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HomeMy WebLinkAboutAGENDA REPORT 1991 0501 CC REG ITEM 08GITEM& - C7• MOORPARK 799 Moorpark Avenue Moorpark, California 93021 (805) 529 -6864 C:4= of 199 ACTION; M E M O R A N D U M By To: The Honorable City Council From: Patrick J. Richards, Director of Community Development Date: April 23, 1991 (City Council Meeting 5 -1 -91) Subject: Traffic Systems Management (TSM) BACKGROUND Under provisions of the Federal Clean Air Act and in an attempt to meet adopted Federal Clean Air Standards, Ventura County has developed an Air Quality Management Plan (AQMP) which is a comprehensive planning document intended to provide guidance to the APCD, the County, and other local agencies on how to progress toward attainment of the ozone standard. The original AQMP was prepared in 1979 and was revised and updated in 1982 and 1987. The AQMP focuses on the ozone non - attainment problem in Ventura County. The AQMP includes stationary source, area sources, mobile source, and transportation control measures to reduce emissions of air pollutants. In addition to implementing these controls, progress toward achieving the national ambient air quality standards for ozone depends upon adherence to population and industrial growth forecasts outlined in the AQMP. Even with adoption of recommended control measures, the AQMP projects that emissions of ozone precursors will begin to increase in the County over the next decade. After 1995, emissions are projected to increase because emissions associated with population and economic growth in the County will overtake decreases associated with anticipated emission controls (1987 AQMP, pages VII -3 and VII -4). The plan does not address control strategies for particulate matter. PAUL W.LAWRASON JR. BERNARDO M.PEREZ SCOTT MONTGOMERY ROY E. TALLEY JR. Mayor JOHN E WOZNIAK a or Pro Tern Councilmember Councilmember Counr 'member a Compliance with Federal Clean Air Act In accord with the Federal Clean Air Act, as with all non - attainment areas, Ventura County was required to attain the national ozone standard by December 1987 to avoid Federal sanctions for violation. Since attainment appeared unlikely, in 1984 the APCD agreed to participate in EPA's Reasonable Extra Efforts Program as part of the District's commitment to do everything technically feasible and economically reasonable to reduce emissions and improve air quality in Ventura County. District programs were improved to reflect EPA recommendations resulting from the program. Several areas, including Ventura County, did not attain the ozone standard by the 1987 deadline. However, sanctions were not imposed because the deadline was extended to August 31, 1988, while members of Congress and the EPA formulated varying policy packages regarding post -1987 guidelines for attainment of the Federal ozone standard. As possible amendments to the Clean Air Act, these policy packages generally require attainment of the standard by a specific date, and emission reductions by about 3 percent per year based on the implementation of different control measures. A policy package was not adopted by August 31, 1988. The EPA recently disapproved the 1982 County AQMP because it was unable to demonstrate attainment of the Federal Ozone Standard by December 31, 1987. The EPA imposed a major source construction ban that became effective October 1988. This ban on volatile organic compounds precludes any large new emission sources or major modifications to existing emission sources on the scale of a refinery or other large facility. In a letter to the County APCD dated September 15, 1987, the EPA stated that more aggressive binding commitments must be shown by all local jurisdictions in the County to implement transportation control measures with specific adoption schedules before the EPA can conclude that all "reasonable efforts" are being made to avoid Federal funding sanctions. Compliance with California Clean Air Act On January 1, 1989, the California Clean Air Act (AB2595) became effective. This State legislation imposes many new requirements on areas of California (including Ventura County) that do not meet State and Federal Clean Air Standards. Pending review by the State Air Resources Board (ARB) by August 30, 1989, Ventura County is likely to be classified as a severe non - attainment area, because the 1987 AQMP is not able to specify an attainment date for meeting the State or Federal standards as discussed above. As a severe non - attainment area, Ventura County would be required to implement several measures necessary to reach attainment, including among others, TSMs to achieve an average commute ridership of 1.5 by 1999, and no net increase in vehicle emissions after 1997. 