HomeMy WebLinkAboutVW Environmental Mitigation Trust Beneficiary Mitigation Plan 11-1-2018-VW
State of Alaska
Volkswagen Environmental Mitigation Trust
Beneficiary Mitigation Plan
Prepared by
November 2018
This report prepared by:
Alaska Energy Authority
813 West Northern Lights Blvd
Anchorage, AK 99503
907-771-3000
www.akenergyauthority.org
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TABLE OF CONTENTS
1. Introduction............................................................................................................................ 1
2. Goals........................................................................................................................................ 2
2.1. Cost Effectiveness .......................................................................................................... 2
2.2. Improve Air Quality and Protect Human Health in Disproprtionately Affected Areas . 3
2.3. Environmental Justice and At-risk Populations ............................................................. 4
2.4. Voluntary Funding Match .............................................................................................. 5
3. Air Quality in Alaska............................................................................................................. 5
3.1. Diesel Pollution .............................................................................................................. 5
3.2. Nitrogen Oxides ............................................................................................................. 6
3.2.1. Transportation ......................................................................................................... 7
3.2.2. Electric Generation ................................................................................................. 8
3.2.3. NOx Nonattainment Area and Maintenance Areas ................................................. 9
3.3. Particulate Matter ........................................................................................................... 9
3.3.1. PM Nonattainment Area and Maintenance Areas ................................................ 11
3.4. Greenhouse Gas Emissions .......................................................................................... 14
3.5. Carbon Monoxide ........................................................................................................ 15
3.5.1. CO Nonattainment Area and Maintenance Areas ................................................ 15
4. Allocation of Environmental Mitigation Trust Funds ..................................................... 17
4.1. EMA 2 – School Buses and Public Transit Buses ....................................................... 17
4.1.1. Type A-D School Buses........................................................................................ 17
4.1.2. Class 4-8 Public Transit Buses ............................................................................. 18
4.2. EMA 4 – Ferries/Tugs and EMA 10 – DERA Marine Vessels ................................... 18
4.3. EMA 10 – DERA Prime Power ................................................................................... 19
4.4. EMA 9 - Light-duty Zero-Emission Vehicle Supply Equipment ................................ 19
5. Expected Ranges of Emission Reductions ......................................................................... 20
5.1. EMA 2 - School Buses ................................................................................................. 20
5.2. EMA 2 - Public Transit Buses ..................................................................................... 21
5.3. EMA 4 – Ferries/Tugs and EMA 10 – DERA Marine Vessels ................................... 21
5.4. EMA 10 - DERA Prime Power .................................................................................... 22
5.5. EMA 9 - Light-duty Zero-Emission Vehicle Supply Equipment ................................ 22
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6. Public Input .......................................................................................................................... 23
6.1. Goals for Outreach ....................................................................................................... 23
6.2. Target Audience ........................................................................................................... 23
6.3. Communications Methods and Tools........................................................................... 23
6.3.1. Public engagement events ..................................................................................... 23
6.3.2. Public Notice ......................................................................................................... 24
6.3.3. Surveys .................................................................................................................. 24
6.3.4. Draft Beneficiary Mitigation Plan ........................................................................ 25
6.3.5. Public Meetings .................................................................................................... 25
6.4. Summary of Public Comments .................................................................................... 25
7. Literature Cited ................................................................................................................... 26
8. Tables .................................................................................................................................... 28
9. Figures .................................................................................................................................. 32
LIST OF TABLES
Table 1. Proposed allocation of VW Environmental Mitigation Trust funds. .............................. 28
Table 2. Project evaluation matrix for upgrade or replacement of eligible school buses and public
transit buses. .................................................................................................................................. 29
Table 3. Eligible public transit buses for replacement with VW Environmental Mitigation Trust
funds. In addition, there are approximately 20 smaller cutaway buses scattered in other
communities throughout the state ranging from Model Year 2006 to 2009. ................................ 30
Table 4. Summary of public support for the Environmental Mitigation Actions. ........................ 30
Table 5. Summary of entities that provided input to Alaska’s Draft Beneficiary Mitigation Plan
for the Volkswagen Environmental Mitigation Trust. .................................................................. 31
LIST OF FIGURES
Figure 1. Map of the census area/boroughs of Alaska. Green areas represent boroughs, blue areas
represent consolidated city-boroughs and yellow areas represent census areas. .......................... 33
Figure 2. Source of NOx emissions in Alaska by sector in 2014. NOx emissions in Alaska in 2014
total 154,373 tons statewide. VW trust Eligible Mitigation Actions occur within the onroad
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diesel, nonroad mobile diesel, locomotive, commercial marine vessel, and electric generation
from oil sectors. Source: EPA 2015b. ........................................................................................... 34
Figure 3. 2014 Diesel NOx emissions (tons per year) by Alaska census area/borough for the
transportation and electric generation sectors that include Eligible Mitigation Actions under the
VW Environmental Mitigation Trust. Source: EPA 2015b. ......................................................... 35
Figure 4. Source of particulate matter (PM10 and PM2.5) emissions in Alaska by sector in 2014.
Source: EPA 2015b. ...................................................................................................................... 36
Figure 5. 2014 particulate matter (PM10) emissions (tons per year) by Alaska census
area/borough for the transportation and electric generation sectors that include Eligible
Mitigation Actions under the VW Environmental Mitigation Trust. Source: EPA 2015b. .......... 37
Figure 6. 2014 particulate matter (PM2.5) emissions (tons per year) by Alaska census
area/borough for the transportation and electric generation sectors that include Eligible
Mitigation Actions under the VW Environmental Mitigation Trust. Source: EPA 2015b. .......... 38
Figure 7. Alaska statewide greenhouse gas emissions in million metric tons of carbon dioxide
equivalents (MMT CO2e per year) by sector 1990 - 2015. Source: ADEC 2018. ........................ 39
Figure A-1. Relative amount of on-road NOx emissions from diesel vehicles by Census Area. ... 1
Figure A-2. Relative amount of diesel particulate matter (PM) by Census Tract statewide. See
Figures A-2a through A-2d for detail within the populated portions of the state. .......................... 2
Figure A-2a. Relative amount of diesel particulate matter (PM) by Census Tract in Anchorage
and Matanuska-Susitna. .................................................................................................................. 3
Figure A-2b. Relative amount of diesel particulate matter (PM) by Census Tract in the Fairbanks
area. ................................................................................................................................................. 4
Figure A-2c. Relative amount of diesel particulate matter (PM) by Census Tract on Kenai
Peninsula. ........................................................................................................................................ 5
Figure A-2d. Relative amount of diesel particulate matter (PM) by Census Tract in Southeast
Alaska. ............................................................................................................................................ 6
Figure A-3. Map of health complaints in rural Alaska related to ambient dust. Red indicates
communities with monitoring sites. Source: ADEC 2011. ............................................................. 7
Figure A-4. Map of Eagle River PM10 Maintenance Area boundary with Parkgate PM10
monitoring site. Source: ADEC 2010. ............................................................................................ 8
Figure A-5. Map of Mendenhall Valley PM10 Maintenance Area boundary, Juneau, Alaska.
Source: ADEC 2009. ...................................................................................................................... 9
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Figure A-6. Map of Fairbanks North Star Borough 24-hour PM2.5 Nonattainment Area boundary.
The area is divided into 3 air quality control zones, each with sub-area specific regulatory control
measures. Source: ADEC 2016..................................................................................................... 10
Figure A-7. Multiple PM2.5 hotspots identified within Fairbanks North Star Borough PM2.5
Nonattainment Area. Source: ADEC 2016. .................................................................................. 11
Figure A-8. Map of Anchorage carbon monoxide (CO) Maintenance Area boundary and CO
monitoring sites. Several monitoring sites were discontinued because the measured CO values
were low compared to comparable monitoring sites in the network. Source: ADEC 2013a. ...... 12
Figure A-9. Map of North Pole carbon monoxide Maintenance Area boundary, Fairbanks North
Star Borough, Alaska. Source: ADEC 2013b. .............................................................................. 13
Figure A-10. Map of Fairbanks and Fort Wainwright carbon monoxide Maintenance Area
boundary, Fairbanks North Star Borough, Alaska. Source: ADEC 2013b. .................................. 14
Figure B-1. EPA’s environmental justice indices for particulate matter PM2.5 generated from
diesel emissions based on population demographics within Census Tracts. The indices are
grouped by percentile rank. For example, communities in the 95-100 percentile, the highest risk
category presented in red, are the most vulnerable 5 percent of the communities in Alaska to
diesel particulate matter. Portions of Fairbanks, Southcentral, and Southeast are also within the
80-100th percentiles; see Figures B-1a through B-1d for detail. Source: EPA 2017b. ................... 1
Figure B-1a. EPA’s environmental justice indices for particulate matter PM2.5 generated from
diesel emissions based on population demographics within Census Tracts of Anchorage and
Matanuska-Susitna Valley. The indices are grouped by percentile rank; communities in the 95-
100 percentile, the highest risk category presented in red, are the most vulnerable 5 percent of the
communities in Alaska to diesel particulate matter. Source: EPA 2017b. ..................................... 2
Figure B-1b. EPA’s environmental justice indices for particulate matter PM2.5 generated from
diesel emissions based on population demographics within Census Tracts of the Fairbanks area.
The indices are grouped by percentile rank; communities in the 95-100 percentile, the highest
risk category presented in red, are the most vulnerable 5 percent of the communities in Alaska to
diesel particulate matter. Source: EPA 2017b. ............................................................................... 3
Figure B-1c. EPA’s environmental justice indices for particulate matter PM2.5 generated from
diesel emissions based on population demographics within Census Tracts of the Kenai Peninsula.
The indices are grouped by percentile rank; communities in the 95-100 percentile, the highest
risk category presented in red, are the most vulnerable 5 percent of the communities in Alaska to
diesel particulate matter. Source: EPA 2017b. ............................................................................... 4
Figure B-1d. EPA’s environmental justice indices for particulate matter PM2.5 generated from
diesel emissions based on population demographics within Census Tracts of Southeast Alaska.
The indices are grouped by percentile rank; communities in the 95-100 percentile, the highest
risk category presented in red, are the most vulnerable 5 percent of the communities in Alaska to
diesel particulate matter. Source: EPA 2017b. ............................................................................... 5
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Figure B-2. EPA’s environmental justice indices for traffic proximity and volume based on
population demographics within Census Tracts of Alaska. The indices are grouped by percentile
rank; communities in the 95-100 percentile, the highest risk category presented in red, are the
most vulnerable 5 percent of the communities in Alaska to pollution from vehicles. Source: EPA
2017b............................................................................................................................................... 6
Figure B-2a. EPA’s environmental justice indices for traffic proximity and volume based on
population demographics within Census Tracts of Anchorage and Matanuska-Susitna Valley.
The indices are grouped by percentile rank; communities in the 95-100 percentile, the highest
risk category presented in red, are the most vulnerable 5 percent of the communities in Alaska to
pollution from vehicles. Source: EPA 2017b. ................................................................................ 7
Figure B-2b. EPA’s environmental justice indices for traffic proximity and volume based on
population demographics within Census Tracts of the Fairbanks area. The indices are grouped by
percentile rank; communities in the 95-100 percentile, the highest risk category presented in red,
are the most vulnerable 5 percent of the communities in Alaska to pollution from vehicles.
Source: EPA 2017b. ........................................................................................................................ 8
Figure B-2c. EPA’s environmental justice indices for traffic proximity and volume based on
population demographics within Census Tracts of the Kenai Peninsula. The indices are grouped
by percentile rank; communities in the 95-100 percentile, the highest risk category presented in
red, are the most vulnerable 5 percent of the communities in Alaska to pollution from vehicles.
Source: EPA 2017b. ........................................................................................................................ 9
Figure B-2d. EPA’s environmental justice indices for traffic proximity and volume based on
population demographics within Census Tracts of Southeast Alaska. The indices are grouped by
percentile rank; communities in the 95-100 percentile, the highest risk category presented in red,
are the most vulnerable 5 percent of the communities in Alaska to pollution from vehicles.
Source: EPA 2017b. ...................................................................................................................... 10
LIST OF APPENDICES
Appendix A. Air Quality Maps
Appendix B. EPA Environmental Justice Screening Maps
Appendix C. Eligible Mitigation Actions and Mitigation Expenditures
Appendix D. Comparison of VW Eligible Mitigation Actions 1-9 and Eligible Mitigation Action
10 (DERA Option).
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LIST OF ACRONYMS, ABBREVIATIONS, AND DEFINITIONS
Abbreviation Definition
AAC Alaska Administrative Code
ADEC Alaska Department of Environmental Conservation
AEA Alaska Energy Authority
CAA Clean Air Act
CARB California Air Resources Board
CFR Code of Federal Regulations
CH4 Methane
CO Carbon monoxide
CO2 Carbon dioxide
CO2e Carbon dioxide equivalent
DERA Diesel Emission Reduction Act
DEQ Diesel Emissions Quantifier
DMV Department of Motor Vehicle
EMA Eligible Mitigation Action
EMT Environmental Mitigation Trust
EPA United States Environmental Protection Agency
EVSE Electric vehicle supply equipment
FNSB Fairbanks North Star Borough
GHG Greenhouse gases
HFC Hydrofluorocarbons
IARC International Agency for Research on Cancer
μg/m3 micrograms per cubic meter of air
MMT Million metric tons
MOA Municipality of Anchorage
MOVES Motor Vehicle Emission Simulator
MPa Megapascals
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Abbreviation Definition
MVEB Motor Vehicle Emissions Budget
MWh Mega Watt hour
N2O Nitrous oxide
NAAQS National Ambient Air Quality Standards
NEI National Emissions Inventory
NO2 Nitrogen dioxide
NOX Nitrogen oxides
O3 Ozone
Pb Lead
PFC Perfluorocarbons
PM2.5 Particulate matter with an aerodynamic diameter of 2.5 micrometers or less
PM10 Particulate matter with an aerodynamic diameter of 10 micrometers or less
PM Particulate matter
ppb Parts per billion
ppm Parts per million
RFA Request for Applications
RPSU Rural Power System Upgrade
SF6 Sulfur hexafluoride
SIP State Implementation Plan
SO2 Sulfur dioxide
TED Trust Effective Date
VMT Vehicle miles travelled
VW Volkswagen Group of America
ZEV Zero emission vehicle
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1. INTRODUCTION
The Clean Air Act (CAA) requires the U.S. Environmental Protection Agency (EPA) to set air
quality standards (40 CFR Part 50) to protect the health and the welfare of the public and the
environment. The law requires EPA to periodically review and update the standards to ensure that
health and environmental protection are adequate based on scientific justifications. Accordingly,
EPA has set National Ambient Air Quality Standards (NAAQS) for six principal criteria
pollutants, including nitrogen dioxide (NO2) and particulate matter (PM), both of which are
produced by diesel engines.
Volkswagen Group of America (VW) installed software in its 2.0 and 3.0 liter diesel engines of
several Volkswagen, Audi and Porsche model vehicles beginning with model year 2009 to alter
emission test results. The “defeat devices” masked the actual levels of nitrogen oxides (NOx)
emitted from these vehicles, which were significantly in excess of the NAAQS for NO2, violating
the Clean Air Act. The devices turned on the emission controls only when a vehicle was being
tested and then disabled emission controls under normal use of the vehicle. These devices resulted
in better driving performance and real world fuel mileage, but allowed the release of NOx
emissions in excess of nearly 40 times the federal NOx limit, depending on driving conditions. The
devices were installed in approximately 11 million vehicles globally, of which about 580,000 were
sold within the U.S., resulting in thousands of tons of excess NOx emissions.
Once discovered, the EPA, the Federal Trade Commission, and the California Air Resources Board
(CARB) sued VW. The parties settled in 2016. The settlement consists of three components that
require VW to (1) implement a Buyback, Lease Termination, Vehicle Modification and Emissions
Compliant Recall Program for the affected vehicles; (2) invest $2 billion into the development,
construction and maintenance of zero-emission vehicle (ZEV) related infrastructure and education
to increase usage of ZEV technology nationwide; and (3) invest $2.925 billion into an
Environmental Mitigation Trust (EMT) to fund specific projects that reduce diesel emissions.
