This collection
of information is approved on a pilot basis for 18 months. OMB is
not granting a full 3-year approval because of its concern over
whether the proposed methodology for the estimat ion of greenhouse
gas emission reductions attributable to the Tra nsportation
Partners program is effective and efficient and stati stically
appropriate for this purpose, as required by 5 CFR 1320. 9(i). If
EPA wishes to continue this collection of information af ter the 18
month expiration date, it should include with its just ification
for renewal a report showing how the data collected thr ough the
annual Partner Profile survey was used to calculate emis sion
reductions from individual projects. This report should incl ude
buth the estimated reductions and the supporting data and cal
culations used to derive them. OMB understands that EPA intends to
base its estimation methodolo gy on the approach developed by the
International Council for Loc al Environmental Initiatives (ICLEI)
and outlined in its report: Quantifying Greenhouse Gas Emission
Reductions from Transportatio n Partners Projects. While this
approach appears theoretically re asonable, OMB is concerned that
its use generally requires more i nformation than the Partner
Profile survey will provide. OMB unde rstands that EPA intends to
supplement the survey information wit h region-specific statistics
for variables such as fuel efficienc y and vehicle occupancy. While
the use of non-project-specific es timates may be unavoidable, care
must be taken to avoid, as much as possible, assumptions that would
bias the resulting estimates in one direction or the other. The
specific sample calculations p resented in the ICLEI report appear
to include a number of such a ssumptions. We are particularly
concerned about the characterization of basel ine activity. For
example, it may not be appropriate to assume, as the ICLEI report
generally does, that a new low-emissions tran sportation
alternative is primarily replacing single occupancy ve hicles
operating at the national average fuel efficiency. People likely to
participate in voluntary programs to protect the enviro nment may
already be using low-emissions transportation alternati ves or fuel
efficient cars, and some of the use of the new altern ative may
represent absolute increases in personal miles traveled (PMTs)
rather than switching from another transportation mode. In
addition, it is important to accurately reflect all of the increm
ental emissions associated with a new alternative. One sample ICL
EI calculation assumes that no additional greenhouse gases would be
produced by new riders on a city transit system because the "s mall
number" of project participants would not require any additi onal
buses. This may or may not be true in an individual case but is
clearly inappropriate as an analytical assumption. Another IC LEI
calculation assumes that the incremental electricity required to
run an expanded light rail system in San Diego, CA is "low ca rbon"
(ie, produces less than half the US average CO2 emissions), because
the average mix of electricity generation capacity in th e Pacific
states overall includes more hydro and nuclear units th an
nationally. It would be more appropriate (and should be fairly
simple) to determine what the marginal generating units for San
Diego would be and calculate CO2 emissions accordingly. OMB
recognizes the importance of developing methodologies for pro
ducing credible, unbiased estimates of greenhouse gas emission re
cutions, based on reasonably available data and easy to perform c
alculations. This is especially important in light of the Decembe r
1997 international agreement in Kyoto calling for an enforceabl e
commitment to reduce greenhouse gas emissions. In refining the
ICLEI methodology, OMB urges EPA to be particularly careful to
avoid assumptions that might bias the resulting estimates in one
direction or the other.
Inventory as of this Action
Requested
Previously Approved
08/31/1999
08/31/1999
195
0
0
8,371
0
0
0
0
0
The Transportation Partners program is
a new, cooperative, voluntary program that seeks to reduce the
growth of vehicle miles traveled (VMT) through the adoption of
measures that provide or promote the use of non-single occupancy
vehicle transportation choices for citizens. The information
collected under this ICR will be used to help assess the
effectiveness of various types of VMT reduction actions on
improving air quality and reducing greenhouse gas emissions. The
respondents will be project partners in the Transportation Partners
program and will include local government agencies, civic
organizations,....
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.
EPA's Transportation Partners