HomeMy WebLinkAboutVW Environmental Mitigation Trust Proposed Draft Beneficiary Mitigation Plan 05-1-2018-VW
State of Alaska
Volkswagen Environmental Mitigation Trust
Proposed Draft Beneficiary Mitigation Plan
Prepared by
May 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 .......................................................................................................... 3
2.2. Improve Air Quality and Protect Human Health ........................................................... 3
2.3. Voluntary Funding Match .............................................................................................. 3
2.4. Target Disproportionately Affected Communities......................................................... 3
3. Air Quality in Alaska............................................................................................................. 5
3.1. Diesel Pollution .............................................................................................................. 6
3.2. Nitrogen Oxides ............................................................................................................. 6
3.2.1. Transportation ......................................................................................................... 7
3.2.2. Electric Generation ................................................................................................. 9
3.2.3. NOx Nonattainment Area and Maintenance Areas ................................................. 9
3.3. Particulate Matter ......................................................................................................... 10
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. Year 1 Allocation ......................................................................................................... 17
4.2. Year 2 Allocation ......................................................................................................... 18
4.3. Year 3 Allocation ......................................................................................................... 19
4.4. Year 4 and Year 5 Allocation....................................................................................... 19
5. Expected Ranges of Emission Reductions ......................................................................... 19
6. Public Input .......................................................................................................................... 20
7. Literature Cited ................................................................................................................... 23
8. Tables .................................................................................................................................... 25
9. Figures .................................................................................................................................. 27
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LIST OF TABLES
Table 1. Proposed allocation of VW Environmental Mitigation Trust funds. .............................. 25
Table 2. Proposed project evaluation matrix for VW Eligible Mitigation Actions (EMAs) 1-8 and
EMA 10 DERA non-prime power. ............................................................................................... 26
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. .......................... 28
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. ........................................................................................... 29
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. ......................................................... 30
Figure 4. Source of particulate matter (PM10 and PM2.5) emissions in Alaska by sector in 2014.
Source: EPA 2015b. ...................................................................................................................... 31
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. .......... 32
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. .......... 33
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. ........................ 34
Figure A-1. Map of health complaints in rural Alaska related to ambient dust. Red indicates
communities with monitoring sites. Source: ADEC 2011. ............................................................. 1
Figure A-2. Map of Eagle River PM10 Maintenance Area boundary with Parkgate PM10
monitoring site. Source: ADEC 2010. ............................................................................................ 2
Figure A-3. Map of Mendenhall Valley PM10 Maintenance Area boundary, Juneau, Alaska.
Source: ADEC 2009. ...................................................................................................................... 3
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Figure A-4. 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....................................................................................................... 4
Figure A-5. Multiple PM2.5 hotspots identified within Fairbanks North Star Borough PM2.5
Nonattainment Area. Source: ADEC 2016. .................................................................................... 5
Figure A-6. 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. ........ 6
Figure A-8. Map of North Pole carbon monoxide Maintenance Area boundary, Fairbanks North
Star Borough, Alaska. Source: ADEC 2013b. ................................................................................ 7
Figure A-9. Map of Fairbanks and Fort Wainwright carbon monoxide Maintenance Area
boundary, Fairbanks North Star Borough, Alaska. Source: ADEC 2013b. .................................... 8
Figure B-1. EPA’s Demographic Indices for Alaska. Source: EPA 2017b. ................................... 1
Figure B-2. Map of 2011 National Air Toxics Assessment for Alaska of particulate matter PM2.5
generated from diesel emissions. Portions of Fairbanks, Anchorage, and Juneau are within the
80-100th percentiles, but areas cannot be seen at this statewide map scale. The indices are
grouped by percentile rank (Appendix B, Figure B-2). 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. Source: EPA 2017b. ................................................................................. 2
Figure B-3. EPA Environmental Indicator map of ozone for Alaska census areas/boroughs.
