Reasonably Available Control Measures Analysis for TCMs



RACM Analysis for Transportation Control Measures for the 2022 AQMP

The District is developing a new Air Quality Management Plan (AQMP) to attain the 2015 federal 8-hour ozone standard. The 2022 AQMP will be submitted to U.S. EPA in August 2022 as part of the State Implementation Plan (SIP). The federal Clean Air Act (CAA) requires a review of reasonably available control measures (RACM) for Transportation Control Measures (TCMs) during the development of the 2022 AQMP. For TCMs to be considered as RACM, they must be both technologically and economically feasible and must advance the attainment date of the federal air quality standard by at least one year.


The District prepared a list of potential TCMs and conducted an analysis to determine their feasibility of producing reasonably available control measures for the 2022 AQMP. TCMs from the Ventura County 2016 AQMP, the Clean Air Act Section 108(f)(1)(A), and from other air quality management plans were used to prepare the list. The TCMs were organized with numbers, titles, and descriptions. If a TCM was found feasible for Ventura County, it was recommended as a RACM for the 2022 AQMP. If a TCM was determined infeasible for Ventura County, it was not recommended as a RACM for the 2022 AQMP. The RACM list was posted on the VCAPCD website and was presented to the Ventura County Transportation Commission staff and their committees for review and comment.


Based on our comprehensive review and analysis, the TCMs that were determined to be feasible are either being implemented or have been implemented in Ventura County. The TCMs determined to be infeasible did not meet the criteria for RACM because of the individual reasons provided in the analysis. Moreover, implementing all feasible TCMs in the RACM analysis would not advance Ventura County’s 8-hour ozone attainment date by at least one year. All feasible TCMs in Ventura County are included in our metropolitan planning organization’s Regional Transportation Plan (SCAG Connect SoCal) and Federal Transportation Improvement Program. Thus, their emissions reductions are already included in the baseline emissions used for the AQMP/SIP modeling. The Ventura County 2022 AQMP may not claim emission reductions separately from TCMs that have already been included in the SCAG’s Connect SoCal and FTIP.


For comments, suggestions, or questions regarding the RACM analysis, contact Ben Cacatian. Thank you.