The EMT is explicitly intended for funding ten categories of Eligible Mitigation Actions (EMAs),
as defined in Appendix D-2 of the 2.0 liter Consent Decree (Appendix C of this document), to
fully mitigate the total, lifetime excess NOx emissions from the 2.0 liter and 3.0 liter affected
vehicles. Under the final terms, two EMTs were established, one for federally-recognized tribes
nationwide ($54.5 million) and a second for states and territories. The states and territories were
allocated funds based on the distribution of the registered affected vehicles. There are
approximately 1,450 affected vehicles registered in Alaska. Alaska was allocated $8.125 million
to fund EMAs over a three- to ten-year period.
The final terms of the settlement regarding the EMT were filed with the court October 2, 2017,
establishing the Trust Effective Date (TED). Alaska filed to become a Beneficiary of the EMT
within the required 60 days of the TED, designating the Alaska Energy Authority (AEA) as the
lead agency to administer the EMT funds. Alaska’s status as a designated Beneficiary of the EMT
was filed with the court by the EMT Trustee, Wilmington Trust, on January 29, 2018.
The Volkswagen settlement provides an opportunity to fund mitigation projects that reduce
pollution, particularly nitrogen oxides, by upgrading and/or replacing older diesel engines that
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meet certain criteria. The settlement requires each Beneficiary to develop a Beneficiary Mitigation
Plan (Plan) through a public process that summarizes the Beneficiary’s high-level vision for use
of the mitigation funds. Specifically, Alaska’s Plan must include:
Alaska’s overall goal for the use of the funds;
Categories of EMAs we anticipate will be appropriate to achieve the stated goals and the
preliminary assessment of the percentages of funds anticipated to be used for each type of
EMA;
Description of how the potential beneficial impact of the selected EMAs on air quality in
areas that bear a disproportionate share of the air pollution burden will be considered;
General description of the expected ranges of emission benefits we estimate would be
realized by implementation of the EMAs identified in the Plan; and
Explanation of the process for seeking and considering public input on the Plan.
As described in Section 6, AEA conducted public outreach on the settlement and developed a
proposed draft Plan in May 2018 and solicited public input to ensure that stakeholders’ interests
were considered in the development of the final Plan. This document represents Alaska’s final
Plan for allocating the EMT funds.
2. GOALS
Alaska’s goals for implementing the settlement are as follows:
1. Reduce NOx emissions in the most cost-effective manner
2. Improve air quality and protect human health in disproportionately affected areas
3. Consider environmental justice and at-risk populations
4. Leverage additional funds to increase benefits to Alaskans
Alaska will offer several solicitations to fund certain EMAs, listed in Appendix C. The proposed
allocation of funds for the various EMAs described in Section 4 and summarized in Table 1 and
the criteria for evaluating projects (Table 2) were developed to achieve these goals with
consideration of the sources and distribution of emissions described in Section 3 and the
demographics and distribution of Alaska’s population.
2.1. Cost Effectiveness
The primary purpose of the mitigation fund is to reduce NOx emissions to fully mitigate for the
lifetime excess emissions of the vehicles installed with defeat devices. As of March 2017, there
were approximately 1,450 affected vehicles registered in Alaska (ADEC 2017 unpublished data).
The total lifetime NOx emissions produced by these vehicles is approximately 10.54 tons. Alaska
has been allocated $8.125 million which will mitigate for these vehicles, but will not be adequate
to replace aging diesel engines in the state. Projects that reduce the most lifetime short tons of NOx
and PM emissions for the least cost will be given a higher priority.
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2.2. Improve Air Quality and Protect Human Health in
Disproprtionately Affected Areas
The settlement requires Alaska to consider how the plan will impact areas that bear a
disproportionate air pollution burden. Air quality is highly variable across the state, from densely
populated areas along the Railbelt to remote isolated villages. Diesel engines are widely used
throughout the state, with the highest transportation use along the Railbelt, Southeast Alaska and
southern coastal areas with significant economic activity, and the highest electric generation use
in rural villages. Alaska will prioritize projects proposed in the most highly impacted air quality
areas of the state to benefit the health of most Alaskans, such as Nonattainment or Maintenance
areas of federal air quality standards and areas with the highest amount of on-road NOx emissions
or diesel particulate matter (see Appendix A).
Nonattainment Area and Maintenance Areas
A Nonattainment Area is an area designated by the EPA that does not meet (or that contributes to
ambient air quality in a nearby area that does not meet) the EPA’s ambient air quality standard for
one of the specified six criteria pollutants. Violations of air quality standards require the state
government and impacted communities to conduct an emissions inventory and develop an
attainment plan describing control measures and programs to reduce the pollutant to bring
Nonattainment Areas into attainment within a given number of years.
A Maintenance Area is an area formerly classified as a Nonattainment Area that has since
consistently met the NAAQS for the specified pollutant through implementation of the control
measures. Maintenance Plans (MPs) are developed for these areas that demonstrate the NAAQS
have consistently been met, establish an emissions budget for the area, and include measures to
ensure the NAAQS will continue to be maintained for a 10-year period after redesignation.
If an area has consistently demonstrated EPA-established threshold emission concentrations well
below the pollutant-specific NAAQS, a state may develop a less rigorous maintenance plan, or
Limited Maintenance Plan (LMP). LMPs may also be developed for areas submitting a second 10-
year maintenance plan. LMPs do not require emission budgets or forecasted emissions to
demonstrate compliance because these areas have such low ambient concentrations that it is
unreasonable to expect emissions growth during the maintenance period to result in violation of
the NAAQS. LMPs must demonstrate maintenance of NAAQS by implementing the control
measures established in the attainment or maintenance plan, provide for continued monitoring, and
include contingency measures that would be implemented if exceedances occurred in the area.
Maintenance Areas with EPA-approved LMPs are redesignated by the EPA from nonattainment
to attainment with a maintenance plan. These areas may be referred to as Limited Maintenance
Areas.
In addition to protecting human health and the environment, it is important to achieve attainment
in these areas because a Nonattainment Area status can potentially limit existing industry, the siting
of new industry, and impact receipt of federal highway dollars. Alaska does not have any areas
that do not meet federal air quality standards for NOx. However, there is a Nonattainment Area for
PM and Maintenance Areas for PM and carbon monoxide (CO).
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Other Air Quality Priority Areas
The amount of on-road NOx and PM emissions from diesel engines varies across the state. For
school bus and transit bus projects, priority will be given to census areas with the highest on-road
NOx emissions and census tracts with the greatest amount of diesel PM (see Appendix A).
2.3. Environmental Justice and At -risk Populations
In addition to considering the areas bearing a disproportionate amount of air pollution as described
above, Alaska will consider population demographics to ensure that the burdens of pollution do
not fall disproportionately on low-income, low-education, minority, and Alaska Native
communities as well as age groups at higher health impact risk (e.g., children five years old or
younger and adults 65 years or older.
EPA Environmental Justice Screening
The EPA has developed an environmental justice screening and mapping tool (EPA 2017b) based
on National Air Toxics Assessment (NATA) data that considers the characteristics of populations
(e.g., income, education, age, minority status) affected by diesel PM emissions and traffic
proximity and volume. These environmental justice indices have been grouped into percentile rank
(see maps in Appendix B) and priority will be given to projects that benefit at-risk populations
through the proposed scoring criteria presented in Table 2. The indices (EPA 2015b) represent a
snapshot in time based on the 2011 NEI. The most current assessment available will be used at the
time of solicitation.
Rural Alaska
The most at-risk populations occur in rural Alaska and in small localized areas within the most
populated areas of the state. Rural Alaska has majority Alaska Native populations, along with very
high costs of living and low incomes. However, EMAs 1-9 are transportation related, allowing for
the replacement or upgrade of diesel engines in medium and heavy duty local freight trucks, port
drayage trucks, school buses, shuttle buses, freight switchers, marine vessels, airport ground
support equipment, or cargo handling equipment; installation of shore-power for ocean going
vessels; or installation of zero-emission vehicle infrastructure. The opportunity for these types of
eligible projects occur throughout the most populated areas of the state, along the Railbelt,
Southeast and southern coastal areas with significant economic activity. Such opportunities are not
available or the projects are of little use in rural Alaska, where road systems are limited and there
are few vehicles eligible for engine replacement or upgrade. Moreover, the cost of generating
electricity in rural Alaska, much of which is generated by burning diesel, is not conducive to the
use of electric vehicles.
EMA 10, The Diesel Emission Reduction Act (DERA) Option, allows EMT funds to be used as
voluntary match to DERA-eligible projects. The DERA is an EPA-administered program that
provides federal funding for projects that reduce emissions from existing diesel engines. While
there is significant overlap between EMAs 1-9 and DERA-eligible projects, replacement of
stationary diesel engines with at least 500 hours of use per year and marine engines with at least
1,000 hours of use per year are only allowed under EMA 10.
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Alaska is one of the few states that uses diesel engines to generate prime power. Alaska produces
more NOx emissions to generate electricity than any other state. More than 200 rural Alaska
communities rely on diesel engines for power. In terms of reducing NOx emissions, rural Alaska
communities would see greater benefit by replacing or upgrading a diesel engine that generates
power 24 hours a day, 365 days a year, than by upgrading eligible vehicles. Moreover, some of
these communities experience wintertime inversions, exposing residents to longer duration and
higher concentrations of NOx and PM from diesel powerhouses, which are typically centrally
located within the community.
To ensure that rural Alaska communities benefit from the EMT, we will allocate EMT funds to
match the funds the state receives from the EPA through the State DERA program one to one on
an annual basis for five years. EMT funds may only be used as voluntary match. As described in
Section 4, matching the State DERA funds one to one will leverage additional funding from the
EPA.
2.4. Voluntary Funding Match
To maximize the potential to achieve the goals with limited funds, priority will be given to projects
that provide voluntary matching funds.
3. AIR QUALITY IN ALASKA
The EPA has set NAAQS for six principal criteria pollutants considered harmful to public health
and the environment: NO2, PM, CO, ozone (O3), lead (Pb), and sulfur dioxide (SO2). Nitrogen
dioxide is the oxide used by the EPA as the indicator for all NOx.
The two EPA criteria pollutants impacted in Alaska are CO and PM. Anchorage and Fairbanks
have designated Maintenance Areas for CO. Portions of Fairbanks are also designated as
Nonattainment Areas for PM2.5, while Juneau and Eagle River are classified as Maintenance Areas
for PM10. Other communities that regularly exceed or are near violating the EPA standards for PM
include Butte (PM2.5) and rural Alaska communities for both PM10 (dust) and PM2.5 (woodsmoke).
Diesel exhaust contributes to all six of the EPA’s principal criteria pollutants. The primary diesel
engine emissions of concern are NOx, PM, and greenhouse gases. The sections below summarize
the emission sources of these pollutants statewide and by the census areas/boroughs of Alaska
based on the 2014 National Emission Inventory (EPA 2015b). Alaska has 19 organized boroughs
and one unorganized borough. The unorganized borough is divided into 10 census areas that
generally align with election districts (Figure 1). For purposes of discussion, both the census areas
and organized boroughs are referred to as boroughs below.
3.1. Diesel Pollution
Diesel exhaust is harmful to both human health and the environment. Acute exposure can cause
eye, throat, and respiratory irritation, lightheadedness, and nausea, while chronic exposure may
lead to inflammation and changes in the lung, asthma, and heart and lung diseases. Diesel exhaust
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is considered a Group 1 carcinogen by the International Agency for Research on Cancer (IARC)
that causes lung cancer and an increased risk of bladder cancer (IARC 2012).
NOx reacts with volatile organic compounds and carbon monoxide in sunlight to produce ground-
level ozone, the major component of smog. Ozone can make it difficult to breathe, cause coughing,
inflammation and damage of the airways, aggravate lung diseases, make lungs more susceptible
to infection and cause chronic obstructive pulmonary disease (COPD) and premature death.
Children are at greatest risk from exposure to ozone because their lungs are not fully developed
and they are more likely to be active outside when ozone levels are high. People with asthma,
elderly people and people who are active outdoors are also at higher risk from exposure.
Particulate matter is a complex mixture of solid and liquid particles of inorganic and organic
chemicals, including carbon, sulfates, nitrates, metals, acids and volatile compounds (ADEC
2016). Particulate matter varies in size and health risk. Coarse particles have a diameter from 10
to 2.5 micrometers, and fine particles have diameters of 2.5 micrometer or less (PM2.5). Coarse
particulates can be inhaled and cause respiratory problems, while PM2.5 particles can lodge deeply
into lungs and enter the bloodstream causing serious respiratory and cardiovascular problems.
Health studies have shown a significant association between exposure to fine particles and
premature mortality. As with NOx, children, older adults, and people with heart and lung disease
are particularly sensitive to fine particle exposure.
NOx and PM also negatively impact the environment by contributing to the development of acid
rain, damaging waterways, ecosystems, agricultural crops, and infrastructure. NOx emissions also
result in the deposition of excess nutrients in waterbodies leading to excess plant and algal growth
and depletion of dissolved oxygen necessary to support aquatic fish and wildlife.
3.2. Nitrogen Oxides
A total of 154,373 tons of NOx were emitted statewide from point, non-point, event and mobile
sources combined in 2014 (EPA 2015b). Figure 2 displays the statewide sources of NOx emissions
by sector. Point sources from Alaska’s major industries include oil and gas exploration, extraction,
refinement and transportation; precious metals and coal mining; seafood processing; electricity
and heat generation; military base operations and municipal operations including waste
management (ADEC 2015).
Major non-transportation sources of NOx emissions consist of industrial and commercial sources
combined (35 percent), electric generation (12 percent), and wildfire (12 percent). Residential fuel
combustion, waste management, prescribed fire and other sources each contributed less than one
percent of the NOx emissions statewide. The transportation sector (onroad mobile, nonroad mobile,
locomotives, commercial marine vessels, and aircraft) accounts for 40 percent of the statewide
NOx emissions, primarily from commercial marine vessels (25 percent) and onroad mobile sources
(10 percent).
As the distribution of Alaska’s population, infrastructure and local economies vary widely across
the state, both the total amount of NOx emissions and sources of NOx are highly variable from
borough to borough. Nearly a quarter of Alaska’s statewide NOx emissions are generated at the
North Slope, primarily from the oil and gas industry (89 percent) and electric generation (10
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percent). The next highest NOx emissions are from the Kenai Peninsula (15 percent), followed by
Anchorage (7 percent), Southeast Fairbanks (7 percent), Valdez-Cordova (6 percent), and
Fairbanks North Star (5 percent). The Aleutians, Kodiak Island, Juneau, Hoonah-Angoon,
Petersburg, and Ketchikan Gateway, each contribute 2 - 4 percent of the statewide NOx emissions,
primarily from commercial marine vessels. The Northwest Arctic borough and Matanuska-Susitna
each contribute less than 3 percent, primarily from electric generation (90 percent) and onroad
sources (70 percent), respectively. The remaining 15 boroughs combined emit 9 percent of the
statewide NOx emissions, with each contributing less than one percent.
Industry and industrial processes are the dominant sources of NOx emissions in the Aleutians,
Bristol Bay, Dillingham, Fairbanks, Kodiak, Kusilvak (formerly Wade Hampton), and Yukon-
Koyukuk areas. Wildfires are a significant source of NOx in Southeast Fairbanks (84 percent),
Kenai Peninsula (36 percent), and Yukon-Koyukuk (17 percent), accounting for 5 percent of the
NOx emissions from Nome and Kusilvak.
The EMT may only be used to fund eligible projects within the transportation and electric
generation sectors, discussed in more detail below.