2 3 The role of the APCD and the State ARB in achieving attainment of the standards is outlined in the Act, which also outlines the progress schedule that must be included in district plans for attainment (these plans are due to the Air Resources Board in July, 1991). If a plan cannot show attainment and the ARB agrees, the ARB will determine whether the plan contains all feasible measures to ensure progress toward attainment. The ARB can return deficient plans for revision and resubmittal. If conflicts cannot be resolved, the ARB has authority to revise the plan as necessary. Impact Assessment Guidelines and Thresholds The 1988 AQMP indicates that the ozone standard will not be attained any time in this century in the Oxnard Plain Airshed given current emission controls and controls scheduled for adoption. Based on this finding, a determination of consistency with the AQMP no longer provides an acceptable method for determining the air quality impact of an individual project. Thus, in response to California Environmental Quality Act (CEQA) Guidelines and conditions of approval for the 1988 AQMP required by the Air' Resources Board, the APCD has revised local guidelines for preparing air quality impact analyses. These revised Guidelines were adopted by the Ventura County Board of Supervisors in October, 1989. All proposed projects are studied pursuant to both Ventura County and CEQA guidelines to determine if the project would have either short or long term effects on the ambient air quality of the area. STATE CEQA Guidelines state that a project will have a significant effect on the environment if it will violate any ambient air quality standard, contribute substantially to an existing or projected air quality violation, or expose sensitive receptors to substantial pollutant concentrations. Recently revised and adopted Ventura County impact assessment guidelines recommend that a determination of significant project specific and cumulative effects should be made in cases where sensitive receptors are exposed to substantial pollutant concentrations. Explicit criteria for determining if a project exceeds an air quality threshold are provided in the Ventura County Air Ouality Impact Analyses Guidelines (October 1989). Relevant thresholds are highlighted in bold print. A project exceeds County thresholds if any of the following conditions are met: 3 4' la. Any general development project located in the Ojai Valley Clean Air Ordinance area and Ventura 1 Nongrowth area capable of daily emissions of: Reactive Organic Compounds: 5 pounds Nitrogen Oxides: 5 pounds lb. Any general development project located in the remainder of the ozone non - attainment area of the County capable of daily emission of: Reactive Organic Compounds: 25 pounds Nitrogen Oxides: 25 pounds These are thresholds for projects that the Ventura County Air Pollution Control Board has determined will individually and cumulatively jeopardize attainment of the ozone standard and thus have a significant adverse impact on air quality in the County. 2. A project which may cause an exceedance of any ambient air quality standard (State or Federal), or makes a substantial contribution to an existing exceedance of an air quality standard. Substantial is defined as making measurably worse an existing exceedance of a State or Federal ambient air quality standard. 3. Any project with emissions greater than two pounds per day of ROC, or two pounds per day of NOx, that are found to be inconsistent with the Ventura county Air Quality Management Plan (AQMP) will have a significant cumulative adverse air quality impact. Projects with emissions below two pounds per day of ROC, and two pounds per day of NOx, are not required to assess consistency with the AQMP. Inconsistent projects are usually those which cause the existing population to exceed the population forecasts contained in the most recently adopted AQMP beyond 1995. 4. Any General Plan Amendment or revision which would provide directly or indirectly for increased population growth above that forecasted in the most recently adopted AQMP will have a significant cumulative adverse air quality impact. 4 5 Contribution to an Off -Site TSM Fund Any project which will have a significant air quality impact should attempt to fully mitigate the impact through the mitigation measures described previously. If a project still has a significant impact after all other quantifiable mitigation measures have been applied, emissions should be bought down through a contribution to the city's TSM fund established specifically to reduce emissions from transportation sources. That is, the remaining emissions in excess of the significance threshold are to be mitigated by funding TSM programs or clean -fuel vehicle programs, which will reduce trips and VMT (Vehicle Miles Traveled). This buydown applies to commercial, industrial, and residential projects. Public transit and ridesharing are two obvious TSM strategies which could reduce motor vehicle trips and emissions if provided additional funding. In the eastern half of the County, the cities of Moorpark, Camarillo, Fillmore, Simi Valley, and Thousand Oaks operate fixed -route transit services primarily