting the present severe imbalance.
2. Flexible funding, providing state and local officials with the flexible use of Urban System funds to meet transportation needs as determined at the local level.
3. Adequate and assured levels of funding for urbanized areas. Local officials in these areas must be assured of an adequate level of funding by direct passthrough of funds attributable to the populations of these areas.
I ask the members of this Committee to consider the criteria and recommendations proposed today in making critical decisions that will affect the future of our nation's transportation system. The bill before you represents the first tentative step in this direction. Your approval of the changes we suggest would take us further toward the goal of a truly balanced national transportation system.
APPENDIX A – SUPPLEMENTAL VIEWS, CITY OF NEW YORK
As outlined in the accompanied testimony, and for reasons explored more fully in Appendix B, the City of New York joins the NLC/USCM in urging this committee to return to the basic structure for state allocation and "passthrough" or urban system funds which was contained in the excellent highway bill (S. 3939) which passed the Senate last year. These provisions would allocate to each state its share of Urban Systems funds based on its proportion of the nation's urbanized population, and to urbanized areas within the state on the same basis. The transportation needs of small urban areas (between 5,000 and 50,000 in population) not contained within urbanized areas would be met through a separate mechanism so as to avoid the irresolvable complications which arise in any attempt to merge the "urban" and "urbanized" concepts.
Even if such a change is made in S. 502, however, the "passthrough" provision assuring each urbanized area its fair share of the state's urban system funds provides very little added protection to large cities such as New York. The New York City Urbanized Area, for example, contains about 11.4 million persons, approximately 80% of the state's urbanized population. As a result, 80% of the state's urban systems funds would be "passed through" in one huge lump sum earmarked for the urbanized area, with no assurance or indication of how these funds are to be allocated within the area. New York City, with approximately 70% of the population of the urbanized area, would have no basis with which to undertake long range planning for the use of the funds which are eventually to be made available.
We propose, therefore, that Sec. 125 of this bill be amended to provide a guaranteed passthrough to legally-constituted municipalities over 250,000 persons, reflecting its share of the urbanized population. It is our position that municipalities of this size, which often constitute the central cities of urbanized areas, be assured of the funds otherwise guaranteed to their urban and suburban neighbors under S. 502. Clearly, if the case is made for guaranteed funds to large "urbanized areas", the arguments are even stronger for guaranteeing such funds to equally large, single municipalities. Funds would flow directly from the federal government to each such municipality in proportion to its share of the urbanized population.
To deny a guaranteed passthrough to such municipalities, which presently have the capacity to plan and implement improvements on existing street, highway, and mass transit systems, effectively robs those municipalities of the opportunity and resources to undertake rational, long-
range planning. To turn this responsibility over to the States or regional authorities actually takes away functions performed capably by these cities. If "home rule" means anything, it means control of a municipality's own streets and subway systems.
Essentially, we view this as a three-staged program. First, those cities over 250,000 should be provided a guaranteed passthrough immediately. Second, cities under 250,000 within urbanized areas, should receive funds through the mechanisms provided in the legislation, that is, through a metropolitan transportation agency, or in its absence, through the state. Thirdly, we propose that when such cities develop the capacity to plan and implement programs under the Urban System, they, too, should be guaranteed a passthrough of funds in direct proportion to their share of the urbanized population of the state.
APPENDIX B – ANALYSIS OF STATE ALLOCATIONS AND "PASSTHROUGH" FORMULAS IN S. 3939 (1972) AND S. 502 (1973)
Last year's highway bill, S. 3939, would have distributed Urban Systems funds to each state based on its urbanized population, and would have assured each urbanized area within a state its fair share based on population. Recognizing that 20% of the nation's "urban" population lies outside urbanized areas, the bill further sought to assist these smaller communities with a new separate "Small Urban" system, more closely tailored to the needs of these communities (i.e., municipalities between 5,000 and 50,000 in population not lying within an urbanized area).
The bill before us this year, however, S. 502, apparently seeks to merge these two systems (Urban and Small Urban) by changing the allocation formula to an "urban" basis, while maintaining a passthrough provision for a portion of the funds to major urbanized areas. A careful analysis of the distinctions between the meaning of "urban" and "urbanized" areas, as used in this bill, would appear to suggest that such a merger cannot be accomplished with a single allocation and distribution formula that bears any rational resemblance to sensible federal policy. The inconsistencies which appear in S. 502 and which, in fact, are inherent in any attempt to mix the urban and urbanized criteria for allocation and passthrough are discussed in considerable detail below.
I. DEFINITIONS
A. Section 106(c) of the bill defines an "urbanized area" as "an area so designated by the Bureau of the Census, within boundaries to be fixed by the Secretary in cooperation with responsible State and Local officials" (amending the existing definition in § 101 (a) of title 23, U.S.C., which now simply reads: "an area so designated by the Bureau of the Census"). While the role of the Secretary vis-a-vis the Census Bureau is not clarified precisely with respect to the setting of these boundaries, this provision would presumably enable him to assure that each "urbanized area" designated for the purpose of receiving urban systems funds would lie within the boundaries of no more than one state. Note, for example, that the "urbanized area" designated by the Census Bureau for New York City is the "New York, N.Y.-Northeastern N.J." Urbanized Area, crossing state lines and including approximately 16.2 million persons: 1.8 million in Northeastern N.J., and 11.4 million in New York City and its in-state surrounding suburbs. Most likely, the N.Y.C. urbanized area will be designated as the portion of that area lying within New York State, namely: all of New York City, plus parts of Nassau, Suffolk, Westchester, Rockland and Putnam Counties, containing a population of 11,369,576 (7,894,862 of which are located in N.Y.C.). But it is difficult to determine with certainty exactly what the New York City urbanized area is for the purpose of this bill, what communities it covers and how many people it contains, unless and until either Congress or the Secretary acts to clarify it.
B. The Census Bureau's designated "urbanized areas" generally contain at least one city of 60,000 inhabitants (or "twin cities" totalling 50,000 in population), but also include surrounding territory which meets specified criteria relating to population density and proximity (regardless of size), and thus often contain nearby towns or unincorporated places with population under 5,000. As a result, the population living in "urbanized areas" (50,000+ in population, and as designated by the Census Bureau and DOT) is not necessarily a subset of the population living in "urban areas" (which title 23 simply defines as municipalities over 5,000 in population). In fact, the two categories simply do not mix:
All cities greater than 50,000 in population are both "urban" and "urbanized."
All cities between 5,000 and 50,000 in population are "urban", but may or may not be part of an "urbanized area", depending on their population density and proximity to a larger city.
No town, city or other place smaller than 5,000 is "urban", but some still may be part of an "urbanized area", again depending on their density and proximity to a 50,000+ city.
As a result, Census figures show that 4.7% of the nation's "urbanized" population resides in unincorporated places or communities smaller than 5,000 (i.e., non-"urban"); and that 19.4% of the nation's "urban" population is located outside "urbanized areas."
II. APPORTIONMENT TO STATES
Section 113(b) of the bill amends the existing apportionment formula for urban systems funds (§ 104(b) (6) of title 23 U.S.C.) by distributing funds to each state according to its proportion of the national "urban" population, rather than the national "urbanized" population. This change in the apportionment formula seriously complicates the "passthrough" provision which has been included in the legislation to assure that local communities get their fair share of each state's allotments.
III. PASS-THROUGH TO LOCAL COMMUNITIES
A. The existing law allows the State (Highway Department) complete discretion as to how to allocate its Urban Systems funds within the state. The 1972 bill, S. 3939, sought to remedy this by requiring that each urbanized area within a state be allocated its share of the state's urban systems funds in proportion to its share of the State's urbanized population. This was entirely consistent with the apportionment formula, which also distributed the funds to states according to each one's share of the national urbanized population. For example, under this formula, the New York City urbanized area, with 79.7% of the state's urbanized population, would receive 79.7% of the State's urban system funds. The other 6 urbanized areas in New York State, with a total of 20.3% of the states' urbanized population, would divide the balance – each receiving a share in proportion to its population not lying in an urbanized area would have received separate allotments under the Small Urban System.
Section 125(a) of this year's bill (S. 502), however, attempts to keep a passthrough provision based on "urbanized areas" in spite of the change in the apportionment formula from "urbanized" to "urban." This introduces considerable confusion and it is not clear precisely what the legislation was intended to achieve. Sec. 125 (a) would set aside for passthrough that portion of each state's urban systems allotment which is "attributable to urbanized areas having a population of 250,000 or more." In New York State, this would include the N.Y.C. urbanized area (population 11.37 million) and four upstate urbanized areas (with a total population of 2.55 million). The combined population of these five major urbanized areas is 13,920,255– 234,107 greater than the total "urban" population of the State. One can only determine, therefore, the portion of the state's urban systems funds "attributable" to these major urbanized areas by subtracting out the approximately 1.5 million persons who are part of the "urbanized" population but do not live in cities of 5,000 or more (i.e., "urban'').
The passthrough formula in Sec. 125 (a) would then allocate these funds among these major urbanized areas in proportion to their complete population (presumably including the localities which were subtracted out for the purposes of determining the amount "attributable").
Note further that, as drafted, Section 125 (a) would not fully allocate all the funds set aside for passthrough as "attributable" to these major urbanized areas. The bill currently reads: the funds "which are attributable to urbanized areas having a population of 250,000 or more shall be allocated among such urbanized areas within any such State in the ratio that the population within any such urbanized area bears to the population of all urbanized areas within such State." (emphasis added). As drafted, the allocation fractions would include the population of all "such urbanized" areas (namely 250,000+) in the numerators, and "all" urbanized areas (including those between 50-250,000 in size) in the denominators, thus adding up to a total of less than one. The word "such" should be inserted before the last "urbanized" in the sentence, if the allocation is going to be complete.
Even if the word "such" is inserted as recommended above, however, this committee must still consider the over-all unworkability of an allocation mechanism within each state ("urbanized") which is inconsistent with the apportionment mechanism for funds to each state ("urban"). For as the bill is currently drafted, Urban System funds would be apportioned to states in a fashion which disregards their "urbanized" population, and then part of these funds would be allocated within the states to major urbanized areas, almost 15 % of whose residents do not live in "urban" areas and thus played no part in earning Urban System funds for the state in the first place.
It is on this basis that the term "attributable", as it appears in Sec. 125(a) of the bill becomes difficult and confusing to define. For if the non-"urban" portion of urbanized areas are subtracted out for the purposes of "attribution", it makes little sense to include them as recipients of Urban System funds. And if they are barred the use of the funds (lest the fair share of other cities in the urbanized areas be diluted), it makes little sense to allocate the funds by urbanized area.
The only solution would thus appear to be a consistent formula for both state apportionment and local passthrough. In this way, if Congress elects to retain an apportionment formula which grants urban systems funds to states according to their urban population, then funds should also be allocated to urban areas within each state (with a guaranteed passthrough to large cities and State direction regarding the balance). And if Congress prefers to allocate the funds to urbanized areas within the states, then the apportionment formula for the distribution of funds to the states should be changed accordingly.
B. Insofar as S. 502 retains a passthrough formula based on "urbanized" rather than "urban" areas, another problem develops, for cities such as New York, as noted in Appendix A. The City's population is 7,894,862, or 69.4 of the population of the urbanized area. But the proposed legislation contains no provision assuring that the City will receive an equivalent share of the funds allocated to the urbanized area. The bill does provide (as did last year's S. 3939) that where there exists a suitable metropolitan transportation agency for the urbanized area (to be created by the State), the funds would be made directly available to such an agency. No such agency currently exists for the N.Y.C. urbanized area, however, and pending its creation, all decisions regarding the dispersal of funds within the urbanized area would be made by the State Highway Department under existing law and S. 502.
This dilemma will become particularly striking when and if the Muskie-Baker provision opening up Urban Systems funds for possible mass transit use is passed into law. In such circumstances, the State Highway Department would be in the position of deciding, for example, what portion of the N.Y.C. urbanized area funds (earmarked for passthrough under § 125 (a)) would go for N.Y.C. subways vis-a-vis suburban highways.
For this reason, we strongly urge Congress to consider some kind of provision to assure that within an urbanized area, any municipality larger than (e.g.) 250,000 in population be assured of funds in proportion to its share of the population of the urbanized area.
Alternatively, the problem could be solved by changing the passthrough provision in § 125 (a) to an "urban" basis rather than "urbanized." That is, allocate a proportional share by population to every municipality larger than (e.g.) 50,000 or 250,000 rather than to every urbanized area of that size.
In either case, a metropolitan transportation agency could still be created to distribute the balance of the funds in the urbanized area and to coordinate planning and construction throughout the metropolitan area. These suggested provisions would merely assure that the large central cities would receive their "fair" share based on population out of the funds made available to such an agency; and prior to the creation of such an agency, it would allow major cities to undertake rational long-range planning with some assurance of the amount of urban systems funds to be made available by the State.
In summary, then, we recommend the following specific changes in S. 502 with respect to the apportionment and allocation of Urban Systems funds.
1. Sec. 106(c) – clarify the breadth of authority being granted to the Secretary to alter the Census Bureau's designation of an "urbanized area", particularly with respect to multi-state urbanized areas, e.g. "New York, N.Y: Northeastern N.J."
2. Adopt an allocation formula within each state (Sec. 125(a)) consistent with the apportionment formula to each state (Sec. 113(b)) preferably by returning to an "urbanized" basis for both sections, as in last year's S. 3939.
3. If Sec. 125 (a) is to be retained in S. 502, clarify the definition of the term "attributable" (if this is possible!) and add the word "such" before the last "urbanized" In the first substantive paragraph.
4. Add a new provision guaranteeing a direct passthrough to cities larger than 250,000 in population.
MARCH 5, 1973.
Hon. EDMUND S. MUSKIE,
Chairman,
Subcommittee on Air and Water Pollution,
U.S. Senate,
Washington, D.C.
DEAR SENATOR MUSKIE: I am pleased to forward, with this letter, my statement in support of the amendments which you have proposed to the Federal-Aid Highway Act. We believe that the passage of these amendments will be of invaluable assistance to urban areas such as Newark which presently suffer from disproportionate transportation funding.
I understand that your amendments, although defeated in committee, will be brought up for consideration on the Senate floor later this week. I am forwarding copies of my statement to Senators Williams and Case and hope that it will be of assistance to you in the days ahead.
Sincerely,
KENNETH A. GIBSON,
Mayor.