Portions of Fairbanks, Anchorage, and Juneau are within the 80-100th percentiles, but areas
cannot be seen at this statewide map scale. Source: EPA 2017b. ................................................... 3
LIST OF APPENDICES
Appendix A. Maps of Nonattainment Area and Maintenance Areas
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).
Appendix E. Draft Beneficiary Mitigation Plan Public Comment Form
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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
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
MVEB Motor Vehicle Emissions Budget
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Abbreviation Definition
MWh Mega Watt hour
N2O Nitrous oxide
NAAQS National Ambient Air Quality Standards
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
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 diesel engines that meet
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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.
This document represents Alaska’s proposed Plan, which AEA is presenting to the public to solicit
input. Providing input and comments on the proposed plan allows stakeholders to ensure that their
interests are considered in the development of the final Plan. The comment period will be open for
60 days. Please provide comments to AEA in writing, via email, or through AEA’s designated VW
Settlement website:
Alaska Energy Authority
Re: VW Settlement
813 West Northern Lights Blvd
Anchorage, AK 99503
vwsettlement@aidea.org
http://www.akenergyauthority.org/programs/vwsettlement
Following the public comment period, AEA will summarize comments and finalize the Plan for
submittal to the EMT Trustee. Per the settlement agreement, the Plan must be submitted to the
Trustee 30 days prior to requesting funds for any EMAs. See Section 6 for more information on
the process for seeking public input. Additional information regarding the settlement can be found
at AEA’s website noted above.
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
3. Leverage additional funds to increase benefits to Alaskans
4. Target actions to benefit disproportionately affected communities
Alaska will offer several solicitations to fund the full suite of EMAs, listed in Appendix C. The
proposed allocation of funds for the various EMAs described in Section 4 (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.
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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 (DMV 2017). The total lifetime
NOx emissions produced by these vehicles is approximately 10.54 tons. Alaska has been allocated
$8.125 million which may mitigate for these vehicles, but will not be adequate to replace aging
diesel engines in the state. Projects that reduce the most tons of NOx and PM emissions for the
least cost will be given a higher priority.
2.2. Improve Air Quality and Protect Human Health
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. Priority will be given
to projects that will reduce the most NOx and PM that benefit the health of the most Alaskans or
vulnerable populations.
2.3. 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.
2.4. Target Disproportionately Affected Communities
The settlement requires Alaska to consider how the plan will impact areas that bear a
disproportionate air pollution burden. 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 that receive a disproportionate
quantity of air pollution from diesel fleets (e.g., ports, rail yards, airports, terminals, bus depots).
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 controls 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.
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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 the 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).
EPA Environmental Justice Screening
The EPA completed the 2011 National Air Toxics Assessment based on the 2011 National
Emission Inventory of 180 air toxics plus diesel PM (EPA 2015b), modeled ambient
concentrations and exposure concentrations, and health benchmark information to estimate risk
for cancer and noncancer effects of inhalation of 138 of the air toxics (EPA 2015a). The potential
carcinogenic risk from diesel PM is not included in the assessment because there is currently no
unit risk estimate available. However, overall cancer risk for an area will be taken into account
because exposure to diesel PM poses a lung cancer hazard to humans (EPA 2002). The assessment
includes respiratory health indices related to diesel PM, which will also be considered.
The EPA has developed an environmental justice screening and mapping tool (EPA 2017b) based
on the National Air Toxics Assessment data for diesel PM, PM2.5, and ozone. The indices are
grouped by percentile rank (Appendix B, Figure B-2). Priority will be given to projects that benefit
these impacted areas through the proposed scoring criteria presented in Table 2. Maps of these
areas can be found in Appendix B. The assessment represents a snapshot in time based on the 2011
inventory; the next assessment will be based on the 2014 National Emission Inventory. The most
current assessment available will be used at the time of solicitation.
