Even with some ports at carrying capacity, the national implementation of TWIC readers is not expected to have cumulative impacts in the foreseeable future on resources driven by traffic, since the alternatives considered (with the exception of the No-Action Alternative, Alternative 1) would likely result in negligible increase in traffic.  Some temporary disruption of traffic flow may occur during implementation of the TWIC readers, but once the system reaches steady state, effects should be modest, when compared to maintaining daily operations.

Cumulative impacts associated with additional air emissions are not considered significant since all analyses of air quality under the four FPEA alternatives show increased pollution within the de minimis threshold range.  GHGs generated by additional truck idling are reduced or unaffected in all but two ports.  In the 2 affected ports, emissions are under 25,000 tonnes/year, which is the threshold of concern for GHGs and their impact on climate change; less than 17 tonnes per year of CO2 is potentially generated in the worst case analysis of the container ports.

4.6 Mitigation of Potential Environmental Impacts
During our analysis of potential impacts on air quality due to truck idling, we considered approaches to mitigate these impacts.  While the USCG does not intend to direct industry or to restrict their flexibility, we have reviewed efforts that industry could consider.  These include: 1) Changes of truck model years to newer trucks, 2) appointment schedules for truck arrivals, and 3) changes in sequencing of port business and security operations.

4.6.1 Changes in Truck Models and Fuels
Ports on both the East and West Coast have instituted programs to require the use of lower polluting newer model drayage trucks.  This includes the Port of New York/New Jersey (EPA 2008) and in the Port of Los Angeles/Long Beach (EPA, 2008), since trucks represent significant air pollution sources in those non-attainment areas.  The NY/NJ Clean Air Strategy Program (NY/NJ, 2011) has not been fully implemented and when fully in place this program is expected to result in significant improvement in air quality.

The Clean Trucks program in LA/LB has been in effect since 2000 and has been very successful.  By January 2012, all trucks entering the port will be required to be of model year 2007 or later.  Since these newer model trucks have significantly lower emissions (Table 3) than older models, this has resulted in air emissions from trucks being 5 to 50 times lower (LB Ports, 2011).  Thus the LA/LB program appears to be a very useful mitigation technique for reducing air pollutants from drayage trucks.

There are a wide range of other environmental initiatives in place in the LA/LB area that may be applicable to other U.S. ports, such as the Vessel Speed Reduction Program, the Alternative Maritime Power initiative, and the California Air Resources Board's regulatory strategies for port-related sources.  These strategies would be expected to be applicable to other ports and to be useful, if needed, to reduce any impacts of TWIC readers at other ports.

Other ports, such as Port Everglades, are considering starting clean truck programs as a consequence of programs elsewhere.  While the air quality in Port Everglades is attainment, that Port is concerned that older truck models, which are no longer allowed in West Coast ports, just as they will not be allowed in the future in the NY/NJ port, may relocate to areas where they are allowed to operate, and have the potential to increase air pollution.  All U.S. ports now have the benefit of improved air quality associated with the use of low sulfur fuels, which has been mandated for trucks nationally.

4.6.2 Appointment Schedules for Truck Arrivals
Several port facilities have recognized that appointment schedules for trucks is a useful technique to reduce the "bunching" of trucks at certain times  -  and thus reducing delays in trucks entering the facilities.  Among the major ports, LA/LB has reported that this program has not been effective and continues to rely on the Clean Trucks Program.

By contrast, the NY/NJ ports, through their scheduling program, have reported that reduced delays and improved safety near the highway exits to the ports (NY/NJ Ports, 2011).  The program moves truck arrivals from peak times during the day to less crowded times.  We have no information about the acceptability of the program to the truckers, but believe that the benefit of quicker entry would help them economically, since they are paid for each trip into the port.

4.6.3 Changes in Sequencing of Port Business and Security Operations
Based on discussions with industry (Appendix E) and through our analysis study on congestion (Appendix E) the USCG considered changes in port business and security operations that might reduce delays and thus serve as mitigation for potential air pollution.  While business decisions are up to industry; this section is put forward as another example of potential mitigation techniques.

In general, port managers have indicated that they are open to flexibility in their operations that will accommodate security programs and allow them to reduce delay times.  As observed by USCG personnel during site visits, all indicated that there is a goal at the ports to minimize turnaround times for trucks.  In NY/NJ port operators seek to have the time from entry to exit of trucks under 1 hour; LA/LB operators have a goal of 40 to 50 minutes.  They all commented that longer delays would hurt their business.  In the case of the TSA TWIC pilot program in LA/LB, the initial program set-up resulted in longer delays, and the TSA and port security managers were able to reach an agreement that during times of excessive delays, the port managers were authorized to switch from TWIC readers to using TWICs as visual identification badges.  While it is anticipated that these start-up issues would be resolved and that the full TWIC reader program could be implemented, that agreement showed the need for flexibility in order not to negatively impact business operations at the port.

The first consideration is the current operations at the ports.  Based on our observations and the congestion study (Appendix B), there are three standard sequences for port operations.  All security operations are performed prior to entry of trucks into the ports.  As discussed in Appendix B, the patterns observed are:

Sequence one: all security and business operations are done at an initial entry point; Sequence two: Security operations are completed and then truck goes to a second location for business transactions; Sequence three: security operations are done in stages, and business transactions are done in stages.

Port managers have reported that they may consider (and have found useful in the past) changes in the number of entry portals, changes in configuration at the portals, increasing or reducing the number of gates operated by security personnel, and changes in software and hardware to accommodate operations.  Participants in TWIC pilot programs have reported that their experience gained during those programs has been valuable and that they estimate that a learning curve without that experience might be as long as several years.  Those groups that did not participate in TWIC pilot programs indicated that the startup of new programs for TWIC readers would extend over several years (Port Everglades, 2011).

While methodology was not specifically addressed, combining security functions (including implementation of TWIC reader programs) with business operations was seen as possible by port operators; their major concern was coming to agreement with labor on acceptable practices (Appendix E).  Mandatory program elements might be more acceptable in labor agreements.  However, at least one port operator indicated that these considerations in labor agreements would not be expected to be a major issue.

4.6.4 Temporary Suspension of Reader Use during High Traffic Events and Other Delays
In the event that high traffic volumes or other delays occur, the use of the readers may temporarily be suspended at the approval of the Captain of the Port and the security system could use the TWIC as visual identity badges, as is currently done at the facilities.  These events have the potential to back up traffic into highway ramps and other access points or to increase idling times for trucks and therefore need to be avoided.  In the event of possible high failure rates for readers temporary suspensions can avoid long idling times for trucks, which in turn could lead to additional air pollution.

5.0 Environmental Significance of Proposed Action

The primary resource area that has the most potential to be affected by the implementation of the TWIC readers is air quality.  Impacts to air quality were examined as a result of expected changes in traffic and truck wait times at port entrances.  Air quality is expected to be unaffected in all ports, except for three facilities in Florida and those impacts are insignificant.  The preferred alternative is not the alternative with the least environmental impact, but has no significant impacts.  Due to cost and implementation issues, installing TWIC readers only in high-risk facilities is preferred.  No environmental justice or socioeconomic impacts are expected to result from the action.  No potential impacts to energy, land use, waste, water, biological resources, health and safety, or historic properties are anticipated for the preferred alternative.

6.0 Identified Environmental Review and Consultation

This environmental assessment adopts the information and conclusions contained in several other reports and studies which were coordinated with agencies and persons who provided constructive input.  The U.S. Coast Guard (USCG) also reviewed the consistency of the approach to the analysis in this Final Programmatic Environmental Assessment (FPEA) to other activities in the Department of Homeland Security (DHS) (see Appendix E of this FPEA).

Homeland Security - Transportation Worker Identification Credential Reader Pilot Program

The purpose of this report is to convey the findings of the Transportation Worker Identification Credential (TWIC) Reader Pilot Program (TWIC pilot).  This document is intended to satisfy the reporting requirements of Section 104 of the Security and Accountability for Every Port Act of 2006 (SAFE Port Act, Pub. L. 109-347) and the USCG Authorization Act of 2010, which requires DHS to submit the findings of the pilot program with respect to technical and operational impacts of implementing a transportation security reader system; any action that may be necessary to ensure that all vessels and facilities to which this section applies are able to comply with such regulations; and an analysis of the viability of equipment under the extreme weather conditions of the marine environment.  The Department of Homeland Security managed the TWIC pilot through the participation of the Transportation Security Administration (TSA).

Booz Allen Hamilton - Port Facility Congestion Study

This was a collaborative study between Booz Allen Hamilton and USCG Headquarters staffs, with additional support and subject matter expertise provided by USCG Area, District, and Sector Prevention staffs.  The USCG is required to comply with the National Environmental Policy Act of 1969, as amended (NEPA, Pub. L. 91-190), Executive Order 12866 on Regulatory planning and Review, and the Regulatory Flexibility Act (5 U.S.C.).  As a part of that compliance effort, the USCG explored cost and operational effects of maritime congestion factors related to Physical Access Control Systems (PACSs) and gate security.  This report concluded a six-month study of the analytical formats and models of maritime worker/truck/vessel congestion factors and their impacts, as related to PACSs.  Further, this study evaluated the impact of existing electronic PACS readers on congestion at selected port facilities, to determine the economic and environmental impact of potential regulations in the future.

Environmental Protection Agency and US Federal Highway Administration - DrayFLEET: EPA SmartWay Drayage Activity and Emissions Model and Case Studies

This was a collaborative study between the U.S. Environmental Protection Agency and the U.S. Department of Transportation to examine drayage operations within U.S. ports.  The report generated a comprehensive model on drayage truck movements within a port to help officials estimate factors such as emissions, costs, and throughput, and can adjust for specific variables such as technology, traffic flow, and amount of tonnage received.  The report uses specific case studies in the ports of LA/Long Beach, NY/NJ, Houston, and the Port of Virginia as examples of how to use the DrayFLEET model and provides a breakdown of drayage patterns for each port.