STATEMENT BY KENNETH A. GIBSON
The proliferating usage of the automobile within the last two decades has had a drastic effect upon urban areas. The quality of air, and the economic stability of many urban areas, has been dramatically altered. Such effects are a direct manifestation based on the funding priorities given to highways at the expense of mass transportation. This disproportionate ratio must be reversed if the basic problems resulting are to be alleviated.
The passage of the Clean Air Act in 1970 served notice of this Nation's commitment to the preservation of air quality consistent with health requirements. The Act recognized the deteriorating quality of air associated with the increased advances of technology and stipulates the need for redress with the coming decade.
Unfortunately, until additional measures are taken by Congress, the standards it has prescribed through the Clean Air Act will not be met in most urban areas throughout the country. Air pollution is presently most concentrated in cities, due, in large measure, to the significant number of automobiles entering during the daily working hours. 95% of all carbon monoxide and 67% of all hydrocarbon are generated by this excessive use of automobiles.
As outlined in the New Jersey State Implementation Plan to meet the standards of the Clean Air Act for example, the City of Newark currently has the highest carbon monoxide level in this air quality region, as well as one of the highest hydrocarbon levels. These levels are consistently in violation of standards set forth in the Clean Air Act.
During the year 1971, the standard for carbon monoxide over an eight hour maximum period was exceeded one-hundred and fifty-six times, at a level nearly three times as high as that permitted within the Clean Air Act. During this same year, the standard for hydrocarbons during the three hour period, 6:00 a.m: 9:00 a.m. was exceeded three hundred and twenty-two times during that year.
The effect from prolonged exposure to carbon monoxide and hydrocarbons is already too well known. Long term exposure to carbon monoxide has resulted in a shortening in life span as well as permanent brain damage due to a shortage of oxygen to red blood cells. Exposure to hydrocarbons, in the presence of other chemicals, has resulted in damage to lung tissues.
Proximity to highways has also resulted in adverse health conditions for those residents who cannot afford to move away. Within fifty feet of a freeway, the air quality level is in excess of maximum standards. Within one hundred and twenty feet of roadways, the air quality level can cause dullness of thought. Within one hundred and fifteen feet of depressed freeways, the levels of noise present create an environment unsuitable for living.
Unfortunately, it is the urban poor, already victims of inadequate medical attention, who must be confronted by such situations daily. The realization that the effects from prolonged exposures are cumulative and synergistic in the presence of other poor sanitary and health conditions, has made the question of alleviation paramount.
The emergence of the automobile as the most viable means of transportation in recent years is due in large measure to the funding priorities of Congress towards transportation. From 1947- 1970, $58 billion has been authorized towards construction, improvement, and maintenance of highways. At the same time, only $795 million have been spent for urban mass transportation.
The urban poor bear most of the costs of this disproportionate expenditure while receiving few, if any, of the benefits. Their economic stability is threatened by highway construction. Low income neighborhoods become target areas for new highways due to the low cost of land acquisition and demolition. Moreover, the homes that remain in the close proximity to the highways suffer a decrease in market value, often by as much as 25%.
The City of Newark welcomes the amendments to the Highway Trust Act as put forth by Senator Muskie. We view these amendments as potential acknowledgment by Congress of the need for a balanced transportation system to alleviate the conditions outlined above.
By permitting cities such as Newark the option of applying highway trust fund money towards mass transit, the grave problems outlined above can slowly be overcome. Without such funds, the re-ordering of transportation priorities cannot be done and air quality standards cannot be met in accordance with the law. Until this does happen, however, the problems inherent in the present transportation system will be only further exacerbated.
MARCH 2, 1973.
Hon. EDMUND S. MUSKIE,
Old Senate Office Building,
Washington, D.C.
DEAR ED: Thank you for forwarding me a copy of your remarks on introduction of Senate Bills 738 and 739. As always, you have thoughtfully addressed yourself to a problem of great concern to the City of Seattle.
We are presently in the process of attempting to devise a plan to reduce automobile-caused pollutants. I am enclosing a copy of the plan as it was initially developed for a 1977 target date.
In response to the recent D.C. Circuit Court decision, we are now developing a new plan to meet the 1975 target.
Your proposed amendments are right to the point. In developing our plans, we have learned that it is not technology or will which stands in the way of achieving clean air, but rather it is a lack of dollars and unwillingness on the part of the state and the surrounding suburbs to cooperate with the central city in solving the problem.
Let me give you two examples. First, the people of King county recently voted to impose upon themselves a tax in order to finance a regional bus transportation network. The Legislature had previously committed to match bus system revenues from the state general fund. In the Governor's 1973 budget this matching fund was so severely limited that the bus system will not be able to provide an alternative to the automobile travel. Second, we find that any effort to significantly restrict automobile use in the CBD may drive businesses and retail stores into suburban areas where automobile use would not be restricted. This would only contribute to urban sprawl and a general increase in dependence on the automobile. Unless there is a general tightening down on automobile use throughout the entire Metropolitan area and alternative modes of transportation provided, we cannot win the battle.
Your proposals will go a long way toward providing the funds necessary to develop alternative means of transportation. They will insure that freeways which serve the suburbs will not be constructed which are destructive of the efforts to attain clean air in the central city. And, they will provide the means for reducing pollution at the source. I want to you to know that your proposals have my complete support.
Sincerely yours,
WES UHLMAN, Mayor.
[The City Council of the City of Seattle, 1101 Seattle Municipal Building]
NOTICE OF HEARING: IMPLEMENTATION OF NATIONAL AIR QUALITY STANDARDS
You are hereby notified that a joint hearing, conducted by the City Council of the City of Seattle and the State of Washington Department of Ecology, will be held on Thursday, February 8, 1973, at 7:30 p.m. in Room 1101, Seattle Municipal Building, 600 4th Avenue, Seattle, Washington, at which time there will be considered the selection of transportation control measures, which are proposed for inclusion in the Washington State plan for the implementation, maintenance and enforcement of primary and secondary ambient air quality standards, pursuant to the Federal Clean Air Act (42 U.S.C. 1856 et seq.). The measures to be discussed comprise a proposed plan for the reduction of carbon monoxide in the Seattle area.
After the City and the Department of Ecology have introduced a proposed plan, including a proposed timetable for implementation, together with evidence that supports the adoption of the plan, any person may introduce, either in person or by counsel, evidence, statements or counterproposals bearing upon the reasonableness of the proposed plan.
Written statements, maps, charts and other exhibits submitted in connection with the proposed plan or any counterproposal, as well as all statements taken down by a stenographer during the hearing, will become a permanent part of the hearing record.
Written statements, maps, charts and other exhibits regarding this matter may also be submitted to the Seattle City Council and the Department of Ecology at Room 1101, Seattle Municipal Building, prior to the close of the public hearing and will be made part of the permanent hearing record.
The proposed plan, together with all other information pertinent to the aforesaid proposal, is available for public inspection and copying at the Office of the City Engineer, Room 708, Seattle Municipal Building, Monday through Friday, 8:00 A.M. to 4:30 P.M. Questions and discussion relating to this project should be directed to Joe MacKechnie at the location and between the times stated above.
It is the purpose of this notice and of the hearing which it announces to provide for the fullest exchange of information and views, regarding the effect of this plan on the community, through full discussion and examination of the planning to date. This purpose is in consonance with the requirements for the preparation, adoption and submittal of implementation plans under Section 110 of the Federal Clean Air Act, as amended (42 U.S.C. 1856 et seq.) and as provided in the Code of Federal Regulations (40 C.F.R., Part 51).
JOHN A. BIGGS,
Director, Department of Ecology.
FOREWORD
This Addendum to the Washington State Air Quality Implementation Plan (transportation elements) has two objectives. First, it is designed to enable the lay reader to acquire a general understanding about air pollution in order to make a better evaluation of the strategies eventually selected and to better enable the citizen to participate in the public hearing process. Second, it presents a plan for the reduction of air pollution emissions from transportation sources in Seattle. The reader is reminded that it is his primary duty to be critical of the ability of the plan to achieve this objective.
Evaluation and critiques of the plan may be presented to the City Council and the Department of Ecology in writing prior to February 8, 1973, or in person at a public hearing on that date.
The principal authors of this document have been Joe MacKechnie of the Seattle Engineering Department and Mike Ruby of the Department of Community Development. Others making substantial contributions to the drafting of this document have been John Raymond of the Department of Ecology, Jim Pearson of the Puget Sound Air Pollution Control Agency, Bill Popp of the Puget Sound Governmental Conference, and Douglas Howell of the Seattle Engineering Department. Special assistance in the preparation of the plan was given by William van Gelder and Kirk Jones of the Engineering Department and by Mike McNamara, Ron Shoemaker, Claudia Denney, and Arne Hagen of the Department of Community Development.
A critical role in the development of the plan was played by the Seattle Chamber of Commerce Clean Air Task Force, which was chaired by James H. Todd. This committee, a mix of businessmen and environmentalists, outlined the strategies that are herein presented. Assistance in the development of the plan was also given by Mrs. Janet Chalupnik of the Air Quality Coalition, Don Hoffman of the Washington State Highway Department, B'Young Ahn of King County, Henry Soderlund (METRO), and Dan Barash of Seattle's Office of Executive Policy.
DRAFT ENVIRONMENTAL IMPACT STATEMENT
This Addendum to the Washington State Air Quality Implementation Plan is clearly a "major action significantly affecting the environment." Accordingly, the State Environmental Policy Act (RCW 43.21c) requires that a Draft Environmental Statement be developed and circulated to solicit comments on the proposed action.
Any such Draft Statement would only repeat the material contained herein. Therefore, this document is designated as its own Draft Environmental Impact Statement. The sections normally set forth in such a statement may be found as follows:
1. The Impact of the Proposed Action.
2. Any Adverse Environmental Effects Should the Proposal Be Implemented.
3. Alternatives to the Proposed Action.
4. The Relationship Between Local Short Term Uses of Man's Environment and the Maintenance and Enhancement for Long Term Productivity.
5. Any Irreversible and Irretrievable Commitments of Resources.
Comments on this Draft Environmental Impact Statement should be submitted (in duplicate) to: Mr. John Raymond, Department of Ecology, Olympia, Washington 98501; and to Mr. Joe MacKechnie, Engineering Department, 708 Municipal Building, Seattle, Washington 98104, before February 8, 1973. Thank you.
SUMMARY
Pursuant to the Clean Air Act Amendments of 1970, the Director of the Environmental Protection Agency has directed the Governor of the State of Washington to submit by February 15, 1973 a plan for reducing the carbon monoxide and photochemical oxidants levels of automobile-related pollutants, such as carbon monoxide and hydrocarbons.
In Seattle, excessive concentrations of carbon monoxide and photochemical oxidants levels of automobile-related pollutants, such as carbon monoxide and hydrocarbons have been recorded in the Central Business District. Even though the concentrations measured are currently not at dangerous levels they do exceed the federal standards established by the Environmental Protection Agency. In addition to the CBD, hydrocarbon problems could potentially occur in the region of Interstate 90 following the completion of that roadway in 1978.
Much of the downtown pollution problem will be eliminated over the next five years by the gradual replacement of older automobiles by newer, less-polluting automobiles. The METRO transit program will make a significant contribution by increasing the percent of bus riders from its present 17 percent to a projected 21 percent of all persons traveling into the Central Business District. A program presently under way to improve the synchronization of signal lights will reduce idling and make a small contribution to the reduction of pollutants.
Additional nostrums will be necessary to achieve the desired levels of air quality. It should be stressed, however, that draconian measures which would destroy Seattle's downtown as a regional retail and business center would be as undesirable as the present air pollution levels. In particular, it is important to avoid measures which overly discriminate against the CBD and favor suburban shopping centers and the relocation of business to rural areas.
There are essentially two ways to reduce automobile pollutants. First, by reducing the amount of emissions from each individual vehicle. Second, by reducing the amount each vehicle is driven.
The emissions from new cars are substantially less than from older cars. Cars sold before 1968 and trucks sold before 1970 did not utilize exhaust emission control. A simple device, costing less than $40, will reduce the carbon monoxide levels of an uncontrolled car by almost 60 percent. If these devices were required to be installed on all older cars, a significant improvement in air quality could be achieved. If an annual inspection of the device were also required, an additional improvement would occur.
Studies in the Los Angeles CBD have indicated that as much as 20 percent of downtown traffic is "unnecessary." Drivers shopping for a less expensive or more convenient parking space, taking a circuitous route to their destination or simply lost, release substantial pollutants and create congestion for no purpose. A program of locating directional signs to reduce downtown traffic by moving it more quickly to its destination would reduce air pollution by a significant amount. If a uniform schedule of parking charges were established, drivers would go immediately to the nearest empty lot. Under a local improvement district, a system of driver advisories to the best parking (and to various businesses) could be developed. Such a program would result in additional reduction in pollution.
The number of automobiles in downtown Seattle can be reduced both by increasing the proportion of transit riders and by increasing the number of occupants of each car. If the present average of 1.4 occupants/vehicle among persons working in the CBD could be raised to 1.7, a reduction in the number of vehicles would occur.
This could be accomplished through an intensive program of computer-matching of employee home addresses and work location. If incentives were added to the program its chances of success would increase.
A major element in the solution will be the increase in bus patronage above and beyond that presently programmed by METRO. If overall patronage could be increased there would be a sufficient reduction in the number of vehicles entering the CBD to complete the mission of reducing air pollution to acceptable levels. However, the increase in bus ridership by this amount cannot be accomplished without some added incentives to an automobile driver. Increasing the cost of parking and controlling the location and amount of parking within the CBD would be critical to the success of any program to increase bus use or promote car pools.
One proposal would be to give the City the authority to regulate the development of new parking lots and to set the rates on existing privately operated lots. Transit operating subsidies should be paid from the State Motor Vehicle Fuel Tax proceeds. Constitutional prohibitions on such payments should be repealed.
Another important element in increasing bus ridership is the creation of a downtown environment which the pedestrian finds enjoyable. Specifically, pedestrian oriented circulation and land uses should be promoted. This might include sidewalk widening, shuttle systems, weather and climate protection such as arcades, colonnades and open plazas, street trees and "street furniture" and other pedestrian amenities.
PART I: INTRODUCTION
(NOTE. – Figures referred to are not reproduced in the RECORD.)
An Emergency Episode Plan provides for public notification when air pollution levels begin to present dangers to health. At the lowest level of warning voluntary cooperation in leaving automobiles at home will be asked for. At higher levels, portions of Seattle will be sealed off to all except emergency vehicles.