within their cities. In the western half of the County, South Coast Area Transit operates fixed -route service in the cities of Ojai, Oxnard, Port Hueneme, Santa Paula, and Ventura, plus unincorporated areas of the County. All of these services have fiscal constraints which limit their ability to expand services. Even with a substantial increase in funding, it is highly unlikely that public transit will be used for home -to -work commuting by more than about 5% of commuters, and it is unlikely that public transit will be used widely for other types of trips when an automobile is available. However, public transit will undoubtedly continue to be a very valuable, highly utilized service for those without access to automobiles. Ridesharing offers more promise for reducing motor vehicle trips than public transit since it has the potential of attracting up to 25% or more of commuter trips. In Ventura County, Commuter Computer provides computerized rideshare matching services. In fiscal year 1988 -89, Commuter Computer received approximately $81,000 for computerized ridshare matching services. Caltrans matched this money for a total of $162,000. Based on a 1990 County employment level of 236,477, this is less than $0.69 per employee annually to reduce and consolidate trips. In order to significantly reduce emissions in Ventura County, it is imperative that adequate funding be provided to reduce motor vehicle trips which represent nearly 50% of the County's air pollution problem. In fiscal year 1987 -88, the cost to Commuter Computer was approximately $129.00 to place one person in a ridesharing arrangement. This figure is derived by dividing Commuter Computer's annual budget by the number of people placed in ridesharing arrangements during the fiscal year. According to a 1987 Commuter Computer Placement Evaluation Report, the average ridesharing arrangement lasts 2.75 years, and based on the 1987 AQMP Appendix R -87, the average ridesharing commute distance is 15.8 miles. 5 (0 In Determining the Amount of Contribution The cost of reducing emissions through a contribution to an off - site TSM fund can be determined using the Equation 1 shown below. The cost should be calculated separately for ROC and NOx. The amount of the contribution is based on only the higher of the two costs since TSM funding will result in implementation of programs which reduce both pollutants. Usually, the cost to mitigate ROC emissions will be greater than the cost to mitigate NOx emissions because the cost per pound reduced through TSM funding is greater for ROC emissions than for NOx emissions. Equation 1• AC (ROC or NOx) where: AC (ROC or NOx) EE = EE (ROC or NOx) x UC (ROC or NOx) xD = Annual cost of ROC or NOx reduced = Excess emissions in lbs. per day UC = Unit cost per lb. of ROC reduced (ROC or NOx) or per lb. of NOx reduced D = Days of operation per year This method of determining a TSM contribution results in an annual cost to fully mitigate both ROC and NOx emissions associated with a project to below the 5 pounds per day threshold in the Ojai Valley Clean Air Ordinance (CAO) area and the Ventura 1 Nongrowth area, or below the 25 pounds per day threshold in the remainder of the ozone nonattainment area of 'the County (this includes Moorpark). In fact, because the contribution will usually be based on the cost to mitigate ROC emissions, there is likely to be a net air quality benefit for NOx emissions. In theory, the funding should occur for the life of the project, or until the federal and state air quality standards have been achieved. At a minimum, the Ventura County APCD recommends that all projects with significant air quality impacts fully mitigate the excess emissions through a TSM buydown for at least three years. A project which uses a three -year buydown is considered to have lessened or reduced the significant environmental impact. A buydown program of this nature is an important mechanism for reducing emissions from motor vehicles because funding for TSM programs also serves to increase public awareness of air quality as a valuable resource. The cost may seem high for a large project, but considering the significant unmitigatable air quality impacts over the life of the project, a contribution which fully mitigates the impacts for just three years is very reasonable. Furthermore, the three year contribution is still very cost effective when compared to stationary source controls whose annualized cost can be several times as much per pound of emissions reduced. VA Guidelines for Use of Off -Site TSM Funds A jurisdiction which requires a project to contribute to a TSM fund may, for example, choose to fund Commuter Computer. Generally, the funding of ridesharing assistance programs will result in the largest reduction of air pollutants. A jurisdiction may also use funds collected on the basis of contribution necessary to mitigate emissions for the construction of off -site TSM facilities, including park and ride