Alaska will also consider demographics to ensure that the burdens of pollution do not fall
disproportionately on low-income, minority, and Native American communities. Figure B-1 in
Appendix B displays the statewide demographic indices (EPA 2017). The highest indices are in
the rural parts of the state that have majorit y Alaska Native populations, along with very high costs
of living and low incomes. Localized areas within urban areas such as Anchorage, Fairbanks, and
Juneau also have higher indices (Appendix B, Figure B-1). EMA projects benefiting populations
of these areas will also be given priority.
Rural Alaska
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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, schools buses, shuttle buses,
freight switchers, marine vessels, airport ground support equipment, 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. However, 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.
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 propose to 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.
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).
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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
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).
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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
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)
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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
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)
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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
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).
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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 coarse
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
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
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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.
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-1)
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
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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-2).
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-3) 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-4) 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
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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.
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-4), 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
1 Federal Register, Vol. 82, No. 89, May 10, 2017
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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
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), 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
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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
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-6). 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.
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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 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-7) and the
Fairbanks-Fort Wainwright Nonattainment areas (Figure A-8). 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 Maintenance 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
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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.
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. The settlement requires the funds to be disbursed within
10 years, with no more than one third disbursed in the first year and no more than two thirds
disbursed in the first two years. We propose to disburse the funds over a 5-year period. 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.
The 10 EMAs are described in Appendix C. Appendix D includes a detailed comparison of EMAs
1-9 to EMA 10 (DERA Option).
4.1. Year 1 Allocation
Light-duty Zero-Emission Vehicle Supply Equipment (EMA 9)
Per the terms of the settlement, funding of EMA 9 is limited to not exceed 15 percent of Alaska’s
EMT. Alaska proposes to fund EMA 9 up to the maximum allowable 15 percent, not to exceed a
total of $1.2 million, to be disbursed at no more than one third ($400,000) in each of Years 1, 2
and 3. EMA 9 projects would be funded through a separate open solicitation and evaluated with
different criteria than EMAs 1-8 and EMA 10. EMA 9 projects will require the development of a
regional plan for electric vehicle infrastructure that includes the local utilities, local government,
ADOT&PF, private industry and electric vehicle owners. After three years, any unused portion of
the EMA 9 funds would roll over year after year until the maximum allowable amount is depleted.
EMA 10 (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
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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 leverage federal funds for
projects in rural Alaska, we propose to set aside approximately $250,000 of the EMT annually for
the state’s voluntary match under the State DERA program for five years.
EMA 1-8 and EMA 10 (non-prime power) for State and Local Government Applicants
In this first year, we propose to set aside $1 million to state and local government applicants only
to fund EMAs 1-8, and EMA 10 (non-prime power DERA-eligible projects only). While
government applicants do not require match under the VW settlement terms, we propose to require
10 percent match from government entities applying for this state and local government allocation
of funds and to limit each grant to $200,000. Any remaining funds from Year 1 would roll over
year after year until the state and local government set aside is depleted.
EMA 1-8 and EMA 10 (non-prime power) for All Applicants
The remaining available funds in Year 1, approximately $1.05 million including administrative
cost, would be made competitively available to all applicants, both government and non-
government, for EMAs 1-8 and EMA 10 through an open solicitation. Match requirements will
follow the VW settlement agreement, as shown in Appendix A. The proposed criteria for
evaluating applications is provided in Table 2.
For projects only eligible under the EMA 10 DERA option (e.g., marine vessels other than
ferries/tugs operated >1,000 hours per year), applicants must also participate in the DERA program
managed by the EPA. There are National and Tribal DERA grants and State allocations issued
annually, subject to the federal budget. The National and Tribal DERA grants are competitiv e
while each state is allocated funds through the State DERA program. DERA has mandatory cost -
share requirements established by the EPA annually (Appendix D). Trust funds may only be used
as voluntary match. Applicants will be required to provide the mandatory match with non-federal
dollars.