Department of Homeland Security, US-VISIT program (as discussed in Appendix E of this FPEA).
7.0 References

American Association of Port Authorities (AAPA). (2009). World Port Rankings - 2009. Retrieved 2011, from American Association of Port Authorities Web site: http://aapa.files.cms-plus.com/PDFs/WORLD%20PORT%20RANKINGS%202009.pdf

Broward County Board of County Commissioners. (2011). About Us. Retrieved 2011, from Port Everglades Web Site: http://www.porteverglades.net/about-us/

Cannon, J. S. (2009). Container Ports and Air Pollution. Retrieved 2011, from Consenseus: http://www.consenseus.org/pdf/2009PortStudy.pdf

CH2M Hill, The Four Gates Company, & John C. Martin Associates. (2006, February). Port of Palm Beach Master Plan 2005-2015. Retrieved 2011, from http://www.portofpalmbeach.com/business-opportunities/master-plan/downloads/031506_ppb_masterplan.pdf

EPA. (2008). DrayFLEET: EPA SmartWay Drayage Activity and Emissions Model and Case Studies. Retrieved 2011, from U.S. Environmental Protection Agency Web site: http://www.epa.gov/smartway/documents/partnership/trucks/drayage/final-dray-fleet-report.pdf

EPA. (2011a). Air and Radiation: National Ambient Air Quality Standards (NAAQS). Retrieved 2011, from U.S. Environmental Protection Agency Web site: http://www.epa.gov/air/criteria.html

EPA. (2011b). General Conformity: Basic Information. Retrieved 2011, from U.S. Environmental Protection Agency Web site: http://www.epa.gov/air/genconform/background.html

EPA. (2011c). General Conformity: De Minimis Levels. Retrieved 2011, from U.S. Environmental Protection Agency Web site: http://www.epa.gov/air/genconform/deminimis.html

EPA. (2011d). General Conformity: Frequent Questions. Retrieved 2011, from U.S. Environmental Protection Agency Web site: http://www.epa.gov/air/genconform/faq.html#10

EPA. (2011e). Green Book. Retrieved 2011, from U.S. Environmental Protection Agency Web site: http://www.epa.gov/oaqps001/greenbk/define.html

EPA. (2011f). Green Book: Currently Designated Nonattainment Areas for All Criteria Pollutants. Retrieved 2011, from U.S. Environmental Protection Agency Web site: http://epa.gov/oaqps001/greenbk/ancl.html

EPA. (2011g, August 30th). Green Book: Currently Designated Nonattainment Areas for All Criteria Pollutants. Retrieved 2011, from U.S. Environmental Protection Agency Web site: http://www.epa.gov/oaqps001/greenbk/ancl.html#CALIFORNIA

EPA. (2011h, August 31st). Green Book: Nonattainment Status for Each County by Year for Florida. Retrieved 2011, from U.S. Environmental Protection Agency Web site: http://www.epa.gov/oaqps001/greenbk/anay_fl.html

EPA. (2011i). Ground-Level Ozone. Retrieved 2011, from U.S. Environmental Protection Agency Web site: http://www.epa.gov/glo/

EPA. (2011j). Nonroad Engines, Equipment, and Vehicles: Frequently Asked Questions about the Emission Control Area Process. Retrieved 2011, from U.S. Environmental Protection Agency Web site: http://www.epa.gov/nonroad/marine/ci/420f09001.htm

EPA. (2011k, August 30th). The Green Book Nonattainment Areas for Criteria Pollutants. Retrieved 2011, from U.S. Environmental Protection Agency Web site: http://www.epa.gov/oaqps001/greenbk/

EPA. (2011l). Ground-level Ozone. Retrieved 2011, from U.S. Environmental Protection Agency Web site: http://www.epa.gov/glo/

EPA. (2011m). Particulate Matter: Basic Information. Retrieved, 2011, from U.S. Environmental Protection Agency Web site: http://www.epa.gov/pm/basic.html

EPA. (2011n). Email from Prashanth Gururaja, June 20.

Florida Deparment of Environmental Protection (FDEQ). (2011). Air Quality Monitoring: Ozone Standard. Retrieved November 2011, from Florida Department of Environmental Protection Web site: http://www.dep.state.fl.us/air/air_quality/ozone_standard.htm

Greenhouse Gas (GHG) and Criteria Air Pollutant (CAP) Emission Inventory (EI) for the Port Authority of New York & New Jersey. (2010, June). Retrieved 2011, from The Port Authority of New York and New Jersey Web site: http://www.panynj.gov/about/pdf/2008-GHG-Inventory-Summary.pdf

Homeland Security. (2006, April). US-Visit Programmatic Environmental Assessment on Potential Changes to Immigration and Border Management Processes. Retrieved 2011, from U.S. Department of Homeland Security Web site: http://www.dhs.gov/xlibrary/assets/usvisit/US-VISIT_FPEA_041006.pdf

Homeland Security. (2006, April). US-Visit Programmatic Environmental Assessment on Potential Changes to Immigration and Border Management Processes. Retrieved 2011, from U.S. Department of Homeland Security Web site: http://www.dhs.gov/xlibrary/assets/usvisit/US-VISIT_FPEA_041006.pdf

Landrum & Brown, Inc. (2008, April). Fort Lauderdale-Hollywood International Airport Environmental Assessment. Retrieved 2011, from Broward.org: http://www.broward.org/Airport/Community/Documents/appendix_a.pdf

National Oceanic and Atmospheric Administration. (2003, February). U.S. National Oceanic and Atmospheric Administration Web site: http://www.glerl.noaa.gov/res/Programs/nsmain.html.

Port of Los Angeles. (2010). Environment - Air Quality Monitoring. Retrieved 2011, from The Port of Los Angeles Web site: http://www.portoflosangeles.org/environment/air_quality.asp

PANYNJ (Port Authority of New York & New Jersey). (2011a). Transportation Greening. Retrieved 2011, from The Port Authority of New York & New Jersey Web site: http://www.panynj.gov/about/transportation-greening.html?tabnum=2

PANYNJ (Port Authority of New York and New Jersey). (2011b). Environmental Initiatives at the Port of New York and New Jersey. Retrieved 2011, from The Port Authority of New York and New Jersey Web site: http://www.panynj.gov/about/port-initiatives.html

Port of Palm Beach. 2010. Financial Statements with Independent Auditors' Report Thereon. Retrieved September 2011, from the Port of Palm Beach Web site: http://www.portofpalmbeach.com/administration/financial-information/downloads/Audit_Report_2010_Port_of_Palm_Beach_District1303478162.pdf

Ross & Associates. (2009, October 21st ). A Clean Air Strategy for the Port of New York & New Jersey. Retrieved 2011, from The Port Authority of New York and New Jersey Web site: http://www.panynj.gov/about/pdf/CAS-FINAL.pdf

San Pedro Bay Ports . (2010-2011, June 1st). Historical Data - past air quality data for ozone. Retrieved from The San Pedro Bay Ports Clean Air Action Plan: http://caap.airsis.com/HistoricalDetail.aspx

Starcrest Consulting Group, LLC. (2007, July). The Porth of New York and New Jersey Heavvy-Duty Diesel Vehicle Emissions Inventory. Retrieved 2011, from The Port Authority of New York & New Jersey Web site: http://www.panynj.gov/about/pdf/The-Port-of-New-York-and-New-Jersey-Heavy-Duty-Diesel-Vehicle%20Emissions-Inventory.pdf

Starcrest Consulting Group, LLC. (2008, November). 2006 Baseling Multi-Facility Emissions Inventory of Cargo Handling Equipment, Heavy-Duty Diesel Vehicles, Railroad Locomotives and Commercial Marine Vessels. Retrieved 2011, from The Port Authority of New York & New Jersey Web site: http://www.panynj.gov/about/pdf/2006-BASELINE-MULTI-FACILITY-EMISSIONS-INVENTORY.pdf

Starcrest Consulting Group, LLC. (2009, January). 2007 Goods Movement Air Emissions Inventory at the Port of Houston. Retrieved 2011, from The Port of Houston Authority Web site: http://www.portofhouston.com/pdf/environmental/PHA-GM-AirEmissions-07.pdf

Starcrest Consulting Group, LLC. (2010). Port of Los Angeles Inventory of Air Emissions - 2009. Retrieved 2011, from Port of Los Angeles Web site: http://www.portoflosangeles.org/DOC/REPORT_Air_Emissions_Inventory_2009.pdf

TSA (U.S. Transportation Security Administration). (2012). Transportation Worker Identification Credential Reader Pilot Program, Final Report, February 27.

USACE, 2011.  (container statistics).

US Coast Guard. 2014. Transportation Worker Identification Credential (TWIC)  -  Reader Requirements. Final Rule. Regulatory Analysis and Final Regulatory Flexibility Analysis. USCG-2007-28915.

Virginia Department of Environmental Quality (DEQ). (2009). Maps of the Recommended Nonattainment Areas. Retrieved 2011, from Virginia Department of Environmental Quality Web site: http://www.deq.state.va.us/air/pdf/air/emissions/Enclosure_II.pdf

8.0 Contacts
The U.S. Coast Guard has been in contact with:

   1) U.S. Environmental Protection Agency experts on Clean Air Act issues related to U.S. ports,
   2) Officials and private operators at the Port of Los Angeles and Long Beach,
   3) Officials and private operators at the Port of New York and New Jersey, and
   4) Officials and private operators at the Port of Miami and Port Everglades.

Specific contact information is available upon request.

USCG Finding of No Significant Impact
                                      FOR
 Transportation Worker Identification Credential (TWIC)  - Reader Requirements

This action has been thoroughly reviewed by the USCG and it has been determined, by the undersigned, that this project will have no significant effect on the human environment. This finding of no significant impact is based on the attached USCG prepared environmental assessment as well as materials which are incorporated therein by reference.  The Final Programmatic Environmental Assessment (FPEA) has been determined to adequately and accurately discuss the environmental issues and impacts of the proposed action and provides sufficient evidence and analysis for determining that an environmental impact statement is not required.

___________	           ____________________________
		          Mr. Ed  Wandelt
Date 		          Environmental Reviewer
                                  Chief, Office of Environmental Management

I have considered the information contained in the FPEA, which is the basis for this FONSI. Based on the information in the FPEA and this FONSI document, I agree that the proposed action as described above, and in the FPEA, will have no significant impact on the environment.

___________              ______________________________
			Paul F. Zukunft, Admiral
Date 			Responsible Official
            Commandant, U.S. Coast Guard

	Appendix A. Affected Environment at Ports

This appendix reviews and summarizes current air quality conditions in the major ports of New York and New Jersey, Los Angeles, Houston, and Florida (Port Everglades and Port of Palm Beach).  This information on ambient conditions in these areas was compared in the analysis to diesel emissions from trucks that may be impacted by Transportation Worker Identification Credential (TWIC) reader regulations.