3.2.1. Transportation
In 2014, transportation emissions from burning fuel produced 62,286 tons of NOx, accounting for
40 percent of Alaska’s total NOx emissions (EPA 2015b). The NOx emissions by mode of
transportation were predominantly produced by commercial marine vessels (25 percent), followed
by onroad vehicles (10 percent), aircraft (2.3 percent), nonroad mobile sources (snow machines,
ATVs, construction equipment, airport ground support equipment, port cargo handling equipment,
and other mobile equipment combined; 2 percent) and rail (0.6 percent) (Figure 2).
Commercial marine vessel emissions are based on fuel sales within Alaska and do not necessarily
represent emissions occurring within Alaskan airspace or within the borough where refueling
occurred. As to be expected, nearly all of the 38,614 tons of NOx emissions from commercial
marine vessels were attributed to the 15 coastal boroughs of the Aleutians, Kodiak, Southcentral
and Southeast with significant commercial fishing industries, oil tankers, cruise ship destination
ports, or served by the Alaska Marine Highway ferry system (Figure 3). Seventy percent of the
commercial marine vessel NOx emissions were attributed to fuel sales in Valdez-Cordova (20
percent), Petersburg (14 percent), Ketchikan Gateway (14 percent), Kenai Peninsula (12 percent)
and the Aleutians (11 percent). Eligible marine vessel engines may be upgraded or repowered with
EMT funds (EMA 4 and EMA 10). In addition, EMA 5 includes the shore-side cost of installing
shore power to ocean-going vessels from the existing utility grid (Appendix C). While not directly
related to commercial marine vessel emissions, NOx emissions at ports could potentially be
reduced through EMA 8 which includes the repower or replacement of port cargo handling
equipment with all electric engines (Appendix C).
Onroad motor vehicles produced 16,121 tons of NOx emissions in 2014, approximately half of
which was produced by diesel engines (8,197 tons) (Figure 2). Given our limited road system,
Alaskans typically drive less miles per year than drivers in the Lower 48. Between 1990 and 2015,
the annual average vehicle miles traveled per person has ranged from 6,500 to 7,600 miles (ADEC
2015). Approximately 80 percent of Alaska’s onroad NOx emissions from diesel vehicles occur in
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the most populated urban areas of Southcentral and portions of the Interior that are connected by
road, Anchorage (30 percent), Matanuska-Susitna (20 percent), Kenai Peninsula (13 percent),
Southeast Fairbanks (8 percent) and Fairbanks North Star (7 percent) (Figure 3). Heavy duty
vehicles disproportionately contribute to these emissions. Juneau and Sitka combined account for
10 percent of the statewide onroad diesel NOx emissions, producing approximately 423 tons and
393 tons of NOx emissions in 2014, respectively. Kodiak Island, Ketchikan Gateway, Valdez-
Cordova, and Yukon-Koyukuk each produced between 100 and 175 tons of NOx from onroad
diesel vehicles. The remaining boroughs produced anywhere from none (Aleutians West) up to
approximately 64 tons (Prince of Wales-Hyder) of NOx emissions from onroad diesel vehicles.
Diesel heavy duty (Class 8) local freight trucks and port drayage trucks, medium duty (Class 4-7)
local freight trucks, and Class 4-8 school buses, shuttle buses and transit buses are eligible for
repower or replacement with EMT funds (EMAs 1, 6, and 2 respectively; Appendix C). EMA 10
expands the range of eligible engines (Appendix D).
In 2014, 1,818 tons of NOx emissions were produced by diesel nonroad mobile sources statewide
(Figure 2). Nonroad mobile sources include snow machines, ATVs, construction equipment,
airport ground support equipment, and port cargo handling equipment. Nearly half of the diesel
nonroad mobile NOx emissions were in Anchorage (45 percent), followed by Fairbanks North Star
(11 percent), Prince of Wales-Hyder (5 percent), and Kenai Peninsula (4 percent) (Figure 3). Both
airport ground support equipment (EMA 7) and port cargo handling equipment (EMA 8) are
eligible for repower or replacement with all electric engines with EMT funds.
The Alaska Railroad runs for approximately 506 miles between Seward in the south to Fairbanks
and Eielson Air Force Base in the north carrying both passengers and freight (ADEC 2015). There
is also a small, summertime passenger rail that runs between Skagway, Alaska and Canada’s
Yukon Territory. Locomotives were the source of 915 tons of NOx emissions in 2014, or 0.6
percent of the statewide total, limited in distribution to the boroughs along the rail and with rail
yards: Valdez-Cordova (Whittier), Kenai Peninsula (Seward), Anchorage, Matanuska-Susitna,
Fairbanks North Star, Yukon-Koyukuk and Skagway. Under EMA 3, eligible diesel freight
switcher locomotives may be repowered or replaced (Appendix C). The DERA option (EMA 10)
expands eligible locomotives to include line haul locomotives carrying passengers or freight
(Appendix D).
Approximately 2 percent (3,616 tons) of the statewide NOx emissions were attributed to aircraft
(Figure 2). Nearly three-quarters of the aircraft NOx emissions were from Anchorage (58 percent)
and Fairbanks North Star (15 percent). As with commercial marine vessels, NOx emissions are
attributed to the location of the fuel sales. While aircraft are not included in any of the EMAs
defined in the trust agreement, airport ground support equipment is eligible to be repowered or
replaced with all electric engines (EMA 8, Appendix C).
3.2.2. Electric Generation
Electric generation emissions are calculated from the amount of fuel (coal, natural gas, diesel)
burned to produce electricity that is delivered to an electric grid serving customers. This sector
does not include electric generation associated with the industrial sector, such as North Slope oil
and gas. In 2014, electric generation accounted for approximately 12 percent of the statewide NOx
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emissions (18,823 tons), of which 10,257 tons were from diesel fuel sources, exceeding NOx
emissions produced by onroad diesel vehicles in the same year by 25 percent (Figure 2).
Alaska produces 3.4 pounds of NOx emissions per megawatt hour (MWh) of electricity generated,
more than any other state and three and a half times the national average (NASEO 2017). Rural
communities in Alaska rely primarily on diesel electric generators for power, and Alaska ranks
second only to Hawaii in the share of its electricity generated from petroleum. Nearly half of the
NOx emissions from diesel electric generators were from rural communities in Northwest Arctic
and Aleutians West boroughs (Figure 3). The Bethel, Bristol Bay, Dillingham, Fairbanks North
Star, Nome, North Slope and Valdez-Cordova boroughs each contributed another 3 to 7 percent of
the statewide NOx emissions. For some of these boroughs, NOx emissions from diesel electric
power generation was the primary source of NOx emissions, ranging from 90 percent of the total
NOx emissions within Northwest Arctic Borough to approximately 40 percent of the emissions
within Bethel, Bristol Bay, Dillingham and Nome, to 26 percent emissions within Aleutians West.
Diesel engines for prime power operate 24 hours a day, 365 days a year. Powerhouses are typically
centrally located within a community. Many of these communities experience wintertime
inversions, exacerbating health impacts from prolonged exposure to elevated levels of NOx and
PM. Under the DERA option (EMA 10), EMT funds may be used as voluntary match to repower
or replace eligible stationary diesel engines used for power production.
3.2.3. NOx Nonattainment Area and Maintenance Areas
The EPA established NAAQSs for NO2 are as follows:
Primary 1-hour: 100 parts per billion (ppb) 98th percentile of 1-hour daily maximum
concentrations, averaged over three years;
Primary and secondary annual: 53 ppb annual mean (EPA 2017d).
Alaska does not have any areas designated as Nonattainment Area of the NO2 NAAQSs. However,
NOx contributes to the formation of particulate matter and there is a 24-hour PM2.5 Nonattainment
Area in the Fairbanks North Star Borough (FNSB). FNSB’s and ADEC’s plan (ADEC 2016) to
reach attainment in the FNSB 24-hour PM2.5 Nonattainment Area identifies voluntary programs
that contribute some reductions to PM2.5 and its precursor NOx. As a required element of the plan,
ADEC established a Motor Vehicle Emissions Budget (MVEB) for the FSNB Nonattainment Area
of 0.33 tons of PM2.5 per day and 2.13 tons of NOx per day (See Section 3.3.1.3 below).
3.3. Particulate Matter
Emissions from both fine particulate matter (PM2.5) and coarse particulate matter are regulated by the
EPA. PM10 is particulate matter with a diameter of 10 micrometers or less. It includes both coa rse
particulate matter and fine particulate matter (PM2.5). Sources of coarse particles include crushing or
grinding operations, and dust from paved or unpaved roads. Sources of fine particles include
wildfire, all types of combustion activities (motor vehicles, power plants, wood burning, etc.) and
certain industrial processes.
A total of 363,532 tons of PM10 were emitted statewide from point, non-point, event and mobile
sources combined in 2014 (EPA 2015b). Figure 4 displays the statewide sources of PM10 emissions
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by sector. More than 96 percent of the PM10 in Alaska statewide is from wildfires (56 percent) and
dust (41 percent). Wildfires are the primary source of PM10 in the Southeast Fairbanks (96 percent)
and Kenai Peninsula (76 percent) boroughs. PM10 emissions in the Yukon-Koyukuk borough are
almost equally caused by wildfires (45 percent) and dust (52 percent). With the exception of these
three boroughs, and Anchorage (83 percent), North Slope (76 percent), Northwest Arctic (73
percent), and Denali (64 percent) boroughs, dust is the source of more than 85 percent of the PM10,
nearly all of which is generated from unpaved roads. Industrial, industrial processes and
commercial sources combined contribute a little more than 1 percent of the statewide PM10, but
were a significant source within Denali (33 percent), North Slope (20 percent), and Northwest
Arctic (16 percent) boroughs. Waste contributed 0.8 percent of the PM10 emissions statewide, but
nearly 11 percent of the PM10 emissions within Anchorage. All sources of transportation combined
produced 0.8 percent of PM10 emissions statewide, while electricity generation contributed 0.2
percent.
The sources of PM2.5 emissions are nearly the same as PM10, with the exception of wildfire and
dust (Figure 4). While wildfire and dust combined both contribute more than 95 percent of all
particulate matter, dust contributes more coarse particulate matter.
In 2014, commercial marine vessels produced 1,029 tons of PM10, followed by diesel onroad
mobile sources (570 tons), diesel nonroad mobile sources (136 tons), and locomotives (23 tons)
(Figure 5). Electricity generated from burning oil contributed 408 tons of PM10 in 2014. PM2.5
comprised more than 75 percent of the PM10 generated from diesel onroad mobile sources and
more than 95 percent of the PM10 emissions from commercial marine vessels, diesel nonroad
mobile sources, locomotives, and electric generation from oil.
The distribution of PM emissions across the state from eligible EMT sectors follows the same
pattern as NOx emissions previously described (Figures 5 and 6). PM2.5 from onroad diesel
emissions were highest in the populated boroughs connected by road, ranging from 30 to 130 tons
per year in each borough, followed by Sitka (25 tons), Juneau (21 tons), and Ketchikan Gateway
(11 tons) in Southeast (Figure 6). Two thirds of the statewide PM2.5 emissions from diesel nonroad
mobile sources occur within Anchorage, Fairbanks North Star, Matanuska-Susitna, and Kenai
Peninsula boroughs; Prince of Wales-Hyder contributes over 4 percent, while Valdez-Cordova,
Juneau, Aleutians West, Bethel, Nome, North Slope, Yukon-Koyukuk each contribute about 2
percent of the statewide PM2.5 emissions. More than half of the 22 tons of PM2.5 emissions from
locomotives occur in the Anchorage and Matanuska-Susitna boroughs. In 2014, commercial
marine vessels accounted for 987 tons of PM2.5 emissions annually. The highest occurrence was
in Valdez-Cordova (19 percent), followed by Petersburg (13 percent), Ketchikan Gateway (13
percent), Kenai Peninsula (11 percent), the Aleutians (11 percent), and Hoonah-Angoon (9
percent).
In 2014, 400 tons of PM2.5 emissions were released from burning oil to generate electricity (Figure
6). Seventy-five percent of the emissions were generated in the Fairbanks North Star (21 percent),
Northwest Arctic (19 percent), Valdez-Cordova (15 percent), the Aleutians (14 percent), and
Bethel (5 percent); fifteen percent of the emissions were attributed to portable generators.
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3.3.1. PM Nonattainment Area and Maintenance Areas
The current EPA NAAQSs for particulate matter are as follows:
Primary annual PM2.5: 12.0 micrograms per cubic meter of air (μg/m3) annual mean
averaged over three years;
Secondary annual PM2.5: 15.0 μg/m3 annual mean averaged over three years;
24-hour PM2.5: 35 μg/m3 98th percentile averaged over 3 years;
24-hour PM10: 150 μg/m3 not to be exceeded more than once per year on average over
three years (EPA 2017d).
The primary standards provide health protection, including protecting the health of sensitive
populations such as asthmatics, children, and the elderly, while secondary standards protect public
welfare, including protection against decreased visibility and damage to animals, crops, vegetation
and buildings (EPA 2017d). In 2012, the EPA reviewed and revised the primary annual PM2.5
NAAQS, strengthening the annual standard from 15 to 12 μg/m3 (EPA 2016). ADEC subsequently
evaluated the most recent air monitoring data within the state to determine compliance with the
revised annual PM2.5 NAAQS and recommended to EPA that all areas of the state be designated
as in attainment. On December 18, 2014, the EPA designated the entire state of Alaska as
“unclassifiable/attainment,” consistent with the recommendation from the state of Alaska.
The 24-hour PM standards are designed to provide health protection against short-term particle
exposures, especially in areas with high peak PM concentrations. PM10 (dust) is of concern in rural
Alaska because of the existence of point sources, unpaved roads and wood smoke which are
prevalent in many communities all around Alaska. Appendix A includes a map (Figure A-3)
showing the rural Alaska communities reporting health problems from dust and identifies the
villages that have initiated PM10 monitoring programs (ADEC 2011). Historically, Eagle River
and Mendenhall Valley in Juneau have violated the air quality standards for PM10, though both of
the areas are now attaining the PM10 NAAQS and are in maintenance status.
In 2006, the EPA strengthened the 24-hour PM2.5 standard from 65 μg/m3 to 35 μg/m3 (EPA 2016).
To develop nonattainment area recommendations for the revised 24-hour PM2.5 NAAQS, ADEC
evaluated three years of air quality data for four areas of Alaska: Anchorage, Fairbanks, the
Mendenhall Valley in Juneau, and the Butte area in the Matanuska-Susitna Borough. The three
year calculated average (2006-2008) of 24-hour PM2.5 for Fairbanks was 43 μg/m3 and the
Mendenhall Valley in Juneau was exactly at 35 μg/m3. Anchorage (26 μg/m3) and Butte (31 μg/m3)
both met the 24-hour PM2.5 standard. Accordingly, ADEC recommended Fairbanks be designated
as a Nonattainment Area and the other three as in Attainment. Because of the prevalence of wood-
fueled heating and limited air quality monitoring data, ADEC recommended that other areas of
Alaska be designated as unclassifiable for the 24-hour standard. (All of the communities showed
attainment for the annual exposure limit which was 15μg/m3 at the time.) Multiple exceedances
of the 24-hour PM2.5 standard have since been measured at Butte monitoring sites on multiple
occasions.
3.3.1.1. Eagle River, Anchorage 24-hour PM10 Maintenance Area
A 9-square mile area of Eagle River was designated a Nonattainment Area for 24-hour PM10 NAAQS
in 1987 due to dust generated from 22 miles of unpaved roads in the area (Appendix A Figure A-4).
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The State and Municipality of Anchorage (MOA) developed an ambitious road paving program to pave
or surface one-third of the roads to reduce PM10 emissions. Nearly all the gravel roads were paved in
the early 1990s, which resulted in Eagle River being reclassified from Serious to Moderate. By 2007,
all roads in the area had been paved or surfaced with recycled asphalt. The MOA and ADEC
subsequently prepared an LMP (ADEC 2010) demonstrating that the area was in attainment and that
continued maintenance of the standard was expected through 2020. Excluding natural events (high
winds, volcanic eruptions), the highest PM10 concentrations measured since 1988 have been
approximately half the 24-hour standard (ADEC 2010). The LMP takes into account increases in PM10
emissions from all sources, including onroad mobile sources, through 2020 to help ensure that PM10
concentrations will remain below the NAAQS. Between 2007 and 2020, the vehicle miles traveled
(VMT) was projected to grow by 36.3% to 226,221 (ADEC 2010). On January 7, 2013 the EPA
approved the LMP and redesignated Eagle River as attaining the PM10 standard. This area of Eagle
River is currently a PM10 Moderate Maintenance Area.