4.2. Year 2 Allocation
In Year 2, another third of the total EMT, or approximately $2.7 million , will be available for
disbursement. During Year 2 we propose to continue with the annual allocations described above
in Table 1 for EMA 9 ($400,000) through a second competitive solicitation and EMA 10 (prime
power) ($250,000). Any remaining funds from the Year 1 $1 million set aside for local and state
government applicants for EMAs 1-8 and EMA 10 (non-prime power) would still be available to
state and local governments. The remaining funds from Year 1 that were available to all applicants
for EMAs 1-8 and EMA 10, as well as an additional 25 percent (approx. $2 million) of the total
EMT funds, would be available through a second solicitation.
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4.3. Year 3 Allocation
In Year 3, the last third of the total EMT will be available for disbursement. Funds in Year 3 would
be allocated similarly to Year 2 with one exception. For EMAs 1-8 and EMA 10 (non-prime
power) for all government and non-government applicants, 19% (approx. $1.5 million) of the total
EMT funds would be added to any remaining funds through a competitive solicitation. Six percent
of the remaining funds would be retained to fund EMA 10 DERA prime power projects in Years
4 and 5.
4.4. Year 4 and Year 5 Allocation
We propose to allocate 3% of the EMT to fund EMA 10 DERA prime power projects in each of
Years 4 and 5. In the event there are any other remaining funds, we propose to open a competitive
solicitation for all of the remaining funds for EMAs 1-9 and 10 (non-prime power).
5. EXPECTED RANGES OF EMISSION REDUCTIONS
The amount of NOx reductions will be determined with each funded project.
Onroad Mobile Diesel Sources
Based on the 2014 NEI, approximately 8,200 tons of NOx are emitted from onroad diesel sources
annually. EMA 1, 2, and 6 include an array of projects aimed at reducing onroad diesel emissions
from heavy and medium duty local freight trucks, school buses, shuttle buses and transit buses.
Nonroad Mobile Diesel Sources
Approximately 1,800 tons of NOx are emitted from sources annually. A portion of these emissions
may be reduced under EMA 7 and EMA 8. Under these EMAs, eligible airport ground support
equipment (EMA 7) and port cargo handling equipment (EMA 8) may be repowered or replaced
with all electric engines with EMT funds.
Commercial Marine Vessels
Commercial marine vessel produced 38,614 tons of NOx emissions. 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. 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.
Locomotive Sources
Locomotives were the source of 915 tons of NOx emissions in 2014. 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.
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Electric Generation with Diesel
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.
Light-duty Zero-Emission Vehicle Supply Equipment (EMA 9)
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). It is difficult to estimate the NOx
reductions from this EMA. This EMA will benefit air quality in the long run by providing
infrastructure to promote electric vehicle use.
6. PUBLIC INPUT
The State of Alaska will receive $8,125,000 from the Volkswagen “Clean Diesel” emissions
cheating settlement. As the Lead Agency, AEA has developed this Draft Plan for selecting and
prioritizing projects to be funded. The Plan is to be developed through a public process to ensure
stakeholder input. The section below outlines AEA’s plan for public outreach and public
involvement. In addition to the State Trust, there are other aspects of the settlement, such as the
Tribal Trust and the National Zero Emission Vehicle fund, that AEA does not have a formal role
in implementing but which stakeholders and the general public should be aware of and may require
assistance in accessing.
Goals for Outreach:
1. Gather input from interested stakeholders and the general public on how settlement funds
should be distributed.
2. Integrate input from the Governor’s office and ADEC about projects and areas of interest
as it relates to use of settlement funds.
3. Distribute information about the settlement to stakeholders and the general public.
Target 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, Cities)
o
o Metropolitan planning organizations for designated Nonattainment and
Maintenance areas (FNSB Pollution Control Commission; Anchorage
Metropolitan Area Transportation Solutions (AMATS))
o School Districts
o Port Authorities: Port of Alaska, Port of Whittier, Port of Seward, Port of
Ketchikan, Port of Juneau
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Tribes, Tribal government and regional Native organizations/corporations
Alaska Native Tribal Health Consortium
Federal agencies
Electric utilities
Airports and airlines
Equipment/service vendors
o Stationary power
o On-road vehicles
o Boats
Communications Methods and Tools:
AEA will update content regularly and publish to its website. AEA has a dedicated email address
and will establish an email listserve to communicate directly with members of the public who
express interest. AEA has developed an online form to submit comments that can be accessed
through our website. The form is also located in Appendix E and can be submitted to AEA via
mail, email or fax. Public meetings will be held in Anchorage, Fairbanks, and potentially in Juneau.