A.1 Florida

           Figure A.1. Current Ozone Levels in Florida (FDEQ, 2011)

         Table A.1. Projections of Anthropogenic VOC and NOX Emissions
                          (Tonnes/day) (75 CFR 29674)
Year
                                   Broward
                                  Palm Beach
Total

                                      VOC
                                                                           2002
                                                                         245.84
                                                                         211.64
                                                                         778.11
                                                                           2005
                                                                         226.61
                                                                         193.09
                                                                         715.99
                                                                           2008
                                                                         207.37
                                                                         174.55
                                                                         653.87
                                                                           2009
                                                                         200.95
                                                                         168.36
                                                                         633.16
                                                                           2011
                                                                            201
                                                                         166.83
                                                                         631.91
                                                                           2014
                                                                         201.07
                                                                         164.52
                                                                         630.04
                                                                           2018
                                                                         201.16
                                                                         161.45
                                                                         627.52

                                      NOX
                                                                           2002
                                                                         238.82
                                                                         159.79
                                                                         648.62
                                                                           2005
                                                                         201.95
                                                                         136.85
                                                                         557.81
                                                                           2008
                                                                         165.09
                                                                         113.92
                                                                         466.99
                                                                           2009
                                                                          152.8
                                                                         106.27
                                                                         436.72
                                                                           2011
                                                                         140.98
                                                                          96.99
                                                                         402.61
                                                                           2014
                                                                         123.25
                                                                          83.06
                                                                         351.44
                                                                           2018
                                                                          99.62
                                                                          64.48
                                                                         283.21

A.2 Los Angeles

Figure A.2. Los Angeles South Coast Air Basin Boundary (Starcrest Consulting Group, LLC, 2010)

Figure A.3. Locations of Air Quality Monitoring Stations in Port of Los Angeles and Port of Long Beach (San Pedro Bay Ports, 2011)

Figure A.4. Port of Los Angeles Daily O3 (8-hour) Emissions Observations (Terminal Island Monitoring Station, June 1[st] 2010  -  June 1[st], 2011) (San Pedro Bay Ports, 2010-2011)

Figure A.5. Monthly Average PM10 Concentrations at the Port of Los Angeles January  -  December 2010 (The Port of Los Angeles, 2010)

Figure A.6. Monthly Average PM2.5 Concentrations at the Port of Los Angeles (The Port of Los Angeles, 2010)

Figure A.7. Annual Average PM2.5 Concentrations at the Port of Los Angeles (The Port of Los Angeles, 2010)

Table A.2. Port of Los Angeles Port-wide Emissions Comparison, tonnes per year and % Change (Starcrest Consulting Group, 2010)
Pollutant
PM10
PM2.5
DPM
NOx
SOx
CO
Year

2009
                                                                            511
                                                                            436
                                                                            467
                                                                         11,244
                                                                          2,432
                                                                          2,777
2008
                                                                            805
                                                                            690
                                                                            736
                                                                         15,577
                                                                          3,822
                                                                          3,826
2007
                                                                            777
                                                                            673
                                                                            682
                                                                         17,052
                                                                          3,553
                                                                          4,036
2006
                                                                          1,140
                                                                            975
                                                                          1,040
                                                                         19,262
                                                                          6,026
                                                                          4,658
2005
                                                                          1,062
                                                                            908
                                                                            974
                                                                         16,812
                                                                          5,552
                                                                          4,093
Previous Year (2009-2008)
                                                                           -37%
                                                                           -37%
                                                                           -37%
                                                                           -28%
                                                                           -36%
                                                                           -27%
CAAP Progress (2009-2005)
                                                                           -52%
                                                                           -52%
                                                                           -52%
                                                                           -33%
                                                                           -56%
                                                                           -32%

A.3 Virginia

Figure A.8. Hampton Roads 2008 8-hour Ozone Standard Nonattainment Area (VDEQ, 2009)

A.4 New York

Figure A.9. New York/New Jersey/Long Island Nonattainment Area (Starcrest Consulting Group, LLC, 2008)

Table A.3. Criteria Pollutant Emission Summary by Source Category for New York Ports, 2006 (Starcrest Consulting Group, LLC, 2008)
Pollutant
                                      NOx
                                     PM10
                                     PM2.5
                                      VOC
                                      CO
                                      SO2
Source Category

Cargo Handling Equipment
                                     1,402
                                      93
                                      86
                                      124
                                      465
                                      219
Heavy-Duty Diesel Vehicles
                                     1,935
                                      59
                                      54
                                      87
                                      564
                                      26
Railroad Locomotives
                                      286
                                      10
                                       9
                                      20
                                      44
                                      32
Ocean-Going Vessels
                                     3,691
                                      348
                                      279
                                      165
                                      319
                                     3,270
Harbor Craft
                                      486
                                      26
                                      24
                                      18
                                      41
                                      50
Total PANY Emissions
                                     7,800
                                      537
                                      452
                                      413
                                     1,434
                                     3,597
NYNJLINA Emissions
                                    445,285
                                    178,451
                                    42,441
                                    522,245
                                   2,840,374
                                    170,044
PANYNJ Percentage
                                     1.8%
                                     0.3%
                                     1.1%
                                     0.1%
                                     0.05%
                                     2.1%

Table A.4. Comparison of Regional and Marine Terminal HDDV Emissions, in tonnes per year (Starcrest Consulting Group, LLC, 2008)

Pollutant                                            VOC                CO                   NOx                      PM10                    PM2.5
                                      SO2
New York and New Jersey

Geographical Extent/Source

New York and New Jersey
                                   1,174,315
                                   7,444,713
                                   1,086,959
                                   1,241,436
                                    427,474
                                    674,616
NYNJLINA
                                    531,178
                                   3,265,051
                                    473,677
                                    392,916
                                    144,915
                                    263,236
PONYNJ HDDV
                                     81.27
                                    639.78
                                     2,059
                                     42.40
                                     41.13
                                     36.51
Percent NYNJLINA Emissions
                                     0.02%
                                     0.02%
                                     0.43%
                                     0.01%
                                     0.03%
                                     0.01%

Figure A.10. Model Year Distribution of Trucks Visiting the PANYNJ (Starcrest Consulting Group, LLC, 2008)

A.5 Houston

Table A.5. Port of Houston Authority 2007 Port Associated Maritime-Related Emissions, tonnes per year (Starcrest Consulting Group, 2009)
Pollutant
NOx
SO2
PM10
PM2.5
CO2
CO
Source

Ocean-going vessels
                                                                          2,386
                                                                          3,296
                                                                            296
                                                                            237
                                                                        195,580
                                                                            222
Heavy-duty diesel-fueled vehicles
                                                                          2,357
                                                                              2
                                                                             56
                                                                             54
                                                                        257,980
                                                                            640
Cargo handling equipment
                                                                          1,020
                                                                             22
                                                                             63
                                                                             61
                                                                        112,618
                                                                            363
Locomotives
                                                                            885
                                                                             18
                                                                             33
                                                                             32
                                                                         56,120
                                                                            148
Harbor vessels
                                                                             68
                                                                              2
                                                                              3
                                                                              3
                                                                          5,276
                                                                             19
Total
                                                                          6,716
                                                                          3,340
                                                                            450
                                                                            386
                                                                        627,574
                                                                          1,392

Figure A.11. 2007 Port of Houston Authority Associated Maritime-Related Sources compared to 2005 HGB Nonattainment Area NOx Emissions (Starcrest Consulting Group, 2009)

   Table A.6. Port Profiles and Air Quality Status (Derived from EPA, 2011g)
                                    Port(s)
                        Maintenance/Nonattainment Area
                                 Pollutant(s)
Port of Los Angeles
South Coast Air Basin (SoCAB) Nonattainment Area
8-hr Ozone (VOC and NOx)
Particulate Matter (PM10 and PM2.5)
Port Authority of New York and New Jersey
New York/Northern New Jersey/Long Island Non-Attainment Area (NYNJLINA)
8-hr Ozone (VOC and NOx)
PM2.5
Hampton Roads
Hampton Roads Maintenance Area/ Hampton Roads Nonattainment Area
1997 8-hr Ozone standard/2008 8-hr Ozone standard
The Port of Houston Authority
Houston-Galveston-Brazoria Nonattainment Area
8-hr Ozone (VOC and NOx)
Port of Palm Beach
Port Everglades
Southeast Florida Maintenance Area/Attainment for all NAAQs
1-hour Ozone (revoked). Area under maintenance plan until 2015

A.6 Florida Ports
We focused on Florida ports because they are the ports in the preferred alternative which have been designated as Risk Group A and will, therefore, require the use of TWIC readers in Mode 3.  Thus these areas needed to be considered quantitatively for potential effects due to truck delays as a result of TWIC readers proposed for these locations in the preferred alternative.

A.6.1 Port of Palm Beach and Port Everglades
The Port of Palm Beach is located in Palm Beach County, Florida.  It is the fourth-busiest container port in Florida and the nineteenth-busiest in the United States.  The Port is a major nodal point of the shipment of bulk sugar (domestic usages), molasses, cement, utility fuels, water, produce, and break-bulk items.  The Port also supports nearly half a million cruise passengers taking day trips in the Atlantic, and a growing ferry service to the Bahamas (CH2M Hill, The Four Gates Company, and John C. Martin Associates, 2006).

Port Everglades is located in Broward County, in the heart of Greater Fort Lauderdale and the City of Hollywood, Florida.  It is one of the busiest cruise ports in the world and a leading container port in Florida.  The Port is South Florida's main seaport for receiving petroleum products including gasoline and jet fuel. The Port is among the top 15 container traffic ports in the United States (Broward County Board of County Commissioners, 2011).

Port Everglades and Port of Palm Beach are located in Broward County and Palm Beach County, respectively.  These counties are located in the Southeast Florida Airshed, which includes Broward, Miami-Dade, and Palm Beach counties.  The Airshed is currently in attainment for all federally-regulated standards (NAAQSs) (EPA, 2011h).  However, the Airshed is under the now revoked 1-hour ozone maintenance plan to ensure that the area remains in attainment for the current ozone standard for at least 10 years.  Figure A.1 presents the current ozone compliance values in Florida.  Broward County is in attainment for the current 75 ppb ozone standard at 60 ppb, while Palm Beach County is in attainment at 63 ppb.  Both counties are in attainment for all other NAAQSs (EPA, 2011h).

A.6.2 Southeast Florida Airshed Maintenance Area: Regulatory History
The Southeast Florida Area was designated nonattainment for the 1-hour ozone standard on November 6, 1991.  On November 8, 1992, the State of Florida submitted a request to re-designate the Southeast Florida Area to attainment for the 1-hour ozone standard. Florida also submitted the required 1-hour ozone monitoring data and maintenance plan ensuring this area would remain in attainment of the 1-hour ozone standard for at least 10 years.  On February 24, 1995, the Southeast Florida Area was designated attainment for the 1-hour ozone standard.  The Southeast Florida maintenance plan went into effect in April 1995 and was later updated to cover additional years such that the entire maintenance period was for at least 20 years after the initial re-designation of the area to attainment (75 FR 29671-29677).

On April 30, 2004, the U.S. Environmental Protection Agency (EPA) designated and classified areas for the 1997 8-hour ozone standard and published a final rule for implementation of the 1997 8-hour ozone standard. The Southeast Florida Area was designated as attainment for the 1997 8-hour ozone standard, effective June 15, 2004.  The areas designated as attainment were consequently required to submit a 10-year maintenance plan under section 110(a)(1) of the Clean Air Act of 1970, as amended (CAA), and the published final rule implementing the 1997 standard.  On July 2, 2009, the State of Florida submitted State Implementation Plan (SIP) revisions containing the 1997 8-hour ozone maintenance plan for Southeast Florida.  The purpose of this plan is to ensure continued attainment and maintenance of the 1997 8-hour ozone standard in the Southeast Florida Area until 2018 (75 FR 29671-29677).

Based on data provided in the latest EPA-approved SIP for Southeast Florida it is demonstrated that the area is in attainment for the 1997 8-hour ozone standard and it is expected to continue attainment.  Table A.1 demonstrates decreasing levels of the ozone precursors VOC and NOx through 2018 and thus continued attainment for both the 1997 8-hour ozone standard and, consequently, the current 2008 8-hour ozone standard (75 CFR 29671-29677).  Even though the Southeast Florida Area is considered attainment for the 8-hour ozone standard, it is still subject to compliance with the now revoked 1-hour ozone maintenance measures till 2015.