3.3.1.2. Mendenhall Valley, Juneau 24-hour PM10 Maintenance Area
The Mendenhall Valley area of Juneau was designated as a Moderate Nonattainment Area for the 24-
hour PM10 standard in 1991 (Appendix A Figure A-5) based on violations that occurred throughout
the 1980s and early 1990s (ADEC 2009). The Mendenhall Valley is the largest residential area within
the City and Borough of Juneau. It is surrounded by mountains on the east, west, and north, contributing
to winter time inversions which elevated PM10 concentrations generated from home heating wood
smoke, vehicle exhaust, and fugitive dust from playgrounds and travel on roads. The ADEC developed
a nonattainment plan that included a wood smoke control program incorporating public education,
real-time monitoring, open burning prohibitions in winter, new stove certification, enforcement of a
borough wood smoke ordinance, and paving unpaved roads. Through implementation of these control
measures, there have been no measured violations of the standard since 1994. Juneau is currently
designated as a Moderate Maintenance Area in attainment for PM10. There is an EPA-approved LMP
(ADEC 2009) in place for the area that provides for continued monitoring and implementation of
control measures, and contingency plans if ambient PM10 issues occur in the future.
3.3.1.3. Fairbanks North Star Borough 24-hour PM2.5 Nonattainment Area
In December 2009, the EPA designated a portion of the Fairbanks North Star Borough (FNSB),
including the City of Fairbanks and the City of North Pole, as a 24-hour PM2.5 Nonattainment Area
(Appendix A Figure A-6) based on measurements collected at the State Office Building (ADEC
2016). During 2006 – 2008, the 98th percentile PM2.5 design value for each of those years was
42.2 μg/m3, 33.1 μg/m3, and 46.7 μg/m3, respectively (ADEC 2016). In 2014, the EPA published a
rule that classified PM2.5 Nonattainment Areas as Moderate areas requiring attainment to be reached
within 6 years of the nonattainment designation. Because it did not attain the NAAQS within the
required six years (i.e., December 2015), EPA reclassified the Nonattainment Area from Moderate to
Serious effective June 9, 2017.1 Accordingly, the State of Alaska and FNSB developed a State
Implementation Plan (SIP) for the 24-hour PM2.5 Nonattainment Area to meet the federal
requirements to reach attainment by December 3, 2019.
1 Federal Register, Vol. 82, No. 89, May 10, 2017
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The SIP describes how the State of Alaska and FNSB will identify and implement air pollution control
measures to achieve lower emissions of PM2.5 as well as NOx, sulfur oxides (SOx), volatile organic
compounds (VOCs), and ammonia (NH3), which can contribute to the formation of PM2.5 (EPA
2016). The nonattainment area consists of three air quality control zones, North Pole Control Zone,
Fairbanks Control Zone and Goldstream Control Zone (Appendix A Figure A-6), with sub-area
specific regulatory control measures established for under 18 AAC 50 to target area-specific
problems (ADEC 2016).
Local emissions from wood stoves, burning distillate oil, industrial sources, and onroad mobile
sources contribute to direct PM2.5 emissions as well as NOx, SO2, NH3 and VOC within and
around the Nonattainment Area. PM2.5 is primarily a health concern during the winter months
(October through March) when extremely strong temperature inversions are frequent and human
impacts on air pollution increase (ADEC 2016).
Fairbanks, located at 65 degrees latitude, experiences a subarctic continental climate. As a result,
Fairbanks is frequently subjected to ground-based temperature inversions that are among the
strongest surface-based inversions found anywhere in the United States (ADEC 2016).
Temperature inversions are a semi-permanent feature of the winter atmosphere in Fairbanks,
occurring about 80 percent of the time in December and January. Inversions are often accompanied
by clear skies, low temperatures, and very poor air pollution dispersion. As a result of stable
boundary layers, low wind speeds and low vertical mixing, the concentration levels of ground level
pollutants in the atmosphere in Fairbanks can approach that of much larger metropolitan areas in
the contiguous United States.
While nearly all of the exceedances of the 24-hour PM2.5 NAAQS have occurred between mid-
November and mid-February, Fairbanks also experiences high concentrations of PM2.5 during the
summer that are the result of wildfires and meteorology (wind speed, wind direction, etc.) (ADEC
2016). However, exceedances from wildfires are considered uncontrollable exceptional events
because they are naturally occurring.
The SIP addresses motor vehicle emissions and their link to transportation planning efforts in the
community. As part of the plan for controlling emissions and reducing ambient levels of PM2.5 and
NOx, ADEC established a Motor Vehicle Emissions Budget (MVEB) for calendar year 2017 and
beyond, which defines the total allowable emissions from onroad vehicles for PM2.5 and its
precursor, NOx. The MVEB for the Fairbanks Nonattainment Area is 0.33 tons of PM2.5 per day
and 2.13 tons of NOx per day, based on ADEC’s analysis of the regional average winter day onroad
vehicle emissions (ADEC 2016). While emissions from onroad sources comprise a relatively small
portion of the PM2.5 (9 percent) and NOx (17 percent) emissions (ADEC 2016), emissions
associated with future federally funded regional transportation plans must not exceed the budgeted
limits.
3.3.1.4. Butte, Matanuska-Susitna 24-hour PM2.5 Exceedances
Monitoring sites in the Butte area of the Matanuska-Susitna Borough have measured 24-hour PM2.5
levels in excess of 35 µg/m3 on a few occasions in each of the last few years. Compliance with
the 24-hr PM2.5 NAAQS is determined using three years of air monitoring data. The design value
(DV) is an average of 98th percentile 24-hr average PM2.5 concentrations over three years. The
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2014, 2015, and 2016 98th percentiles were 38.1 µg/m3, 37.9 µg/m3, and 29.2 µg/m3, respectively,
producing a 3-year average DV of 35.1 µg/m3. The NAAQS is currently 35 µg/m3, an area is
considered to violate the standards if the DV is 35.5 µg/m3 or above. The DV cannot exceed 35.4
µg/m3. If the area continues to experience elevated levels of PM2.5, EPA may designate the area as
a nonattainment area.
3.4. Greenhouse Gas Emissions
Greenhouse gases (GHGs) are gases in the atmosphere that absorb and emit radiant energy within
the Earth’s thermal infrared range, causing the greenhouse effect. Greenhouse gases include
carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), and manmade fluorinated gases. The
most common GHGs in Earth's atmosphere, CO2, CH4, and N2O, have both natural and human-
caused sources and sinks. However, since the Industrial Revolution, human activities, including
the production, transport and burning of fossil fuels, have increased the atmospheric concentrations
of these gases significantly. Fluorinated gases (sulfur hexafluoride (SF6), hydrofluorocarbons
(HFC), and perfluorocarbons (PFC)) are synthetic gases emitted from a variety of industrial
processes. Greenhouse gas emissions are commonly reported in million metric tons (MMT) of
carbon dioxide equivalents (CO2e). The US produced 6,587 MMT CO2e in 2015 (EPA 2017c).
While Alaska has not established a target for GHG emissions, the ADEC Division of Air Quality
quantified Alaska’s greenhouse gas emissions from anthropogenic sources within Alaska from
1990 through 2015. ADEC’s analysis found that Alaska’s GHG emissions comprise approximately
0.63 percent and 0.09 percent of the nationwide and global GHG emissions, respectively (ADEC
2018). While Alaska ranks 40th among the United States, it ranks fourth highest in the nation on a
per capita basis due to our small population and the presence of a large oil and gas industry.
Between 1990 and 2015, Alaska’s gross annual GHG emissions ranged from approximately 39.01
MMT CO2e to 54.64 MMT CO2e (ADEC 2018). The GHG emissions in Alaska are predominantly
produced from the industrial sector (oil and gas industry), followed by the transportation,
residential and commercial, and electric generation sectors. Waste, agriculture, and industrial
process sectors each comprise less than 1 percent of the total statewide GHG emissions.
Transportation
Transportation emissions from burning fuel contribute approximately one quarter of Alaska’s
GHG emissions. Carbon dioxide is the most prevalent greenhouse gas (82 percent). The
transportation sector produces 35 percent of Alaska’s carbon dioxide emissions. The CO2
emissions are directly proportional to the quantity of fuel consumed, while the CH4 and N2O
emissions depend on the type of equipment. In 2015, the GHG emissions by mode of transportation
were predominantly produced by aircraft (72 percent), followed by onroad cars and trucks (27
percent), commercial marine vessels (0.8 percent) and other transportation sources combined
including rail, snow machines, ATVs, construction equipment, and other mobile equipment (0.5
percent).
Electric Generation
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Electric generation has consistently accounted for approximately 8 percent of Alaska’s GHG
emissions over the past 25 years.
3.5. Carbon Monoxide
More than 90 percent of the CO emissions statewide are a result of wildfires, nearly all of which
occur in the Southeast Fairbanks and Kenai Peninsula boroughs. In 2014, 164,636 tons of CO were
emitted by non-diesel onroad mobile (3 percent), non-diesel nonroad mobile (2 percent), waste (1
percent), and industrial sources (1 percent) (EPA 2015b). More than 80 percent of the non-diesel
onroad mobile CO emissions are generated within the most densely populated boroughs connected
to the road system: Anchorage, Matanuska-Susitna, Fairbanks North Star and Kenai Peninsula.
Cold starts and warm-up idling are significant components of overall vehicle emissions.
Diesel engines emit far lower levels of CO than gasoline engines. Diesel engines run by creating
pressure and do not require actual spark that gasoline engines require to start and diesel engines
process fuel more efficiently than gasoline engines. The CO emissions for all of the sectors
combined that include EMAs related to diesel onroad mobile, diesel nonroad mobile, locomotives,
commercial marine vessels, and electricity generated from oil, account for less than one percent of
the statewide CO emissions. It is unlikely that these EMAs will have much impact on reducing
ambient CO concentrations. However, the promotion of electric vehicle use, through the
installation of charging infrastructure (EMA 9), would contribute to less gasoline vehicles on the
road over time, reducing the occurrence of cold starts and extended vehicle warm-ups in residential
areas. Additionally, EMA 7 allows for the repower or replacement of both diesel powered and
spark ignition engine powered airport ground support equipment with all electric engines
(Appendix C). And EMA 8 includes the repower or replacement of port cargo handling equipment
with all electric engines or equipment.
3.5.1. CO Nonattainment Area and Maintenance Areas
The EPA established NAAQSs for CO as follows:
Primary 1-hour: 35 parts per million (ppm), not to be exceeded more than once per year;
Primary 8-hours: 9 ppm, not to be exceeded more than once per year (EPA 2017b).
3.5.1.1. Anchorage CO Maintenance Area
A major portion of the Anchorage urban area was declared a Nonattainment Area for CO in 1978
(Appendix A Figure A-8). The Municipality of Anchorage (MOA) and ADEC prepared a CO
attainment plan intended to meet the CO NAAQS by December 1987, which did not occur (ADEC
2013A). In 1990, the EPA designated Anchorage as a Moderate Nonattainment Area. The MOA
and ADEC submitted a revised plan to bring the area into attainment by December 1995. However,
the area was reclassified by the EPA as a Serious Nonattainment Area in 1998 after two violations
of the NAAQS were measured in 1996. Anchorage has not violated the CO NAAQS since 1996
(ADEC 2013A). In 2002, the EPA approved Anchorage’s attainment plan and designated
Anchorage as a CO Maintenance Area. MOA and ADEC subsequently prepared a maintenance
plan that demonstrated ambient CO emissions were low enough to ensure continued attainment of
the NAAQS through 2023. Accordingly, the EPA reclassified Anchorage in 2004 as in attainment
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with the CO NAAQS. The MOA has since developed an LMP for the second 10-year maintenance
period (2014-2024) (ADEC 2013A). With approval of the LMP, a regional emissions budget and
future forecasting of emissions or concentrations is no longer required.
The major source of ambient CO concentrations in Anchorage is from vehicle emissions during
the winter from vehicle cold starts and warm up idling (ADEC 2013A). Cold engines emit
considerabl y more CO at start-up than warm engines. In addition, many Anchorage drivers engage
in extended vehicle warm-ups, particularly prior to their morning commute. As a consequence, a
large portion of CO emissions occur mid-week in residential areas where morning commute trips
begin. According to the emissions inventory compiled for base year 2007, almost 80 percent of
winter season CO emissions in the Maintenance Area (125 tons CO per day) were from motor
vehicles. The MOVES model suggested that start emissions account for about two-thirds of all
motor vehicle emissions (ADEC 2013A). Other significant sources of CO in Anchorage include
aircraft and residential wood burning. Airport operations at Anchorage International Airport and
Merrill Field contributed 12.4 and 0.7 tons per day of CO, respectively.
The LMP includes continued monitoring and the following primary control measures to ensure
continued attainment of the CO NAAQS: (1) an air quality public awareness program aimed at
promoting use of engine block heaters to reduce CO cold start emissions and the promotion of
bicycling, walking, mass transit and other alternatives to the single occupancy vehicle; (2) a transit
marketing program; and (3) carpooling and vanpooling. The plan identifies contingency measures
as well.
3.5.1.2. Fairbanks CO Maintenance Area
EPA designated the urban portion of the Fairbanks North Star Borough (FNSB) a Nonattainment
Area for CO in 1991. Appendix A shows the boundaries of the North Pole (Figure A-9) and the
Fairbanks-Fort Wainwright Nonattainment areas (Figure A-9). The Fairbanks area experiences
severe wintertime temperature inversions, resulting in the trapping of pollutants near ground level,
with little vertical dispersion. Low winds and the presence of hills around most of the urban area
combine to limit horizontal dispersion as well. As a result, Fairbanks has the most significant air
quality impacts in the state.
EPA approved the FNSB's CO Maintenan ce Plan and the FNSB officially became a CO
Maintenance Area on September 27, 2004, initiating a 20-year maintenance planning period. The
modeled emissions inventory developed for the area without local control measures estimated a
total of 90.5 tons of CO emissions per day, with the majority of the emissions coming from onroad
vehicles (45.2 tons), followed by area sources including residential wood combustion (25 tons per
day), nonroad sources (16.8 tons per day), and point sources (3.5 tons per day). Approximately 4.2
tons per day were attributed to airport operations and locomotives contributed another 0.2 tons CO
per day (ADEC 2013b).
The FNSB has not violated the NAAQS for carbon monoxide since 1999. Because the CO
emissions were consistently well below 85 percent of the CO NAAQS (<7.65 ppm) during the first
ten-year planning period, FNSB developed an LMP for the second 10-year maintenance planning
period (ADEC 2013b). The EPA approved the LMP October 8, 2013.
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The LMP includes continuation of monitoring and implementation of control measures: (1)
expanded availability of plug-ins to promote use of engine block heaters to reduce CO cold start
emissions; (2) a consumer-based oxygen sensor replacement program; (3) an episodic woodstove
burn ban; and (4) voluntary programs that promote public awareness on actions to reduce CO, and
transit system improvements.
4. ALLOCATION OF ENVIRONMENTAL MITIGATION TRUST FUNDS
Alaska has been allocated $8.125 million to fund projects within the 10 EMAs, as defined in
Appendix C. The settlement requires the funds to be disbursed within 10 years from the Trust
Effective Date of October 2, 2017, with no more than one third disbursed in the first year and no
more than two thirds disbursed in the first two years.