At least two webinars will be hosted in order to facilitate statewide participation. AEA is
coordinating directly with other stakeholder groups including National Tribal Air Association,
Alaska Native Tribal Health Consortium, etc.
Project Updates to Public
AEA will maintain a page on AEA’s website dedicated to the Trust and will update
regularly.
AEA will send out notice to the VW listserve when substantive events occur.
Surveys
1. AEA will publish on its website and send notice to listserve, a survey soliciting
information both about interest in eligible mitigation actions and current fleet/equipment
in-use to assist in determining where opportunities exist. This survey will be completed
prior to publishing the final Beneficiary Mitigation Plan.
a. The transportation survey will have three sections, 1. diesel or alternate fuel, 2.
Electric Vehicle (EV), and 3. marine. The survey will be performed online and via
email with follow up direct outreach to known large potential beneficiaries.
2. AEA is also completing a survey of rural diesel powerhouses to define the opportunity
for DERA projects to repower or replace diesel engines or gensets. This survey is being
performed by a combination of telephonic, email and on-site data collection.
Publish Beneficiary Mitigation Plan
This Draft Beneficiary Mitigation Plan will be distributed as following:
It will be published on the AEA website.
It will be published on the State of Alaska public notice site.
It will be emailed to key audiences and listserve.
Public engagement events
The events below are opportunities to provide information about the Settlement and to gather input
on the draft Plan and the use of Settlement funds. At these events presentations will cover the
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Beneficiary Mitigation Plan and feedback will be solicited through facilitated Q&A, feedback
forms, links to online comment forms, contact information to provide feedback via phone.
Past meetings/presentations:
Sept 11-12, 2017 Intelligent Transportation Society annual meeting
Sept 13-15, 2017 Alaska Power Association annual meeting
Oct 19-21, 2017 Alaska Federation of Natives conference
Oct 24, 2017 Alaska Tribal Conservation Alliance
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
April 10-12, 2018 Rural Energy Conference
Public Meetings:
Anchorage (in person and as broadcast webinar) – Date TBD
Fairbanks (in person and as broadcast webinar) - Date TBD
Juneau (in person and as broadcast webinar)
Two statewide webinars – Dates TBD
Timeline:
March 2017 to present: Informal comment period; public comments collected through
email and online form
October 2, 2017: Trust Effective Date (TED) established
November 16, 2017: Alaska filed Beneficiary Certification Form with the Court
Updated project fact sheet and website
Created one-page fact sheet for Tribal Trust
January 2018: Incorporate public input from informal pre-TED comment period and
surveys into Draft Beneficiary Mitigation Plan (Plan)
January 29, 2018: Alaska designated as Beneficiary of the Trust
February 27, 2018: AEA sent Notice of Availability of Mitigation Action Funds to
federal agencies.
May 1, 2018: Publish Draft Plan; submit news release with dates of the comment period
and public meetings.
May 1, 2018 – July 1, 2018: Open survey and open formal public comment period on
draft Plan, including public meetings and webinars.
July 2018: Summarize public comments, publish Final Plan incorporating any changes in
response to public comments, and submit to Trustee.
July 2018: Receive receipt authority; choose projects to fund.
August 2018: Open solicitation for applications.
October 2018: Choose projects to fund and submit to Trustee.
December 2018: Begin funding projects.
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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. 2018. Alaska Greenhouse Gas Emissions Inventory 1990-2015. ADEC Division of Air
Quality. January 30, 2018. 48 pages.
