Instructions for Region 9’s Challenge Goals

A facility that uses contract diesel fleet carriers traveling at least 100,000 miles per year for that facility is challenged to reduce the associated NOx or PM 2.5 by 15% after normalizing. To make this challenge goal, the facility should choose Suppliers' Environmental Performance as a category and either NOx or PM 2.5 as the indicator. Thus the "future" quantity on line 4c of the Performance Track application must be at least 15% lower than the "baseline" quantity on line 4c. Under Question 4, the facility should select "Normalized goal."

Suggested strategy for reducing and tracking NOx and PM 2.5 emissions by 15% from contract diesel carriers:

• Modifying contract language to express a preference for carriers operating clean diesel fleets (e.g. fleets using many of the following strategies: idling controls, improved aerodynamics, improved freight logistics, automatic tire inflation systems, wide-based tires, driver training, and low viscosity lubricants, aftermarket emissions controls or trucks that comply with EPA's 2007 emissions standards).
  
• However, that alone is not enough; carriers should also provide an emissions estimate for the specific trucks sent to a facility or estimate emissions for a carrier's regional fleet.
  • EPA should be consulted on the scope and accuracy of these estimates, particularly for regional fleets.
• Facilities accepting this goal shall periodically audit trucks arriving on-site by tracking the vehicle model year, the presence of aftermarket emissions control devices, and other fleet characteristics (e.g. idling controls, improved aerodynamics, etc.) to verify that the carriers are shipping goods in a manner consistent with their contract requirements.
  • EPA should be consulted on the method and frequency of these audits.

Emissions improvements must be in excess of any applicable state requirements.

EPA Region 9 encourages facilities making this goal to contact Tom Kelly or Andre Villasenor, at (415) 972-3856 or (213) 244-1813, to discuss this further.

A facility can make this challenge goal by choosing Air Emissions as a category and either NOx or PM 2.5 as the indicator in the Performance Track application. In order to receive credit for the challenge goal, the facility must commit to reducing the selected emissions facility-wide by at least 15 percent. Thus the "future" quantity on line 4c of the Performance Track application must be at least 15 percent lower than the "baseline" quantity on line 4c. Under Question 4, the facility should select "Normalized goal."

Alternatively, a facility that owns a fleet of at least 5 diesel vehicles may receive credit for a challenge goal by reducing fleet NOx or PM 2.5 emissions, provided fleet emissions represent a significant portion of facility-wide NOx or PM2.5 emissions. The emissions data that a facility submits in its application and annual performance reports should represent the NOx or PM 2.5 emissions for the entire facility, but the goal level need only reflect a 15% reduction in NOx or PM 2.5 for the fleet. For example, if a facility emits 10 tons of NOx annually, with 6 tons of those emissions due to fleet operations (and 4 tons due to stationary sources), the goal for the goal should be no higher than 9.1 tons. Under Question 1d, the facility should specify 1) what quantities of the baseline total emissions are from mobile sources and what quantities are from stationary sources, and 2) the intended primary activities for achieving emissions reductions.

• While collective reductions from fleet emissions is encouraged, EPA will review for (1) opportunities to reduce overall facility emissions, (2) the significance of the fleet size and emissions reductions relative to facility-wide emissions and (3) the significance of the reductions relative to the benefits of receiving credit for two goals.

Region 9 suggests these strategies for reducing NOx and PM 2.5 emissions from facility-owned fleets:

A facility that chooses this challenge goal should select Energy Use as the category, Total (non-transportation) Energy Use as the indicator, and Reduce Total Energy Use as the goal. In question 4e, on the line for "Total Energy Use," the "Future" quantity must be at least 10 percent less than the "Baseline" quantity. The selected response for question 4 should be "Absolute goal."

In order to participate in this challenge goal, a facility must select Materials Use as the category and Hazardous Materials Used as the indicator and answer "yes" to Question 2a. Next, a facility should click on the "Priority Chemicals List" link. A table will appear where a facility should select the chemical(s) to be reduced by checking the appropriate box(es), and then pressing the save button. The selected priority chemicals will appear as the response to the sub-question under Question 2a. In order to receive credit for the challenge goal, the facility must commit to reducing its use of the priority chemical by at least 10% before normalizing (i.e., check "Absolute Goal" in Question 4). Thus, the "Future" quantity must be at least 10% less than the "Baseline" quantity.

Eligible Priority Chemicals*

Organic Chemicals and Chemical Compounds

• 1,2,4-Trichlorobenzene
• 1,2,4,5-Tetrachlorobenzene
• 2,4,5-Trichlorophenol
• 4-Bromophenyl phenyl ether
• Acenaphthene
• Acenaphthylene
• Anthracene
• Benzo(g,h,i)perylene
• Dibenzofuran
• Dioxins/Furans
• Endosulfan, alpha & Endosulfan, beta
• Fluorene
• Heptachlor & Heptachlor epoxide
• Hexachlorobenzene
• Hexachlorobutadiene
• Hexachlorocyclohexane, gamma-
• Hexachloroethane
• Methoxychlor
• Naphthalene
• PAH Group (as defined in TRI)
• Pendimethalin
• Pentachlorobenzene
• Pentachloronitrobenzene
• Pentachlorophenol
• Phenanthrene
• Pyrene
• Trifluralin

Metals and Metal Compounds

• Cadmium
• Lead
• Mercury

* Although Polychlorinated Biphenyls (PCBs) are on EPA's Priority Chemicals list, they are not included in this challenge goal due to prohibitions on their manufacture, processing, and distribution in commerce.