Surveillance of air pollution levels will be improved by the installation of additional carbon monoxide and nitrogen oxide monitors.
What is air pollution?
The restoration and preservation of environmental qualities, such as the air we breathe, has in recent years gained the interest and concern of citizens throughout our nation and the world.
Increases in population, urbanization, mobility, and consumption, common elements of large cities and daily living, have created a complex problem of air pollution which is now threatening the health and well-being of all of us. Many air pollution authorities agree much still is to be learned about the adverse effects air pollution has on the environment and public health. Yet, sufficient evidence has been assembled that supports the argument that air pollution can kill, can impair health, wastes essential natural resources and threatens the delicate balance of natural systems on which all life depends.
What is air pollution? Is it as serious as it sounds? The study of air pollution problems has been gathering momentum over the last ten years. General pollutant types, their sources and their impact on man have been identified and, recently, steps begun to bring them under control.
From the classification list of pollutants, six are major elements of air pollution: (1) Sulfur Oxides, (2) Particulate Matter, (3) Carbon Monoxide, (4) Hydrocarbons, (5) Nitrogen Oxides, and (6) Photochemical Oxidants. The appendix of this document provides a description of the source, nature and adverse effects on health of each pollutant.
The sources of pollution are generally divided into five categories: transportation, fuel combustion in stationary sources, industrial processes, solid waste disposal, and miscellaneous sources. The amount of pollution these five sources produce is usually given in millions of tons per year of the six major pollutants.
Table 1-2 is useful in that it provides insight to identifying the principal contributors to each type of air pollution problem and estimates the amount each source emits.
Statistics of this kind are impressive, but the knowledge gained has a very limited use. When the emission from the various sources have been combined with local topographies and meteorological conditions, the problem becomes far more complex and must be dealt with at the local level. The amounts of contaminating emissions that prevail and the means for controlling them are details that must be ascertained and considered for each source in each locale.
What is being done about air pollution control?
Our nation began meeting the challenge of cleaner air as early as 1955 when the first federal control act was passed. Although that act was restricted to research into the nature and extent of the nation's air pollution problem, it marked the beginning of an era where environmental
qualities would soon be placed at a higher value. Since 1955, Congress has passed the 1967 Air Quality Act and the implementation plans to meet and maintain Clean Air Amendments of 1970.
Together, those standards in these Acts have provided stronger legal tools and an even larger mandate for citizen participation. The central thought of the federal air pollution control program has been “... the prevention and control of air pollution at its primary source is the primary responsibility of the states and local governments.” However, if the states fail to meet their control responsibilities, the federal government, acting through the newly established Environmental Protection Agency (EPA) has a responsibility and authority to establish and enforce pollution controls. To date, and with the assistance of each state, EPA has designated air quality control regions, developed air quality criteria, defined national ambient air quality standards, and has begun formulating state implementation plans to meet and maintain those standards.
NATIONAL AMBIENT AIR QUALITY STANDARDS
In 1971 EPA established national ambient air quality standards specifying the maximum levels to be permitted in the ambient air for the six principal and most widespread pollutants. The levels are specified as "primary standards" (required to protect public health) and "secondary standards" (further reductions in particulates and sulfur oxides required to prevent the many other undesirable effects of pollution). Table1-3 lists the current National Ambient Air Quality Standards for the six major pollutants. Also included are the standards adopted by our local air pollution control agency – Puget Sound Air Pollution Control Agency (PSAPCA):
To the average person, it may be difficult to grasp the meaning from the values stipulated in Table 1-3. Appendix A provides some insight as to the effects the six pollutants have on health and should increase one's feel for what are good and bad levels of air pollution. It is valuable to know the amounts of pollutant emissions in proportion to the amount of air – that is, the number of parts of the pollutant for each million parts of air (abbreviated ppm) or the number of milligrams of pollutant for each cubic meter of air.
This information is necessary when effectiveness in methods of controls is being assessed or when an evaluation of the danger present at any given time is being made.
Although the maximum pollution concentrations were established by the Federal Government, states may set more stringent standards to protect against further degradation of air quality which may already be below the standards. Primary standards must be achieved by 1975 and secondary standards within a reasonable time period. The Act provides for a two-year extension where technology or alternatives will not be available soon enough to permit compliance with the standards.
Control regions
EPA has divided the nation into air quality control regions, the areas for which the standards were designed. The nation is now divided into some 250 control regions and large states often contain several regions. Control region boundaries were established based on consideration of climate, meteorology, topography, urbanization, and other factors affecting air quality. The State of Washington has been divided into six quality control regions as indicated in Figure I-1; Seattle is in the Puget Sound Intrastate Region.
State and Regional Agencies
DEPARTMENT OF ECOLOGY
Prior to 1967, authority for air pollution control activities at the state level was vested in the State Director of Health. A state air pollution control board existed but its functions were mainly advisory. The Washington Clean Air Act of 1967 established a State Air Pollution Control Board with power to adopt regulations, issue orders, hold hearings, and assume jurisdiction over certain classes of air pollution sources. The State Director of Health became the statutory chairman of the State Board; the head of the State Health Department Air Quality Control Section was appointed executive director.
The more significant legislation adopted by the State Air Pollution Control Board includes: setting air quality standards for carbon monoxide (1969) and sulfur oxides, suspended particulate, fluorides and particle fall out (1970) and assuming jurisdiction over Kraft mills and aluminum plants. In 1968, the State Board assumed jurisdiction over motor vehicles "for the purpose of controlling air contaminant emissions resulting from the operation of such motor vehicles." The regulation prohibited the removal or by-passing of any auto emission control device required by federal law.
The Washington Environmental Quality Reorganization Act of 1970 created the State Department of Ecology (DOE), and transferred from existing state agencies those powers, duties and functions with reference to air and water pollution control and disposal of solid wastes to the Director of DOE. A seven-man Ecological Commission was created, but only for advice and guidance to the Director. To date the Director of DOE has adopted regulations assuming jurisdiction over sulfite pulping mills, establishing an emergency Episode Plan for the State; amending air quality standards adopted by the now-defunct State Air Pollution Control Board; establishing new air quality standards for photochemical oxidants, hydrocarbons and nitrogen dioxide; and establishing regulations for control of stationary air pollution sources in areas of the state not covered by regulations of local air pollution control authorities. These regulations were all adopted in 1972.
Puget Sound Air Pollution Control Agency
The first municipal air pollution control regulation in King County was adopted by Seattle in 1961. In 1966, King County joined with Seattle to form a countrywide air pollution control program. The Seattle-King County Director of Public Health became the enforcing officer. The County Commissioners, sitting as a County Board of Health, adopted countywide air pollution control regulations later that year. In 1967, the Washington State Clean Air Act was passed.
Among many important features of the Act was one creating a multicounty air pollution control authority for King, Pierce and Snohomish counties, effective June 8, 1967.
By the end of June, 1967, a governing body for the new authority had been named, a budget was adopted, and the authority named "Puget Sound Air Pollution Control Agency" (PSAPCA). In July, 1967, the Board of Directors (governing body) appointed an Air Pollution Control Officer; personnel of the air pollution control division of the Seattle-King County Health Department and Tacoma-Pierce County Health Department were transferred to the new agency.
The State Clean Air Act authorized enforcement of existing municipal or county air pollution control regulations until superseded by multi-county regulations. In March, 1968, the Agency's Board of Directors adopted Regulation I which, together with the Clean Air Act, became the primary law for control of air pollution from stationary sources in the counties of King, Pierce and Snohomish. Effective January 1, 1970, the Agency's authority to control air pollution was extended to Kitsap County.
Regulation I has been amended several times to date (December, 1972). Some of the more significant amendments were: setting a 10% process weight limit on sulfur compounds emitted from a manufacturing process; setting standards for sulfur dioxide emissions from fuel burning sources; adopting air quality standards equivalent to or more stringent than national secondary air quality standards; adopting the civil penalty powers authorized by the State Clean Air Act; and implementing the "one-permit" system as directed by the state legislature for regulation of open burning.
Commencing in 1969, the Agency developed a "compliance schedule" program that is proving effective in achieving over industrial air pollution sources, open burning, and incineration practices. As of June 30, 1972, 177 compliance schedules have been completed, and 77 were on active status. The Agency keeps a cumulative record of emissions reduction estimates accomplished through compliance schedules and other remedial measures. As of December, 1972, more than 49,000 tons/year of a wide variety of pollutants that were being emitted in 1967 have been removed from the air.
Air pollution – Does Seattle have a problem?
Normal day-to-day activities, fluctuating seasons and occasional scenic glances provide the local citizens with only a casual relationship and awareness of varying levels of air quality. Degrees of air pollution in Seattle are not always obvious to the city's residents and visitors outside of an occasional hazy day. However, careful measurements of Seattle's air quality do indicate that air pollution is a problem and the federal standards are being exceeded.
The Puget Sound region is fortunate in that monitoring pollution emission has been under way since the late 1960's. Monitoring programs have been carried out jointly by the Washington State Department of Ecology (DOE), the Puget Sound Air Pollution Control Agency (PSAPCA), and just recently the Environmental Protection Agency (EPA Region X). Consolidation and interpretation of emission measurements have been a primary task of the Puget Sound Air Pollution Control Agency (PSAPCA). PSAPCA, in their annual report, display an emission inventory for five of the six major pollutants. Emission estimates from the area-wide sources (e.g. automobiles) and approximately 200 point sources (e.g. industrial plants) within the Puget Sound region are presented in Table 1-4.
The most obvious conclusion derived from Table 1-4 is that gasoline-powered vehicles account for the bulk of CO, HC, and NOx emissions while fuel combustion (stationary) and industrial processes account for most of the particulate and SO2 emissions.
Knowing the amount (tons per year) and sources of emission is not sufficient in itself to determine whether or not there are air pollution problem areas within the Puget Sound region. It is useful for determining where to direct controls once a problem has been found; however, more definitive data such as concentration measurements are required for locating air pollution problems and defining control programs.
Monitoring stations throughout the Puget Sound region have made it possible to estimate the levels of pollutant concentrations. Seven sites in the Seattle area have provided PSAPCA with concentration measurements since January, 1970. The approximate location of those stations and the time period for which data has been collected are illustrated in Figure 1-2.
The assessment of the air pollution problems for Seattle is based upon the data acquired at those seven locations, other research data provided by PSAPCA, the GCA Corporation of Bedford, Massachusetts (air pollution consultants for EPA – Region X) and Mathematical Sciences Northwest (air pollution consultants to the City).
Part V of this document provides a program for increasing the existing surveillance system.
Particulates
Under the earlier implementation plan which was filed with the Environmental Protection Agency on January 31, 1972, the Puget Sound region will meet the primary particulate standards before 1975. In order to meet the secondary standards, strategies must be developed which will continue to reduce the particulate problem of that area after all point sources are in compliance and before new industry is added. Strategies are presently being developed to meet this standard; however, it is not necessary to discuss those in this document at this time.
Sulfur Dioxide
The PSAPCA's standards for SO2 are now more stringent than the National Ambient Air Quality Standards. Assuming that the single major source of SO2 (i.e., industrial processes) meets the variance schedule on time, no problems in controlling this pollutant are expected by 1975.
Nitrogen oxides
Measurements taken by the Environmental Protection Agency's National Air Sampling Network have recorded violations of the Nitrogen Oxide standards in the Seattle CBD. However, the measurement technique which was utilized has since been acknowledged by EPA to produce high readings. Measurements taken by the Puget Sound Regional Air Pollution Control Agency since February, 1971 by another generally accepted technique have never recorded readings anywhere in the region in excess of the federal standards. EPA has not required Washington to provide strategies to reduce Nitrogen Oxides.
Carbon monoxide
For the Seattle area, carbon monoxide concentrations have been observed at the seven
monitoring sites for the highest one-hour and eight-hour concentrations. The national one-hour standard of 35 ppm was reached or exceeded once at I-5 and Dearborn (October, 1970) and once at the City Municipal Building (February, 1972). At the City Municipal Building high concentrations are consistently experienced during working hours all four seasons. The concentration increases sharply to an early morning maximum at about 8 AM local time, remains at high levels throughout the middle of the day, increases to the maximum for the day at about 4 PM local time, and decreases abruptly thereafter to a fairly uniform evening level. As would be expected, the lowest concentrations are experienced between 2 AM and 5 AM, local time, when traffic flow is at a minimum. The daily variations experienced at I-5 and Dearborn and at Westlake Mall are roughly similar to the daily variation at the Municipal Building, but the amplitudes of the curves are greatly reduced. Also, concentrations at I-5 and Dearborn remain relatively high throughout the evening. Concentrations at Duwamish, McMicken Heights, and Food Circus remain low at all times of the day.
Of the recent measurements, only the Municipal Building readings exceeded the federal eight-hour standards of 9 ppm. Between August, 1971 and July, 1972, the federal eight-hour standard was exceeded 726 times. The highest concentrations usually occurred between 6 AM and 6 PM; the highest eight-hour between 9 AM and 5 PM (see Figure 1-3).
Table 1-5 lists the highest and second highest one-hour and eight-hour average concentrations observed in Seattle between January, 1970 and July, 1972.
It would have been necessary to reduce the levels of carbon monoxide by 57 and 53 percent on the two worst days in order to avoid violating the primary standards. The central assumption of the plan here presented is that the levels of air pollution are directly proportional to the amount generated at the surface. Thus, a reduction of carbon monoxide generated by traffic of 57 percent is assumed to result in reducing the carbon monoxide in the air by 57 percent.
The regulations of the Environmental Protection Agency permit the calculation of maximum allowable levels of pollutant emission either by such a proportion calculation or by a more sophisticated "diffusion model" (36 F.R. 15490). The diffusion model utilizes specific information on the local topography, meteorology and the location of specific stationary and mobile (automobiles, etc.) sources to predict the actual concentration of the pollutant at a given time and place. Such models require a substantial data base to develop.
Since there is a lack of ambient air quality monitoring data available to adequately define the air pollution problem in the City of Seattle, Part V of this document recommends a surveillance and analysis program for improving the reporting, monitoring, and interpretation of air pollution data. Such a program will permit the development of a diffusion model for future revision of this plan.
However, the data that has been collected to date does indicate that a carbon monoxide problem exists in the Central Business District of Seattle. The Environmental Protection Agency has located two additional monitoring stations in the Seattle CBD to check the validity of the I-5, Westlake Mall and Municipal Building sites. The data collected over the next three months should provide the opportunity for verifying the data listed in Table 1-5.