lots, bicycle paths, transit shelters and bus pullouts, freeway High Occupancy Vehicle (HOV) lanes, and HOV ramp metering bypass lanes. TSM funds may also be used for programs to reduce emissions from motor vehicles such as a clean fuels vehicle acquisition program if collected for that purpose. The funds may also be used for operational programs including public transit services, or vanpool subsidies. Decisions regarding which TSM programs are supported are made by the local jurisdiction not APCD. According to the APCD the following conditions should apply to the use of TSM funds and all accumulated interest earned from the funds: 1. The approving jurisdiction should determine the basis for collection and how the funds are to be spent. The funds should be spent or committed to a project within five years of receipt of the funds. 2. TSM funds must be used for projects or programs in the airshed in which the proposed project will be located (i.e. either the Oxnard Plain Airshed or the Ojai Valley Airshed). Ridesharing arrangements or public transit services which originate outside the airshed but which serve the airshed are also eligible uses of the funds. 3. The approving jurisdiction should establish a TSM fund to receive and hold the funds until such time as the funds are spent on an approved project or program. 4. Moorpark TSM funds should not be used for traffic engineering projects, including signal synchronization, intersection improvements, and channelization, as the benefits from these projects are primarily traffic - related and not air quality - related. 5. Any TSM facilities provided by a project to mitigate its emissions prior to determining the buydown contribution should not be credited toward the funds paid by the project as a buydown mitigation measure. 6. A project which is to be developed in phases should calculate the pro -rata share of funding from each phase of development based on emissions for the year of complete buildout. Such pro -rata share of funding should be paid in one lump sum or spread out evenly over three years in order to minimize the initial cost and provide a stable funding source. 7 In 7. The calculation and use of a contribution to a TSM fund must be in accordance with all applicable statutory requirements. Attached is additional information related to Traffic Systems Management from Appendix "D" of the APCD Guidelines. Staff Recommendation Receive and file this report. Attachments: ITEMS WHICH SHOULD BE INCLUDED IN TDM PLANS FOR COMMERCIAL /INDUSTRIAL PROJECTS INSTRUCTIONS FOR PREPARING THE TARGET COMBINATION OF TRIP REDUCTION MEASURES PROJECTED TO ACHIEVE A 1.35 AVR ITEMS WHICH SHOULD BE INCLUDED IN TDM PLANS FOR RESIDENTIAL PROJECTS: EXHIBIT A: EXAMPLE OF TARGET COMBINATION OF TRIP REDUCTION STRATEGIES FOR A HYPOTHETICAL COMPANY WITH 300 EMPLOYEES & TRAVEL PATTERNS APPENDIX E: SAMPLE CALCULATIONS FOR MITIGATING EMISSIONS THROUGH AN ON -SITE TDM PROGRAM AND CONTRIBUTION TO AN OFF- SITE TDM FUND PJR /CCIMAY91 cc: Steven Kueny, City Manager E': 9 so ITEMS WHICH SHOULD BE INCLUDED IN TDM PLANS FOR COMMERCIAL/ INDUSTRIAL PROJECTS: 1. General description of the project: A- Types of businesses and projected employment by business type. Where information is available, TDM plans should include an approximation of the percent of employees by type (e.g. clerical, professional, part-time, etc.). B. Description of any unique aspects of the project (e.g. project phasing, relocation of existing businesses, peak business season, etc.). C. Parking spaces: - Total number of.off- street spaces and proposed parking fees - Number of carpool /vanpool spaces and proposed fees - Availability of free on- street parking -r l E D, Site map showing buildings by type of business. Where applicable, site map should show location of preferential carpool / vanpool parking and placement of bicycle lockers and /or racks. E. Project vicinity map showing street network, and any existing and proposed bicycle lanes /paths and, park and ride facilities. Project vicinity map should also indicate any impediments to bicycle or pedestrian travel (e.g. railroad tracks, flood control channels, etc.). F. Description of public transit services serving project. 2. Description of any design features and facilities to encourage TDM. For example: - On -site banking services or automatic teller machine - On -site postal services - Cafeteria or restaurants 3 u /b 10 - Participation with nearby employers /developers in a transportation management organization (TMO) E. Annual performance reporting and TDM plan updates. Performance reports to the local jurisdiction and APCD should include the current AVR and a description of the TDM incentives provided. See Rule 210, Trip Reduction Plan, for a description of the survey methodology used for determining current AVR. 4. Other items to be addressed in a TDM plan: A. The plan should specify a stable funding mechanism (e.g. tenant lease agreements, parking fees, association dues, etc.) for staffing the TDM program and the ongoing incentives. B. Exact - wording of all proposed Covenants, Conditions, and Restrictions (CC&Rs) and /or lease agreements which relate to TDM. C. Description of any proposed program to reduce the impacts of motor vehicle emissions from public travel to the project. For example, delaying public business hours to after 10:00 a.m. whereby the traffic emissions are less likely to form ozone later that day than emissions from the early morning peak commute hours. D. Discussion of the methodology and emission reductions from anv other proposed mitigation measure which reduces trips and /or vehicle miles. travelled. 