A.7 The San Pedro Bay Ports: Port of Los Angeles and Port of Long Beach
The Port of Los Angeles and neighboring Port of Long Beach together share the San Pedro Bay and are jointly known as the San Pedro Bay Ports.  The Ports comprise a significant regional and national economic engine for California and for the United States (Starcrest Consulting Group, LLC, 2010).  The San Pedro Bay Ports both ranked, in 2009, among the top 20 ports for the most container traffic in the world (American Association of Port Authorities, 2009).

A.7.1 California South Coast Air Basin (SoCAB)
The Ports are located within the California South Coast Air Basin (SoCAB, Figure A.2), which is the air basin that contains the largest urban area in the western US It has California's largest cities and the most industry, making it the most polluted air basin of the state (Starcrest Consulting Group, LLC, 2010).  The SoCAB is a non-attainment area for the national 8-hour ozone standard, PM10, and PM2.5 (EPA, 2011g).

Air quality monitoring stations have been placed throughout the San Pedro Bay Ports (Figure A.3).  There are currently six monitoring stations, which provide daily readings on emissions levels for all criteria pollutants.  Figure A.4 presents the daily observations from June 2010 to June 2011 for ozone.  Readings from the Terminal Island Monitoring Station suggest that ozone levels in Port of Los Angeles are lower than both the current ozone federal standard (0.075 ppm) and the California standard (0.07 ppm).  Readings for ozone levels from other monitoring stations are very similar to the levels shown by the Terminal Island Monitoring Station and do not exceed the federal standard.

Figure A.5 presents the monthly average PM10 concentrations at all the monitoring stations in Port of Los Angeles for 2010.  Readings suggest that while PM10 levels at the beginning of 2010 have mostly exceeded the state standard (20 ug/m[3]), they have not exceeded the Federal standard (150 ug/m[3]).  As shown in Figure A.5, PM10 levels start to decrease in September.

Figure 6 presents the monthly average PM2.5 concentrations at all monitoring stations in the Port of Los Angeles.  Readings show that levels of PM2.5 at the Port do not exceed the state and Federal standard in 2010.  In addition, readings at all monitoring stations show that levels of PM2.5 at the Port of Los Angeles have decreased in the last 5 years (Figure A.7).  In fact, as shown in Table A.2, levels of all criteria air pollutants, according to readings from all monitoring stations in the Port of Los Angeles, decreased significantly from 2005  -  2009.

These observations demonstrate that while the San Pedro Bay Ports are located within a non-attainment area, emissions from the ports are mostly in attainment with the Federal standards for most criteria pollutants.  The progress that the San Pedro Bay Ports have made in reducing their emissions is, for the most part, a result of their joint initiative to develop and implement port-wide measures and programs to achieve their emissions reductions goals.

A.7.2 Environmental Initiatives
In November 2006, the San Pedro Bay Ports adopted their landmark Clean Air Action Plan (CAAP), designed to reduce health risks and emissions associated with port-related operations while allowing port growth to continue.  In order to track port commitment to cleaner air, the Port of Los Angeles develops annual inventories of port-related sources starting with the 2005 Inventory of Air Emissions, which is the CAAP baseline.  The San Pedro Bay Ports CAAP initiative proposes to curb port-related air pollution from trucks, ships, locomotives and other equipment by at least 45% in 5 years.  The CAAP is the boldest air quality initiative by any seaport, consisting of wide-reaching measures to significantly reduce air emissions (Starcrest Consulting Group, LLC, 2010).

As anticipated cargo volumes increase in the upcoming years, the reduction trend may not continue at the same rate experienced over the last few years.  However, continued implementation of several significant emission reduction programs, such as the Port's Clean Truck Program, Vessel Speed Reduction, Alternative Maritime Power Program, and the California Air Resource Board's (CARB's) regulatory strategies for port-related sources, is expected to substantially mitigate the impact of resumed cargo growth (Starcrest Consulting Group, 2010).

For heavy-duty vehicles, implementation of the Port's Clean Truck Program has resulted in a significant turnover of older trucks to newer and cleaner trucks.  The percentage of 2007+ model year trucks increased from about 4% in 2008 to 16% in 2009 (population-weighted basis).  The average age of the Port-related truck fleet was 10.9 years in 2009 compared to 12.1 years in 2008.  In terms of the calls made by these trucks to terminals, the call-weighted average age in 2009 was 6.9 years as compared to 11.6 years in 2008.  This indicates that a large number of newer trucks made proportionally more calls than their older counterparts (Starcrest Consulting Group, 2010).

A.8 Port of Hampton Roads, Virginia
The Port of Hampton Roads, Virginia is the oldest continuously operating port system and the seventh-largest container port in the United States.  The combined ports of Norfolk, Newport News, and Plymouth along the banks of the James and Elizabeth rivers near the mouth of Chesapeake Bay comprise the Port of Hampton Roads.  Roughly 1,700 container ships visit Hampton Roads each year.  About 1,200 trucks and 4 trains leave the port carrying containers every day.  The port is managed by the Virginia Port Authority (VPA), a State government agency (Cannon, 2009).

A.8.1 Hampton Roads Nonattainment Area
The Port of Hampton Roads is located in the Hampton Roads Nonattainment Area for the current 8-hr Ozone standard (Figure A.8).  However, it is under a maintenance plan for the 1997 8-hour Ozone standard.  The maintenance plan is effective until 2018 and helps the state achieve attainment levels (72 CFR 30490).

A.8.2 Environmental Initiatives
In May 2005, the VPA formally adopted an environmental policy statement committing the VPA to strive to meet four environmental objectives.  The environmental protection program at Hampton Roads has focused on replacing the existing diesel engines in its vehicle fleet of cargo-handling equipment, generally older and more polluting models, with newer engines that comply with stricter emissions standards for on-road vehicle applications.  In October 2007, the VPA partnered with the EPA to launch a pilot program that offers low-cost financing to purchase diesel trucks with more emission-efficient engines or to retrofit older models for efficiency (Cannon, 2009).

A.9 Port Authority of New York and New Jersey
The Port of New York and New Jersey (PANYNJ) is the largest on the east coast, the third-largest in the U.S., and among the ten largest in the world.  It provides almost immediate access to one of the country's wealthiest regions and rail and truck access to half the nation (Starcrest Consulting, LLC, 2008).  It ranks 21 among the top-25 ports in the world for 2009 container traffic (AAPA, 2009).
A.9.1 New York/New Jersey/Long Island Nonattainment Area
PANYNJ is located in the New York/Northern New Jersey/Long Island Nonattainment Area (NYNJLINA) which includes 17 counties across the States of New Jersey and New York (Figure A.9).  The NYNJLINA boundary, recognized by the Regional Air Team, coincides with the EPA determination that this area has levels of ozone that "persistently exceed the national ambient air quality standards" (EPA, 2011).  In addition, in 2005 EPA determined that much of this area does not meet the current national air quality standards for PM2.5 (Starcrest Consulting Group, LLC, 2008).  Figure A.9 presents the NYNJLINA.  The area in blue represents nonattainment for PM2.5 while the area surrounded by the red dots represents the nonattainment area for 1997 8-hr Ozone.

Table A.3 presents criteria pollutant emissions by source category, the total PANYNJ emissions, the total emissions in the NYNJLINA in tonnes per year, and the percentage that the PANYNJ emissions make up of the total NYNJLINA emissions.  Heavy Duty Diesel Vehicles-related emissions for VOC, an ozone precursor, are minimal compared to NOx emissions, also an ozone precursor, which is the second-highest emission level in 2006.  Levels of PM2.5 emissions from heavy-duty diesel vehicles are not as significant.

A 2007 report from PANYNJ, "Heavy Duty Diesel Vehicle (HDDV) Emissions Inventory," was developed to quantify emissions from heavy-duty diesel trucks that serve major marine terminal operations within PANYNJ.  Table A.4 compares statewide emissions, NYNJLINA emissions and emissions from heavy duty diesel vehicles within PONYNJ (Starcrest Consulting Group, LLC, 2008).  The results of the HDDV study indicate that emissions from HDDVs vehicles serving the marine terminals within the PANYNJ represent a small percentage of the total emissions within the NYNJLINA (Starcrest Consulting Group, LLC, 2008).  NOx emissions are probably the most significant contribution to the NYNJLINA emissions from HDDVs, although under 1% of NYNJLINA emissions.  It is also the most notable of the criteria pollutants because of its importance as an ozone precursor and the New York City area's continuing nonattainment area status within PANYNJ (GHG and CAP EI for the PANYNJ, 2010).

A.9.2 Drayage Truck Population
A 2008 survey of drayage trucks conducted at PANYNJ includes model year distribution of the fleet of trucks serving the Port Authority terminals and an estimate of the total number of trucks in various model year groups.  Model year is an important characteristic of drayage trucks because newer trucks usually have lower emissions than older trucks since newer trucks are subject to stricter emission standards.

Figure A.10 illustrates the percentage of trucks of each model year from the survey sample used in the report.  The most common model years are 1999 and 2000, which together account for slightly more than 25% of the trucks surveyed.  The average model year is 1998, which is 10 years old, and the median model year is 1999, which is 9 years old.  Only about 0.03% of trucks visiting the PANYNJ are model year 2007 or newer.

A.9.3 Environmental Initiatives
PANYNJ has developed a Clean Air Strategy for the Ports of New York and New Jersey.  One of the main concerns is to significantly reduce nitrogen oxide (NOx) and particulate matter (PM) pollution, as well as greenhouse gases (GHG) (PANYNJ, 2011).  The 2009 completed Drayage Truck Characterization Survey will be used to prioritize actions to address truck emissions, with the overall goal of phasing out the oldest, most polluting trucks first (Ross & Associates, 2009).

PANYNJ and its marine terminal tenants have completed an initial phase of truck-related emissions reductions with a range of voluntary actions. For instance, tenant terminals have installed electronic gates, relocated gates, and extended gate hours to reduce air emissions associated with truck delays and congestion.  To begin the next phase of action, the Port Authority has begun the preliminary analysis needed to assess long-term improvements in the age of trucks calling the port, and to consider structural changes in the trucking business model (Ross & Associates, 2009).

A.10 Port of Houston Authority
Known as a leader among U.S. ports, the Port of Houston is the 14[th]-largest port in the world, and is ranked first in the U.S. in foreign waterborne tonnage and second in the U.S. in total tonnage.  The port is located in the Houston-Galveston-Brazoria (HGB) eight-county area, classified by the EPA as an ozone nonattainment area.  Port of Houston Authority (PHA) launched the implementation of the Clean Air Strategy Plan in 2009.

The PHA's associated emissions contribution is 3.1% to the overall 2005 HGB nonattainment area for NOx.  Emissions contributions from PHA HDDVs to the nonattainment area are 1.1 percent.

On-terminal (as opposed to on-road) HDDV emissions are 10% of total HDDV emissions for NOx, PM and CO2, 30% of the CO emissions, and 1% of the SO2 emissions (Starcrest Consulting Group, LLC, 2009).  The on-road and on-terminal HDDV emissions associated with PHA facilities contribute 3.1% of NOx emissions, 5.6% of PM10 emissions, and less than 1% each of CO and SO2 emissions to the HGB nonattainment area HDDV emissions (Figure A.11).