With respect to carbon monoxide sources, motor vehicles were estimated to produce approximately 93 percent of the carbon monoxide emitted in the Puget Sound Intrastate Air Quality Control Region in 1970. Any strategy to control carbon monoxide must therefore emphasize control of carbon monoxide from motor vehicles.
Photochemical oxidants and hydrocarbons
The barely understood pollution products of photochemical processes, the chemical changes due to sunlight, are commonly lumped together under a general heading of photochemical "smog" (Los Angeles type). The sun plays a major part because its energy can be absorbed by nitrogen dioxide (NOx) in the presence of some hydrocarbons.
Photochemical oxidant production is often a function of the hydrocarbon to NOx emission ratio, and thus a reduction in hydrocarbons will aid in reducing photochemical oxidant production. Based on the federal primary one-hour standards for carbon monoxide and photochemical oxidant which were set with health effects in mind, photochemical oxidant is approximately 250 times as potent as carbon monoxide.
The national standard for the highest one-hour concentration of total oxidants was exceeded 85 times at the I-5 and Dearborn site during a four-month period (July to October, 1970) . This oxidant data was not corrected for nitrogen dioxide, however. At other sites in Seattle, the standard was exceeded six times at the Duwamish site (only a two-month sample period is available at this time), and three times at the Food Circus for the sample period beginning January, 1970 and ending May, 1972.
Table 1-6 lists the highest and second highest one-hour average oxidant concentration of the day for each month at each oxidant monitoring site. Given the oxidant values and knowing the ratio of oxidants produced to hydrocarbons emitted, the percent reductions required in HC emissions were tabulated (also included in Table I-6).
As with CO, strategies must be directed toward control of automotive hydrocarbon emissions if the federal standards are to be met. The Federal Motor Vehicle Emission Control Program has been projected by the GCA Corporation as being sufficient to reduce the hydrocarbon emissions to acceptable levels.
Can Seattle's air be cleaned up?
Regional and State programs have been developed to control most of the pollutants emitted from stationary sources; however, a clean air implementation plan for mobile sources has not been previously developed.
Following promulgation of the National Ambient Air Quality Standards by the EPA Administrator on April 30, 1971 (36 F.R. 8186) each state, within nine months, was required to adopt and submit to the Administrator, a plan which provides for the implementation, maintenance and enforcement of national ambient air quality standards within each air quality control region of the state.
The State of Washington submitted its implementation plan on January 28, 1972. At that time a request was made for a two-year extension for attainment of the standards for carbon monoxide, nitrogen dioxide, and photochemical oxidant in the Puget Sound Interstate Air Quality Control Region, and carbon monoxide in the Eastern Washington-Idaho Interstate Air Quality Control Region.
The State of Washington was advised on May 31, 1972 through publication of regulations in the Federal Register (37 F.R. 10842) that this extension was granted and that no later than February 15, 1973, a transportation control plan must be submitted:
"52.2479 Transportation and land use controls:
"(a) To complete the requirements of 51.11 (b) and 51.14 of this chapter, the Governor of Washington must submit to the Administrator:
"(1) No later than February 15, 1973, the selection of the appropriate transportation control alternative and a demonstration that said alternative, along with Washington's presently adopted source emission limitations for hydrocarbons and carbon monoxide and the Federal Motor Vehicle Control Program, will attain and maintain the national standards for photochemical oxidants hydrocarbons) in the Puget Sound Intrastate Region and for carbon monoxide in the Washington portion of the Eastern Washington-Northern Idaho Interstate Region by June, 1977. By this date (February 15, 1973), the State also must include a detailed timetable for implementing the legislative authority, regulations, and administrative policies required for carrying out the transportation control alternative by June, 1977.
"(2) No later than July 1, 1973, the legislative authority that is needed for carrying out the required transportation control alternative.
"(3) No later than December 30, 1973, the necessary adopted regulations and administrative policies needed to implement the transportation control alternative."
The subsequent parts of this document provide a plan which exhibits a potential for meeting the above requirements and improving the air quality of the Seattle area.
1977 air quality levels
The previous sections of this document have introduced to the reader known facts about air pollution and how pollution relates to Seattle's air quality. The sections that discussed carbon monoxide, photochemical oxidants and hydrocarbons – using today's air quality (1971 data) and comparing it to the 1975 federal standard – demonstrated that if the standards were imposed now, areas of Seattle would exceed the carbon monoxide standard by an estimated 57 percent and the hydrocarbon standard by 53 percent (computed from highest 1971 measurement on several occasions during the year). Because the federal standards for the State of Washington are to be met by 1977, it becomes necessary to look at air quality relative to that time. Projecting today's problems into the future enables governmental agencies and private organizations an opportunity to gauge the magnitude of the future problem and to evaluate control strategies for achieving the federal requirements by 1977.
Given the limited data base and the difficulty of making any accurate projections into the future, the only reasonable estimates of the 1977 air pollution levels in Seattle have been made by two consulting firms under contract to the Environmental Protection Agency (EPA). These firms are the G.C.A. Corporation of Bedford, Massachusetts, responsible for assessing the severity of the existing and future levels of air pollution, and A. M. Voorhees and Associates of Seattle, Washington, responsible for analyzing the relevant transportation characteristics. These firms were retained by EPA to identify potential control strategies in the event the Administrator of EPA disapproved the State (DOE) plan or portions thereof, or should the State fail to submit a plan or portions thereof.
The methodology presented in the G.C.A. Corporation's draft report of December, 1972 and their evaluation of Seattle's 1977 air quality is representative of the current state of the art. For these reasons, their methodology and estimates of the 1977 air quality levels for Seattle have been adopted as part of this document. The following is a summary of sections two and three of the G.C.A. report. (If more definitive information is required, a copy of the report can be obtained from the EPA-Region K office located in Seattle, Washington.)
Methodology
Computation of vehicle-miles of travel (VMT) within high traffic density areas of the Puget Sound Control Region for the estimation of vehicle emissions and subsequent evaluation of air quality is the first step toward developing transportation control strategies that will achieve air quality standards for carbon monoxide and oxidants by 1977. The steps in the procedure include selection of critical areas by inspection of traffic counts, calculation of vehicle-miles of travel for 1971, and projection of vehicle-miles of travel to 1977 based on recent growth trends.
Vehicle-mile data for the Puget Sound Region were developed by the Washington State Highway Department and the Puget Sound Governmental Conference. These data, however, were either for the region as a whole or were for specific facilities within the region. Therefore, a methodology had to be developed to provide data on vehicle miles of travel for small areas within the region where air pollution emissions were high and air quality was poor.
One-square-mile grids were plotted on USGS maps at a scale of 1:24,000. Using a twenty-four hour average daily traffic (ADT) flow map produced in 1969 for the Puget Sound Region by the Puget Sound Governmental Conference, areas of greatest traffic concentration were selected for coverage with these mile-square grids. Initially, 19 square-mile grids were analyzed in the Seattle, Tacoma and Bellevue area. In taking areas of one square mile, some much smaller areas of high traffic concentration are not clearly illuminated as potential pollution problems. These areas will require a more fine-grained analysis during future studies for revisions in the implementation plan.
Data was collected from screen line and arterial traffic counts so that the hourly traffic profile could be evaluated. Figure 1-4 shows the profile for the Seattle Ship Canal Crossings. For each grid square, the emissions in grams were estimated using the Environmental Protection Agency's curves that relate grams emitted per vehicle-mile to average speed. The emissions calculated for grids where air quality measurements were available were adjusted by the ratio of the measured air quality to the federal standards. The adjusted emissions total was used as a base to test other grids.
In order to ensure that calculations of vehicle-miles of travel were available for all potential "hot spots" of poor air quality, additional grids were added to the system until it appeared that coverage was achieved where the grids with high emission levels were surrounded by grids with emissions below critical level. The Seattle level total was increased to 50 grids as shown in Figure 1-5.
For estimating 1977 vehicle miles of travel the following assumptions were used:
1. The distribution of vehicle miles of travel by type of vehicle is the same as 1971.
2. The daily traffic profile is the same as 1971.
3. The implementation of the METRO bus system, starting in 1973, will cause patronage to increase by 1977 more than 23 percent in Seattle, and over 600 percent in the suburbs. A copy of "A Transit Plan for the Metropolitan Area," which details the plan for the development of the METRO Transit System, adopted by the Metropolitan Council, is attached to this document.
4. The King County Domed Stadium will be open in the fall of 1975 just south of downtown Seattle. It is assumed that few events will begin or end during weekday peak hours. (A City ordinance may be necessary to insure the validity of this assumption.) Unless Saturday VMT grows excessively by 1977, it is assumed that an analysis of weekday travel under non-stadium conditions would provide a reasonable evaluation for the grid zone.
Using the above assumptions as guidelines, 1971 and 1977 total daily vehicle-miles of travel were calculated for the one-mile-square grids of Seattle and are exhibited in Figure 1-6.
Estimation of Carbon Monoxide Levels
Emission densities were calculated by G.C.A. for all 50 one-mile square zones for 1971 and 1977 using:
1. The total daily vehicle-miles of travel for each square mile grid.
2. The average speeds on various streets in the grid.
3. Non-vehicular emissions accounted for 4 percent of the total for King County. For the Seattle Central Business District (CBD), 2 percent of CO was estimated to be from non-vehicular sources.
4. It is assumed that the Federal Motor Vehicle Emissions Control Program will have been achieved by 1975 and 1976. This program stipulates that new motor vehicles manufactured in 1975 must emit 90 percent less carbon monoxide and hydrocarbons than 1970 models. By 1976, emissions of oxides of nitrogen must be reduced 90 percent from the 1971 model level. It is assumed that auto manufacturers will meet this requirement on time. If not, the 1977 estimates will be recalculated and additional control measures may be adopted. An estimate of the emissions from each model year of light duty and heavy duty vehicles were made by GCA.
5. The estimates of the increase in bus ridership as a result of the METRO transit plan.
Computing the kilograms of CO emitted/maximum 8-hour period/square-mile (kgm/ 8hr/mil) for each of the grids yielded the values illustrated in Figure 1-7. The 1971 value of 14,301 kgm/8hr/mile in the Seattle CBD is assumed to correspond (with the inclusion of 292 kgm/8hr/ mls due to stationary sources) to the air quality measurements of 20-21 ppm (measured at the Seattle Municipal Building). When this is reduced by 55 percent to meet the primary standard, the allowed emission level from mobile sources can be calculated.
Comparing this value to the values in Figure 1-7 one finds the primary CO standards being satisfied throughout the City by 1977 with the exception of Seattle's CBD.
To achieve the 8-hour average CO standard throughout the CBD will require an additional reduction from motor vehicles of about 1800 kgm/8hr/mil. The 1-hour average CO level would be well within the primary standard throughout the city with the implementation of strategies to meet the 8-hour standard.
Estimation of Oxidant and Hydrocarbon Levels
The following basic assumptions were used by G.C.A. in estimating 1971 and 1977 hydrocarbon emission densities:
1. The assumptions used for estimating 1977 CO concentrations also apply to estimating hydrocarbon concentrations.
2. The local air mass of concern is the one having the highest hydrocarbon content. Its source is the central Seattle region defined by Zones 7 through 29, where maximum vehicular emissions occur.
3. Hydrocarbons from non-vehicular sources are uniformly distributed throughout the city of Seattle.
4. The amount of hydrocarbon emissions within Seattle is directly related by population to total emissions within King County.
Figure 1-8 shows the 1971 and 1977 three-hour hydrocarbon emissions densities calculated for the Seattle area from mobile sources. For the 23 square mile area (zones 7 through 29) the following was derived:
The data available at the present time indicates that photochemical oxidants and hydrocarbons in the Seattle area will fall within the national standards by 1977 without the imposition of special transportation control strategies.
In late 1978 a new Interstate freeway is expected to be completed in a corridor connecting Interstate 5 and the Lake Washington Bridge (Interstate 90). Studies conducted by Mathematical Sciences Northwest, a consultant to the City of Seattle, indicate that there is sufficient reason to believe that soon after opening, the potential for hydrocarbon levels in excess of the Federal Primary Standard will exist over a substantial portion of the valley between Mount Baker Ridge and First Hill.
The ridge system engenders stable atmospheric conditions, slow wind speeds and frequent inversions. Extensive data from nearby Boeing Field showed air stability patterns D and E 86 percent of the time with prolonged stagnation periods from 1 to 5 days 71 times in a 36-month period.
Given the calculated pollutant emission levels and the known meteorological data available, this area is sufficiently presumptive of potential violation of standards to warrant the development of a diffusion model to evaluate the air quality problems which might be anticipated in 1978 and the potential results of possible solutions. Such an investigation will be conducted by the City of Seattle and the results will be contained in the next Semi-annual Report.
PART II: CITIZEN INVOLVEMENT
The evolution of a plan
On April 30, 1971 the Environmental Protection Agency (EPA) set the "National Ambient Air Quality Standards" for the six major air pollutants. Within nine months thereafter each state was required to adopt and submit a plan which provided for implementation, maintenance and enforcement of the federal standards by 1975 within each air quality control region. Prior to the original submission of the Washington Implementation Plan on January 18, 1972, hearings were conducted in both Seattle and Spokane. The Seattle hearing was held on January 5, 1972, at which time approximately 60 persons attended (speakers and non-speakers).
Following the State's submission of the plan to the federal government, EPA approved all but four parts of the plan on May 31, 1972. One of these was the control of transportation emissions. EPA requested the preparation of a more detailed transportation control plan by the State for EPA's review by February 15, 1973.
In formulating the Seattle area transportation control plan, two processes were initiated. First, EPA retained a private consulting firm to develop transportation control strategies for Spokane and Seattle areas, in the event the State did not present a plan for controlling CO, NOx and HC.
That effort began on August 20, 1972 and was completed during January, 1973. During the course of that study, several meetings were held by EPA to report the progress to various governmental agencies. A representative of the Air Quality Coalition, a Seattle organization, attended some meetings. Additionally, one of the consultant's staff met with various public officials for discussions of strategies.