As described below and in Table 1, Alaska intends to disburse the funds over a 5-year period on
school buses, public transit buses, ferries/tugs and marine vessels, electric vehicle charging
infrastructure and diesel engines used for prime power. Up to 15 percent of the trust may be
allocated to the lead agency for administrative costs, to be reimbursed at a rate of up to 15 percent
of each funded project. Each allocation of trust funds described in Table 1 includes the 15 percent
administrative costs. The relative allocations of funds may change over time depending on the
analysis of emission benefits and costs for each proposed project.
4.1. EMA 2 – School Buses and Public Transit Buses
Eligible Mitigation Action 2 includes the repower or replacement of Types A-D school buses, or
Classes 4-8 shuttle or transit buses. Vehicles eligible for scrappage and repower or replacement
include those with engine model years of 2009 or older. The engines/buses may be replaced with
new cleaner diesel engines/vehicles, alternative fueled engines/vehicles (e.g., CNG, propane,
electric hybrid), or all-electric engines/vehicles.
4.1.1. Type A-D School Buses
Alaska intends to allocate 50% of the VW Trust to the replacement of old high-pollution emitting
school buses. A little more than half of the people providing public comment supported using the
EMT funds to replace older diesel school buses. Nearly all school districts have eligible buses for
replacement, some of which are more than 20 years old. There will not be any mandatory funding
match requirement for school bus upgrade/replacement as the eligible recipients are government
entities and there are no federal programs that support replacing or upgrading school buses other
than the EPA’s DERA rebate program which does not allow VW Trust funds to be used as
mandatory cost-share.
Two request for applications (RFA) will be solicited for the upgrade/replacement of eligible school
buses, each allowing for the disbursement of up to $2 million. The first solicitation wil l occur
during the winter 2018/2019 and the second in late fall 2019. As described in Table 2, school bus
projects will be evaluated based on:
Cost effectiveness ($/lifetime short ton NOx reduction)
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Location in a NOx emission priority area
Location in an air quality priority area
Location within at-risk communities
Voluntary matching funds
4.1.2. Class 4-8 Public Transit Buses
Alaska intends to allocate 10% of the VW Trust to the replacement of old high-pollution emitting
public transit buses. Nearly 60% of the public responses supported use of the EMT funds to replace
public transit buses. Several municipalities have eligible buses for replacement. Although not a
condition of the VW Trust, Alaska will require 80% matching funds from applicants for the
upgrade/replacement of eligible public transit buses because there are federal funds available to
the state and urbanized areas for the replacement of public transportation and fixed-route buses via
both state formula allocation and competitively. VW Trust funds may be used as mandatory cost-
share for these federal funds.
Up to $800,000 will be made available for the upgrade/replacement of eligible public transit buses
through an RFA in winter 2018/2019. As described in Table 2, public transit bus projects will be
evaluated based on:
Cost effectiveness ($/lifetime short ton NOx reduction)
Location in a NOx emission priority area
Location in an air quality priority area
Location within at-risk communities
Voluntary matching funds
4.2. EMA 4 – Ferries/Tugs and EMA 10 – DERA Marine Vessels
Ferries or tugs equipped with unregulated, Tier 1, or Tier 2 marine engines may be repowered
under EMA 4. These tugs and ferries may be repowered with any new Tier 3 or Tier 4 diesel or
alternate fueled engine, or with all-electric engines. In addition, under the DERA Option (EMA
10), commercial marine vessels with pre-Tier 3 engines operated at least 1,000 hours per year are
eligible for upgrade.
Alaska intends to allocate 10% of the VW State Trust to upgrade eligible marine vessels, require
mandatory matching funds, and cap the funds at $200,000 per project. Approximately 15% of the
public comments supported the use of EMT funds to repower marine engines. Interest in upgrading
eligible diesel engines in marine vessels has been expressed by the Inter-Island Ferry Authority
and the City and Borough of Ketchikan, as well as private commercial fishing vessels and marine
tour companies in Southeast Alaska.
The VW Trust stipulates funding limitations for the replacement of ferry/tug engines that are non-
government owned (See Appendix C). Alaska will apply the same funding limitations to
government-owned ferries and tugs. For eligible marine vessels other than ferries or tugs, the
funding limitations established by the EPA under the DERA program would apply (See Appendix
D).
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Up to $800,000 will be made available for the upgrade/replacement of eligible marine engines
through an RFA in late fall 2019. These projects will be evaluated based on:
Cost effectiveness ($/lifetime short ton NOx reduction)
Alaska residency or Alaska-based business
Voluntary matching funds
Applicant experience with managing grants
4.3. EMA 10 – DERA Prime Power
In recent years, Alaska has been allocated approximately $250,000 of federal funds per year
through the EPA’s State DERA program. The ADEC and AEA have historically used these funds,
along with other state funds and Denali Commission funds, to repower or upgrade diesel engines
in power houses in rural Alaska. The State DERA program requires a mandatory cost-share by the
State, for which the EMT funds may not be applied per the terms of the VW settlement agreement.
However, EMT funds may be applied as voluntary match. Under the State DERA program, as an
incentive to providing voluntary match, if the state provides a 1:1 voluntary match to the State
DERA funds, the EPA awards an additional 50 percent funding. To fully leverage federal funds
for projects in rural Alaska, Alaska intends to set aside approximately $250,000 of the EMT
annually for the state’s voluntary match under the State DERA program for five years.
Approximately 18% of the public comments supported use of EMT funds to replace older diesel
engines used for prime power. VW State Trust funds will be made available for these projects
winter 2018/2019 ($500,000), spring 2019, spring 2020 and spring 2021. The Alaska Energy
Authority will determine which projects receive VW Trust funding based on the same criteria used
to prioritize state Rural System Power Upgrade (RPSU) projects.
4.4. EMA 9 - Light-duty Zero-Emission Vehicle Supply Equipment
Alaska intends to allocate 15% of the EMT funds to electric vehicle charging infrastructure, the
maximum amount allowable per the settlement agreement. One-third of the public comments
supported use of the EMT funds for electric charging infrastructure. Alaska will allocate the funds
regionally based on populations within the connected road systems as follows:
Railbelt and Copper Valley Region (79% statewide population) - $950,000
Southeast Region (10% statewide population) – $125,000
Other areas of the state combined (11% statewide population) - $135,000
The Trust agreement establishes funding limitations based on the location and availability of the
charging infrastructure: publically available on government-owned property (100%); publically
available on non-government-owned property (80%); and generally non-public sites at work places
or multi-unit buildings (60%) (See Appendix C). Alaska will require a minimum matching fund
amount of 20% for all publically-available sites whether owned by government or non-government
entities.
The funds will be made available to each of the areas as early as spring 2019. The Railbelt/Copper
Valley and Southeast regions will each be required to develop a regional comprehensive plan that
includes AEA, DEC, utilities, statewide and local transportation planners, local government, fleet
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owners, electric vehicle owners, and car dealerships. The plans will include locations of existing
infrastructure and proposed locations for new level 2 and level 3 charging stations, rationale for
site selections, prioritization of site installation, and schedule. Within each region funds will be
prioritized based on the population of the area served, traffic volumes/commuting corridors,
average miles of road traveled, and the amount of anticipated NOx reduction. Plans will need to
demonstrate how the EV stations are sited in the most cost-effective manner and will need to
include agreements with the entities who will own and maintain each site (e.g., local utility or
government). All installations will be required to have interoperability.
For areas outside of these two regions, an RFA will be solicited and projects will be evaluated
following the same criteria for prioritizing charging sites described above.
5. EXPECTED RANGES OF EMISSION REDUCTIONS
The terms of the Trust require each beneficiary to provide a general description of the expected
ranges of NOx emission reductions that would be realized by implementation of the EMAs
identified in the Plan. To do so, AEA gathered fleet data from several school districts and
municipalities and used the EPA’s Diesel Emission Quantifier tool. However, the information
presented below is for demonstrative purposes only and does not represent an agreement to pursue
specific projects within the various EMAs. Separate RFAs will be solicited for school bus, transit
bus, and ferry/tug projects and the applications will be evaluated based on the criteria previously
presented.
The actual amounts of NOx emission reductions will depend on the types of projects, manufacture
years of the engines being replaced, the type of replacement engine, fuel usage, and the amount of
annual runtime, idling and start/stops of the engines. The amount of NOx reductions will be
determined for each funded project and will be presented in the semi-annual reports submitted to
the Trustee.
5.1. EMA 2 - School Buses
None of the school districts interviewed were interested in all-electric or alternative fuel buses
because of the upfront costs or unknowns; the preference was for new cleaner diesel buses which
are considerably less expensive. However, in the future, school districts may choose to apply for
the replacement of eligible diesel school buses with all-electric or alternative fuel buses, such as
propane. Respondents indicated that the average cost of a new cleaner diesel school bus is
approximately $135,000 and an all-electric bus is approximately $400,000. Accordingly, Alaska’s
proposed allocation of 50% of the EMT fund could replace approximately 25 older buses with
cleaner diesel buses or 8 older buses with all-electric buses.
For purposes of estimating the amount of anticipated reduction in NOx emissions for this Plan,
AEA used the EPA Diesel Emissions Quantifier (DEQ) tool and information from the four largest
school districts in Alaska. The Anchorage and Kenai Peninsula Borough school districts provided
model years, average miles driven per year, fuel usage, and idling time estimates for their district-
owned fleet. These two school districts combined have more than 25 buses of model year 1998
and 1999, and average annual miles driven of approximately 9,200 and 7,500 miles, respectively.
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The Fairbanks and Matanuska-Susitna Valley school districts use contracted school buses, more
than 25 of which are model year 2007. Nearly all of the school buses in the rest of Alaska’s school
districts fall within the range of these model years. Because the school districts that own their buses
do not replace the buses until they have adequate funds for replacement and there are currently
school buses within some fleets that are more than 23 years old, a school bus lifetime was assumed
to be 25 years. Based on the information for these four school districts and our assumptions,
replacement of these model year buses with model year 2019 diesel buses could result in a
reduction of 0.7 to 3.5 short tons of NOx emissions annually or a lifetime reduction of 9 to 14 short
tons of NOx.
5.2. EMA 2 - Public Transit Buses
Alaska intends to allocate 10% of the VW Trust to the replacement of old high-pollution emitting
public transit buses and require 80% in matching funds from recipients. Anchorage (17), Fairbanks
(12), Matanuska-Susitna (9), Juneau (7), and Ketchikan (4) have eligible diesel buses for
replacement (see Table 3). In addition, there are 20 smaller cutaway buses scattered in other
communities throughout the state ranging from Model Year 2006 to 2009.
The Municipality of Anchorage and the City and Borough of Juneau are both interested in
replacing older diesel buses with all-electric buses while Fairbanks North Star Borough is
interested in newer diesel buses. The average cost of a new cleaner diesel 35-foot to 40-foot transit
bus is $400,000 while an electric bus is $1,075,000; the cost of an alternative fuel bus falls
between. An allocation of 10% of the EMT fund with a required 80% match could replace
approximately 10 older buses with cleaner diesel buses or 4 older buses with all-electric buses.
For purposes of estimating the amount of anticipated reduction in NOx emissions for this Plan,
AEA used the EPA Diesel Emissions Quantifier tool; model years, average miles driven per year,
fuel usage, and idling time estimates provided by the Municipality of Anchorage and Fairbanks;
and an assumed lifetime of 15 years. Based on the information for these two areas and our
assumptions, replacement of 10 model year 2007 buses with 10 model year 2019 diesel buses
could result in a reduction of approximately 1.9 short tons of NOx emissions annually or a lifetime
reduction of 7 short tons of NOx. Replacing four of the buses with 4 all-electric buses could result
in a reduction of approximately 0.9 short tons of NOx emissions annually or a lifetime reduction
of 3.5 short tons of NOx.
5.3. EMA 4 – Ferries/Tugs and EMA 10 – DERA Marine Vessels
Ferries/tugs and other commercial marine vessels operated at least 1,000 hours per year equipped
with unregulated, Tier 1, or Tier 2 marine engines may be repowered under EMA 4 and EMA 10
(DERA Option), respectively. It is difficult to estimate the amount of NOx reductions for these
projects as the size of the engine, run time, fuel consumption, and idle time varies greatly as well
as the type of the replacement engines (e.g., non-tiered mechanically controlled versus Tier 2).
Interest in upgrading eligible diesel engines has been expressed by the Inter-Island Ferry
Authority, the City and Borough of Ketchikan, as well as private commercial fishing vessels and
marine tour companies in Southeast Alaska. The cost of these projects can range from
approximately $250,000 to well over $1 million. Alaska intends to allocate 10% of the State trust
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to upgrade eligible marine vessels, require a 50% match and cap the allowable funds at $200,000
per project. This allocation would assist in upgrading at least 4 engines.
As an example, NASEO (2017) has provided the following typical emission impact per ferry per
year as follows:
Pre-control replaced with Tier 3: -38,198 pounds of NOx
Pre-control replaced with Tier 4: -62,336 pounds of NOx
Tier 1 replaced with Tier 3: -23,973 pounds of NOx
Tier 1 replaced with Tier 4: -47,812 pounds of NOx
Tier 2 replaced with Tier 3: -12,198 pounds of NOx
Tier 2 replaced with Tier 4: -36,337 pounds of NOx
5.4. EMA 10 - DERA Prime Power
In 2014, electric generation from diesel fuel sources resulted in 10,257 tons of NOx emissions.
Under the DERA option (EMA 10), EMT funds may be used as voluntary match to repower or
replace eligible stationary diesel engines used for power production.
We propose to allocate approximately 15% of the EMT State Trust funds to upgrade or replace
diesel engines used for prime power in rural Alaska. This amount allows for the state to leverage
State DERA funds to the maximum extent possible each year over 5 years. The State typically
receives approximately $250,000 in State DERA. By using the EMT funds as voluntary match at
a 1:1 ratio, we could leverage an additional $125,000 in EPA funds each year.
The cost of replacing an engine is approximately $100,000 to $200,000 if the generator is replaced
as well. Over 5 years, with the use of 15% of the EMT along with $625,000 leveraged from the
EPA, approximately 18 engines or 9 engine-generator sets could be replaced. The amount of NOx
reduction is highly variable from engine to engine depending on the engine size, power load,
efficiency, fuel usage, runtime, type of engine being replaced and type of replacement engine.
Based on estimates of NOx reduction for previous DERA projects, replacement of an eligible
diesel engine with a higher-tiered engine can result in 1-5 tons of NOx reduction over a 10-year
period.
5.5. EMA 9 - Light-duty Zero-Emission Vehicle Supply Equipment
EMA 9 allows for up to 15 percent of Alaska’s allocation of the trust to be used to fund the
acquisition, installation, operation and maintenance of new light duty zero emission vehicle supply
equipment (Level 1, Level 2 or fast charging equipment). There are too many factors to reasonably
estimate the NOx reductions from this EMA at this time. The anticipated reduction in NOx
emissions would also depend on the amount of NOx produced by the source of electricity. The
greatest emission reduction would occur in areas with hydropower or other renewable energy
resources. This EMA will benefit air quality in the long term by providing infrastructure to promote
electric vehicle use.
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6. PUBLIC INPUT
The section below outlines the public outreach and public involvement that has been implemented
by AEA since being designated the Lead Agency.
6.1. Goals for Outreach
The goals for public outreach were as follows:
Gather input from interested stakeholders and the general public on how settlement funds
should be distributed.
Integrate input from the Governor’s office and ADEC about projects and areas of interest
as it relates to use of settlement funds.
Distribute information about the settlement to stakeholders and the general public.
6.2. Target Audience
AEA targeted outreach to the following audience:
General public
Governor's office
State and local governments:
o ADEC
o Alaska Department of Transportation and Public Facilities (ADOT&PF)
o Local governments (Boroughs and Cities)
o Metropolitan planning organizations for designated Nonattainment and
Maintenance areas (Fairbanks Metropolitan Area Transportation Solutions
(FMATS); Anchorage Metropolitan Area Transportation Solutions (AMATS))
o School Districts
o Port Authorities
Tribes, Tribal government and regional Native organizations/corporations
Alaska Native Tribal Health Consortium
Federal agencies
Electric utilities
Equipment/service vendors
6.3. Communications Methods and Tools
6.3.1. Public engagement events
AEA staff presented information regarding the settlement and the Draft Plan and solicited feedback
through facilitated Q&A, comment forms, links to online comment forms, email and phone. AEA
also maintained consistent coordination directly with other stakeholder groups including National
Tribal Air Association/ITEP and Alaska Native Tribal Health Consortium.