Appendix B. Sequencing of Activities at Port Facilities and Potential Implications for Alternative Analysis

Port facility operations have been studied by the U.S. Coast Guard (USCG) with the assistance of a contractor (Booz et al., 2011) in which they made observations on processing of security and other business functions (container custody transfers, safety checks, compliance with schedules, etc., Booz et. al, p. 9).  Their information confirmed that there is no "typical" port facility.  In general, the requirements and processes for arriving vehicles prior to gaining unescorted access to the port facility included:

      * Security screening of inbound vehicles.  When a truck arrived at the terminal for an import load, the driver communicated with security either through direct (face-to-face) communication with a security guard (or port police officer) who was physically located at the gate; or a more technology-centric process involving a combination of intercoms and cameras that enabled security staff to confirm, from a remote location, that the driver possessed a valid Transportation Worker Identification Credential (TWIC) and port-issued identification, and that those were matched to the driver's identity.  Once the officer verified the identity of the driver, verified their need for legitimate access to the facility (often a valid port-issued card served this purpose), determined that the driver was alone in the vehicle (either via Q&A or visual inspection of the vehicle cab/sleeper if required by State law) and had no other suspicions, the truck was allowed to proceed towards the interchange.

      * Business processing of vehicles/cargo inside port facilities (interchange transactions).  In addition to security gates at the entrances to port facilities, "business processes" are also an integral part of commerce operations at port facilities.  While the specific functions performed at interchanges varied by facility, the most common functions performed included conducting transfer of custody of cargo from the truck to the facility (for inbound trucks), providing locations and directions to truckers to drop-off cargo for subsequent transfer to a ship, checking for "holds" on cargo being imported to the U.S. (e.g., Customs or Department of Agriculture checks), conducting vehicle safety checks, etc.  These business processes may be labor intensive (e.g., gate operations personnel checking cargo manifests, chassis numbers and other paperwork prepared by a shippers prior to arrival at the gate), and sometimes resulted in diversion of the vehicle to a customer service area to resolve discrepancies.  The trucks were allowed to proceed to the transfer location on the yard (or depart the facility in the case of outbound trucks) when discrepancies were resolved and business processing was completed.  The location of the business processing at facilities also varied by facility.  At some facilities business processing occurred at the same gate as the security screening of drivers.  However, a number of facilities used secondary "Interchange" gates on the interior of the facility to manage business processes associated with cargo transfer operations.  These interchange gates were most often used for trucks carrying cargo into a terminal, but could also be used for outbound trucks.  More often, trucks exiting a facility were subjected to screening at exit gates...."
                                          Booz et al., pp. 9-10

Nine facilities were selected for the study and the sequence of each operation is summarized in Table B.1.

     Table B.1. Analysis of Sequence of Port Entry Operations (Booz, 2011)
Facility/type
First step
Second step
Third step
Fourth step

Fifth step
Large container/
Mid-Atlantic

Truck enters queue
Port police officers check TWIC and port cards visually
Union Laborers conduct Interchange transaction and check chassis and container for road ability
Truck enters terminal

Medium container/
Mid-Atlantic
Truck enters queue
Port police Officers check TWIC and port cards using a proximity reader, cameras, and intercom
Union Laborers conduct Interchange transaction and check chassis and container for road ability
Truck enters terminal

Small-medium container/
Mid-Atlantic
Trucks pulls up to gate
Driver provides TWIC to Security Guard, who visually inspects and compares picture to driver
Security Guard places TWIC on proximity reader and computer display in guard shack shows picture of TWIC and confirms both driver identity and destination of vehicle within port facility
Gate opens automatically and truck enters terminal

Large break-bulk and car/
Mid-Atlantic
Truck pulls up to one of two sets of automated kiosks, depending on destination terminal
Driver picks up phone that rings automatically inside Security Guard booth
Remote cameras provide a video feed to the Security Guards showing the license plate, chassis numbers and the driver
Driver passes name, license number to Security Guard, who verifies that both the driver and vehicle are registered in eModal
If driver is registered in eModal or visiting the port for the first time, the kiosk prints out an access pass and river proceeds to terminal
Break bulk and container/
Southeast
Truck pulls up to guard shack where security guard visually checks drivers/TWICs
Driver advances to PACS pylon, speaks via phone to gate agent located remotely, who uses remove cameras to inspect the chassis number and Driver's license number
Driver pulls under canopy to confirm the Interchange transaction and have the chassis and container checked for safety and reliability
Truck pulls into terminal

Break-bulk and container/
Southeast
Truck pulls up and hands TWIC and port card to Gate Attendant
Gate Attendant processes in choice of three ways: 1) magnetic strip swipe linked to computers, 2) use handheld scanner, or 3) manually input
Gate Attendant visually checks the TWIC to verify the photo and expiration date
Trucks pulls into terminal

Small container/
Southeast
Truck pulls up and hands TWIC and port card to attendant
Gate Attendant processes in choice of three ways: 1)  magnetic strip swipe linked to computers, 2) use handheld scanner, or 3) manually input
Gate Attendant visually checks the TWIC to verify the photo and expiration date
Trucks pulls into terminal

Small Container/
Southeast
A single entry gate does security checks, port ID validation, TWIC validation, cargo, cargo custody transfer, trailer road ability and sleeper cab inspection

Large break-bulk and container/
Southeast
Driver pulls up to gate
Driver inserts port card into a swipe reader and TWIC into a video slot
Officers by remote use intercom and cameras to confirm identity of truck, container and chassis
Driver advances to privately operated interchanges

Analysis:  Review of the nine sample ports shows three general sequences (Table B.2):

* Sequence one: all security and business operations are done at an initial entry point (two sites),
* Sequence two: Security operations are completed and then truck goes to a second location for business transaction (four sites), or
*  Sequence Three: security operations are done in stages, and business operations are done in stages (three sites).

It is not known to what extent these are a representative sample of the entire array of more than 3,000 port facilities, but there does appear to be both variability and flexibility in the way that entry procedures are administered.  The implication with respect to security is addressed separately, but it appears that no trucks are allowed to enter a facility without first conducting a security review, which is usually a visual inspection of credentials, but sometimes involves TWIC readers for local port identification materials.  It would be expected that the utilization of TWIC readers will cause some delay in the processing of security information at truck entry.

Implication for alternative analysis:

In order to avoid potential delays, alternative approaches and the framework for alternative procedures may be considered.  However, there is limited information at this point on which to base a firm plan.  The basic approach would be to either provide additional access/entry points to speed processing and avoid backups at the present entry points or to consider doing security in stages.  For instance, the facilities might preserve the present security arrangements, but add an additional step in which TWICs would be read by TWIC readers and processed while business transactions are being conducted.  While this might have an advantage of avoiding processing delays at the entry of the facility, it would lead to additional resource requirements to create appropriate infrastructure (at the least, TWIC reader stations) and the implementation of administrative procedures.

While there is the potential advantage of avoiding processing delays at the entry of the facility by changing business practices and thus mitigating any potential adverse environmental impacts, in the present situation, as shown in Table B.2, security arrangements are performed outside the facility before business practices.  Thus a change in sequencing might lead to additional resource requirements to create appropriate infrastructure (at the least, TWIC reader stations), changes in site perimeter designations, moving fences, etc., and the implementation of administrative procedures.  These are discussed in greater detail in Chapter 3 of the FPEA.

               Table B.2. Patterns of truck entry to facilities

Location of activity

Facility
Outside
Inside
General Pattern
1
security
business
2
2
security
business
2
3
security/destination
business
3
4
security/eModal
business
3
5
security/business
none
1
6
security
business
2
7
security
business
2
8
security/business
none
1
9
security/business
business
3

Appendix C. Data Sets

This section describes the data assumptions, formulas and calculations used in the U.S. Coast Guard's (USCG's) Final Programmatic Environmental Assessment (FPEA) for the potential impacts to air quality.
C.1 TSA Data
Data were derived from information at the Transportation Security Administration (TSA) pilot sites (Table 3).  TSA evaluated processing times for facilities using Transportation Worker Identification Credentials (TWIC) readers in an Initial Capability Evaluation (ICE) by measuring throughput, which is defined as the time taken for an ICE participant TWIC-holder to obtain entry as indicated by a TWIC reader response.  The time to pass through an access point was not included for ICE.  As reported by TSA, the time to complete a visual inspection when in Mode 1 was not included.  Based on data from the TSA pilot studies, delays due to TWIC reader operations are expected to be 1.75 seconds per transaction in Mode 1 and 8.36 seconds in Mode 3, and those are the TWIC reader baseline throughputs from ICE (Table C.1).
ICE was performed as a series of anticipated operational scenarios.  System implementation for ICE was relegated to the prospective TWIC reader vendor.  For ICE, the vendor system implementation was presumed by TSA to represent a preferred configuration for their TWIC reader.  ICE TWIC-holders were selected as participants based on their familiarity with the use of their TWIC for all TWIC reader modes of operation a TWIC reader might support.  TSA permitted either real or simulated Physical Access Control System (PACS) to be used during TWIC reader evaluation.  The prospective TWIC reader vendor was allowed to optimize the TSA's Canceled Card List (CCL) checking feature.

Table C.1. TWIC reader ICE Throughput Baseline in Seconds Per Transaction by Mode of Operation (TSA, 2012)[*]
                                  TWIC Reader
Mode 1
                                    Mode 3
                                     Fixed
                                     1.75
                                     8.36

   * Modes refer to operational steps: Mode 1 is use of the TWIC reader to verify the TWIC, including status, expiration date and visual verification of identity. Mode 3 is Mode 1 plus a biometric reading.

C.2 Comparison of ICE Baseline Measures against the Visual Inspection Baseline Measure
C.2.1 Adjustment of Time for Visual Inspections in Mode 1
The time for visual inspections without use of TWIC reader is estimated at 6 seconds by TSA (TSA, 2011).  When the TWIC is used in Mode 1, it is estimated by subject matters experts that visual inspections take 3 seconds.  Visual inspection time using TWIC readers replaces the time that facilities would take to do a visual inspection of site-specific identification cards used for that specific facility.  The total idling time in Mode 1 is 1.75 seconds plus 3 seconds for a total of 4.75 seconds.  Thus, the event of doing a visual inspection in Mode 1 on the TWIC saves time and reduces idling time for the trucks 1.25 seconds.  Mode 3 adjustment was to remove 6 seconds from the processing time as described below.
ICE throughput in Mode 1 was compared to the visual inspection time of 6 seconds (which was reduced to approximately 3 seconds when the TWIC was used, since the card use eliminated some of the processing time for the security guard).  Note that a full identity verification was not performed in ICE for Mode 1, to ensure an accurate measure of TWIC reader transaction times.
Mode 1 provides enhanced security over visual inspection using many automated cross checks, including a cancel card check against the CCL.  In Mode 3, for fixed TWIC readers, processing time was 2.36 seconds slower than visual inspection.  In Mode 3 the TWIC reader checks that the "TWIC holder is the intended bearer of the TWIC" (TSA, 2011).
Throughputs for Mode 3 reflect the time a TWIC-holder needed to properly place their finger on a biometric sensor; a contributor in the final throughput value.  Further, ICE observed that even for experienced TWIC-holders, placement of their finger on the biometric sensor would occasionally result in a failure to attain a biometric match, thereby requiring a second attempt or additional time to resolve the issue.