0 C. The TDM plan should include the target combination of trip reduction measures which will achieve the 135 AVR. The target combination should project the number of employees who will commute to work by each ridesharing mode and by bicycling and walking. It should project the number of employees who will be on a compressed work week indicating the type of schedule and it should project the number of employees who will telecommute, indicating the frequency they will work at home. See the last section of this Appendix on Instructions for Preparing Target Combination of Trip Reduction Measures Projected to Achieve 135 AVR and Exhibit A for an example of a worksheet and target combination of strategies for a hypothetical company. D. List of ongoing incentives which will be provided in order to achieve the 135 AVR target. The Iist should specify when incentives will be provided, a s description of how each incentive will be marketed to the employees, and the estimated costs. Examples of ongoing TDM incentives include: - Provision of ridematching services (e.g. Commuter Computer) - Marketing of TDM services with direct financial incentives - Operation of a commuter information center ( ridesharing store) - Use of fleet vehicles for personal needs by ridesharing employees - Provision of day care facilities - Parking management including employee parking fees - Employer- sponsored and /or subsidized vanpools - Provision of shuttle bus and /or extension of existing public transit services - Subsidized transit passes available to employees - Flexible work schedules for transit users, bicyclists, and pedestrians - Compressed work schedules and telecommunications - Longer business hours in support of compressed work weeks /4R 40 INSTRUCTIONS FOR PREPARING THE TARGET COMBINATION OF TRIP REDUCTION MEASURES PROJECTED TO ACHIEVE A 1.35 AVR The target combination of trip reduction measures projected to achieve a 1.35 AVR should be based on a weekly averaging period to reflect the fact that employees rideshare only part -time. The target combination should utilize the following assumptions: - Average of 2.2 persons per carpool - Average of 9.0 persons per vanpool - Transit vehicles are not counted in trip totals - Carpool, transit, walk, bicycle mode frequency 4 days per week; 5th day employees drive alone. - All telecommuting employees drive alone - All employees on compressed work weeks drive alone See F_ hibit A for an example of a worksheet and target combination of strategies projected to achieve a 1.35 AVR for a hypothetical company of 300 employees.. 0 /3 Milo ITEMS WHICH SHOULD BE INCLUDED IN TDM PLANS FOR RESIDEti'ITAL PROJECTS: 1. General description of project: A. Number and type of residential units. B. Description of any unique aspect of the project (e.g. project phasing, etc.). C. Project vicinity map showing street network, local public and private primary and secondary schools, any existing and proposed bicycle lanes /paths, and park and ride facilities. Project vicinity map should also indicate any impediments to bicycle travel (e.g. railroad tracks, flood control channels, etc.). D. Description of public transit services serving the project. l 2• Description of any design features to encourage TDM. For example: 1 - Bike lanes /paths 1 - Sidewalks - Bus pullouts, bus stop shelters and benches - Pedestrian access to bus stop - Park and ride facilities 3. Other items to be addressed in a TDM plan: A. Exact wording of all proposed CC &Rs and /or lease agreements -hich relate to TDM. r Iq Now EXHIBIT A: Example of target combination of trip reduction strategies for a hypothetical company with 300 employees and the following travel patterns: 84 employees (28 %) commuting in a mode other than drive alone or motorcycling 30 employees (10 %) telecommuting 2 days per week 90 employees (30 %) on 4/40 work schedules Employee Total (F) 300 Number A.M. Persons Mode Commute Parti- (D) = A(5-B) per Freq. —)-lode ci atin 55 vehicle per week (A) + ( 55x 1) = 155 5 (B) Drive alone 205 / 1.0 x 5 = Motorcycle 11 / 1.0 x 5 = Carpool 55 / 2.2 x 4 = Vanpool 9 / 9.0 x 5 = Transit 9 4 `Valk 5 4 Bicycle 6 4 Employee Total (F) 300 Less number telecommuting: 30 employees x 2 telecommuting days per week x 1 trip per day = ( 60 Less number on 4/40 work schedules: 90 employees x 1 day