Meetings/presentations:
Apr 13, 2017 Juneau Renewable Energy Cluster Working Group
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May 1-4, 2017 National Tribal Forum on Air Quality
May 2017 Alaska Power Association Environmental Regulations Committee meeting
Aug 10, 2017 Juneau Renewable Energy Cluster Working Group
Sept 11-12, 2017 Intelligent Transportation Society annual meeting
Sept 13-15, 2017 Alaska Power Association annual meeting
Sept 19-21, 2017 Southeast Conference Annual Meeting
Oct 19-21, 2017 Alaska Federation of Natives conference
Oct 24, 2017 Alaska Tribal Conservation Alliance
Nov 11, 2017 Juneau Renewable Energy Cluster Working Group
Nov 13-17, 2017 Alaska Municipal League
Nov 28-30, 2017 BIA Providers Conference
Feb 9-11, 2018 Rural Small Business Conference
Feb 12-16, 2018 Alaska Forum on the Environment
Feb 13, 2018 Chugach Electric, ML&P, MEA EV infrastructure meeting
Apr 10-12, 2018 Rural Energy Conference
May 18, 2018 DOT&PF, AMATS and FMATS meeting
6.3.2. Public Notice
AEA received assistance from the media in advertising public comment opportunities both prior
to the development of the Draft Plan and after the official public comment period opened with the
publishing of the Draft Plan, including:
http://www.alaskajournal.com/2018-06-06/state-seeks-input-plan-81m-vw-settlement-
funds
http://www.ktuu.com/content/news/State-of-Alaska-to-receive-81-million-from-
Volkswagen-settlement-484601771.html
http://fm.kuac.org/post/agency-seeks-input-using-vw-lawsuit-settlement-funds-improve-
air-quality
https://www.alaskapublic.org/2017/03/16/alaska-gets-millions-of-dollars-from-
volkswagen-settlement/
https://www.adn.com/business-economy/energy/2017/03/29/alaska-seeks-your-ideas-on-
spending-8-million-from-volkswagen-settlement/
6.3.3. Surveys
AEA developed an online survey form located on our website for interested parties to submit
comments. AEA sent the VW listserve notice of a survey soliciting information about interest in
Eligible Mitigation Actions. The online survey was updated prior to the release of the Draft Plan
and was also included as an appendix of the Draft Plan. The survey could be completed online or
submitted to AEA via mail, email or fax.
AEA followed up with public transit fleet owners, school districts, the Alaska Railroad
Corporation, and the Inter-Island Ferry Authority to gather information on current fleet/equipment
in-use to assist in determining where opportunities exist.
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AEA also developed an inventory of engines in rural diesel powerhouses to define the opportunity
for Diesel Emission Reduction Act (DERA) projects to repower or replace diesel engines or
gensets. This survey was completed through a combination of telephonic, email and on -site data
collection.
6.3.4. Draft Beneficiary Mitigation Plan
AEA developed a Draft Plan to solicit public input. The Draft Plan was published on May 1, 2018
initiating a 60-day public comment period. The Draft Plan was distributed as follows:
published on the AEA website
published on the State of Alaska public notice site
emailed to key audiences and listserve
6.3.5. Public Meetings
During the 60-day public comment period for the Draft Plan, public meetings were held in
Anchorage, Fairbanks, and Juneau to describe the State’s proposed allocation of the Trust funds
amongst the Eligible Mitigation Actions and to solicit input. Two teleconferenced webinars were
also held to make the presentations accessible to people outside these three areas. The presentation
was posted to AEA’s website as well.
Anchorage – June 4, 2018 at AHFC Board Room
o 3 pm – 5 pm – 7 attendees
o 6 pm – 8 pm – 1 attendee
Fairbanks – June 1, 2018 at FNSB Assembly Chambers
o 3 pm – 5 pm – 3 attendees
o 6 pm – 8 pm – 0 attendees
Juneau – June 7, 2018 - (in person and as teleconference)
o 3 pm – 5 pm – 10 attendees
o 6 pm – 8 pm – 2 attendees
Webinar – June 20, 2018 at 1pm – 3 pm
o 3 attendees, technical difficulties
Webinar – June 21, 2018 at 12 pm – 2 pm
o 4 attendees
6.4. Summary of Public Comments
AEA received about 100 comments from email, phone, the first online survey prior to posting the
Draft Plan, the second survey during the 60-day Draft Plan comment period, and the public
meetings held during June 2018. Table 4 ranks the EMAs that received high public support. Table
5 characterizes the entities that provided input to Alaska’s Plan.
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7. LITERATURE CITED
ADEC. 2009. Juneau’s Mendenhall Valley Proposed PM10 Limited Maintenance Plan. Adopted
February 20, 2009. 40 pages.
ADEC. 2010. Amendments to State Air Quality Control Plan; Vol. II: Analysis of Problems,
Control Actions; Section III.D.2 Eagle River PM-10 Limited Maintenance Plan. Adopted
August 20, 2010. 21 pages.
ADEC. 2011. Dust Complaints in Rural Alaska. Map. 1 page.
ADEC. 2013a. Amendments to: State Air Quality Control Plan Vol. II: Analysis of Problems,
Control Actions; Section III.B: Anchorage Transportation Control Program. Anchorage
CO Limited Maintenance Plan for 2014-2024. Prepared by the Municipality of Anchorage
Department of Health and Human Services. Amended April 9, 2013. 69 pages.
ADEC. 2013b. Amendments to: State Air Quality Control Plan Vol. II: Analysis of Problems,
Control Actions; Section III.C: Fairbanks Transportation Control Program. Fairbanks
Limited CO Maintenance Plan. A plan addressing the second 10 years of the 2004-2024
CO maintenance planning period. Prepared by the Fairbanks North Star Borough for
inclusion in the State Implementation Plan for Air Quality. Adopted February 22, 2013. 27
pages.
ADEC. 2015. 2014 Triennial Air Emissions Reporting Plan. ADEC Air Quality Division Non-
Point Mobile Sources Program. 10 pages.
ADEC. 2016. Amendments to: State Air Quality Control Plan Section III.D.5.1-5.14 {Section III.
Area-wide Pollutant Control Program; D. Particulate Matter; 5. Fairbanks North Star
Borough PM2.5 Control Plan}. Adopted December 24, 2014. Amended September 7, 2016.
ADEC. 2017. Unpublished. Lifetime excess NOx emissions data from affected vehicles registered
in Alaska as of March 2017.
ADEC. 2018. Alaska Greenhouse Gas Emissions Inventory 1990-2015. ADEC Division of Air
Quality. January 30, 2018. 48 pages.
EPA. Health Assessment Document for Diesel Engine Exhaust (Final 2002). U.S. Environmental
Protection Agency, Office of Research and Development, National Center for
Environmental Assessment, Washington Office, Washington, DC, EPA/600/8-90/057F,
2002.
EPA. 2015a. 2011 National Air Toxics Assessment.
EPA. 2015b. 2014 National Emissions Inventory data. https://www.epa.gov/air-emissions-
inventories/2014-national-emissions-inventory-nei-data.
EPA. 2016. Integrated Review Plan for the National Ambient Air Quality Standards for Particulate
Matter. December 2016. EPA-452/R-16-005. 173 pages.
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EPA. 2017a. Detailed comparison of VW Eligible Mitigation Actions 1-9 and Eligible Mitigation
Action #10 (DERA Option). Office of Transportation and Air Quality. January 2017. 6
pages.
EPA 2017b. Environmental Justice Screening and Mapping Tool (Version 2017).
EPA. 2017c. Inventory of U.S. Greenhouse Gas Emissions and Sinks 1990-2015. 633 pages.
EPA. 2017d. NAAQS Table. https://www.epa.gov/criteria-air-pollutants/naaqs-table. January 19,
2017.
IARC. 2012. IARC: Diesel Engine Exhaust is Carcinogenic. World Health Organization,
International Agency for Research on Cancer. June 12, 2012. Page 1.
https://www/iarc.fr/en/media-centre/pr/2012/pdfs/pr213_E.pdf
NASEO. 2017. Volkswagen Settlement Beneficiary Mitigation Plan Toolkit. 61 pages.
United Nations Framework Convention on Climate Change (UNFCCC). 2014.
http://unfccc.int/kyoto_protocol/items/2830.php.
BENEFICIARY MITIGATION PLAN
Volkswagen Settlement Alaska Energy Authority
Environmental Mitigation Trust Page 28 November 2018
8. TABLES
Table 1. Proposed allocation of VW Environmental Mitigation Trust funds.
Percent
of Total
Fund
Allocat
ed
Eligible Mitigation Actions (EMAs)
2019 2020 2021
Q1 Q2 Q3 Q2 Q2
50% EMA 2 – School Buses
Match requirement:
none
$2 million $2 million
10% EMA 2 – Transit Buses
Match requirement:
80%
Applies to both government
and non-government
$800,000
10% EMA 4 – Ferries/Tugs; EMA 10 – Marine Vessels
Match requirement:
60% repower with
diesel/alternative fuel
25% (ferries/tugs) 40% (other
marine vessels) repower with
all-electric
Applies to both government
and non-government
$800,000
15% EMA 10 - Prime Power
Match requirement:
none $500,000 $250,000 $250,000 $250,000
15% EMA 9
Match requirement:
20% at publically available
sites
40% at workplace or multi-
unit dwellings
Applies to both government
and non-government owned
property
$950,000
$125,000
$135,000
BENEFICIARY MITIGATION PLAN
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Environmental Mitigation Trust Page 29 November 2018
Table 2. Project evaluation matrix for upgrade or replacement of eligible school buses and
public transit buses.
Criteria Criteria Points
Total
Possible
Points
Cost effectiveness in lifetime
reduction of NOx emissions
($/short ton NOx reduction)
Least cost effective (<40th percentile) 10
30
40th to 60th percentile 15
60th to 80th percentile 20
80th to 90th percentile 25
Most cost effective (90th to 100th percentile) 30
NOx emission priority area
(total annual tons of on-road
diesel NOx emissions by Census
Area)
Least on-road NOx emissions
(zero to 70th percentile):
one point for each 10 percentiles
0-7
20
70th to 80th percentile 10
80th to 90th percentile 15
90th to 95th percentile 18
Most on-road NOx emissions
(95th to 100th percentile) 20
Air quality priority area
Not located in priority area or
least diesel particulate matter by Census Tract
(<60th percentile)
0
10 60th to 80th percentile diesel particulate matter 5
Located in maintenance area or
>80th percentile diesel particulate matter 7
Projects located within non-attainment areas 10
Environmental Justice Index –
diesel particulate matter and at-
risk population demographics
Zero to 90th percentile:
one point for each 10 percentiles 0-8
10 90th to 95th percentile 9
Located in most at-risk population Census
Tract
(95th to 100th percentile)
10
Environmental Justice Index -
traffic proximity and volume and
at-risk population demographics
Zero to 90th percentile:
one point for each 10 percentiles 0-8
10 90th to 95th percentile 9
Located in most at-risk population Census
Tract
(95th to 100th percentile)
10
Voluntary funding match 0.5 points for every 1% match up to 20 points 0.5 - 20 20
BENEFICIARY MITIGATION PLAN
Volkswagen Settlement Alaska Energy Authority
Environmental Mitigation Trust Page 30 November 2018
Table 3. Eligible public transit buses for replacement with VW Environmental Mitigation
Trust funds. In addition, there are approximately 20 smaller cutaway buses scattered in
other communities throughout the state ranging from Model Year 2006 to 2009.
Location Total Number of
Buses
Number of
Eligible Buses
Eligible Model
Years
Anchorage 50 17 2007
Fairbanks 14 12 1994-2007
Mat-Su Valley 9 9 1995
Juneau 18 7 2003-2006
Ketchikan 6 4 2008
Table 4. Summary of public support for the Environmental Mitigation Actions.
EMA Description EMA # Rank Percent High
Support
Class 4-8 transit buses EMA 2 1 57 %
Class 4-8 school bus EMA 2 2 52 %
ZEV supply equipment (15% of funds) EMA 9 3 33 %
DERA Voluntary match for diesel powerhouses EMA 10 4 18 %
Ferries/tugboats/marine vessels EMA 4 5 15 %
Class 8 local freight trucks and port drayage trucks;
Class 4-7 local freight trucks
EMA 1, EMA 6 6 14 %
Freight switcher locomotives EMA 3 7 8 %
Forklifts and port cargo handling equipment EMA 8 7 8 %
Airport ground support equipment EMA 7 9 3 %
Shore power for ocean going vessels EMA 5 10 1 %
BENEFICIARY MITIGATION PLAN
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Environmental Mitigation Trust Page 31 November 2018
Table 5. Summary of entities that provided input to Alaska’s Draft Beneficiary Mitigation
Plan for the Volkswagen Environmental Mitigation Trust.
Alaska Residents
Anchorage – 8 1
Chugiak – 1 1
Big Lake – 1 1
Fairbanks – 2 1,2
Kenai – 1 1
Trapper Creek – 1 1
Juneau - 4 1,2
Kodiak – 1 1
Port Lions – 1 2
Government
Federal
Tongass National Forest 2
Tribe
Native Village of Nightmute 1
Native Village of Kwigillingok
2
State
ADEC 1,2
DOT&PF Statewide Public Transit 3
DOT&PF – AMATS and FMATS
2,3
Alaska Railroad Corporation 2,3
Inter-Island Ferry Authority 2,3
Local
Municipality of Anchorage
Transportation Department 1,2,3
MOA Solid Waste Services 1,2,3
Fairbanks North Star Borough Transit 3
City and Borough of Juneau 1
City and Borough of Sitka 1
School Districts
Anchorage 1,2,3
Fairbanks North Star 2,3
Mat-Su 2,3
Kenai Peninsula Borough 2,3
Sitka 2,3
Cordova 2,3
Craig 2,3
Iditarod Area 1
ANCSA Corporation
Kootznoowoo, Inc. 1
Utilities
Chugach Electric Association
1,2
Homer electric Association 1
Municipal Light and Power 1,2
Matanuska Electric
Association 2
Alaska Electric Light and Power 1,2
Cordova electric Cooperative 2
Kodiak Electric Association 1,2
Iliamna Newhalen Nondalton
Electric Cooperative 2
TDX Power (Sand Point, Manley,
Adak) 1,2,3
City of Chefornak 2,3
Organizations
Local
Alaska Fisheries Development
Foundation 2
Ketchikan Shipyard 2
Alaska Transit Association 3
350 Juneau 1,2
Renewable Juneau 1,2
National
Diesel Technology Forum 1
NGVAmerica 1
The Hydrogen Association 1
Americans for Prosperity, Alaska 1
Industry
Local
UnCruise Adventures 2
Kenai Fjords Tours 1
Reliant Transportation (ASD
School Bus Contractor) 1
National
Blue Bird Corporation 2
The Lion Electric Company 2
New Flyer Industries 3
Cummins, Inc. 1,2,3
General Motors 1
Penske Truck Leasing 1
MedicAire, LLC Medidock 2
NordCo 1
Knoxville Locomotive Works 1,2
EV Infrastructure
Orange EV 1
Charge Point 1
Greenlots 1
SemaConnect Inc. 1
Innogy eMobility US 1
1 completed AEA survey
2 expressed interest in VW through email, phone, or meeting
3 contacted by AEA for additional information regarding fleet/project eligibility
BENEFICIARY MITIGATION PLAN
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Environmental Mitigation Trust Page 32 November 2018
9. FIGURES
BENEFICIARY MITIGATION PLAN
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Figure 1. Map of the census area/boroughs of Alaska. Green areas represent boroughs, blue areas represent consolidated city-boroughs and yellow
areas represent census areas.
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Figure 2. Source of NOx emissions in Alaska by sector in 2014. NOx emissions in Alaska in 2014 total 154,373
tons statewide. VW trust Eligible Mitigation Actions occur within the onroad diesel, nonroad mobile diesel,
locomotive, commercial marine vessel, and electric generation from oil sectors. Source: EPA 2015b.
Wildfire
12%
Other
1%
Industrial/
Commercial…
Electric Generation
(Non-oil)
6%
Electric Generation
(Oil)
7%
Aircraft
2%
Commercial
Marine
Vessels
25%
Locomotives
<1%
Onroad
Mobile
(Diesel)
5%
Onroad
Mobile
(Non-
diesel)
5%
Nonroad
Mobile
(Diesel)
1%
Nonroad
Mobile
(Non-
diesel)
1%
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Figure 3. 2014 Diesel NOx emissions (tons per year) by Alaska census area/borough for the transportation and electric generation sectors that include
Eligible Mitigation Actions under the VW Environmental Mitigation Trust. Source: EPA 2015b.
0
1,000
2,000
3,000
4,000
5,000
6,000
7,000
8,000
NOx Emissions (tons per year)Census Area/Borough
Onroad Mobile (Diesel)
Nonroad Mobile (Diesel)
Locomotives
Commercial Marine Vessels
Electric Generation - Oil
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Figure 4. Source of particulate matter (PM 10 and PM2.5) emissions in Alaska by sector in 2014. Source: EPA
2015b.
Transportation
0.8%
Electric
Generation
0.2%
Industrial/
Commercial
1%Waste
0.8%
Other
0.6%
Dust
41%
Wildfire
56%
Sources of PM10 Emissions
Transportation
1.3%
Electric
Generation
0.3%
Industrial/
Commercial
1.3%Waste
1.2%Other
1%
Dust
8%
Wildfire
87%
Sources of PM2.5 Emissions
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Figure 5. 2014 particulate matter (PM10) emissions (tons per year) by Alaska census area/borough for the transportation and electric generation sectors
that include Eligible Mitigation Actions under the VW Environmental Mitigation Trust. Source: EPA 2015b.
0
50
100
150
200
250
300
PM10 (tons per year)
Onroad Mobile (Diesel)
Nonroad Mobile (Diesel)
Locomotives
Commercial Marine Vessels
Electric Generation - Oil
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Environmental Mitigation Trust Page 38 November 2018
Figure 6. 2014 particulate matter (PM2.5) emissions (tons per year) by Alaska census area/borough for the transportation and electric generation sectors
that include Eligible Mitigation Actions under the VW Environmental Mitigation Trust . Source: EPA 2015b.
0
50
100
150
200
250
300
PM2.5
Onroad Mobile (Diesel)
Nonroad Mobile (Diesel)
Locomotives
Commercial Marine Vessels
Electric Generation - Oil
BENEFICIARY MITIGATION PLAN
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Figure 7. Alaska statewide greenhouse gas emissions in million metric tons of carbon dioxide equivalents (MMT CO2e per year) by sector 1990 - 2015.
Source: ADEC 2018. GHG Emissions (MMT CO2e) 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015
60
50
40
30
20
10
0
Industrial Transportation Residential and Commercial
Electricity Production Industrial Processes Waste
Agriculture
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BENEFICIARY MITIGATION PLAN
APPENDIX A:
AIR QUALITY MAPS
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Environmental Mitigation Trust Appendix A Page 1 November 2018
Figure A-1. Relative amount of on-road NOx emissions from diesel vehicles by Census Area.
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Environmental Mitigation Trust Appendix A Page 2 November 2018
Figure A-2. Relative amount of diesel particulate matter (PM) by Census Tract statewide. See Figures A-2a
through A-2d for detail within the populated portions of the state.
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Figure A-2a. Relative amount of diesel particulate matter (PM) by Census Tract in Anchorage and
Matanuska-Susitna.
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Environmental Mitigation Trust Appendix A Page 4 November 2018
Figure A-2b. Relative amount of diesel particulate matter (PM) by Census Tract in the Fairbanks area.
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Figure A-2c. Relative amount of diesel particulate matter (PM) by Census Tract on Kenai Peninsula.
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Figure A-2d. Relative amount of diesel particulate matter (PM) by Census Tract in Southeast Alaska.
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Figure A-3. Map of health complaints in rural Alaska related to ambient dust. Red indicates communities
with monitoring sites. Source: ADEC 2011.
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Environmental Mitigation Trust Appendix A Page 8 November 2018
Figure A-4. Map of Eagle River PM10 Maintenance Area boundary with Parkgate PM10 monitoring site.
Source: ADEC 2010.
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Environmental Mitigation Trust Appendix A Page 9 November 2018
Figure A-5. Map of Mendenhall Valley PM10 Maintenance Area boundary, Juneau, Alaska. Source: ADEC
2009.
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Figure A-6. Map of Fairbanks North Star Borough 24-hour PM2.5 Nonattainment Area boundary. The area is
divided into 3 air quality control zones, each with sub-area specific regulatory control measures. Source:
ADEC 2016.
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Figure A-7. Multiple PM2.5 hotspots identified within Fairbanks North Star Borough PM2.5 Nonattainment
Area. Source: ADEC 2016.
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Environmental Mitigation Trust Appendix A Page 12 November 2018
Figure A-8. Map of Anchorage carbon monoxide (CO) Maintenance Area boundary and CO monitoring sites.
Several monitoring sites were discontinued because the measured CO values were low compared to
comparable monitoring sites in the network. Source: ADEC 2013a.
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Environmental Mitigation Trust Appendix A Page 13 November 2018
Figure A-9. Map of North Pole carbon monoxide Maintenance Area boundary, Fairbanks North Star
Borough, Alaska. Source: ADEC 2013b.
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Figure A-10. Map of Fairbanks and Fort Wainwright carbon monoxide Maintenance Area boundary, Fairbanks North Star Borough, Alaska . Source:
ADEC 2013b.
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BENEFICIARY MITIGATION PLAN
APPENDIX B:
EPA ENVIRONMENTAL JUSTICE SCREENING MAPS
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Figure B-1. EPA’s environmental justice indices for particulate matter PM 2.5 generated from diesel emissions
based on population demographics within Census Tracts. The indices are grouped by percentile rank. For
example, communities in the 95-100 percentile, the highest risk category presented in red, are the most
vulnerable 5 percent of the communities in Alaska to diesel particulate matter. Portions of Fairbanks,
Southcentral, and Southeast are also within the 80-100th percentiles; see Figures B-1a through B-1d for detail.
Source: EPA 2017b.
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Figure B-1a. EPA’s environmental justice indices for particulate matter PM2.5 generated from diesel
emissions based on population demographics within Census Tracts of Anchorage and Matanuska -Susitna
Valley. The indices are grouped by percentile rank; communities in the 95-100 percentile, the highest risk
category presented in red, are the most vulnerable 5 percent of the communities in Alaska to diesel
particulate matter. Source: EPA 2017b.
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Environmental Mitigation Trust Appendix B Page 3 November 2018
Figure B-1b. EPA’s environmental justice indices for particulate matter PM 2.5 generated from diesel
emissions based on population demographics within Census Tracts of the Fairbanks area. The indices are
grouped by percentile rank; communities in the 95-100 percentile, the highest risk category presented in red,
are the most vulnerable 5 percent of the communities in Alaska to diesel particulate matter. Source: EPA
2017b.
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Environmental Mitigation Trust Appendix B Page 4 November 2018
Figure B-1c. EPA’s environmental justice indices for particulate matter PM 2.5 generated from diesel
emissions based on population demographics within Census Tracts of the Kenai Peninsula. The indices are
grouped by percentile rank; communities in the 95-100 percentile, the highest risk category presented in red,
are the most vulnerable 5 percent of the communities in Alaska to diesel particulate matter. Source: EPA
2017b.
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Figure B-1d. EPA’s environmental justice indices for particulate matter PM 2.5 generated from diesel
emissions based on population demographics within Census Tracts of Southeast Alaska. The indices are
grouped by percentile rank; communities in the 95-100 percentile, the highest risk category presented in red,
are the most vulnerable 5 percent of the communities in Alaska to diesel particulate matter. Source: EPA
2017b.
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Environmental Mitigation Trust Appendix B Page 6 November 2018
Figure B-2. EPA’s environmental justice indices for traffic proximity and volume based on population
demographics within Census Tracts of Alaska. The indices are grouped by percentile rank; communities in
the 95-100 percentile, the highest risk category presented in red, are the most vulnerable 5 percent of the
communities in Alaska to pollution from vehicles. Source: EPA 2017b.
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Environmental Mitigation Trust Appendix B Page 7 November 2018
Figure B-2a. EPA’s environmental justice indices for traffic proximity and volume based on population
demographics within Census Tracts of Anchorage and Matanuska -Susitna Valley. The indices are grouped
by percentile rank; communities in the 95-100 percentile, the highest risk category presented in red, are the
most vulnerable 5 percent of the communities in Alaska to pollution from vehicles. Source: EPA 2017b.
BENEFICIARY MITIGATION PLAN
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Environmental Mitigation Trust Appendix B Page 8 November 2018
Figure B-2b. EPA’s environmental justice indices for traffic proximity and volume based on population
demographics within Census Tracts of the Fairbanks area. The indices are grouped by percentile rank;
communities in the 95-100 percentile, the highest risk category presented in red, are the most vulnerable 5
percent of the communities in Alaska to pollution from vehicles. Source: EPA 2017b.
BENEFICIARY MITIGATION PLAN
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Environmental Mitigation Trust Appendix B Page 9 November 2018
Figure B-2c. EPA’s environmental justice indices for traffic proximity and volume based on population
demographics within Census Tracts of the Kenai Peninsula. The indices are grouped by percentile rank;
communities in the 95-100 percentile, the highest risk category presented in red, are the most vulnerable 5
percent of the communities in Alaska to pollution from vehicles. Source: EPA 2017b.
BENEFICIARY MITIGATION PLAN
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Environmental Mitigation Trust Appendix B Page 10 November 2018
Figure B-2d. EPA’s environmental justice indices for traffic proximity and volume based on population
demographics within Census Tracts of Southeast Alaska. The indices are grouped by percentile rank;
communities in the 95-100 percentile, the highest risk category presented in red, are the most vulnerable 5
percent of the communities in Alaska to pollution from vehicles. Source: EPA 2017b.
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BENEFICIARY MITIGATION PLAN
APPENDIX C:
VW ELIGIBLE MITIGATION ACTIONS AND MITIGATION
EXPENDITURES
Source: Appendix D2 of the 2.0 Liter Consent Decree.
BENEFICIARY MITIGATION PLAN
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Environmental Mitigation Trust Appendix C Page 1 November 2018
1. Class 8 Local Freight Trucks and Port Drayage Trucks (Eligible Large Trucks)
a. Eligible Large Trucks include 1992-2009 engine model year Class 8
Local Freight or Drayage. For Beneficiaries that have State
regulations that already require upgrades to 1992-2009 engine model
year trucks at the time of the proposed Eligible Mitigation Action,
Eligible Large Trucks shall also include 2010-2012 engine model
year Class 8 Local Freight or Drayage.
b. Eligible Large Trucks must be Scrapped.
c. Eligible Large Trucks may be Repowered with any new diesel or
Alternate Fueled engine or All-Electric engine, or ma y be replaced
with an y new diesel or Alternate Fueled or All-Electric vehicle, with
the engine model year in which the Eligible Large Trucks Mitigation
Action occurs or one engine model year prior.
d. For Non-Government Owned Eligible Class 8 Local Freight Trucks,
Beneficiaries ma y onl y draw funds from the Trust in the amount of:
1. Up to 40% of the cost of a Repower with a new diesel or Alternate
Fueled (e.g. CNG, propane, H ybrid) engine, including the costs of
installation of such engine.
2. Up to 25% of the cost of a new diesel or Alternate Fueled (e.g.
CNG, propane, Hybrid) vehicle.
3. Up to 75% of the cost of a Repower with a new All-Electric
engine, including the costs of installation of such engine, and
charging infrastructure associated with the new All-Electric
engine.
4. Up to 75% of the cost of a new All-Electric vehicle, including
charging infrastructure associated with the new All-Electric
vehicle.
e. For Non-Government Owned Eligible Dra yage Trucks, Beneficiaries may
only draw funds from the Trust in the amount of:
1. Up to 40% of the cost of a Repower with a new diesel or Alternate
Fueled (e.g. CNG, propane, H ybrid) engine, including the costs of
installation of such engine.
2. Up to 50% of the cost of a new diesel or Alternate Fueled (e.g.
CNG, propane, Hybrid) vehicle.
3. Up to 75% of the cost of a Repower with a new All-Electric
engine, including the costs of installation of such engine, and
charging infrastructure associated with the new All-Electric
engine.
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Environmental Mitigation Trust Appendix C Page 2 November 2018
4. Up to 75% of the cost of a new all-electric vehicle, including
charging infrastructure associated with the new All-Electric
vehicle.
f. For Government Owned Eligible Class 8 Large Trucks, Beneficiaries may draw
funds from the Trust in the amount of:
1. Up to 100% of the cost of a Repower with a new diesel or Alternate
Fueled (e.g. CNG, propane, Hybrid) engine, including the costs of
installation of such engine.
2. Up to 100% of the cost of a new diesel or Alternate Fueled (e.g. CNG,
propane, Hybrid) vehicle.
3. Up to 100% of the cost of a Repower with a new All-Electric engine,
including the costs of installation of such engine, and charging
infrastructure associated with the new All-Electric engine.
4. Up to 100% of the cost of a new All-Electric vehicle, including
charging infrastructure associated with the new All-Electric vehicle.
2. Class 4-8 School Bus, Shuttle Bus, or Transit Bus (Eligible Buses)
a. Eligible Buses include 2009 engine model year or older class 4-8 school buses,
shuttle buses, or transit buses. For Beneficiaries that have State regulations that
alread y require upgrades to 1992-2009 engine model year buses at the time of
the proposed Eligible Mitigation Action, Eligible Buses shall also include 2010-
2012 engine model year class 4-8 school buses, shuttle buses, or transit buses.
b. Eligible Buses must be Scrapped.
c. Eligible Buses ma y be Repowered with any new diesel or Alternate Fueled or
All-Electric engine, or may be replaced with any new diesel or Alternate Fueled
or All-Electric vehicle, with the engine model year in which the Eligible Bus
Mitigation Action occurs or one engine model year prior.
d. For Non-Government Owned Buses, Beneficiaries may draw funds from the
Trust in the amount of:
1. Up to 40% of the cost of a Repower with a new diesel or Alternate
Fueled (e.g. CNG, propane, H ybrid) engine, including the costs of
installation of such engine.
2. Up to 25% of the cost of a new diesel or Alternate Fueled (e.g.
CNG, propane, Hybrid) vehicle.
3. Up to 75% of the cost of a Repower with a new All-Electric
engine, including the costs of installation of such engine, and
charging infrastructure associated with the new All-Electric
engine.
4. Up to 75% of the cost of a new All-Electric vehicle, including
charging infrastructure associated with the new All-Electric
vehicle.
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Volkswagen Settlement Alaska Energy Authority
Environmental Mitigation Trust Appendix C Page 3 November 2018
e. For Government Owned Eligible Buses, and Privately Owned School Buses
Under Contract with a Public School District, Beneficiaries may draw funds
from the Trust in the amount of:
1. Up to 100% of the cost of a Repower with a new diesel or Alternate
Fueled (e.g. CNG, propane, Hybrid) engine, including the costs of
installation of such engine.
2. Up to 100% of the cost of a new diesel or Alternate Fueled (e.g. CNG,
propane, Hybrid) vehicle.
3. Up to 100% of the cost of a Repower with a new All-Electric engine,
including the costs of installation of such engine, and charging
infrastructure associated with the new All-Electric engine.
4. Up to 100% of the cost of a new All-Electric vehicle, including
charging infrastructure associated with the new All-Electric vehicle.
3. Freight Switchers
a. Eligible Freight Switchers include pre-Tier 4 switcher locomotives that operate
1000 or more hours per year.
b. Eligible Freight Switchers must be Scrapped.
c. Eligible Freight Switchers may be Repowered with any new diesel or Alternate
Fueled or All-Electric engine(s) (including Generator Sets), or may be replaced
with any new diesel or Alternate Fueled or All-Electric (including Generator
Sets) Freight Switcher, that is certified to meet the applicable EPA emissions
standards (or other more stringent equivalent State standard) as published in the
CFR for the engine model year in which the Eligible Freight Switcher
Mitigation Action occurs.
d. For Non-Government Owned Freight Switchers, Beneficiaries may draw funds
from the Trust in the amount of :
1. Up to 40% of the cost of a Repower with a new diesel or Alternate
Fueled (e.g. CNG, propane, Hybrid) engine(s) or Generator Sets,
including the costs of installation of such engine(s).
2. Up to 25% of the cost of a new diesel or Alternate Fueled (e.g. CNG,
propane, Hybrid) Freight Switcher.
3. Up to 75% of the cost of a Repower with a new All-Electric engine(s),
including the costs of installation of such engine(s), and charging
infrastructure associated with the new All-Electric engine(s).
4. Up to 75% of the cost of a new All-Electric Freight Switcher,
including charging infrastructure associated with the new All-Electric
Freight Switcher.
BENEFICIARY MITIGATION PLAN
Volkswagen Settlement Alaska Energy Authority
Environmental Mitigation Trust Appendix C Page 4 November 2018
e. For Government Owned Eligible Freight Switchers, Beneficiaries may draw
funds from the Trust in the amount of:
1. Up to 100% of the cost of a Repower with a new diesel or Alternate
Fueled (e.g. CNG, propane, Hybrid) engine(s) or Generator Sets,
including the costs of installation of such engine(s).
2. Up to 100% of the cost of a new diesel or Alternate Fueled (e.g. CNG,
propane, Hybrid) Freight Switcher.
3. Up to 100% of the cost of a Repower with a new All-Electric
engine(s), including the costs of installation of such engine(s), and
charging infrastructure associated with the new All-Electric engine(s).
4. Up to 100% of the cost of a new All-Electric Freight Switcher,
including charging infrastructure associated with the new All-Electric
Freight Switcher.
4. Ferries/Tugs
a. Eligible Ferries and/or Tugs include unregulated, Tier 1, or Tier 2 marine
engines.
b. Eligible Ferr y and/or Tug engines that are replaced must be Scrapped.
c. Eligible Ferries and/or Tugs ma y be Repowered with any new Tier 3 or Tier 4
diesel or Alternate Fueled engines, or with All-Electric engines, or may be
upgraded with an EPA Certified Remanufacture System or an EPA Verified
Engine Upgrade.
d. For Non-Government Owned Eligible Ferries and/or Tugs, Beneficiaries may
onl y draw funds from the Trust in the amount of:
1. Up to 40% of the cost of a Repower with a new diesel or Alternate
Fueled (e.g. CNG, propane, Hybrid) engine(s), including the costs of
installation of such engine(s).
2. Up to 75% of the cost of a Repower with a new All-Electric engine(s),
including the costs of installation of such engine(s), and charging
infrastructure associated with the new All-Electric engine(s).
e. For Government Owned Eligible Ferries and/or Tugs, Beneficiaries may draw
funds from the Trust in the amount of:
1. Up to 100% of the cost of a Repower with a new diesel or Alternate
Fueled (e.g. CNG, propane, Hybrid) engine(s), including the costs of
installation of such engine(s).
2. Up to 100% of the cost of a Repower with a new All-Electric
engine(s), including the costs of installation of such engine(s), and
charging infrastructure associated with the new All-Electric engine(s).
BENEFICIARY MITIGATION PLAN
Volkswagen Settlement Alaska Energy Authority
Environmental Mitigation Trust Appendix C Page 5 November 2018
5. Ocean Going Vessels (OGV) Shorepower
a. Eligible Marine Shorepower includes s ystems that enable a compatible vessel’s
main and auxiliary engines to remain off while the vessel is at berth.
Components of such systems eligible for reimbursement are limited to cables,
cable management s ystems, shore power coupler systems, distribution control
systems, and power distribution. Marine shore power systems must comply
with international shore power design standards (ISO/IEC/IEEE 80005-1-2012
High Voltage Shore Connection Systems or the IEC/PAS 80005-3:2014 Low
Voltage Shore Connection Systems) and should be supplied with power sourced
from the local utility grid. Eligible Marine Shorepower includes equipment for
vessels that operate within the Great Lakes.
b. For Non-Government Owned Marine Shorepower, Beneficiaries may only draw
funds from the Trust in the amount of up to 25% for the costs associated with
the shore-side s ystem, including cables, cable management s ystems, shore
power coupler s ystems, distribution control systems, installation, and power
distribution components.
c. For Government Owned Marine Shorepower, Beneficiaries may draw funds
from the Trust in the amount of up to 100% for the costs associated with the
shore-side system, including cables, cable management systems, shore power
coupler s ystems, distribution control systems, installation, and power
distribution components.
6. Class 4-7 Local Frei ght Trucks (Medium Trucks)
a. Eligible Medium Trucks include 1992-2009 engine model year class 4-7 Local
Freight trucks, and for Beneficiaries that have State regulations that already
require upgrades to 1992-2009 engine model year trucks at the time of the
proposed Eligible Mitigation Action, Eligible Trucks shall also include 2010-
2012 engine model year class 4-7 Local Freight trucks.
b. Eligible Medium Trucks must be Scrapped.
c. Eligible Medium Trucks may be Repowered with any new diesel or Alternate
Fueled or All-Electric engine, or ma y be replaced with any new diesel or
Alternate Fueled or All-Electric vehicle, with the engine model year in which
the Eligible Medium Trucks Mitigation Action occurs or one engine model year
prior.
d. For Non-Government Owned Eligible Medium Trucks, Beneficiaries may draw
funds from the Trust in the amount of:
1. Up to 40% of the cost of a Repower with a new diesel or Alternate
Fueled (e.g. CNG, propane, Hybrid) engine, including the costs of
installation of such engine.
BENEFICIARY MITIGATION PLAN
Volkswagen Settlement Alaska Energy Authority
Environmental Mitigation Trust Appendix C Page 6 November 2018
2. Up to 25% of the cost of a new diesel or Alternate Fueled (e.g. CNG,
propane, Hybrid) vehicle.
3. Up to 75% of the cost of a Repower with a new All-Electric engine,
including the costs of installation of such engine, and charging
infrastructure associated with the new All-Electric engine.
4. Up to 75% of the cost of a new All-Electric vehicle, including
charging infrastructure associated with the new All-Electric vehicle.
e. For Government Owned Eligible Medium Trucks, Beneficiaries may draw
funds from the Trust in the amount of:
1. Up to 100% of the cost of a Repower with a new diesel or Alternate
Fueled (e.g. CNG, propane, Hybrid) engine, including the costs of
installation of such engine.
2. Up to 100% of the cost of a new diesel or Alternate Fueled (e.g. CNG,
propane, Hybrid) vehicle.
3. Up to 100% of the cost of a Repower with a new All-Electric engine,
including the costs of installation of such engine, and charging
infrastructure associated with the new All-Electric engine.
4. Up to 100% of the cost of a new All-Electric vehicle, including
charging infrastructure associated with the new All-Electric vehicle.
7. Airport Ground Support Equipment
a. Eligible Airport Ground Support Equipment includes:
1. Tier 0, Tier 1, or Tier 2 diesel powered airport ground support
equipment; and
2. Uncertified, or certified to 3 g/bhp-hr or higher emissions, spark
ignition engine powered airport ground support equipment.
b. Eligible Airport Ground Support Equipment must be Scrapped.
c. Eligible Airport Ground Support Equipment may be Repowered with an All-
Electric engine, or ma y be replaced with the same Airport Ground Support
Equipment in an All-Electric form.
d. For Non-Government Owned Eligible Airport Ground Support Equipment,
Beneficiaries ma y onl y draw funds from the Trust in the amount of:
1. Up to 75% of the cost of a Repower with a new All-Electric engine,
including costs of installation of such engine, and charging
infrastructure associated with such new All-Electric engine.
2. Up to 75% of the cost of a new All-Electric Airport Ground Support
Equipment, including charging infrastructure associated with such new
All-Electric Airport Ground Support Equipment.
BENEFICIARY MITIGATION PLAN
Volkswagen Settlement Alaska Energy Authority
Environmental Mitigation Trust Appendix C Page 7 November 2018
e. For Government Owned Eligible Airport Ground Support Equipment,
Beneficiaries ma y draw funds from the Trust in the amount of:
1. Up to 100% of the cost of a Repower with a new All-Electric engine,
including costs of installation of such engine, and charging
infrastructure associated with such new All-Electric engine.
2. Up to 100% of the cost of a new All-Electric Airport Ground Support
Equipment, including charging infrastructure associated with such new
All-Electric Airport Ground Support Equipment.
8. Forklifts and Port Cargo Handling Equipment
a. Eligible Forklifts includes forklifts with greater than 8000 pounds lift
capacit y.
b. Eligible Forklifts and Port Cargo Handling Equipment must be
Scrapped.
c. Eligible Forklifts and Port Cargo Handling Equipment may be
Repowered with an All-Electric engine, or may be replaced with the
same equipment in an All-Electric form.
d. For Non-Government Owned Eligible Forklifts and Port Cargo
Handling Equipment, Beneficiaries may draw funds from the Trust in
the amount of:
1. Up to 75% of the cost of a Repower with a new All-Electric engine,
including costs of installation of such engine, and charging
infrastructure associated with such new All-Electric engine.
2. Up to 75% of the cost of a new All-Electric Forklift or Port Cargo
Handling Equipment, including charging infrastructure associated with
such new All-Electric Forklift or Port Cargo Handling Equipment.
e. For Government Owned Eligible Forklifts and Port Cargo Handling
Equipment, Beneficiaries may draw funds from the Trust in the amount of:
1. Up to 100% of the cost of a Repower with a new All-Electric engine,
including costs of installation of such engine, and charging
infrastructure associated with such new All-Electric engine.
2. Up to 100% of the cost of a new All-Electric Forklift or Port Cargo
Handling Equipment, including charging infrastructure associated with
such new All-Electric Forklift or Port Cargo Handling Equipment.
BENEFICIARY MITIGATION PLAN
Volkswagen Settlement Alaska Energy Authority
Environmental Mitigation Trust Appendix C Page 8 November 2018
9. Light Duty Zero Emission Vehicle Supply Equipment.
Each Beneficiar y may use up to fifteen percent (15%) of its allocation of Trust Funds on
the costs necessary for, and directly connected to, the acquisition, installation, operation
and maintenance of new light duty zero emission vehicle supply equipment for projects as
specified below. Provided, however, that Trust Funds shall not be made available or used
to purchase or rent real- estate, other capital costs (e.g., construction of buildings, parking
facilities, etc.) or general maintenance (i.e., maintenance other than of the Supply
Equipment).
a. Li ght dut y electric vehicle supply equipment includes Level 1, Level 2 or fast
charging equipment (or analogous successor technologies) that is located in a
public place, workplace, or multi-unit dwelling and is not consumer light duty
electric vehicle suppl y equipment (i.e., not located at a private residential
dwelling that is not a multi-unit dwelling).
b. Li ght dut y h ydrogen fuel cell vehicle supply equipment includes hydrogen
dispensing equipment capable of dispensing h ydrogen at a pressure of 70
megapascals (MPa) (or analogous successor technologies) that is located in a
public place.
c. Subject to the 15% limitation above, each Beneficiary may draw funds from
the Trust in the amount of:
1. Up to 100% of the cost to purchase, install and maintain eligible light
duty electric vehicle supply equipment that will be available to the
public at a Government Owned Propert y.
2. Up to 80% of the cost to purchase, install and maintain eligible light
duty electric vehicle supply equipment that will be available to the
public at a Non-Government Owned Propert y.
3. Up to 60% of the cost to purchase, install and maintain eligible light
duty electric vehicle supply equipment that is available at a workplace
but not to the general public.
4. Up to 60% of the cost to purchase, install and maintain eligible light
duty electric vehicle supply equipment that is available at a multi-unit
dwelling but not to the general public.
5. Up to 33% of the cost to purchase, install and maintain eligible light
duty h ydrogen fuel cell vehicle supply equipment capable of
dispensing at least 250 kg/da y that will be available to the public.
6. Up to 25% of the cost to purchase, install and maintain eligible light
duty h ydrogen fuel cell vehicle supply equipment capable of
dispensing at least 100 kg/da y that will be available to the public.
BENEFICIARY MITIGATION PLAN
Volkswagen Settlement Alaska Energy Authority
Environmental Mitigation Trust Appendix C Page 9 November 2018
10. Diesel Emission Reduction Act (DERA) Option.
Beneficiaries ma y use Trust Funds for their non-federal voluntary match, pursuant to
Title VII, Subtitle G, Section 793 of the DERA Program in the Energy Policy Act of
2005 (codified at 42 U.S.C. § 16133), or Section 792 (codified at 42 U.S.C. § 16132) in
the case of Tribes, thereby allowing Beneficiaries to use such Trust Funds for actions
not specificall y enumerated in this Appendix D-2, but otherwise eligible under DERA
pursuant to all DERA guidance documents available through the EPA. Trust Funds
shall not be used to meet the non- federal mandator y cost share requirements, as
defined in applicable DERA program guidance, of any DERA grant.
Eligible Mitigation Action Administrative Expenditures
For an y Eli gible Mitigation Action, Beneficiaries may use Trust Funds for actual
administrative expenditures (described below) associated with implementing such Eligible
Mitigation Action, but not to exceed 15% of the total cost of such Eligible Mitigation Action.
The 15% cap includes the aggregated amount of eligible administrative expenditures incurred
by the Beneficiary and an y third-part y contractor(s).
1. Personnel including costs of employee salaries and wages, but not consultants.
2. Fringe Benefits including costs of employee fringe benefits such as health insurance,
FICA, retirement, life insurance, and pa yroll taxes.
3. Travel including costs of Mitigation Action-related travel by program staff, but does
not include consultant travel.
4. Supplies including tangible property purchased in support of the Mitigation Action that
will be expensed on the Statement of Activities, such as educational publications, office
supplies, etc. Identif y general categories of supplies and their Mitigation Action costs.
5. Contractual including all contracted services and goods except for those charged under
other categories such as supplies, construction, etc. Contracts for evaluation and
consulting services and contracts with sub-recipient organizations are included.
6. Construction including costs associated with ordinar y or normal rearrangement
and alteration of facilities.
7. Other costs including insurance, professional services, occupanc y and equipment
leases, printing and publication, training, indirect costs, and accounting.
BENEFICIARY MITIGATION PLAN
APPENDIX D:
COMPARISON OF VW ELIGIBLE MITIGATION ACTIONS 1-9 AND
ELIGIBLE MITIGATION ACTION 10 (DERA OPTION)
Source: EPA 2017.
BENEFICIARY MITIGATION PLAN
Volkswagen Settlement Alaska Energy Authority
Environmental Mitigation Trust Appendix D Page 1 November 2018
BENEFICIARY MITIGATION PLAN
Volkswagen Settlement Alaska Energy Authority
Environmental Mitigation Trust Appendix D Page 2 November 2018
BENEFICIARY MITIGATION PLAN
Volkswagen Settlement Alaska Energy Authority
Environmental Mitigation Trust Appendix D Page 3 November 2018
BENEFICIARY MITIGATION PLAN
Volkswagen Settlement Alaska Energy Authority
Environmental Mitigation Trust Appendix D Page 4 November 2018
BENEFICIARY MITIGATION PLAN
Volkswagen Settlement Alaska Energy Authority
Environmental Mitigation Trust Appendix D Page 5 November 2018