A comparison of the range of TWIC reader ICE throughput results per TWIC reader mode of operation, against the visual inspection throughput baseline, is illustrated in Figure C.2.  The blue vertical lines indicate the range of minimum ICE throughput to maximum ICE throughput for each TWIC reader mode of operation.  Thus they are measures of the confidence limits for these mean values in the pilot studies.  As shown in Figure C.2, calculating the simple average for each TWIC reader mode of operation indicates that Mode 1 is faster than visual inspection.  There was a wide variance in ICE throughput for Mode 3.  The line at 6 seconds indicates the baseline time, i.e., the time it takes to do a visual inspection without a TWIC reader.

Figure C.2. ICE Throughput Results in Seconds for TWIC Readers (based on TSA, 2011)

C.2.2 Calculation of Delay Time Difference
For the analysis, to express the difference in processing time between the baseline (which is visual inspection only, analyzed at 6 seconds, in the TSA Report) and the delays in different modes the following assumptions are made in the FPEA as summarized below:

            1.  A Mode 1 transaction still requires a visual identification matching the photograph on the TWIC to the TWIC-holder.  There is some time saved in having the TWIC-holder flash a picture of the approved driver, with a camera display showing the driver and allowing the guard or video attendant to compare both images.  USCG subject matter experts estimated that it takes 3 seconds for this visual process when using a TWIC reader.  For the purposes of calculating a transaction time when using TWIC readers in Mode 1, the FPEA added these 3 seconds to the 1.75 seconds for a Mode 1 transaction, resulting in 4.75 seconds for a complete verification.  Thus, according to these calculations, a Mode 1 transaction is 1.25 seconds faster than a visual inspection without using the TWIC reader.

            2. The total ICE transaction time reported for a Mode 3 transaction is 8.36 seconds.  However, a Mode 3 TWIC read does not require any visual inspection because it uses biometric (i.e., fingerprint) matching and, thus, 6 seconds per transaction (the time for a visual inspection as reported by TSA) is avoided.  In a Mode 3 transaction for an environmental analysis a potential impact from a baseline is analyzed.  The baseline for Mode 3 is the Mode 3 transaction time of 8.36 seconds minus the visual impact time of 6 seconds, for a net Mode 3 transaction time of 2.36 seconds.  This means that a Mode 3 read is 2.36 seconds slower than a visual inspection without a TWIC reader.

Table C.2 TWIC Reader ICE Transaction Time Difference (Seconds) Compared to Visual Inspection[*]
                                  TWIC Reader
Mode 1
                                    Mode 3
                                     Fixed
                                     -1.25
                                     +2.36
                * Minus refers to time saved in the transaction

C.3 Emissions Data

C.3.1 U.S. Environmental Protection Agency Data
The U.S. Environmental Protection Agency (EPA) provided a weighted average of emissions based on the composition of model years of trucks entering the port.  These averages are used to calculate emissions in the Port of New York, Houston, Hampton Roads, Port of Palm Beach, and Port Everglades.

The data in Table C.3 were derived from an EPA study Houston, and were used as the standard for all but California ports (EPA, 2011n).

Table C.3. EPA Dataset that has a Weighted Average Emission Rate per Truck for an Average Port in the U.S.

Pollutant Type Emission rate [g/hr]
Model year
% Trucks entering the port
NOX
PM
THC
CO
pre-1990
3.55%
181.98
4.21
15.41
37.45
1990
0.65%
140.55
4.21
15.41
37.45
1991-1993
5.14%
132.14
4.21
15.41
37.45
1994-1997
24.25%
132.14
6.44
15.41
37.45
1998
9.84%
110.96
6.16
15.41
37.45
1999-2002
36.91%
146.37
6.16
15.41
37.45
2003-2006
13.48%
53.84
5.56
10.07
32.06
2007-2009
6.09%
26.92
0.30
2.01
6.41
2010
0.09%
6.43
0.19
1.11
3.53

Weighted Average rate
120.05
5.60
13.86
34.80

EPA also provided data for weighted averages for ports in California.  Under California's Clean Truck Program, trucks models must be 2007 or newer.  These weighted averages are used to calculate emissions in the ports of LA and Long Beach.  THC and CO were not provided for these ports (EPA, 2011n), and so they are not included in Table C.4 below.

Table C.4. EPA Dataset that has a Weighted Average Emission Rate for an Average Port in California

                             Emission Rate [g/hr]
Model Year
CO
NOx
PM
                                                                           2007
                                                                        3.52628
                                                                        26.9216
                                                                       0.016486
                                                                           2008
                                                                        3.52628
                                                                        26.9216
                                                                       0.016486
                                                                           2009
                                                                        3.52628
                                                                        26.9216
                                                                       0.016486
                                                                           2010
                                                                        3.52628
                                                                        6.42787
                                                                       0.016107
                                                                           2011
                                                                        3.52628
                                                                        6.42787
                                                                       0.016107
Weighted Average rate
                                                                        3.52628
                                                                      18.724108
                                                                       0.016335

C.4 Data Calculations

The following formula is used to estimate emissions from major ports.

       Table C.5. Sources of Values Used in Emission Data Calculations
Inputs
Sources of Values
# of TEU per year
EPA 2008 (LA, Hampton Roads, NY, and Houston), AAPA 2009 (Everglades), and Port of Palm Beach. 2010 (Palm Beach)
Average TUE per container
EPA 2008
Delay time difference
Table C.2
Criteria pollutant
Tables C.3 (Average Port) and C.4 (California Port)

An example of the use of this formula is as follows:

The number of TEUs divided by the average TEU per container is to estimate the number of trucks per year.  The number of trucks is then multiplied by the transaction time difference and converted into hours.  This is then converted into hours and is multiplied by each criteria pollutant weighted average to get grams, which are converted into metric tonnes.  This provides each criteria pollutant emitted as expressed as metric tonnes per year.

The following tables show results of calculations.  Total yearly emissions of the major ports of LA/Long Beach, Hampton Roads, Port of New York, Houston, Port of Palm Beach and Port Everglades are calculated using equation and values designated in the equation above.  See Chapter 4 of this FPEA for a discussion of the results.

For each value shown below in Table C.6, the sources are designated in the equation above.  The total ICE transaction time difference is multiplied by each criteria pollutant weighted average rate to give the total criteria pollutant (expressed as grams) reduced per year. The LA port is a combination of the Port of LA and Long Beach and uses criteria pollutant values from Table C.4.  The remainder of the ports uses criteria pollutant values from Table C.3.

       Table C.6. Mode 1 Emission Calculations of Four Major U.S. Ports
                                    Mode 1
                                    # TEU
                                   per year

                           Average TEU per container

                                  # of Trucks
                                   per year

         Mode 1 Total ICE transaction time difference (hours per year)

                               NOx (g) per year

                               SOx (g)  per year

                               PM (g)  per year

                               THC (g)  per year

                               CO (g)  per year

                                  CO2 (g)
                                   per year

                                 Input/Output
                                     Input
                                     Input
                                     Input
                                     Input
                                    Output
                                    Output
                                    Output
                                    Output
                                    Output
                                    Output
                                      LA
                                  15,667,504
                                     1.85
                                   8,468,921
                                     2,941
                                    55,060
                                      N/A
                                      48
                                      N/A
                                    10,369
                                      N/A
                                 Hampton Roads
                                   2,128,366
                                     1.74
                                   1,223,199
                                      425
                                    51,179
                                      31
                                     2,378
                                     5,887
                                    14,780
                                   3,314,104
                                      NY
                                   5,299,105
                                     1.71
                                   3,098,892
                                     1,076
                                    129,658
                                      79
                                     6,026
                                    14,913
                                    37,445
                                   8,396,060
                                    Houston
                                   1,020,002
                                     1.61
                                    633,542
                                      220
                                    26,508
                                      16
                                     1,232
                                     3,049
                                     7,655
                                   1,716,502

Table C.7. Grams from Previous Table Converted into Metric Tonnes (1 metric tonne = 106 grams)
                                   U.S. Port
                                      NOx
                                      SOx
                                      PM
                                      THC
                                      CO
                                      CO2
                                      LA
                                    0.05506
                                      N/A
                                   0.000048
                                      N/A
                                   0.010369
                                      N/A
                                 Hampton Roads
                                   0.051179
                                   0.000031
                                   0.002378
                                   0.005887
                                    0.01478
                                   3.314104
                                      NY
                                   0.129658
                                   0.000079
                                   0.006026
                                   0.014913
                                   0.037445
                                    8.39606
                                    Houston
                                   0.026508
                                   0.000016
                                   0.001232
                                   0.003049
                                   0.007655
                                   1.716502
                             De minimis threshold
                                      100
                                      100
                                      70
                                      N/A
                                      100
                                      N/A

For each value shown below in Table C.8, the sources are designated in the equation above.  The total ICE transaction time difference is multiplied by each criteria pollutant weighted average rate to give the total criteria pollutant (expressed as grams) emitted per year.  The LA port is a combination of the Port of LA and Long Beach and uses criteria pollutant values from Table C.4.  The remainder of the ports uses criteria pollutant values from Table C.3.

       Table C.8. Mode 3 Emission Calculations of Four Major U.S. Ports
                                    Mode 3
                                      TEU
                                   per year

                           Average TEU per container

                                Trucks per year

         Mode 3 Total ICE transaction time difference hours per year)

                               NOx (g) per year

                                   SOx (g)
                                   per year
                                PM (g) per year

                               THC (g) per year

                                    CO (g)
                                   per year

                                   CO2 (g)
                                   per year

                                 Input/Output
                                     Input
                                     Input
                                     Input
                                     Input
                                    Output
                                    Output
                                    Output
                                    Output
                                    Output
                                    Output
                                      LA
                                  15,667,504
                                     1.85
                                   8,468,921
                                     5,552
                                    103,953
                                      N/A
                                      91
                                      N/A
                                    19,577
                                      N/A
                                 Hampton Roads
                                   2,128,366
                                     1.74
                                   1,223,199
                                      802
                                    96,626
                                      64
                                     4,490
                                    11,114
                                    27,905
                                   6,257,029
                                      NY
                                   5,299,105
                                     1.71
                                   3,098,892
                                     2,031
                                    269,690
                                    244,795
                                    11,376
                                    28,157
                                    70,696
                                  15,851,761
                                    Houston
                                   1,020,002
                                     1.61
                                    633,542
                                      415
                                    55,136
                                      30
                                     2,326
                                     5,756
                                    14,453
                                   3,240,755

Table C.9. Grams from Previous Table Converted into Metric Tonnes (1 metric tonne = 10[6] grams)
                                   U.S. Port
                                      NOx
                                      SOx
                                      PM
                                      THC
                                      CO
                                      CO2
                                      LA
                                     0.104
                                      N/A
                                    0.00009
                                      N/A
                                    0.0196
                                      N/A
                                 Hampton Roads
                                    0.0966
                                   0.000059
                                    0.00449
                                    0.0111
                                    0.0279
                                     6.26
                                      NY
                                     0.245
                                   0.000148
                                    0.0114
                                    0.0282
                                    0.0707
                                     15.9
                                    Houston
                                     0.05
                                    0.00003
                                    0.00233
                                    0.00576
                                    0.0145
                                     3.24
                             De minimis threshold
                                      100
                                      100
                                      70
                                      N/A
                                      100
                                      N/A

For each value shown below, the sources are designated in the equation above.  The total ICE transaction time difference is multiplied by each criteria pollutant weighted average rate to give the total criteria pollutant (expressed as grams) emitted per year.  Specific information on average TEU per container for these ports was unavailable so for the purpose of this analysis, an estimated 1.7 TEU per container was based on EPA 2008 data.