U.S. 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.
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8. TABLES
Table 1. Proposed allocation of VW Environmental Mitigation Trust funds.
Percent
of Total
Fund
Allocated
Eligible
Mitigation
Actions (EMAs) Eligible Applicants Disbursement
YEAR 1 (33%)
5% EMA 9 Government and Non-
government
Competitive solicitation requiring
comprehensive plan with multiple community
partners, support from local utility, and match.
3% EMA 10 (prime
power only)
State of Alaska as voluntary
match for State DERA grants
AEA will prioritize communities with eligible
engines through transparent process.
12% EMAs 1-8 and
EMA 10 (non-
prime power)
State and Local Government
sponsored projects as match for
other secured non-State funding
sources
Competitive solicitation requiring 10% match;
not to exceed $200,000 per grant. Remaining
funds will rollover year after year until
depleted.
13% EMAs 1-8 and
EMA 10 (non-
prime power)
Government and Non-
government Competitive solicitation with mandatory match
requirements for non-government applicants
per settlement terms.
YEAR 2 (33%)
5% EMA 9 Government and Non-
government
Competitive solicitation requiring
comprehensive plan with multiple community
partners, support from local utility, and match.
3% EMA 10 (prime
power only) State of Alaska as voluntary
match for State DERA grants AEA will prioritize communities with eligible
engines through transparent process.
25% EMAs 1-8 and
EMA 10 (non-
prime power)
Government and Non-
government
Competitive solicitation with mandatory match
requirements for non-government applicants
per settlement terms.
YEAR 3 (27%)
5% EMA 9 Government and Non-
government
Competitive solicitation requiring
comprehensive plan with multiple community
partners, support from local utility, and match.
3% EMA 10 (prime
power only) State of Alaska as voluntary
match for State DERA grants AEA will prioritize communities with eligible
engines through transparent process.
19% EMAs 1-8 and
EMA 10 (non-
prime power)
Government and Non-
government Competitive solicitation with mandatory match
requirements for non-government applicants
per settlement terms.
YEAR 4 and YEAR 5 (6%)
3%
annually EMA 10 (prime
power only) State of Alaska as voluntary
match for State DERA grants AEA will prioritize communities with eligible
engines through transparent process.
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Table 2. Proposed project evaluation matrix for VW Eligible Mitigation Actions (EMAs) 1-
8 and EMA 10 DERA non-prime power.
Criteria Criteria Points
Total
Possible
Points
NOx emission priority areas < 100 tons per year 5 25
100 – 500 tons per year 10
500 – 1,000 tons per year 15
>1,000 tons per year 25
Cost effectiveness in reducing
NOx emissions (ton reduction/$)
Least cost effective 10 35
Middle cost effective 20
Most cost effective 35
Voluntary funding match 0.5 points for every 1 % match up to 20 points 20
Air quality priority areas Not located in priority area 0 10
Located in maintenance and other priority
areas 7
Projects located within non-attainment
areas 10
Applicant experience < 1 yr. 2 10
1 -5 years 5
> 5 yr. 10
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9. FIGURES
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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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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
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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
PROPOSED DRAFT BENEFICIARY MITIGATION PLAN
APPENDIX A:
MAPS OF NONATTAINMENT AREA AND MAINTENANCE AREAS
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Figure A-1. Map of health complaints in rural Alaska related to ambient dust. Red indicates communities
with monitoring sites. Source: ADEC 2011.
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Figure A-2. Map of Eagle River PM10 Maintenance Area boundary with Parkgate PM10 monitoring site.
Source: ADEC 2010.
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Figure A-3. Map of Mendenhall Valley PM10 Maintenance Area boundary, Juneau, Alaska. Source: ADEC
2009.
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Figure A-4. 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-5. Multiple PM2.5 hotspots identified within Fairbanks North Star Borough PM2.5 Nonattainment
Area. Source: ADEC 2016.