per week x 1 trip per day = ( 90) AVR Calculation (F x 5 divided by G): 300 employees x 5 trips per week 1,110 Total A.M. vehicle trips per week Total A.M. Vehicle trips per week (G) 1,110 = 1.35 AVR i Correction A.M. Subtotal for drive alone days Vehicle trips per meek (C) (D) = A(5-B) (E) = C= D 1,025 + (205 x 0) = 1,025 55 + ( 55 x 0) = 55 100 + ( 55x 1) = 155 5 + ( 9x0) = 5 0 + ( 9x1) = 9 0 + ( 5x1) = 5 0 + ( 6x1) _ 6 1 Subtotal A.M. Vehicle trips per week 1,260 Less number telecommuting: 30 employees x 2 telecommuting days per week x 1 trip per day = ( 60 Less number on 4/40 work schedules: 90 employees x 1 day per week x 1 trip per day = ( 90) AVR Calculation (F x 5 divided by G): 300 employees x 5 trips per week 1,110 Total A.M. vehicle trips per week Total A.M. Vehicle trips per week (G) 1,110 = 1.35 AVR i /5 APPENDIX E SAMPLE CALCULATIONS FOR (MITIGATING EMISSIONS THROUGH AN ON -SITE TDM PROGRAIM AND CONTRIBUTION TO AN OFF -SITE TDM FUND r . f - 1 /6 goo= APPENDIX E: SAMPLE CALCULATIONS FOR MITIGATING EMISSIONS THROUGH AN ON -SITE TDM PROGRAM AND CONTRIBUTION TO AN OFF -SITE TDM FUND Project Description: 300,000 sq. ft. light Industrial open 250 days per year 25,000 sq. ft. Shopping Center open 308 days per year 9,000 sq. ft. High Turnover Restaurant open 365 days per year Year of Completion: 1990 Project Location: Simi Valley Sample Calculations: Step 1: Estimate the emissions for each land use using [he Emission Rate Tables (Appendices B and C) or URBEMIS -2 computer model as described in Chapter 5. 1 Land Use 300,000 sq. ft- Light Industrial 25,000 sq. ft. Shopping Center 9,000 sq. ft_ High Turnover Restaurant 1990 Emissions Jpounds per day) ROC NOx 36S 48.0 50 -7 69.1 22-1 30.0 109-3 147.1 Step 2: Reduce emissions associated with a TDM program by multiphrirg the emissions for the project by the TDM credit factor as liven in Appendix C. Less On -Site TDM Program Credit -2.7 -3.6 106.6 143.5 i ti 1*7 Step 3: Determine excess emissions in ounds P per day by subtracting applicable significance threshold. 1990 Emissions (pounds per day) Less applicable significance threshold -25.0 -z5A Excess emissions (EEROC and EENOx) 81.6 1185 Step 4: Determine the unit cost per pound of ROC reduced and per pound o 1`Ox reduced by using Tables 7 -3 and 7-4 in Chapter 7 for the year of project completion (this amount will vary with the type of facility or service proposed). Unit Cost (UCROC) = S621 per lb. in 1990 Unit Cost (UCNOx) = $2.87 per lb. in 1990 Step 5: 1 Estimate the weighted average number of daysper year of operation. Light industry and office development usually trips and e Y ene to g � P missions 250 days per year. Retail commercial is open from 308 to 359 days per year. High turnover restaurants are often open 365 days per year. For mixed use projects, use a weighted average based on the number of trips generated per land use as given in Appendix C and calculated as follows: Number of Trips er day er near Light Industrial (6.97 trips / 1000 sq. ft.) 2,090 522 , _ �_� Shopping Center (166 trips /1000 sq. ft.) 4,159 1,_SO,S9.; High Turnover Rest. (201 trips /1000 sq. ft.) 1.848 69 9,40 .. Total: 8,057 2,463,360 Days (D) = 2,463,360 / 8,057 = 306 A Step 6: Insert excess emissions, unit cost, and days of operation into Equation 1 to estimate the 1990 annual cost of buying down the emissions through a contribution to a TDM fund.. Equation 1: AC(ROC or NOx) = EE(ROC or NOx) x UC(ROC or NOx) x D where: AC(ROC or NOx) = Annual cost of ROC or NOx reduced EE = Excess emissions in lbs. per day UC(ROC or NOx) = Unit cost per lb. of ROC reduced or per lb. of NOx reduced D = Days of operation per year Therefore, Annual Cost (ACROC) = 81.6 x $6.21 x 306 = $155,061 Annual Cost (ACNOx) = 1185 x S2.87 x 306 = $104,069 J T Step 7: Compare the annual cost of reducing ROC emissions with the annual cost of reducing NOx emissions_ and select the higher of the two. The contribution should be made based on only the higher of the two costs as TDM funding would result in implementation of programs which reduce both pollutants. Therefore, in the example, the recommended 1990 year annualized contribution to an Off -site TDM fund is 5155,061. Step 8. Repeat Steps 1 through 7 to determine the 1991 and 1992. annualized contribution to an Off -site TDM fund. For 1991, the contribution is $157,942, and for 1992, the contribution is 5160,811. An alternate and simpler method to calculate the contribution for the second and third years is simply to increase the one year contribution by 4% per year to reflect inflation. Using this method, the amounts are slightly higher (5161,263 and s Iq $167,714) because the total emissions to be "bought down" are actually less in the second and third years. A jurisdiction may require the total three vear contribution at completion of the project and prior to occupancy or it may spread the buydown over three years in order to minimize the initial cost and to provide a stabilized revenue stream. M I