           Table C.10. Mode 3 Emission Calculations of Florida Ports
                                    Mode 3
                                 TEU per year

                           Average TEU per container

                                    Trucks

           Mode 3 Total ICE transaction time difference (hours/year)

                               NOx (g) per year

                                   SOx (g)
                                   per year

                                PM (g) per year

                               THC (g) per year

                                    CO (g)
                                   per year

                              CO2 (g)   per year

                                 Input/Output
                                     Input
                                     Input
                                     Input
                                     Input
                                    Output
                                    Output
                                    Output
                                    Output
                                    Output
                                    Output
                              Port of Palm Beach
                                    206,585
                                      1.7
                                    121,521
                                      80
                                     9,599
                                       6
                                      446
                                     1,104
                                     2,772
                                    621,614
                                Port Everglades
                                    796,160
                                      1.7
                                    468,329
                                      307
                                    36,995
                                      22
                                     1,719
                                     4,255
                                    10,684
                                   2,395,645

Table C.11. Grams from Previous Table Converted into Metric Tonnes (1 metric tonne = 106 grams)
                                   U.S. Port
                                      NOx
                                      SOx
                                      PM
                                      THC
                                      CO
                                      CO2
                              Port of Palm Beach
                                    0.0106
                                   0.000006
                                   0.0004446
                                    0.0011
                                    0.00277
                                     0.622
                                Port Everglades
                                    0.0406
                                   0.000022
                                    0.00172
                                    0.00426
                                    0.0107
                                      2.4
                             De minimis threshold
                                      100
                                      100
                                      100
                                      N/A
                                      100
                                      N/A

C.5 Solving for Transaction Time
In Chapter 4 of this FPEA, an estimate of time TWIC readers needed to add to transaction times in order to have a significant impact on air quality, the output of emissions was set at 10 metric tonnes to solve for transaction time.  For the purpose of this exercise, the Port of New York and the criteria pollutant NOx was selected.  The following equation was used to solve for transaction time difference.

Appendix D. Air Quality Criteria.
Table D.1. National Ambient Air Quality Standards under the Clean Air Act (EPA, 2011a)

                               Primary Standards
                              Secondary Standards
                                   Pollutant
                                     Level
                                Averaging Time
                                     Level
                                Averaging Time
Carbon
Monoxide
9 ppm
(10 mg/m[3])
8-hour [(1)]
                                     None

35 ppm
(40 mg/m[3])
1-hour [(1)]

Lead
0.15 ug/m[3] [(2)]
Rolling 3-Month Average
                                Same as Primary
Nitrogen
Dioxide
53 ppb [(3)]
Annual
(Arithmetic Average)
                                Same as Primary

100 ppb
1-hour [(4)]
                                     None
Particulate
Matter (PM10)
150 ug/m[3]
24-hour [(5)]
                                Same as Primary
Particulate
Matter (PM2.5)
15.0 ug/m[3]
Annual [(6)]
(Arithmetic Average)
                                Same as Primary

35 ug/m[3]
24-hour [(7)]
                                Same as Primary
Ozone
0.075 ppm
(2008 std)
8-hour [(8)]
                               Same as Primary

0.08 ppm
(1997 std)
8-hour [(9)]
                               Same as Primary

0.12 ppm
1-hour [(10)]
                                Same as Primary
Sulfur
Dioxide
0.03 ppm [(11)]
(1971 std)
Annual
(Arithmetic Average)
                                   0.5 ppm
                                 3-hour [(1)]

0.14 ppm [(11)]
(1971 std)
24-hour [(1)]

75 ppb [(12)]
1-hour
                                     None
[(1)] Not to be exceeded more than once per year.
[(2)]Final rule signed October 15, 2008. The 1978 lead standard (1.5 ug/m[3] as a quarterly average) remains in effect until one year after an area is designated for the 2008 standard, except that in areas designated nonattainment for the 1978 standard, the 1978 standard remains in effect until implementation plans to attain or maintain the 2008 standard are approved.
[(3)] The official level of the annual NO2 standard is 0.053 ppm, equal to 53 ppb, which is shown here for the purpose of clearer comparison to the 1-hour standard.
[(4)] To attain this standard, the 3-year average of the 98th percentile of the daily maximum 1-hour average at each monitor within an area must not exceed 100 ppb (effective January 22, 2010).
[(5)] Not to be exceeded more than once per year on average over 3 years.
[(6)] To attain this standard, the 3-year average of the weighted annual mean PM2.5 concentrations from single or multiple community-oriented monitors must not exceed 15.0 ug/m[3].
[(7)] To attain this standard, the 3-year average of the 98th percentile of 24-hour concentrations at each population-oriented monitor within an area must not exceed 35 ug/m[3] (effective December 17, 2006).
[(8)] To attain this standard, the 3-year average of the fourth-highest daily maximum 8-hour average ozone concentrations measured at each monitor within an area over each year must not exceed 0.075 ppm (effective May 27, 2008).
[(9)] (a) To attain this standard, the 3-year average of the fourth-highest daily maximum 8-hour average ozone concentrations measured at each monitor within an area over each year must not exceed 0.08 ppm. (b) The 1997 standard - and the implementation rules for that standard - will remain in place for implementation purposes as EPA undertakes rulemaking to address the transition from the 1997 ozone standard to the 2008 ozone standard. (c) EPA is in the process of reconsidering these standards (set in March 2008).
[(10)] (a) EPA revoked the 1-hour ozone standard in all areas, although some areas have continuing obligations under that standard ("anti-backsliding"). (b) The standard is attained when the expected number of days per calendar year with maximum hourly average concentrations above 0.12 ppm is <= 1.
(11) The 1971 sulfur dioxide standards remain in effect until one year after an area is designated for the 2010 standard, except that in areas designated nonattainment for the 1971 standards, the 1971 standards remain in effect until implementation plans to attain or maintain the 2010 standards are approved.
[(12)] Final rule signed June 2, 2010. To attain this standard, the 3-year average of the 99th percentile of the daily maximum 1-hour average at each monitor within an area must not exceed 75 ppb.

Appendix E. Department of Homeland security (DHS) Approaches: US-VISIT Program Draft Environmental Assessment

In April 2006, the U.S. Department of Homeland Security (DHS) analyzed potential changes to the immigration and border management processes in the United States Visitor and Immigrant Status Indicator Technology (US-VISIT) Final Programmatic Environmental Assessment (FPEA), which resulted in a Finding of No Significant Impact (FONSI) (DHS, 2006).  The US-VISIT Program was established to develop entry and exit processes and integrate immigration data and processes with other DHS agencies.  The FPEA examined the environmental impacts of implementing strategic, high-level changes to the immigration and border management environment.  The Proposed Action in the FPEA examined implementation of a system (such as a biometrically-based system, i.e., finger scans) capturing the unique identity of travelers.  The goals of US-VISIT are to enhance the security of U.S. citizens and visitors to the U.S., facilitate legitimate travel and trade, ensure the integrity of the U.S. immigration system, and protect the privacy of visitors to the United States.  Of all the immigration and border management facilities, land border ports of entry are the places where changes in processes and infrastructure are more likely to affect the environment and are therefore the focus of the US-VISIT FPEA.

US-VISIT took a programmatic approach to the analysis because no matter where implemented, the proposed actions have common timing, common impacts, common alternatives, common methods of implementation and common subject matter.  The programmatic analysis will inform policy and strategy development for modifying plans or systems in order to minimize potential environmental impacts.  This approach allows decision-makers to prepare tiered analyses to discuss the particular resources and potential impacts at site-specific locations or for specific initiatives and to allow for implementing the appropriate mitigation, monitoring and adaptive management techniques before moving forward with specific proposals on the ground.  For example, if an area is in non-attainment or maintenance in terms of air quality requirements, coordination with the appropriate state agency will be sought.  Subsequent tiered analyses would evaluate air quality impacts at the site-specific level.  The FPEA considered the following alternatives:

E.1 Alternatives Considered (Including the No Action Alternative)

No-Action Alternative (as required by NEPA):
   * Calls for current processes for assessing individuals and planned improvements and/or increases facilities, infrastructure, technology and staff to continue at the current rate without significant change.
   * Entry, exit and status processes would continue as they are today.

Hybrid Alternative (preferred alternative):
   * Involves a blend of technology and physical resource solutions that would be used to meet the purpose and need.
   * Involves a combination of installing information technology with remote scanners, TWIC readers, biometrics and some physical construction.
   * Involves changes in immigration processes, such as establishing procedures to assign a unique identity to individuals and to standardize data collection.
   * Involves new applications of existing technologies, such as fingerprinting, and the use of new technologies.
   * Involves the construction or expansion of facilities, such as centralized facilities for data analysis and some exit-related infrastructure.  It could also include the addition of special lanes at land border crossings.

Physical Border Alternative:
   * Requires interaction with a government official at every encounter.
   * Expansion of existing ports of entry to meet demand for increased data collection.
   * Introduce exit processes that mirror current entry processes as well as the associated physical infrastructure.
   * Constructing or reconstructing immigration and border management facilities, expanding lanes and roads at entry and exit points.
   * Adding additional processes and personnel to meet the purpose and need.

Virtual Border Alternative:
   * Seeks to move processes abroad and use information technology and automated processes such as remote TWIC readers and smart chips to increase data acquisition and analysis, and to improve status determination on individuals.
   * Relies on decentralized acquisition of data (mostly abroad) and integrated databases.
   * Most immigration and border management processes currently taking place at land border ports of entry would be moved and combined with processes that occur at other facilities overseas and in the United States, resulting in a dispersion of processes away from the land border.
Appendix F. Memorandum from EPA on the Use of Moves Model and Data Application

MEMORANDUM

From: 	Prashanth Gururaja
      U.S. Environmental Protection Agency
      Office of Transportation & Air Quality
      2000 Traverwood Dr.
      Ann Arbor, MI 48105
<PHONE_NUMBER>

To: 	Jon C. Cooper
	Office of Standards Evaluation and Development CG-523
	US Coast Guard
	Washington, DC 20593

Date: July 29, 2011

Subject: Emissions Impacts of TWIC

This memo explains our assistance to you concerning the TWIC 2 process.

Background:

The US Coast Guard (USCG) is in the process of developing a rule-making for the Transport Worker Identification Cards (TWIC) Card Reader program, an element of a security program to protect US ports. This program is being done in association with the Transport Security Agency (TSA) of Department of Homeland Security.  To support that process the CG-5231 program is preparing an Environmental Assessment for that rule. It is anticipated that the TWIC Reader program will result in delays while the cards are being processed by the TWIC Reader system. These delays are being quantified through a pilot study by the TSA at selected US ports.  These delays have been measured to be between 1 to 24 seconds in most facilities. It is then anticipated that these delays will result in idling of trucks during this period, resulting in additional air emissions during that period.

The USCG has asked us to assist them in the technical application of models and information on air quality from the US EPA on this issue. We have discussed these matters through emails and a telephone conversation and now explain our methodology.

Methodology:

Our office at EPA has developed a mobile source emissions inventory model, Motor Vehicle Emissions Simulator (MOVES), which estimates vehicle emissions for a broad range of pollutants at various scales.  MOVES is the most comprehensive mobile source emissions inventory model in use today.  It has been peer-reviewed by technical experts and vetted by a multitude of stakeholders, including state/local environmental and transportation agencies, industry, and environmental groups.  It is the model states are required to use when developing their State Implementation Plans to minimize air pollution from the mobile source sector.

A component of the inputs to MOVES is gram-per-hour emission rates for different operating modes.  One of these operating modes is curb idling.  Curb idling is vehicle idling occurring during normal driving patterns.  For combination long-haul trucks, there is also an extended idling operating mode, which is discretionary overnight idling for the purposes of providing climate control or powering electrical devices.  For the purpose of the TWIC problem, we assume that any delays from just that program will result in additional time of truck curb idling only.   Therefore, the issue is how to quantify any emissions associated with that idling.

I identified data on curb idling for Class 8 diesel vehicles (the types of vehicles that would be expected at port facilities).  These data, which are default inputs in MOVES, quantify emission rates in g/hr for nitrogen oxides (NOx), particulate matter (PM), total hydrocarbons (THC), and energy consumption rates in kJ/hr.  These rates are stratified by model year group and age group.  Since curb idling is an independent operating mode in MOVES, there is no need to run the actual model to come up with an emission factor for this problem.  The appropriate factors can be queried from the existing default input tables.  In fact, running MOVES and using MOVES output would be inappropriate since the output is generally fleet-wide in nature and combines all operating modes within the selected scale and geography.

To estimate average emission rates while idling, we prepared an estimate of the composition of trucks of various model years that would be expected. This table was based on a study that we are in the process of completing for the Port of Houston. In that study, we obtained from the Port of Houston model year information of trucks entering the port over a twelve-month period from 2008 to 2009. While the results of that study are being finalized, we are confident that these data are a reasonably representative sample of trucks that would be expected at that port.  As a simplifying assumption and due to lack of nationwide port data, we considered this model year mix as a reasonable representation of the entire country's ports.

We have presented our tables on the mixture of model years and our calculation of weighted average emission rates to you in a previous email, and we have reproduced the results in Table 1 below.

Table F.1. EPA Estimates of Emissions Rates from Diesel Truck while Curb Idling

                             Emission rate [g/hr]
Model year
Port entrances
NOX
PM
THC
CO
                                                                       pre-1990
                                                                          3.55%
                                                                         181.98
                                                                           4.21
                                                                          15.41
                                                                          37.45
                                                                           1990
                                                                          0.65%
                                                                         140.55
                                                                           4.21
                                                                          15.41
                                                                          37.45
                                                                      1991-1993
                                                                          5.14%
                                                                         132.14
                                                                           4.21
                                                                          15.41
                                                                          37.45
                                                                      1994-1997
                                                                         24.25%
                                                                         132.14
                                                                           6.44
                                                                          15.41
                                                                          37.45
                                                                           1998
                                                                          9.84%
                                                                         110.96
                                                                           6.16
                                                                          15.41
                                                                          37.45
                                                                      1999-2002
                                                                         36.91%
                                                                         146.37
                                                                           6.16
                                                                          15.41
                                                                          37.45
                                                                      2003-2006
                                                                         13.48%
                                                                          53.84
                                                                           5.56
                                                                          10.07
                                                                          32.06
                                                                      2007-2009
                                                                          6.09%
                                                                          26.92
                                                                           0.30
                                                                           2.01
                                                                           6.41
                                                                           2010
                                                                          0.09%
                                                                           6.43
                                                                           0.19
                                                                           1.11
                                                                           3.53

Average rate -->
                                                                         120.05
                                                                           5.60
                                                                          13.86
                                                                          34.80

Volatile organic compounds (VOC) are a subset of THC.  For pre-2007 model years, you can assume VOC emission rates equal to THC emission rates.  Because the use of diesel particulate filters (DPFs) in diesel trucks changes the VOC-to-THC ratio, a ratio of 0.5327 should be used to estimate VOC emission rates for model years 2007 and later, which are equipped with DPFs.  This ratio was determined from the Advanced Collaborative Emissions Study (ACES) directed by the Health Effects Institute and Coordinating Research Council, with participation from a range of government and private sector sponsors.

CO2 and SO2 do not vary by model year group in MOVES.  They are both based off of the curb idling energy rate of 107,131 kJ/hr for Class 8 diesel vehicles.  For diesel fuel, we can assume a heating value of 138,451 kJ/gallon, a CO2 content of 10,084 g/gallon, and a density of 6.9 lb/gallon.  EPA limits sulfur content in diesel fuel to 15 ppm mass.  Also, for every lb of sulfur in the fuel, you get 2 lb of SO2 in the exhaust (i.e. one mole of sulfur in the fuel yields one mole of SO2 in the exhaust).  These assumptions and calculations are described by the equations below.

It would appear that using these weighted average emission rates along with data on idling times for trucks (due to TWIC) would allow you to calculate quantities of pollutants at each facility (for which you have data).

You can also make some estimates on future scenarios by changing the ratio of trucks' model years for the purpose of your analysis. So, for instance, you might have a higher percentage of model year 2010 trucks and lower percentage of pre-1990 model year trucks.

As we discussed, I suggest that you speak with other specialists to assess how to analyze the above data with respect to air quality impacts. Using geographic specific ambient air quality in the port areas you have studied will allow you to make predictions on potential increases in pollutants to those areas.
Appendix G. Summary of Field Trips to Container Facilities and Observations by USCG Personnel

FACILITY/LOCATION
DATES
OBSERVATIONS
Port of Los Angeles and Long Beach
21-23 September 2011
Participated in TWIC pilot program. USCG were told that TSA reported delay times were optimistic and that there were failure rates with contact TWIC readers of up to 12% and 70% with contactless TWIC readers; technology needed improvement. Other facilities liked TWIC program and found it led to a drop in theft do to screening of TWIC eligible individuals.
Observed some longer processing times due to need for training of drivers on how to insert cards, etc.
Port managers advised that there were no significant biological or historical resources to be impacted by TWIC readers.
Port of New York and New Jersey
27-29 July 2011
Participated in TWIC pilot program. One facility reported massive delays during TWIC pilot and need to ask for exemption during rush times for trucks; delays during shift changes at pedestrian gates; one facility reported that it would be difficult to institute process changes to accommodate TWIC readers, if required.
Port managers advised that there were no significant biological or historical resources to be impacted by TWIC readers.
Port of Baltimore
12 January 2012
Facilities had no experience with TWIC readers, but due to relatively large number of entry points, facilities reported that there would be significant expense and training needed if TWIC readers were required.
Port of Miami and Everglades
26-27 October 2011
Due to configuration of Port Everglades, it appeared that a large number of TWIC portable readers would be needed if required by regulation (as is presently planned by TWIC reader program office. Facilities reported that they were need up to 3 years to upgrade facilities and do training to implement a TWIC reader program. No experience in pilot program with TSA.
Port managers advised that there were no significant biological or historical resources to be impacted by TWIC readers.

Appendix H. Marine Security Risk Analysis Model Description
As discussed in the Final Programmatic Environmental Assessment (FPEA), Transportation Worker Identification Credential (TWIC) reader deployment to specific facilities is determined by a risk-based analysis.  This analysis under the Marine Security Risk Analysis Model (MSRAM) assigns three levels of risk groups: Risk Groups A, B, and C and are defined as shown in Figures H.1 and H.2.  This material was developed for the Advanced Notice of Proposed Rulemaking (ANPRM) and further studied for the Notice of Proposed Rulemaking (NPRM) and the final rule.

At the direction of the Office of Management and Budget (OMB), the U.S. Coast Guard (USCG) tasked the Homeland Security Institute (HSI) to conduct an independent peer review of its TWIC implementation analysis.  This included an independent verification and validation of the reader requirements development process.  This involved a verification and validation of the MSRAM-based risk hierarchy presented in the ANPRM.  Based in part on the findings and recommendations of this study, the USCG adjusted the applicability of the reader requirements from the ANPRM in the NPRM.  As the HSI report shows, the distinction between Risk Groups A and B, based on the Analytic Hierarchy Process (AHP) is well defined, with Risk Group A scores greater or equal to a specified threshold.  The distinction between Risk Groups B and C is not as clear as that between A and B, with entities in both Risk Group B and Risk Group C having AHP scores lower than the threshold.  As such, for the final rule, we have removed the reader requirements for Risk Group B and will focus only on the requirements for Risk Group A.  Figure H.3 below shows the rank-ordered AHP scores for all 68 TWIC asset categories.  Current risk groupings considered in the TWIC report are also displayed.  As discussed in the final rule Regulator Analysis, the Coast Guard considered the costs and benefits when deciding which facilities should be required to install readers and concluded that the level of risk, discussed as consequence, associated with targets in Risk Groups B and C does not warrant the investment in readers.  In contrast, facilities in Risk Group A have significantly higher risk and can be more cost-effectively protected through this rule.

              Figure H.1. Risk Groups for MTSA-regulated Vessels
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Risk Group A
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(1) Vessels that carry Certain Dangerous Cargoes (CDC) in bulk;
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(2) Vessels certificated to carry more than 1,000 passengers; and
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(3) Towing vessels engaged in towing barges subject to paragraphs (1) or (2).
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Risk Group B
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(1) Vessels that carry hazardous materials other than CDC in bulk;
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(2) Vessels subject to 46 CFR chapter I, subchapter D, that carry any flammable or combustible liquid cargoes or residues;
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(3) Vessels certificated to carry 500 to 1,000 passengers; and
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(4) Towing vessels engaged in towing a barge or barges subject to paragraphs (1), (2), or (3).
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Risk Group C
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(1) Vessels carrying non-hazardous cargoes that are required to have a vessel security plan;
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(2) Vessels certificated to carry fewer than 500 passengers;
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(3) Towing vessels engaged in towing barges subject to paragraphs (1) or (2);
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(4) Mobile Offshore Drilling Units; and
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(5) Offshore Supply Vessels (OSVs) subject to 46 CFR chapter I, subchapters L or I.