The second planning effort was generated by the EPA study. The work being done by the consultants for EPA, the exposure of the general public to the requirements of the federal program through the media, and the desire by local governmental agencies to accept the responsibility for meeting the challenge of controlling air pollution spurred on the organization of two committees. The first was formed by the Seattle Chamber of Commerce with a membership including representatives from the Central Association, the Seattle Chamber and community groups. In parallel, Wes Uhlman, Mayor of Seattle, invited local, regional and State governmental agencies to participate on a technical committee. The A. M. Voorhees consulting firm was retained by the Department of Ecology to assist in evaluating strategy alternatives. Using the EPA/G.C.A. plan and the recommendations' of the Chamber Committee, the technical committee prepared this implementation plan.
During the course of formulating the Seattle area plan, attempts were made to inform the public of the plan development and its content prior to its completion. An informational meeting was held with the Transportation Policy Advisory Committee of Puget Sound Governmental Conference on December 5, 1972. A similar meeting was held with the Seattle City Council Transportation Committee on December 12, 1972 and the King County Council on December 15, 1972. During the months of November and December 1972, numerous newspaper articles explained the air pollution problem in Seattle and what the requirements are of the Federal Air Quality Act for correcting the problem. During January 1973 news articles were published outlining the details of the plan being proposed for submission to the EPA.
On January 8, 1973 a one-hour "public meeting" was televised by KCTS--TV, Channel 9. This program followed the format of a public meeting with a panel of "experts" explaining the problem and proposed solutions and a studio audience asking questions and making comments.
Approximately one-half hour was allotted to questions and comment by the audience. In addition to answering questions from the studio audience, a telephone number was announced for the viewing audience to call and ask questions of several engineers and technicians who were instrumental in developing the proposed plan. More than 45 calls were received. The complete program was video taped to be broadcast again on January 11, 1973. The League of Women Voters and the Air Quality Coalition played a major role in organizing the KCTS-TV program.
Public notice of the formal hearing on the transportation addendum to the State Implementation Plan was required to be given 30 days prior to the formal hearing. On January 9, 1973 the hearing for February 8, 1973 was publicly advertised as a joint hearing sponsored by Seattle's City Council and the Department of Ecology.
At this time a public meeting is scheduled on January 17, 1973 by the Seattle City Council Transportation Committee and a public seminar is scheduled for February 3, 1973 by the Air Quality Coalition. Presentations of the implementation plan have been requested by the Municipal League, the American Society of Civil Engineers and other community and professional organizations.
Continued citizen involvement
These six steps are suggested to citizens as a preparation for participating in the hearing scheduled for February 8, 1973:
1. Know what is meant by air pollution,
2. Know what the air pollution problem is in the Seattle area,
3. Know who the responsible agencies are for the Seattle vicinity and the State of Washington,
4. Know the existing air pollution laws,
5. Prepare a critique of the proposed plan, and
6. Use the critique as testimony at the hearing.
Part I of this document should provide adequate insight to each of the above steps. If additional information is needed, the Environmental Protection Agency-Region X of Seattle has valuable documents for public use and study.
Following the formal hearing on February 8, 1973 and the receipt of public critiques, the plan must be submitted by the Governor to EPA by February 15, 1973. Within four months from the date of submittal, the EPA must approve or disapprove the plan or a portion thereof. Legislative authority that is required for carrying out the transportation control alternates must also be demonstrated by December 30, 1973. While the hearing of February 8, 1973 is the time for a critical look at the plan, it is apparent that continued citizen involvement is needed to ensure that the elements of the plan will be implemented. Figure II-1 further illustrates the steps for adoption of an Implementation Plan.
Revisions
The plan can be revised from time to time, as may be necessary, to take account of:
(1) Revisions of national standards,
(2) The availability of improved or more expeditious methods of attaining such standards, such as improved technology or emission charges or taxes, or
(3) A finding by the Administrator that the plan is substantially inadequate to attain or maintain the national standard which it implements.
Revisions of the rules and regulations included in the plan would be adopted after reasonable notice and public hearings. Those revisions can be described in the semi-annual report, described in the following section.
Reports
Two types of reports are required, a quarterly report and a semi-annual report:
(a) On a quarterly basis commencing with the end of the first full quarter after approval of the plan, the State will submit to the Administrator (through the appropriate Regional Office) information on air quality. The quarters of the year are January 1-March 21, April 1-June 30, July 1-September 30, and October 1-December 31.
(b) On a semi-annual basis commencing with the end of the first full semi-annual period after approval of the plan, the State will submit to the Administrator (through the appropriate Regional Office) reports on progress in carrying out the applicable plan. The semi-annual periods are January 1 – June 30 and July 1– December 31.
(c) The reports required by this section will be submitted within 45 days after the end of each reporting period.
Therefore, over the next four years, there will be substantial opportunity for citizen review of the program. If the plan herein recommended proves not to be adequate, new strategies must be developed and submitted for public reaction as a part of the revision. If the plan is more than adequate to provide the desired levels of air quality, various strategies might be deleted.
PART III: TRANSPORTATION CONTROL PROGRAM
Introduction
There are a number of techniques that can be used to work toward reducing air pollution and achieving acceptable ambient air quality levels. Various strategies being tried in other parts of the world were presented in December, 1972 in a report by the 22-nation Organization for European Economic Cooperation and Development (OECD). The report stated that more than 70 cities in Western Europe have barred autos from key downtown areas among other efforts to curb growing air pollution problems. In Vienna, bus-only zones have been designated in downtown areas during the hours from 10:30 AM to 7:00 PM; delivery trucks are allowed to function only in the mornings (7:00 AM to 10:30 am); and plans are being developed to provide expanded car-free zones. In Goteborg, Sweden, only trolley cars and buses are allowed to cross the downtown area with all other traffic using a "ring road" leaving and entering specific downtown precincts by special routes. In West Germany staggered work hours have been adopted by 2,000 firms. Marseilles tested a total ban on downtown parking while traffic was allowed to move freely; the net result was a 40 percent reduction in carbon monoxide emissions. The most significant finding of OECD was that in these European cities "there was firm evidence that automobiles can be kept out of limited areas without hurting retail sales downtown."
In the United States, the techniques are similar to those being used in Europe with variations according to the characteristics of the individual problems. Portland, New York, Washington, D.C. and other cities confronted with air pollution problems are adopting measures such as annual emission inspection programs and improved transit service to reduce the CO, HC and NOx emissions. Washington, D.C. has also included a car pool locator service, downtown parking restrictions, and the installation of advanced control devices on pre-1975 autos and light duty trucks. Perhaps one of the most extreme and yet to be approved strategies is the "gas rationing" proposal being made by the Environmental Protection Agency for the South Coast Air Basin in California.
It should be stressed that draconian measures which would destroy Seattle's downtown as a regional retail and business center would be as undesirable as the present air pollution levels. In particular, it is important to avoid measures which overly discriminate against the CBD and favor suburban shopping centers and the relocation of businesses to rural areas.
The air quality and traffic data available at this time are not sufficiently refined to enable precise and accurate calculations of all the effects of various strategies advanced to correct the air quality problem. Substantial additional data must be developed in order to better evaluate future revision of this plan.
Selection of strategies
In developing this implementation plan, staff were often confronted with a bombardment of pet strategies for controlling air pollution. As a base for starting the strategy selection process, the recommended strategies of the GCA Corporation plan were reviewed and parts adopted. A sampling tool known as a "desirability matrix," was also employed for the purpose of determining which strategies had the greatest potential. In assembling the array of ideas, it became apparent that various concepts could be grouped or classified under a general strategy heading. The three basic groups formulated were: (1) Emission and Energy Controls, (2) Transportation Controls, and (3) Person Trip Controls.
When the final list was assembled, 135 ideas had been tabulated. Under Emission and Energy Controls, strategies listed ranged from controlling air pollution at the source (i.e., new fuels, retrofit, inspection programs, etc.) to gas rationing and processing polluted air. Under the second group, Transportation Controls, strategies included ideas on ways to increase transit patronage, improving traffic flow, restricting off-street parking, discouraging the use of the auto and increasing the facilitation of alternate means of travel (e.g., pedestrian walkways, bike lanes and facilities, auto-free zones. The third class, Person Trip Controls, addressed those strategies which focused in on land use controls such as limiting population densities, staggered work hours/days, providing better communication systems, and many others.
Based on the intuitive estimates of (1) desirability, (2) economic impact, and (3) social impact, scores were compiled for each of the 135 strategies. The population of individuals sampled included seven environmentalists, ten businessmen, eight transportation and land use planners, and three design engineers. Though this population was limited, it did constitute a varied cross-section of interests and professions. Appendix B contains the list of the 50 most desirable strategies based upon the composite score of the 28 persons sampled.
From that list, strategies were selected and evaluated relative to their effectiveness in reducing CO emissions, the cost, and the time it took to implement each. Strategies which could not be "on-line" by 1977 were eliminated. Strategies which could only affect a small number of the total person trips in the CBD were eliminated. Strategies which had only a very short-term impact were eliminated. Strategies which required either public or private expenditures which were large relative to the degree of reduction in emissions they yielded were eliminated or revised to improve the ratio. Table III-1 summarizes the strategies selected and indicates the estimated amount that carbon monoxide emissions can be expected to be reduced in the CBD when each strategy is fully implemented. The total reduction of 1800 kgm/8hr/mi meets the goal calculated in Par. I. This package of strategies will enable Seattle to achieve air pollution levels which meet the federal primary standards by 1977.
Retrofit
Beginning with the 1968 model year, all new cars (1970 for trucks) have been required by Federal law to meet standards for the amount of pollutants in the exhaust. However, due to the nine-year average lifetime of automobiles, in 1972 uncontrolled (pre-1968 light duty, pre-1970 heavy duty) vehicles accounted for approximately 61% of the vehicle population in King County.
In 1977 these uncontrolled vehicles will still account for some 18% of the vehicle population.
The emissions from uncontrolled vehicles can be reduced substantially by the installation of an "Air Bleed to Intake Manifold" device. Tests by EPA attribute a 58% reduction in carbon monoxide to this device. EPA further states that it can be expected to retain its initial effectiveness with periodic inspection (an annual inspection test of the retro-fitted vehicles is required by EPA). This device is discussed in detail in the EPA publication, "Analysis of Effectiveness and Costs of Retrofit Emission Control Systems for Used Motor Vehicles." A very similar device was on many of the early (1966-1967) emission control systems used by the manufacturers in California.
The estimated retail cost of such a device is $40. Installation costs and the cost of readjusting the engine might add another $20. This cost will be a significant fraction of the total value in 1977 of a pre-1968 vehicle, although it may be only a fraction of the total maintenance expense for that year.
The retrofitting of such older uncontrolled vehicles will bear hardest on those least able to pay. However, the State of Washington has filed suit against the principal domestic automobile manufacturers for conspiring to delay the research, development and installation of effective pollution control devices. The principal relief sought is the installation, at the expense of the auto manufacturers, of the appropriate devices on uncontrolled vehicles throughout Washington. This matter is set for trial beginning on March 13, 1973 in the United States District Court for the Central District of California, where it is consolidated with several other similar actions.
As the legal actions already initiated may not be resolved in the favor of the people, legislation will be proposed (see Appendix D) such that installation may be required by the Director of the Department of Ecology on all uncontrolled vehicles at the time of ownership transfer, or during 1976 (according to a staggered schedule). This is intended to reduce to the minimum possible the impact upon individual citizens. It is recommended that the legislature consider means to soften the economic impact of retrofit on the public by such means as a one-time bounty for older, uncontrolled vehicles which are scrapped.
Vehicle Emission Inspection
EPA regulations require that whenever an Implementation Plan proposes a retrofit program, it must also propose an inspection program. This is intended to ensure that the promised reduction in emissions will continue into the future, in order that the lower pollution levels of 1977 will be maintained. The inspection program required by EPA must meet the following criteria:
1. An annual inspection using a dynamometer to simulate actual driving conditions.
2. The inspection standards must be consistent with the reduction in pollutants claimed in the Implementation Plan.
3. All failed vehicles must be retested after correction to ensure compliance.
4. A program to ensure vehicles are not intentionally adjusted after inspection so that they would no longer comply with the inspection standard must be initiated.
Because the inspection system specified by EPA has never been used in practice, a very careful step-by-step implementation would be needed to minimize public impact. The program will begin with a required annual inspection of all vehicles owned by units of government in King County and fleets of three or more vehicles.
The experience with this initial program will serve as a basis to project the costs and benefits of such a program. At the present time, the initial cost of such a facility is estimated to be $50,000, with an annual operating cost of $25,000. Extra maintenance on the part of the vehicle operators might average $20 a year beyond normal good practice. Vehicle owner costs need to be known and perhaps limited before a general inspection begins.
Subsequently, all vehicles first registered and all used vehicles offered for sale would be required to pass an inspection. Additionally, all vehicles retrofitted pursuant to this plan would be required to pass an inspection following retrofit and annually on the anniversary month of their retrofit. No vehicles would be permitted to operate on the public roads until they pass their inspection.
These programs will bear most heavily on automobile dealers who do not now adjust or maintain vehicles for minimum emissions. With this added incentive it is assumed that they will begin to obtain the necessary equipment and train their mechanics. The public would be only minimally inconvenienced.
Conversion to gaseous fuel
In an effort to encourage the use of non-polluting gaseous fuels, the Legislature of the State of Washington has deleted the normal taxes on propane and liquid natural gas. However, the Act provided a cut-off of July 1, 1975.
In order to maintain the existing benefit beyond that date and, possibly, to expand it slightly, legislation will be proposed to eliminate the cut-off date and to eliminate the restriction on applicability to only fleet vehicles.
Traffic signal optimization program (SIGOP)
For pre-1975 controlled and pre-1968 uncontrolled vehicles, emissions are inversely related to speed.
Clearly, if unnecessary stops can be eliminated, emissions can be substantially reduced. Seattle is presently engaged in a project to revise the timing cycles in its CBD signal system to reduce the number of such stops using a traffic signal optimization computer program (SIGOP) developed by Peat, Marwick, Mitchell and Company under contract to the Bureau of Public Roads. Its purpose is to determine optimum cycle lengths, phase splits, and coordination of traffic signal displays in a grid network. Using data on traffic characteristics and network geometry, SIGOP expresses the data in terms of delays, stops, and system cost. System cost is computed by the program as weighted sum of delays and stops. A mathematical technique is applied which minimizes the combination of delays and stops specified.
Indications are that the SIGOP program will provide usable signal timing patterns which, system wide, are comparable to or better than the timing patterns developed over a long period of time by manual trial and error methods presently employed.
To date, approximately three-fourths of the project has been implemented. By June 15, 1973 the results will be available for evaluation. The expected performance of the system is an increase in average speeds in the Seattle Central Business District by two miles per hour through reducing stops in the CBD by approximately 33 percent and reducing delays in CBD by 10 percent . It is important to remember that the program is experimental, and a major product of the operation is an evaluation of what improvements actually result.
Car Pool Program
Beyond the programs previously discussed, it is necessary to eliminate approximately 40,000 vehicle trips per day from the CBD in order to achieve the federal primary standards for air quality. Since a large percent of automobile trips into the CBD carry only the driver, it is possible to significantly decrease the number of vehicles by increasing the average vehicle occupancy. If the present average occupancy of 1.4 occupants/ vehicle (for CBD employees) could be increased to 1.7, then 9,000 trips could be eliminated.
A method to encourage car pool use is to develop a system through which drivers can contact potential riders. Done on a large scale, such a matching system would need to be computerized to be efficient and rapid. Geo-coding would be a definite aid in a computerized matching system as it would greatly simplify the actual matching process. The availability of the Census Department's DIME file for the Seattle metropolitan area, and the ADMATCH program makes geo-coding of addresses feasible.
An effective car pool matching system would have to include a collection system for gathering the necessary data from potential drivers and riders, the computer software and hardware necessary to do the matching, and a distribution system to inform drivers and riders of possible matches. The system could initially start on a small scale, e.g., dealing with all the City employees working in the Municipal Building. Thus, everyone's destination would be the same, and matching could be done on the basis of origin.
Initially only one-time matches would be made, i.e., possible drivers would be matched on the basis of origin and arrival-departure time and the working out of details would be left up to the individuals involved. The system could later be expanded to include the other city and county offices, which in Seattle are all located across the street from each other. Other common destinations, such as groups of office buildings, could be included as the system is extended. The system for collecting input data could possibly operate within these groups of buildings or common destinations.
In setting up the system, data definition would be necessary. That is, decisions would be necessary regarding what items of information would be required for input in order to effectively match drivers and riders. Before the necessary computer programs could be written, refinement of the matching process would also be required. Analysis would be necessary to determine the parameters, i.e., for a potential driver-rider match, how close destinations should be, would matching be done solely on proximity of origins, or should route of travel be considered, etc. The question of imposing a user charge or making the system a public service would also have to be considered. Some type of security measures would probably be necessary to guard against abuse of the system.
Some types of incentive to encourage people to use car pools would be necessary to achieve high levels of participation. For example, the Seattle Blue Streak Bus Rapid Transit Demonstration Project presently has exclusive use of the downtown Cherry-Columbia reversible lane on-off ramp for I-5. It might be possible to extend the exclusive use of this ramp to car pools as well as transit. Likewise, other on-off ramps of the reversible lanes or regular lanes might be closed to all except car pools and transit.
An essential incentive would be the provision of reserved parking for car pools, for example within or near the Municipal Building or in the County Parking Garage in stalls presently reserved for administrators, executives, and government vehicles.
At the heart of the problem lies the availability and cost of parking. At present, parking availability and rates encourage using automobiles for commuter work trips. If parking costs are increased (either through restricting the supply or by regulating the rates) a real incentive is created to participate in such a program. At present, some 29,700 spaces exist in the CBD with 8-hour rates in some lots in the outer edges as low as 50¢.
An approach which would remedy these problems is legislation which would give the City the authority to regulate parking, both through competition and through the setting of rates. A bill setting out such authority is being introduced into the current session of the Legislature (see Appendix D). Another is a proposal to designate parking as a "Conditional Use" in the two central CBD land use zones, and thus require City Council approval of each new parking lot, which would come before the City Planning Commission. An alternative approach might be the requirement of a special permit, similar to the Shorelines permit, for the development of parking throughout the CBD and CBD fringe. Before any regulation of parking development or rates can be implemented, a parking plan for the CBD which responds to land use, transportation and economic factors, as well as air pollution, must be developed. The Parking Plan and, hence, any regulation of parking rates would require recognition of the fact that different structures and lots have radically different amortization rates.
Some parking is provided to employees and executives as a fringe benefit. The Air Quality Planning Committee of the Metropolitan Washington Council of Governments is reported to have suggested a court test of the IRS rules which allow businesses to deduct such expenditures as a legitimate expense. Such an action should be joined by the City of Seattle.
Uniform parking rates and driver advisories to parking facilities and destinations
Little is known about the need for better informational signing to reduce the search for parking spaces or if shopping for more inexpensive parking contributes significant excess travel in the CBD. The one-way street pattern and driver unfamiliarity with Freeway access routes most likely contribute to additional travel. In 1968, Los Angeles found that 22 percent of downtown travel during peak periods was "search for parking" travel.
A system of informational signs to privately owned parking lots and businesses should be developed, which might eventually include signs indicating the nearest reservoir of unoccupied stalls. Such a system could be financed through a local improvement district. Legislative authority for the initiation of such a district currently exists.
The parking legislation discussed previously would give the City more direct authority to construct parking structures on the periphery of the Central Business District. One such structure, adjacent to I-5 is presently in the final design stage. Such structures, when coupled with proper transportation links to major destinations, would provide parking spaces easily available to drivers which would eliminate driving through the CBD.
This legislation also provides the authority for the City to establish uniform parking rates, which would reduce "searching" travel. On-street (metered) parking is currently far less expensive than off-street parking, and to suggest a signing system without consideration of this discrepancy tends to defeat the effectiveness of the advisory program. The present street meters are near the end of their economic life, so an adjustment in the short-term parking rate structure could be coordinated with the replacement of city meters.
Increase transit ridership
The METRO Transit program, approved by the voters of King County on September 19, 1972, has already resulted in a significant increase in transit ridership, especially in the suburban portions of the county. Estimates generated in the course of developing the transit plan indicate that by 1977 as much as 35 percent of the work-oriented trips into the CBD will be by transit. Non-work oriented trips are estimated to divide at 15 percent transit riders.
A substantial increase in bus ridership over and above that plan is necessary to meet the needs of this Implementation Plan. Acceptable air pollution levels can be achieved if the work-oriented trip mode-split (number who arrive by bus vs. number who arrive in automobiles) is increased to 50 percent and the mode-split for non-work oriented trips is increased to 21 percent. This would place average mode-split for CBD trips at approximately 32 percent, up from the METRO Transit plan estimate of 21 percent and the 1971 average of 17 percent. This is not wholly unrealistic: the modal split for CBD trips exceeded 40 percent in 1962.
Such an increase in transit ridership would mean approximately 8,000 additional riders in the peak hours. This would fill 200 more transit buses. However, if a program of staggered work hours can be implemented, the present 45-minute long peak travel period could be doubled, allowing the same riders to be carried on the existing transit fleet. Should transit ridership expand beyond the capacity of the present fleet, it is assumed that METRO Transit will acquire the necessary additional vehicles.
Three factors influence the choice between the automobile and transit: relative convenience, relative speed and relative costs. The METRO Transit plan estimates assume significant improvements in each of these categories. Under the Transportation Improvements Action Program (TIAP) the City of Seattle will conduct studies and develop plans for transit-related improvements as follows:
Phase I: Basic Market and Planning Data
1. Transit Patron– Origin and Destination Data.
2. Patronage Volume (Detailed Flow Map).
3. CBD Patronage and Transfer Volumes.
4. CBD and University District Total Volume Studies.
Phase II: Finding Operational Deficiencies
1. Non-user Survey.
2. Speed and Delay Studies.
3. Terminal Delays– CBD.
4. Develop Modal Split Model.
Phase III: West Seattle Freeway Bus Lanes
Phase IV: CBD Distribution System
1. Express routing-wrong way transit lanes.
2. CBD shuttles and local service.
3. CBD shelters, orientation and conversion systems.
4. CBD Terminals, Modal Interface, People Movers.
5. Coordination with Personal Rapid Transit Studies.
Phase V: Express System
1. Line Haul Express Planning.
2. Park 'n Ride Lots.
3. Transfer and load point improvements.
Phase VI: Management and Finance
Phase VII: Special Services
Phase VIII: TOPICS System Improvements
Phase IX: Scheduling Improvements
The Urban Mass Transit Administration (UMTA) has recently approved a grant for the funding of Phase I of the TIAP program. It is assumed the remainder of the program will be funded in subsequent applications.
If the modal split estimated in the METRO Transit plan is to be improved, we must go beyond the TIAP efforts. Following the three factors mentioned above, programs should be implemented to improve transit patronage. First, the installation of additional Park 'n Ride lots. Some sites inside the city, such as West Seattle, could serve as terminals for local service and provide express bus service to the CBD over exclusive busways. Second, increases in service frequency on local routes in Seattle (approximately 54 percent of trips into the CBD originate in Seattle, south of 100th Street and north of Spokane Street). Classic transportation planning theory assigns a very strong interaction between improvements in frequency of service and increases in ridership.
Operating subsidies for improved transit programs should be supplied from the State Motor Vehicle Fuel Tax. A resolution seeking a vote of the people to repeal the State Constitution's prohibition on the diversion of such funds to transit operation expenses will be introduced into the current session of the Legislature (see Appendix D).
Improve pedestrian environment
One important corollary to increasing the use of car pools and transit is the creation of an urban environment which the pedestrian finds enjoyable. Specifically pedestrian-oriented circulation and land uses should be promoted. This might include sidewalk widening, shuttle systems, weather and climate protection (such as arcades and colonnades), open spaces, street trees, street "furniture" and other pedestrian amenities. At the present time the City of Seattle is developing several programs which will seek to achieve these ends.
Public Education
Because these strategies will require changed behavior patterns, an extensive public education campaign should be initiated to inform the public of the nature of the problem and the need for the selected strategies and to encourage the public to participate in the program.
Maintenance of Standards
The Clean Air Act Amendments not only require that the Implementation Plan propose a means of meeting the Federal standards, but they also require that these standards be maintained in the face of growing traffic volumes.
The Puget Sound Governmental Conference has projected an increase in CBD traffic volumes of 30 percent by 1990, assuming that no significant fuel shortages (and consequent disproportionate increases in gasoline costs) occur and that the transportation control strategies contained herein, other than the METRO Transit plan, are not implemented.
By 1990, less than 5 percent of all vehicles will be pre-1975 models. This means that emissions from mobile sources will be decreased 94 percent by 1990.
If the Primary Standards are indeed met by 1977 as proposed in this Plan, the ambient air quality will remain slightly better than required by the Primary Standard in 1990.
ALTERNATIVES
Rejected alternatives were often more appealing intuitively than when subjected to analysis. The following sections discuss some of the more popular (with various groups) strategies which were subsequently discarded in developing the plan.
Construct CBD Off-Ramps from Alaska Way Viaduct
Analysis of travel patterns indicated that there would be a reduction in east-west traffic from I-5 to the Waterfront and some reduction in north-south traffic from the Aurora exit at Denny Way. Because the resultant gain in air quality was small, that benefit in itself could not justify the estimated expense of constructing additional ramps.
Convert all fleet vehicles to gaseous fuels
While it does result in significant reductions in pollutants in 1973, the gain does not carry forward into the future, as all post1975 automobiles are required to meet emission standards which are roughly equivalent to the emission from gaseous fueled vehicles. As fleet vehicles are newer than the total automobile population, there would be no significant gain by 1977. Additionally, the benefit-cost ratio was very poor.
Build a Regional Rapid Transit System in CBD
A study of the feasibility of a PRT system in Seattle (funded by UMTA) is underway. At this time, the study has not determined the best corridor for PRT development. Should a corridor in the CBD be selected, and should such a system be capable of being in operation by 1977, then the potential positive effects on air quality should be analyzed and included in subsequent revisions of this plan.
Develop Peripheral Parking and Bus Shuttle System
The construction of the King County Domed Stadium at the south end of the CBD would permit the development of a peripheral parking-shuttle system such as has been operating from the Seattle Center for several years. This is not without merit, but it would not affect a large enough number of person trips without direct ramps from I-5 and 1-90. These do not appear feasible by 1977.
Interstate 90
Although the increased traffic in the corridor due to the opening of I-90 may well result in local air quality in excess of primary standards, the exclusive bus lanes (7-year contract) will provide a significant transit service which will generally strengthen the METRO Transit program. This is essential to solving the CBD air quality problem.
Provide Free Bus Service
During the evaluation of the METRO Transit plan, a computer model test was made assuming free transit service. It was found that it did not achieve a significant increase in patronage, while losing substantial fare box revenues. METRO Transit fares are already among the lowest in the nation (as a percentage of average income). Local free service does deserve additional study.
I-5 Ramp Metering and Surveillance
Calculations made by A. M. Voorhees and Associates in the course of conducting the study for EPA indicated that such a system could be expected to improve flow on the Freeway, but could also be expected to divert substantial traffic to city arterials which would move at a slower speed and create as much pollution as was eliminated by the Freeway Improvements. Development of ramp metering would permit the installation of preferential bus ramps. This alternative should be given additional study.
Extend Retrofit Program to All Pre-1975 Vehicles
The cost of a control system to bring a pre-1975 vehicle into compliance with the federal emission standard is expected to exceed $300. This is considered to be an excessive burden on the individual citizen.
Extend Annual Inspection to Include All Vehicles
While this would have some valuable side-effects if it were to include a safety and noise inspection as well, the cost of such a system, the logistic difficulty of testing and implementing such a system by 1977 and the poor experience in some other states makes this an unattractive candidate.
Establish Auto-Free Zones in CBD
Vehicle travel tables indicate that the air pollution problem is not localized in any one portion of the CBD. The establishment of an auto-free zone would benefit only those who happen to be in the zone or work in an office facing into it. The CBD is physically too large to make the entire area an auto-free zone.
Lid Interstate 5 Through the CBD
One theory holds that air pollution in the CBD rises ("urban heat island effect") but is replaced by polluted air flowing down hill from the Freeway. Thus, If Interstate 5 from, roughly Olive Way to Columbia Street were to be enclosed by the construction of a lid, the polluted air could be exhausted and dispersed through high stacks. If exhausted at a high level, it would be distributed over a large enough area that the concentration would not be harmful. This strategy was rejected because the initial engineering analysis indicated that there would be too many "holes" in the lid to make the evacuation of the gases economically feasible.
Exclusion of Certain Vehicles From the CBD
If uncontrolled vehicles were banned from the CBD, or if truck traffic were prohibited or discouraged (by not being allowed the use of loading zones during day-time hours), large reductions could be achieved. Applications of these strategies was rejected because it is too discriminatory and would have an adverse economic impact on the CBD.
Compliance schedules
The following outlines the anticipated anniversary dates for implementing the various elements of the proposed strategies:
Retrofit
July 1, 1973: Legislature provides authority to Department of Ecology for requiring retrofit.
December 30, 1973: Department of Ecology adopts regulations implementing program.
March 1, 1974: Department of Ecology certifies eligible retrofit control systems.
March 1, 1975: Retrofit required at time of ownership transfer on all uncontrolled vehicles (light duty and heavy duty) registered within defined geographic area.
March 1, 1976: All uncontrolled vehicles must retrofit according to the last number of the license plate October– 0, November– l, etc.).
Vehicle Emission Inspection
July 1, 1973: Legislature provides authority to Department of Ecology for requiring inspection.
December 30, 1973: Department of Ecology adopts regulations implementing program, including motor vehicle exhaust emission standards for carbon monoxide.
March 1, 1974: All government and fleet (3 or more) vehicles in King county must pass an annual inspection at a State operated facility.
March 1, 1975: All used vehicles offered for sale and first registered within defined geographic area must pass an inspection at the State operated facilities. Initiate program of spot-checking dealers' lots to insure that vehicles are not intentionally detuned. All retrofitted vehicles must be inspected annually on anniversary of retrofit.
SIGOP
Jane 15, 1973: Complete project. Issue evaluation.
Car Pool Program
July 1, 1973: Legislature provides authority to City of Seattle to regulate parking, initiate consultant selection process for developing an experimental program to test various elements of the system.
December 30, 1973: City budget adopted with adequate funding to support first phase effort.
City adopts ordinances to regulate parking and adopts CBD parking plan.
July 1, 1974: Initiate experimental program and begin evaluating effectiveness. Begin development of expanded program. Determine manpower and resource needs to establish full-time service.
July 1, 1975: Implement fall-scale program which includes most CBD employees in eligible population (assuming experimental program successful).
Uniform Parking Rates and Driver Advisories to Parking Facilities and Destinations
July 1, 1973: Legislature provides authority to City of Seattle to regulate parking. Prepare prospectus for conducting a study to determine cause and magnitude of "search" type trips.
December 30, 1973: City adopts ordinances to regulate parking and adopts CBD parking plan.
Conclude study and evaluate findings. Initiate plan formulation and establishment of local improvement district.
July 1, 1974: Complete plan. Formally develop local improvement district.
July 1, 1975: Execute program.
Increase Transit Ridership
July 1, 1973: Legislature provides authority to City of Seattle to regulate parking and submits constitutional amendment to vote of the people. Funding applications for TIP submitted to EMIT. Studies initiated to determine sites for additional Park 'n Ride lots.
December 30, 1973: City adopts ordinances to regulate parking and adopts CBD parking plan.
July 1, 1974: Additional funding applications for TIP submitted to EMIT. Plans for development of additional Park 'n Ride lots initiated.
July 1, 1975: Additional funding applications for TIP submitted to EMIT. Acquisition and construction of additional Park 'n Ride lots initiated.
Program for Long-Range Planning
Role of Agencies
Different agencies in the Puget Sound region will play a role in the long-range planning for air quality control. These agencies include local agencies such as the City of Seattle, as well as regional, state and federal agencies.
On the regional scale, the Puget Sound Governmental Conference will have a strategic planning role as the agency responsible for regional long-range transportation and land use planning in the central Puget Sound region. In addition, PSGC has the responsibility for reviewing all applications for federal funding of civil projects under the requirements of the Metropolitan Cities Development Act of 1966. Under this act, PSGC reviews projects and certifies as to compliance with regional policies, plans and programs. Further detailing of PSGC plans, policies, and programs to include air quality requirements would ensure that future federally funded studies and projects are compatible with air quality requirements of the central Puget Sound region. The Puget Sound Air Pollution Control Agency, the State Department of Ecology, and the Environmental Protection Agency would be necessarily involved with PSGC in specifying the long-range air quality requirements and in helping to define those PSGC plans, policies, and programs where these requirements would be incorporated.
Further, under the National Environmental Policy Act of 1969 and the State Environmental Policy Act of 1971, agencies are required to submit environmental impact statements with regard to all decisions, including private developments under certain conditions, which "significantly affect the environment." In the future all agencies preparing and reviewing the draft impact statements will have to develop an increased awareness and understanding of air pollution considerations.
Impact of New Transportation Technology and Planning Concepts
With the development of cleaner internal combustion engines, the reductions in air pollution per vehicle will be substantial. Offsetting this is the steady forecasted increase in vehicle travel. By 1990, for instance, vehicle miles of travel in the CBD of Seattle are estimated by the Puget Sound Governmental Conference to increase some 30 percent over 1977 levels. This estimate assumes a modest amount of growth in employment (from 70,100 in 1970 to 105,400 in 1990) and an all-bus transit system as described in the 1980 METRO Transit Plan.
Clearly, considerations other than the 1977 control strategy program are going to be necessary for long-range decision making in the City of Seattle.
The most likely future development that will significantly impact transportation systems and air quality is the emerging energy crisis. Many oil industry sources and federal studies are predicting that the world's known and anticipated oil reserves will be depleted by the end of this century, given our present consumption rate. The crisis will probably follow a classic pattern of significant increases in the cost of fuel and then radical changes to new technology. This will most probably result in sophisticated mass transportation systems and the application of many concepts now well understood in the laboratory.
Several concepts merit attention:
(1) Telecommunications (i.e., picture phones and advanced video systems using laser holograms) can impact considerably the need to travel for business trips. There is every reason to believe that this means of interaction may substitute for a measurable amount of the business travel in the Central Business District. This innovation can also result in a decrease in growth rates of high density nodes by making possible more use of one's home as an office. Decentralization will remove the inconvenience of daily peak hours commuting through highly congested corridors and thus reduce overall travel and resultant air pollution.
(2) A "Personal Rapid Transit System" for the CBD of Seattle offers a high potential for reducing vehicular travel in the core area of the CBD. A logical follow-up on development, more regional in scope, would be a fixed guide-way mass transportation system. This might even include very high-speed ground transportation through the Puget Sound-Willamette corridor from Vancouver, British Columbia to Eugene, Oregon. This offers the highest potential for reducing area wide transportation-created air pollution.
(3) Long range goods movement and passenger transportation planning will definitely need to be coordinated to develop comprehensive transportation plans for the mobility of the region. Combining the movement of freight on fixed right-of-way with mass rapid transit in the denser urban areas will result in a considerable reduction in the amount of truck traffic.
PART IV: EMERGENCY EPISODE PROGRAM
Introduction
Occurrences of excessive levels of air pollution are referred to euphemistically as "episodes" by EPA. Without some procedure being implemented to control or reduce the level of air pollution in a specific area, an episode could result in air pollution levels which would constitute "imminent and substantial endangerment to public health." The federal government through EPA requires that all states formulate a plan specifying the procedures to prevent such air pollution episodes.
EPA has divided these episodes into four stages. The first stage, "Forecast," is activated whenever an Air Stagnation Advisory is issued by the National Weather Service. This is a warning that a high air pollution potential exists due to possible climatic conditions.
The second, or "alert," stage occurs whenever adverse meteorological conditions and pollutants approach levels at which preventive action becomes necessary. At this stage voluntary action by the public to reduce unnecessary driving will be requested with encouragement to use public transportation facilities.
The third, or "warning," stage occurs when indications of farther deterioration in air quality are expected and more restrictive controls are required (short-term health effects possible). Voluntary actions will continue but in those affected areas some restrictive traffic control measures must be put into effect.
The final, or "emergency," stage occurs when air quality continues to deteriorate to a level where the most stringent control actions are necessary to protect the public health from substantial harm. The banning of all vehicles from entering the area and even the closing of businesses are possible control measures.
Table IV-1 outlines EPA's adopted (36 P.R. 15503) episode criteria for each stage, the standards which empirically define each stage and a brief outline of action which should be taken to control pollution concentrations from increasing to a more critical stage.
Each important pollutant has a system which is to be implemented at various stages so as to control and reduce the emission of that pollutant.
In the Puget Sound Region, detailed programs called Source Emission Reduction Plans (SERPS) have been formulated for the control of sulfur dioxide and suspended particulate matter from industrial sources. The Washington State Air Quality Implementation Plan has considerable detail on these procedures. This addendum provides the details of episode procedures for control of motor vehicle generated pollutants (i.e., carbon monoxide, oxidants, and hydrocarbons).
Emergency episode plan
Emission estimates presented in Part I indicate that of the total inventory of air pollutants approximately 95 percent of CO, 81 percent of HC, 81 percent of NOx, 4 percent of SO2 and 15 percent of the particulates are caused by the various transportation modes. Therefore, if an immediate reduction in CO, HC, and NOx is required to curtail an emergency situation, then it must be made through programs emphasizing the emergency control of emissions from motor vehicles.
It is generally expected that high levels of air pollution from motor vehicle emissions will be limited to a small area. Assuming this is correct, emergency control measures might then be classified in the following manner:
(1) those which reduce emissions generated by the vehicle engine
(2) those which restrict the number or size of emission sources
(3) those which restrict or increase the mobility of the source.
One must also keep in mind that these strategies must be aimed at curtailing the advance of any progression to the next higher stage, with emphasis placed on preventive action rather than remedial action after the fact. Each strategy will then become more restrictive as air quality declines until control measures become effective.
The following sections outline proposed guidelines recommended by the Department of Ecology for instituting an Emergency Episode Program. Those guidelines are being presented at this time as potential elements of the program. Over the next few months these elements will be refined and expanded so that a more definitive system can be implemented. A presentation of the Emergency l Episode Program in its final form is anticipated at the end of the first semi-annual reporting period (February 14, 1974).
Communications
The contingency plans for emergency episodes must include provisions for communications procedures for contacting public officials, major sources, and news media. A proposal for a short range program to be implemented during episodes is illustrated in Figure IV-1. Estimated costs to implement this system are included as part of the proposed system for continuous surveillance outlined in Part V: Surveillance Program.
Emergency traffic control area (ETCA)
In order to maximize the flexibility and effectiveness of emergency control measures for motor vehicle traffic, it is necessary that these controls be limited to small, well defined, areas where high pollution levels are concentrated. In other words, there would be little reason to ban the use of automobiles in West Seattle or Ballard during an "emergency" episode in the CBD.
Emergency measures would be required only in those areas where hazardous pollution levels exist.
It is assumed that Seattle's Central Business District is the ETCA in which emergency emission control strategies are to be first implemented. In refining the surveillance system and establishing a clearer picture of Seattle's air pollution problems, it will perhaps be necessary to redefine and expand the ETCA zones or establish other, separate, ETCA zones. Upon receipt of more precise surveillance data, the following criteria will be used to designate what the ETCA's should be:
1. Boundaries should coincide with major streets, highways, or other geographical features generally well known to the. public. Maximum attention should be given to defining boundaries that are easily communicated by the public information media.
2. Consideration should be given to the location of mass transit routes, major traffic patterns, and population concentrations.
3. Consideration should be given to this assumption in defining not only the core area ETCA, but also in designating adjoining areas. In some cases a concentric arrangement, each ETCA partially or totally surrounding the previous one, might be considered.
4. The number of ETCA should be minimized in order to make the plan as uncomplicated as possible.
Based upon the "Episode Criteria" defined in the previous table (Table IV-1), the different episode stages require varying degrees of action. The procedures recommended for each episode stage present generalized strategies and responsible agencies. These must be addressed in greater detail within the next year before they can be successfully implemented.
Forecast stage
This stage occurs upon receipt of an Air Stagnation Advisory from the Meterological Support Unit of the National Weather Service. Upon declaration of forecast conditions:
1. PSAPCA, DOE, EPA Region X are notified.
2. PSAPCA begins additional surveillance of conditions.
3. No specific actions with regard to motor vehicles will be required.
Alert stage
This stage occurs when the pollution levels detailed in Table IV-1 are reached. Upon declaration of an Alert condition:
1. The public is notified through various media of the conditions and the necessary steps to be taken. Public health officials, City engineering departments and public transportation officials will be notified of their responsibilities.
2. The public will be encouraged to utilize public transportation and curtail or eliminate the use of private motor vehicles within the designated Emergency Traffic Control Area.
3. Public transportation systems will provide additional services to encourage greater use of public transportation.
4. Preparations are initiated to take warning measures, if necessary.
5. Additional monitoring pollutant levels instituted.
Warning stage
Upon declaration of this stage:
1. The public is notified through various media of the conditions and the necessary steps to be taken. Public utilities, public health officials, City engineering departments and public transportation officials, will be notified of their responsibilities.
2. Continue Alert measures.
3. Motor vehicles carrying fewer than three persons are to be prohibited from entering or operating within the designated ETCA. Exceptions would be public transportation, emergency vehicles, commercial vehicles and through traffic remaining on Interstate or primary highways.
4. If ordered by DOE, operation of all private vehicles within the ETCA may be prohibited.
5. Maximum public transportation will be provided, possibly at no cost.
6. Prepare to take emergency measures as required.
Emergency state
Upon declaration of an emergency:
1. The public is notified through various media of the conditions and the necessary steps to be taken. Public utilities, public health officials, City engineering departments and public transportation officials will be notified of their responsibilities.
2. All non-emergency use of motor vehicles within the ETCA is prohibited.
Communications manual
A basic tool of the Emergency Episode Program will be a Communications Manual for use by those persons who must react and implement the controls of each episode stage. This manual will include, as a minimum, for each episode stage:
1. Persons and organizations to be contacted including individual names and telephone numbers.
2. Actions to be taken by each official involved in implementing the Plan.
3. Sample announcements by the media and press releases.
PART V: SURVEILLANCE PROGRAM
Introduction
At present the ambient surveillance system for carbon monoxide consists of one continuously recording instrument in the downtown area of the City of Seattle and one at 6770 East Marginal Way South, both operated by the State Department of Ecology. Short term monitoring has been performed for carbon monoxide by the Puget Sound Air Pollution Control Agency at the Westlake Mall and at 1-5 and Dearborn. These sites are shown in Figure 1-2.
To base a decision as to whether a problem exists on the data from a single station is, of course, open to challenge. On the other hand, no criteria have been established as to what an adequate number of stations would be or where they should be located.
It is not possible to totally monitor an entire area thought to be affected. However, computerized atmospheric diffusion modeling, as discussed in Part I, can provide a vital supplementary effect since it permits the estimation of the pollutant concentrations at points not served by monitoring instruments. With diffusion models, a more refined estimation of the severity of the problem can be made than is possible with the use of proportional formulas. It is possible that adequate air quality monitoring would show that the extent of transportation controls needed is different from that presently contemplated.
The need for real-time communications during episodes is illustrated by the following example. On October 18, 17, and 18, 1972, during a forecast stage, there were 16 occasions when the federal episode alert level for carbon monoxide was reached or exceeded at the James Street monitoring station in Seattle. The sensor used at this station is not connected to a real-time system, and it was not possible to implement the notification strategies detailed in Part IV.
Surveillance system
A minimum of seven non-dispersive infrared CO monitoring stations will be operated continuously in the Seattle area, three of which would be located in the CBD. In addition, ten nitrogen oxide monitors will be established in the Puget Sound Intrastate region to provide comprehensive monitoring. At present no hydrocarbon monitors which meet EPA specifications are available.
Meteorological and air quality data must also be available to meteorologists and air pollution engineers. These data must then be interpreted and made available in usable form to the responsible control strategy authority.
PART VI: INTER-GOVERNMENT COOPERATION AND RESOURCES
Introduction
The task of controlling air pollution, because of its magnitude, cannot be expected to be carried out by a single agency. Since air pollution is an area- or region-wide problem its solution is dependent upon a multitude of responsibilities, skills and coordination. While the City of Seattle can implement various strategies, the City cannot be expected to bear the full burden of the economic impact within its own business community, nor can the City be expected to provide a surveillance system and sophisticated predictive air pollution and transportation models for evaluating strategies and air pollution. If an effective air quality improvement program is to be implemented the City and the Department of Ecology must involve other agencies in the solutions.
In developing this document, two committees and a private consultant were the resources which the City and DOE depended upon. Although such committees are essential to an on-going program and should retain their important role, the function provided by the consultant should ultimately be replaced, in kind, with staff personnel and resources equipped to implement the plan over the next five years.
Systems management provides many techniques which are useful for designing a mechanism by which many groups and elements can be coordinated and monitored. With a system defined, resource requirements can be determined and the elements of the control program implemented. Using available management tools for the air quality program, three basic systems can be identified. Those are: (1) Program formulation and initiation, (2) Program monitoring, updating and revisions, and (3) Program implementation.
Program Formulation and Initiation
Part II: Citizen Involvement has described the steps utilized in formulating this plan. Figure II-1 of Part II outlines past events and future activities. Attainment of required legislation, the formulation of regulations and administration policies and the adoption of the proposals of the plan herein by EPA are unfinished events that remain to be completed in the initiation phase. The resources depended upon during the phase will include citizen organizations, the Inter-Government Technical Committee, and local and state legislative bodies.
Program Monitoring, Updating and Revisions
The process illustrated in Figure VI-1 provides a means by which program control and effectiveness can be monitored, evaluated, updated and revised. As is indicated in Figure VI-1, many agencies are involved in the various parts of that process.
The first element involves weather surveillance and air pollution monitoring. The Department of Ecology is presently seeking a revision of its current fund grant from EPA in order to provide the surveillance described in Part V. One output from the monitoring system will be the quarterly air quality report.
If monitoring indicates the strategies are working to improve air quality then the program will continue without revision. However, if the air quality does not appear to be responding to the plan, the City and DOE must take steps to expand the program and include other strategies. If, and when, new strategies are developed, public hearings and EPA approval are required before this plan can be amended. Upon adoption of the new strategy, implementation, monitoring and review will continue in a cyclic manner until the air quality goals are achieved and maintained.
Program Implementation
The third system is the implementation of the control strategies recommended in Part III: Transportation Control Program. Table VI-1 provides a summary of work to be completed for each strategy, estimated cost for the first two years, potential funding sources and agencies responsible for implementation. EPA (36 F.R. 15493) request projections of the extent to which resources will be acquired at 1-, 3-, and 5-year intervals. Table VI-1 represents the first two years of the implementation program. To proceed with estimates for those strategies such as car pools, transit incentives, and parking controls without knowing the details and results of the first two years of study and experience would be difficult to justify. Therefore, cost estimates beyond the first two years are being deferred until more meaningful estimates can be made.
APPENDIX A – GENERAL FACTS ABOUT SIX MAJOR POLLUTANTS
Source: "A Citizens Guide to Clean Air"; The Conservation Foundation; Washington, DC.; January, 1972.
WHAT WE KNOW ABOUT OXIDES OF SULFUR
Major source: fuel combustion.
Minor sources: chemical plants, metal processing, trash burning.
Nature: Sulfur is a nonmetallic element found in coal and fuel oil. When these fuels are burned, sulfur joins with oxygen in the air to form gaseous oxides of sulfur, including dioxide (SO.) and sulfur trioxide (SO.).
Effects: Sulfur oxides, in combination with moisture and oxygen, can yellow the leaves of plants, dissolve marble, and eat away iron and steel. They can limit visibility and cut down the light from the sun. They can affect man's breathing: at sufficiently high concentrations, sulfur dioxide irritates the upper respiratory tract; at even lower concentrations, when carried on particulates, it appears able to do still greater harm by injuring lung tissue.
Conclusions found in the federal criteria document: The criteria Resume for sulfur oxides reports that increased mortality occurred when the annual geometric mean was as high as 115 micrograms per cubic meter. Adverse effects can be detected when SOx pollution exceeds certain levels for short periods of time. These effects are especially evident in the case of sulfur dioxide. Levels of 300 micrograms per cubic meter of SOx for three or four days have been associated with a variety of adverse health effects.
WHAT WE KNOW ABOUT PARTICULATE MATTER
Source: Pollutants can exist as solid matter, liquid droplets, or gas. Both the solid and liquid matter are called particulates (which simply means particles in the atmosphere). Solid particulates consist of dust, smoke or fumes; liquid particulates are mists and sprays. Particulate pollution results from many kinds of industrial and agricultural operations and from combustion products, including automobile exhausts.
Effects: Particulate matter in the respiratory tract may produce injury by itself, or it may act in conjunction with gases, altering their sites or their modes of action. Particles suspended in the air scatter and absorb sunlight, reducing the amount of solar energy reaching the earth, producing hazes and reducing visibility. Particulate air pollution causes a wide range of damage to materials. It may chemically attack materials through its own intrinsic corrosivity or through the corrosivity of substances absorbed or adsorbed by it. Merely by soiling materials and thereby necessitating more frequent cleaning, particulates can accelerate deterioration.
Conclusions found in the federal criteria document: The criteria Resume reports that adverse health effects were noted when the annual geometric mean for particulate matter reached 80 micrograms per cubic meter.
WHAT WE KNOW ABOUT CARBON MONOXIDE
Major source: Internal combustion engines in motor vehicles, primarily the automobile.
Minor sources: various industrial processes, solid waste disposal.
Nature: Carbon monoxide, an invisible, odorless, and tasteless gas, is formed when any carbon-
containing fuel (gasoline, coal, and so on) is not completely burned to carbon dioxide (C02), but only half-way to carbon monoxide (CO). Because of its characteristics, the internal combustion engine, especially in cars, is responsible for by far the largest fraction of man-made emissions of carbon monoxide.
Effects: Compared to other common air pollutants, carbon monoxide has a unique mechanism of action. It does not irritate the respiratory tract but rather passes through the lungs directly into the blood stream. There it combines with the red blood cell's hemoglobin, the substance that normally carries oxygen to all the tissues of the body. Because hemoglobin binds carbon monoxide over 200 times as strongly as oxygen, a low concentration of carbon monoxide in the ambient air has a greatly magnified effect on the body. Since the heart and brain are the two tissues most sensitive to oxygen deprivation, they show the most serious effects from carbon monoxide exposure. Thus at high concentration (1000 ppm and more), carbon monoxide kills by paralyzing normal brain function. At much lower levels, effects on these two tissues are also the predominate ones (see below).
Because of its unique mode of action, carbon monoxide is not known to have adverse effects on vegetation, visibility, or material objects.
Conclusions found in the federal criteria document: The criteria Resume reports that exposure to 35 mg/ms (30 ppm) will, after a few hours, inactivate about 5% of the blood's hemoglobin, thus lowering its oxygen content. This loss can impair performance on certain psychomotor tests, indicating a significant effect on brain function. At higher exposures, excess strain is put on patients with heart disease. Exposure to 12-17 mg/ms (10-15 ppm) for several hours also affects the brain by altering time interval discrimination. In addition, there is some very preliminary evidence that at even lower weekly average levels of carbon monoxide (9-16 mg/ms or 8-14 ppm), people hospitalized for heart attacks have increased death rates.
WHAT WE KNOW ABOUT PHOTOCHEMICAL OXIDANTS
Nature: Photochemical oxidants are several different pollutants (notably ozone and a group of chemicals called peroxyacylnitrates or PAN) which can come from several sources. All of those pollutants share three properties;
1. They are all formed by the chemical reaction of other pollutants ("-chemical").
2. The reactions forming them proceed much more rapidly in areas with intense sunlight ("photo-").
3. They are extremely reactive chemical substances, acting as oxidizing agents ("oxidants").
Among the most effective combinations for producing this class of pollutants are the oxides of nitrogen and reactive hydrocarbon (organic) vapors. Los Angeles, with its sunny climate and high number of cars, offers extremely good conditions for the production of photochemical oxidants, and in fact this pollution comprises the main part of that city's infamous smog. It is not confined to Los Angeles, however. The constituents of photochemical smog can now be readily detected in many metropolitan areas.
Effects : The various components of photochemical oxidants can have several adverse effects. First, they can directly affect the lungs and eyes of people, causing respiratory irritation and possibly changes in lung function, as well as subjective eye irritation. They are extremely toxic to many kinds of plants, affecting primarily the leaves. In addition, they can physically weaken such materials as rubber and fabrics.
Conclusions found in the federal criteria document: The criteria Resume for photochemical oxidants reports impairment of the performance of student athletes occurred over a range of hourly oxidant levels from 60-590 ug/ms (0.03-0.3 ppm). Increased frequence of attacks in some people with asthma have been observed when hourly averages, as determined from peak measurements, were 100-120 ug/ms (0.05-0.06 ppm). Eye irritation occurs in people at once upon exposure to about 200ug/ms (0.10 ppm); this is roughly equivalent to an hourly average of
60-100 u9/1118 (0.03-0.05).
Adverse effects on vegetation have been noted at levels of about 100 ug/ms (0.05 ppm) maintained for four hours. Damage to materials, while clearly observed at levels present in many cities, has not been accurately quantitated at this time.
WHAT WE KNOW ABOUT HYDROCARBONS
Major source: internal combustion engines in motor vehicles, primarily the automobile.
Minor sources: evaporation of organic solvents (from painting, dry cleaning, etc.), agricultural burning, gasoline marketing
Effects: At levels of hydrocarbons currently measured in urban areas, no adverse human effects are known to be caused by the hydrocarbons in isolation. However, as discussed in the section on photochemical oxidants, hydrocarbons are an extremely important component of photochemical oxidants, whose effects have been observed. Thus the effects of photochemical oxidants can be, in part, traced back to the hydrocarbons. These, outlined earlier, include respiratory irritation, plant damage, and damage to materials.
Certain specific hydrocarbons do have other effects. Ethylene, for example, damages plants; it can inhibit growth and cause the leaves and flowers to fall.
Conclusions found in the federal criteria document: The criteria Resume clearly states that damaging levels of photochemical oxidants are directly related to concentrations of hydrocarbons in the air which are, if alone, without effect. The Resume states that hydrocarbon concentrations (excluding methane) of 200 ug/m (0.3 ppm as carbon) for three hours may produce photochemical oxidant levels of up to 200 ug/m (0.10 ppm) a few hours later. If the relationship holds true at lower levels of photochemical oxidant known to be damaging, the hydrocarbon concentration that may be associated with adverse effects is about 100 ug/ms (0.15 ppm )
WHAT WE KNOW ABOUT OXIDES OF NITROGEN
Major source: fuel combustion
Minor source: chemical plants
Nature: Nitrogen gas, normally a relatively inert (unreactive) substance, comprises about 80 percent of the air around us. At high temperatures (and also under certain other conditions), it can combine with the oxygen in the air to form several different gaseous compounds collectively called the oxides of nitrogen (NOx). Nitric oxide (NO) and nitrogen dioxide (NOx) are the two most important.
Effects: Until recently, it has been difficult to obtain equipment that can detect the oxides of nitrogen in polluted air. Therefore, less is known about these effects than is known, for example, about the effects of oxides of sulfur. Nevertheless, it is clear that the oxides of nitrogen can, at certain concentrations, cause serious injury to vegetation, including the bleaching or death of plant tissue, the loss of leaves, and a reduced growth rate. Oxides of nitrogen can also cause fabric dyes to fade and fabrics themselves to deteriorate. Nitrate salts, formed from the oxides of nitrogens, have been associated with the corrosion of metals. Finally, NOx can reduce visibility.
Certain members of this group of pollutants are known to be highly toxic to various animals, as well as to man. High levels can kill; lower levels affect the delicate structure of lung tissue. This leads, in experimental animals, to a lung disease that resembles emphysema in man. Exposure to NOx lowers the resistance of animals to such diseases as pneumonia and influenza; the same may possibly occur in man. Exposure to high levels causes humans to suffer lung irritations and potential damage. Exposure of people to lower levels has been associated with increased respiratory disease.
In addition, oxides of nitrogen, in the presence of sunlight, can react with hydrocarbons to form photochemical oxidants.
Conclusions found in the federal criteria document: The criteria Resume states that a higher incidence of chronic bronchitis has been found in children living in areas where daily averages of NOx varied from 118 to 156 ug/m (0.062 to 0.083 ppm) and where nitrate salts in the air were also at elevated levels. Adverse effects on plants have been observed when NOx levels exceed 470 ug/m (0.25 ppm) for several months. Corrosion and damage to electrical equipment has occurred when elevated levels of nitrate salts and NOx levels of 124 to 158 ug/m (0.066 to 0.084 ppm) were present. Limited evidence suggests that somewhat higher levels of NOx (roughly 214 ug/ms or 0.11 ppm) in the morning hours may be associated, under certain conditions, with the production later in the day of photochemical oxidant levels harmful to human health.