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Figure A-6. 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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Figure A-8. Map of North Pole carbon monoxide Maintenance Area boundary, Fairbanks North Star
Borough, Alaska. Source: ADEC 2013b.
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Figure A-9. Map of Fairbanks and Fort Wainwright carbon monoxide Maintenance Area boundary, Fairbanks North Star Borough, Alaska. Source:
ADEC 2013b.
PROPOSED DRAFT BENEFICIARY MITIGATION PLAN
APPENDIX B:
EPA ENVIRONMENTAL JUSTICE SCREENING MAPS
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Figure B-1. EPA’s Demographic Indices for Alaska. Source: EPA 2017b.
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Figure B-2. Map of 2011 National Air Toxics Assessment for Alaska of particulate matter PM2.5 generated from diesel emissions. Portions of Fairbanks,
Anchorage, and Juneau are within the 80-100th percentiles, but areas cannot be seen at this statewide map scale. The indices are grouped by percentile
rank (Appendix B, Figure B-2). 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. Source: EPA 2017b.
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Figure B-3. EPA Environmental Indicator map of ozone for Alaska census areas/boroughs. Portions of Fairbanks, Anchorage, and Juneau are within
the 80-100th percentiles, but areas cannot be seen at this statewide map scale. Source: EPA 2017b.
PROPOSED DRAFT BENEFICIARY MITIGATION PLAN
APPENDIX C:
VW ELIGIBLE MITIGATION ACTIONS AND MITIGATION
EXPENDITURES
Source: Appendix D2 of the 2.0 Liter Consent Decree.
PROPOSED DRAFT BENEFICIARY MITIGATION PLAN
Volkswagen Settlement Alaska Energy Authority
Environmental Mitigation Trust Appendix C Page 1 May 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.
PROPOSED DRAFT BENEFICIARY MITIGATION PLAN
Volkswagen Settlement Alaska Energy Authority
Environmental Mitigation Trust Appendix C Page 2 May 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.
PROPOSED DRAFT BENEFICIARY MITIGATION PLAN
Volkswagen Settlement Alaska Energy Authority
Environmental Mitigation Trust Appendix C Page 3 May 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.
PROPOSED DRAFT BENEFICIARY MITIGATION PLAN
Volkswagen Settlement Alaska Energy Authority
Environmental Mitigation Trust Appendix C Page 4 May 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).
PROPOSED DRAFT BENEFICIARY MITIGATION PLAN
Volkswagen Settlement Alaska Energy Authority
Environmental Mitigation Trust Appendix C Page 5 May 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.
PROPOSED DRAFT BENEFICIARY MITIGATION PLAN
Volkswagen Settlement Alaska Energy Authority
Environmental Mitigation Trust Appendix C Page 6 May 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.
PROPOSED DRAFT BENEFICIARY MITIGATION PLAN
Volkswagen Settlement Alaska Energy Authority
Environmental Mitigation Trust Appendix C Page 7 May 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.
PROPOSED DRAFT BENEFICIARY MITIGATION PLAN
Volkswagen Settlement Alaska Energy Authority
Environmental Mitigation Trust Appendix C Page 8 May 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.
PROPOSED DRAFT BENEFICIARY MITIGATION PLAN
Volkswagen Settlement Alaska Energy Authority
Environmental Mitigation Trust Appendix C Page 9 May 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.
PROPOSED DRAFT BENEFICIARY MITIGATION PLAN
APPENDIX D:
COMPARISON OF VW ELIGIBLE MITIGATION ACTIONS 1-9 AND
ELIGIBLE MITIGATION ACTION 10 (DERA OPTION)
Source: EPA 2017.
PROPOSED DRAFT BENEFICIARY MITIGATION PLAN
Volkswagen Settlement Alaska Energy Authority
Environmental Mitigation Trust Appendix D Page 1 May 2018
PROPOSED DRAFT BENEFICIARY MITIGATION PLAN
Volkswagen Settlement Alaska Energy Authority
Environmental Mitigation Trust Appendix D Page 2 May 2018
PROPOSED DRAFT BENEFICIARY MITIGATION PLAN
Volkswagen Settlement Alaska Energy Authority
Environmental Mitigation Trust Appendix D Page 3 May 2018
PROPOSED DRAFT BENEFICIARY MITIGATION PLAN
Volkswagen Settlement Alaska Energy Authority
Environmental Mitigation Trust Appendix D Page 4 May 2018
PROPOSED DRAFT BENEFICIARY MITIGATION PLAN
APPENDIX E:
DRAFT BENEFICIARY MITIGATION PLAN PUBLIC COMMENT FORM
Volkswagen Environmental Mitigation Trust
Page 1 of 2
State of Alaska Draft Beneficiary Mitigation Plan (DBMP) Public Comment Form
The DBMP describes how the State proposes to distribute its $8.125 million Trust allocation to fund projects
within 10 Eligible Mitigation Actions (EMAs), as described in Appendix C of the DBMP:
1. Class 8 local freight trucks and port drayage trucks
2. Class 4-8 school bus/shuttle/transit buses
3. Freight switcher locomotives
4. Ferries/tugboats
5. Shore power for ocean going vessels
6. Class 4-7 local freight trucks
7. Airport ground support equipment
8. Forklifts and port cargo handling equipment
9. Light duty ZEV supply equipment (limited to 15% of funds)
10. Voluntary match for Diesel Emission Reduction Act (DERA) projects
AEA is seeking public input on the DBMP. We want to hear from you!
*Name: _____________________________________ *Affiliation: ___________________________________
*Email: ________________________________________ *City: _____________________________________
Street address (optional): ________________________________ Zip code (optional): ___________________
* Required
1. The DBMP proposes to allocate total funding as summarized below. Please indicate if you agree
or disagree with allocating these levels of funding for the specified purposes/recipients.
Strongly
Agree Agree Neutral Disagree Strongly
Disagree
58% of funds allocated through competitive solicitation
open to all applicants (government and non-
government) for (EMAs 1-8 and EMA 10) 1 2 3 4 5
12% of funds allocated for state and local government
sponsored projects (EMAs 1-8 and EMA 10 (non-prime
power)) 1 2 3 4 5
15% of funds allocated for Diesel Emissions Reduction Act
(DERA) projects, primarily diesel prime power in rural
Alaska power houses (EMA 10) 1 2 3 4 5
15% of funds allocated for Electric Vehicle
infrastructure (i.e., charging stations) (EMA 9) 1 2 3 4 5
PERSONAL INFORMATION
QUESTIONS
State of Alaska Draft Beneficiary Mitigation Plan (DBMP) Public Comment Form
Page 2 of 2
2. Please rank the following criteria from 1 to 5, in order of importance.
Most
Important
Very
Important Important Somewhat
Important
Least
Important
Project is in a NOx emission priority area 1 2 3 4 5
Project cost-effectively reduces NOx emissions (tons/$) 1 2 3 4 5
Project has voluntary match funds 1 2 3 4 5
Project is located in an air quality priority area 1 2 3 4 5
Project is being developed by an applicant with experience 1 2 3 4 5
3. Do you favor an open competitive process for selecting projects? Circle one: ( Y / N )
4a. Do you favor a set aside for specific projects or sectors? Circle one: ( Y / N )
4b. If yes, please indicate low, medium or high priority sectors: (circle one, per line item)
Low Medium High
Locomotive: L M H
Marine Vessels: L M H
Rural Powerhouses: L M H
School buses: L M H
Electric Vehicle Infrastructure (charging stations): L M H
Public Transportation: L M H
Freight trucks: L M H
Construction equipment: L M H
Airport ground support equipment/Port Cargo handling equipment: L M H
5a. Do you think there should be a maximum amount of funding any single project should receive?
Circle one: ( Y / N )
5b. If yes, what should the maximum limit be? __________________________________________
Additional Comments: