text:
A Cost Evaluation of Cross-
Border Truck Emissions Testing
Using Heavy Duty Remote
Sensing Equipment
Final Report 601
Prepared by:
Vi Brown
Prophecy Consulting Group, LLC
2005 S. Henkel Circle
Mesa, AZ 85202- 6564
June 2008
Prepared for:
Arizona Department of Transportation
206 South 17th Avenue
Phoenix, Arizona 85007
In cooperation with
U. S. Department of Transportation
Federal Highway Administration
The contents of the report reflect the views of the authors who are responsible for the facts and the
accuracy of the data presented herein. The contents do not necessarily reflect the official views or
policies of the Arizona Department of Transportation or the Federal Highway Administration. This
report does not constitute a standard, specification, or regulation. Trade or manufacturers' names that
may appear herein are cited only because they are considered essential to the objectives of the report.
The U. S. Government and The State of Arizona do not endorse products or manufacturers.
Technical Report Documentation Page
1. Report No.
2. Government Accession No.
3. Recipient's Catalog No.
4. Title and Subtitle
5. Report Date
June 2008
A Cost Evaluation of Cross- Border Truck Emissions Testing Using
Heavy Duty Remote Sensing Equipment
6. Performing Organization Code
7. Author
Vi Brown
8. Performing Organization Report No.
9. Performing Organization Name and Address
10. Work Unit No.
Prophecy Consulting Group, LLC
2005 S. Henkel Circle
Mesa, AZ 85202- 6564
11. Contract or Grant No.
12. Sponsoring Agency Name and Address
13. Type of Report & Period Covered
March 2006 – March 2008
Project Manager: Estomih M Kombe
14. Sponsoring Agency Code
15. Supplementary Notes
Prepared in cooperation with the U. S. Department of Transportation, Federal Highway Administration
16. Abstract
The objective of this research study was to perform a thorough evaluation of the feasibility and cost
implications for initial system installation and ongoing program and maintenance costs for a Land Port of
Entry truck emissions program utilizing Heavy Duty Remote Sensing technology. This study includes funding
recommendations to maintain such a program. To meet the study objective, project tasks included the
following: i) Develop a work plan for approval by the Technical Advisory Committee, 2) Review the literature
on cross- border truck traffic, truck emissions, and truck emissions testing, 3) Prepare a detailed data
collection plan, 4) Implement the data collection plan and provide detailed discussion and analysis to support
the proposed testing program's elements and cost components, 5) Prepare a final report and a four- page
research note.
Cost data were developed for each alternative and includes figures for capital equipment installation and five
years of operation and maintenance expenses. The present worth costs for each data plan utilizing contract
labor ranged from $ 1,320,828 to $ 2,177,467. If employees of ADOT or ADEQ are used, the present worth
costs range between $ 1,140,349 and $ 1,923,247. While it is obvious that the use of employees is less
expensive than contract labor, the agency could find it difficult to attract highly skilled employees for a
proposed HDRS emissions measurement program at the Arizona- Mexico border. It is important to note that
measurement of emissions by remote sensing is still an emerging technology that has limitations in its
ADOT can partner with ADEQ to determine if a monitoring program is warranted at the border at this time.
ADEQ has an established air quality monitoring program throughout the state and has trained staff,
equipment, and facilities to support such a program.
17. Key Words
Truck Emissions, Border Port of Entry, Emissions
Monitoring, Heavy Duty Remote Sensing,
18. Distribution Statement
Document is available to the
U. S. public through the
National Technical Information
Service, Springfield, Virginia
23. Registrant's Seal
19. Security Classification
20. Security Classification
21. No. of Pages
22. Price
Symbol When You Know Multiply By To Find Symbol Symbol When You Know Multiply By To Find Symbol
in inches 25.4 millimeters mm mm millimeters 0.039 inches in
ft feet 0.305 meters m m meters 3.28 feet ft
yd yards 0.914 meters m m meters 1.09 yards yd
mi miles 1.61 kilometers km km kilometers 0.621 miles mi
in2 square inches 645.2 square millimeters mm2 mm2 Square millimeters 0.0016 square inches in2
ft2 square feet 0.093 square meters m2 m2 Square meters 10.764 square feet ft2
yd2 square yards 0.836 square meters m2 m2 Square meters 1.195 square yards yd2
ac acres 0.405 hectares ha ha hectares 2.47 acres ac
mi2 square miles 2.59 square kilometers km2 km2 Square kilometers 0.386 square miles mi2
fl oz fluid ounces 29.57 milliliters mL mL milliliters 0.034 fluid ounces fl oz
gal gallons 3.785 liters L L liters 0.264 gallons gal
ft3 cubic feet 0.028 cubic meters m3 m3 Cubic meters 35.315 cubic feet ft3
yd3 cubic yards 0.765 cubic meters m3 m3 Cubic meters 1.308 cubic yards yd3
NOTE: Volumes greater than 1000L shall be shown in m3.
oz ounces 28.35 grams g g grams 0.035 ounces oz
lb pounds 0.454 kilograms kg kg kilograms 2.205 pounds lb
T short tons ( 2000lb) 0.907 megagrams
( or " metric ton")
( or " t")
mg megagrams
( or " metric ton")
1.102 short tons ( 2000lb) T
TEMPERATURE ( exact) TEMPERATURE ( exact)
º F Fahrenheit
or ( F- 32)/ 1.8
Celsius temperature º C º C Celsius temperature 1.8C + 32 Fahrenheit
º F
fc foot candles 10.76 lux lx lx lux 0.0929 foot- candles fc
fl foot- Lamberts 3.426 candela/ m2 cd/ m2 cd/ m2 candela/ m2 0.2919 foot- Lamberts fl
lbf poundforce 4.45 newtons N N newtons 0.225 poundforce lbf
lbf/ in2 poundforce per
square inch
6.89 kilopascals kPa kPa kilopascals 0.145 poundforce per
square inch
lbf/ in2
SI is the symbol for the International System of Units. Appropriate rounding should be made to comply with Section 4 of ASTM E380
Table of Contents
Section 1 – Introduction ............................................................................ 1
1.1 Scope of Work .................................................................................. 1
1.2 Report Organization.......................................................................... 2
Section 2 – Background............................................................................. 3
2.1 Regulatory Requirements ................................................................. 3
2.2 New Vehicle Standards..................................................................... 3
2.3 Diesel Engine Technology ............................................................ 5
2.4 Remote Sensing Technology .......................................................... 7
2.5 Cross Border Programs................................................................... 10
Section 3 – Literature Review Summary............................................... 15
Section 4 – Data Collection Plan............................................................. 18
4.1 Nogales- Mariposa Land Port of Entry Visit ................................... 18
4.2 Data Collection System .................................................................. 20
Section 5 – Cost Estimate ........................................................................ 23
5.1 Cost Estimating Methodology ........................................................ 23
5.2 Cost Information, Assumptions, and Issues.................................... 24
5.3 Data Plan Cost Estimates................................................................ 25
5.4 Present Worth Costs........................................................................ 27
5.5 Future Cost Projections ................................................................. 27
5.6 Alternate Cost Analysis – Employee Labor ................................... 28
5.7 Alternate Cost Analysis – Present Worth ....................................... 29
5.8 Alternate Cost Analysis – Future Projections................................. 30
Section 6 – Conclusions and Recommendations ................................... 31
6.1 Conclusions..................................................................................... 31
6.2 Recommendations........................................................................... 32
References................................................................................................. 34
Appendix 1 Southern Border LPOE Traffic Data..................................... 36
Appendix 2 Roadway Steel Structure Design Options ............................. 38
Appendix 3 Cost Data Sheets ................................................................... 40
Appendix 4 U. S. Customs and Border Patrol Fee Schedule..................... 44
List of Figures and Tables
List of Figures
Figure 1 Illustration of On- road Remote Sensing Setup......................... 8
Figure 2 Example of a Tag EditTM Computer Screen............................. 9
Figure 3 Illustration of Proposed Expansion Layout for
Nogales- Mariposa LPOE ( September 2007) ......................... 19
List of Tables
Table 1 EPA Emissions Standards for New Heavy- Duty
On- road Diesel Engines ............................................................. 4
Table 2 Heavy Duty Truck Classification and Statistics ........................ 6
Table 3 Diesel Truck and Bus Emissions ( 2002) ................................... 7
Table 4 Summary of Diesel Emissions Measurement Technology
and Equipment ......................................................................... 16
Table 5 HDRS Emissions Measurement Systems –
Present Worth Costs................................................................. 27
Table 6 HDRS Emissions Measurement Systems –
Future Cost Projections............................................................ 28
Table 7 HDRS Emissions Measurement Systems Alternate
Cost Analysis – Present Worth ................................................ 30
Table 8 HDRS Emissions Measurement Systems Alternate
Cost Analysis – Future Projections.......................................... 30
hwy highway
% percent
™ trademark
PbSe lead selenide or selenide of lead
Units of Measurement
bhp brake- horsepower
cm centimeter
oC degree Celcius
oF degree Farenheit
gm gram
gal gallon
h hour
oK degree Kelvin
kg kilogram
kPa kilo Pascals
lbs pounds
m meter
mi mile
μg microgram
μm micrometer
mm millimeter
nm nanometer
ppb parts per billion
ppm parts per million
rpm revolutions per minute
CO carbon monoxide
CO2 carbon dioxide
HAP hazardous air pollutant
HC hydrocarbons
NH3 ammonia
NO nitrogen oxide
NO2 nitrogen dioxide
NOX nitrogen oxides ( or oxides of nitrogen)
NMHC non- methane hydrocarbons
O3 ozone
PM particulate matter
PM2.5 fine particulate matter of size 2.5 microns or less
PM10 particulate matter of size 10 microns or less
SO2 sulfur dioxide
THC total hydrocarbons
VOC volatile organic carbon
ACE Automatic Commercial Environment
ADEQ Arizona Department of Environmental Quality
ADOT Arizona Department of Transportation
APF Air Policy Forum
AZACTS Arizona Alternative Compliance and Testing Study
BAR Bureau of Automobile Repair ( a California agency)
BG Betty Gray
BTS Bureau of Transportation Statistics
CAA Clean Air Act
CAP Consumer Assistance Program
CARB California Air Resources Board
CATI Clean Air Technologies International, Inc.
CBP Customs and Border Protection
CCDET California Council on Diesel Education and Technology
CDPHE Colorado Department of Public Health and Environment
CE- CERT College of Engineering – Center for Environmental Research and
CEMS continuous emissions monitoring system
CHP California Highway Patrol
CMAQ Congestion Mitigation and Air Quality
COV coefficient of variations
CPC condensation particle counter
CRC Coordinating Research Council
DAQEM Department of Air Quality and Environmental Management
( Clark County)
DOT Department of Transportation
DPF diesel particle filters
DPS Department of Public Safety
DU Denver University
DUV dispersive- ultra- violet
DRI Desert Research Institute
E- 56 emissions study number 56
EEA Energy and Environmental Analysis, Inc.
ECM electronic control module
EMC Emissions Measurement Center
EPA Environmental Protection Agency
ERG Eastern Research Group
ESP Environmental System Products
FAA Federal Aviation Administration
FDA Food and Drug Administration
FEAT fuel efficient automobile test
FID flame ionized detector
FTA Federal Transit Administration
FTE full- time equivalent
FMCA Federal Motor Carriers Association
FTIR Fourier Transform Infrared
FTP Federal Test Procedure
GEI gross- emitter identification
GPS global positioning system
GSA General Service Administration
GVW gross vehicle weight
HDGV heavy duty gasoline vehicles
HDDV heavy duty diesel vehicles
HDRS heavy duty remote sensing
HDRSD heavy duty remote sensing device
HDVIP Heavy Duty Vehicle Inspection Program ( California)
HEP high emitter profiles
I& M inspection & maintenance
IR infrared
JCAP Japan Clean Air Program
LasIR laser- Infrared
LII laser induced incandescence
LIDAR light detecting and ranging
LORAX LIDAR on- road aerosol experiment
LPOE land port of entry
MAG Maricopa Association of Governments
MARI Mid- Atlantic Research Institute
MOUDI micro- orifice uniform deposit impactor
MVD Motor Vehicle Department
NAFTA North American Free Trade Agreement
NDIR non- dispersive- Infrared
NIR near- Infrared
NJDEP New Jersey Department of Environmental Protection
NOV notice of violation
NTSEL National Traffic Safety and Environmental Laboratory ( Japan)
NTRC National Transportation Research Center
OBD on board diagnostics
OBDII on board diagnostics- second generation
ODEQ Oregon Department of Environmental Quality
OMR Operations Management Report
OREMS on- road emissions measurement system
PA photo acoustic
PART particulate emissions factor model
PAS photoelectric aerosol sensor
PEM portable emissions monitor
POV privately owned vehicles
PSIP Periodic Smoke Inspection Program
QCM quartz crystal microbalance
RAVEM ride- along vehicle emissions measurement
ROVER real- time on- board vehicle emissions reporter
RPM- 100 real- time PM
RSD remote sensing device
SAE Society for Automotive Engineers
SBRC Santa Barbara Research Center
SDM source detector module
SIP State Implementation Plan
SMPS scanning mobility particle sizer
SNAQS Southern Nevada Air Quality Study
SPOT simple portable on- vehicle testing
TAC Technical Advisory Committee
TCEQ Texas Commission on Environmental Quality
TDL tunable diode laser ( also TDLas)
TEOM tapered element oscillating microbalance
TILDAS tunable infrared laser differential absorption spectrometer
TRC Transportation Research Center
TTI Texas Transportation Institute
TXT text
UDDS urban dynamometer drive schedule
UV ultra- violet
VDF vehicle data file
VERSS Vehicle Emission Remote Sensing System
VMT Vehicle miles traveled
VSP vehicle specific power
VTM vertical transfer mirror
WVU West Virginia University
Section 1.0 – Introduction
The Arizona Transportation Research Center ( ATRC) prepared a solicitation for a
contractor to evaluate the potential and cost for a program of cross- border truck
emissions testing using heavy duty remote sensing ( HDRS) equipment. Prophecy
Consulting Group, LLC ( hereafter referred to as Contractor) was awarded the contract for
this research study.
1.1 Scope of Work
The objective of this research study was to perform a thorough evaluation of the
feasibility and cost implications for a land port of entry ( LPOE) truck emissions program
covering initial system installation, operation, and maintenance. This study includes
funding recommendations to maintain such a program. To meet the study objective, six
tasks were identified:
Task 1: Develop a work plan for approval by ADOT's Technical Advisory
Committee ( TAC).
Task 2: Review the literature on cross- border truck traffic, truck emissions, and
truck emissions testing using HDRS equipment. Use this review to
develop a preliminary assessment of the potential benefits of employing
this technology at an LPOE.
Task 3: Prepare a detailed data collection plan identifying the type of testing
program that will be necessary to make a realistic assessment of the cost
implications of a successful program. Develop an operational concept ( or
set of alternatives, if applicable) bringing together the main components of
the ideal testing program. Identify the potential sources of information for
the key program variables.
Task 4: Implement the data collection plan and provide detailed discussion and
analysis to support the proposed testing program's elements and cost
components. Provide some insight, if possible, of expected variations in the
figures if the program is implemented in one, two, or five years in the
Task 5: Submit a Project Final Report and a four- page Research Note to ATRC.
Five bound copies of the report shall be submitted to the ATRC Project
Manager. The Final Report shall conform to the version of the ATRC
document, Guidelines for Preparing ATRC Research Reports, in effect at
the time the contract is executed.
Task 6: Provide a brief presentation to the Research Council or other audience
designated by the TAC. ( optional)
1.2 Report Organization
Section 1 – Introduction
The Introduction provides a brief statement of the scope of work that is to be completed
for this research study and includes an outline of the Project Final Report.
Section 2 – Background
This section provides a summary of the regulatory requirements associated with
inspection programs of heavy duty vehicle emissions as well as U. S. vehicle standards for
heavy duty diesel engines. An overview is provided on emissions of diesel engines and
on remote sensing technology. Existing cross- border emissions testing programs for state
and federal agencies are discussed.
Section 3 – Literature Review Summary
The literature on vehicle emissions measurement was reviewed. Research tools such as
technical journals, technical reports, newspaper articles, newsletters, and the internet
were used to collect relevant information. This section summarizes the relevant remote
emissions data capture systems identified during the review.
Section 4 – Data Collection Plan
This section summarizes the steps that were taken to develop three design alternatives for
HDRS emission measurement systems at an Arizona LPOE. Also documented within this
section are the summary and outcome of the second meeting of the TAC, the site visit to
Mariposa LPOE at Nogales, Arizona, and a description of proposed equipment for each
HDRS emissions measurement system design.
Section 5 – Cost Analysis
Cost figures gathered from equipment vendors are presented along with assumptions that
were made in this analysis.
Section 6 – Conclusions and Recommendations
The results of the research study are presented along with recommendations for potential
future work and analysis.
Section 2 – Background Information
This section provides background information on the regulatory requirements and new
vehicle standards for heavy duty diesel engines. Background information is provided on
diesel engine technology, remote sensing technology, and cross border programs that are
currently in place between the United States and Mexico.
2.1 Regulatory Requirements
The Clean Air Act ( CAA) gives the Environmental Protection Agency ( EPA) authority to
regulate emissions from new on- road vehicles, including heavy- duty on- road vehicles.
California has authority to adopt its own emissions standards for these vehicles, as long
as they are at least as stringent as federal standards. Other states can adopt either the
California or the federal standards. 1 and localities are free to set their own emissions
standards for existing on- road vehicles.
Heavy- duty trucks and buses account for about one- third of the nitrogen oxides ( NOX)
emissions and one- quarter of particulate matter ( PM) emissions from mobile sources. 2 In
some urban areas, the contribution is even greater. EPA's new engine standards program
is expected to show PM and NOX emission levels that are 90% and 95% lower than
previous levels. " The results of this historic program are comparable to the advent of the
catalytic converter on cars, as the standards will for the first time result in the widespread
introduction of exhaust emission control devices on diesel engines." 2 Just as removing
lead from gasoline enabled the use of catalytic converters, this program removes sulfur
from diesel fuel enabling the use of advanced emission control devices on diesel vehicles.
There have been signs that some lawmakers would like to see more stringent controls for
cross- border trucks. On October 8, 2004, a bill to amend Title 49 of the United States
Code was presented to the house ( and senate) to require motor carriers to comply with
vehicle emission performance standards established by the EPA. 3 The senate bill failed.
2.2 New Vehicle Standards
EPA considers any vehicle over 8,500 pounds ( lbs) gross vehicle weight ( GVW) to be
heavy- duty, and therefore, subject to different regulations than light- duty cars and trucks.
The exception to this is that under EPA Tier 2 regulations for light- duty vehicles, certain
very large sport utility vehicles ( SUVs) and passenger vans used for personal
transportation ( 8,500– 10,000 lbs GVW) are re- classified as medium- duty passenger
vehicles and are subject to the light- duty vehicle rules. 1
Unlike light- duty vehicles that are tested and certified at the vehicle level using a chassis
test, only the engines are certified for heavy- duty vehicles, using an engine test. 2 The
numerical emissions limits from heavy- duty engines is expressed as grams per
brake- horsepower hour ( gm/ bhp- hr). This is equivalent to grams of emissions per unit of
work done by the engine.
EPA first set exhaust smoke opacity standards for new heavy- duty on- road diesel engines
beginning in model year 1970. Starting in model year 1974, new engines were required to
meet numeric emissions limits for CO, NOX, and hydrocarbons ( HC); however, PM was
not regulated until 1988.1 As shown in Table 1, between 1988 and 1998, EPA's limits for
HC and CO remained the same, but allowable levels of both NOX and PM were reduced
in several steps.
Table 1: EPA Emissions Standards for New Heavy- Duty
On- road Diesel Engines ( gm/ bhp- hr) 1
Model Year
1988 1.3 15.5 10.7 0.6
1990 1.3 15.5 6.0 0.6
1991 1.3 15.5 5.0 0.25
1993 1.3 15.5 5.0 0.25( 0.10a)
1994 1.3 15.5 5.0 0.10( 0.07a)
1996 1.3 15.5 5.0 0.10( 0.05a)
1998 1.3 15.5 4.0 0.10( 0.05a)
2004 0.5 15.5 2.5b 0.10( 0.05a)
2007c 0.14 15.5 0.2d 0.01
a. This lower PM limit applies to urban transit buses only.
b. This limit is for NOX and non- methane hydrocarbons ( NMHC)
c. After 2007, any crankcase emissions must be added to tailpipe
emissions subject to these limits.
d. The new NOx limits are phased in between the 2007 and 2010 model
years on a percent- of- sales basis. The 2007 rules also add new steady-state
tests and not- to- exceed limits for NOx.
At 4.0 gm/ bhp- hr NOx and 0.10 gm/ bhp- hr PM, the emissions limits for the 1998 model
year are 63% and 83% lower, respectively, than those for the 1988 model year. In 1997,
EPA adopted an even lower standard for heavy- duty diesel engine NOX emissions to take
effect in the 2004 model year. The next year EPA signed a consent decree with the six
major heavy- duty engine manufacturers to settle its claims. According to EPA,
manufacturers had for a number of years been using an " emissions defeat device" that
modified engine control software to improve fuel economy, but that increased NOX
emissions during certain high- speed steady- state ( highway) driving modes. Among other
remedies, the consent decree mandated the 2004 NOX standard of 2.5 gm/ bhp- hr for
engines built after October 2002. Under the consent decree, engine manufacturers were
also required to develop modified software for model year 1993– 1998 engines that would
reduce off- cycle highway NOX emissions ( this software is often referred to as an
electronic control module ( ECM) or chip " reflash") and to make this software available
to vehicle owners free of charge. The consent decree required that all engines be
upgraded with this new software at the time of normal engine overhaul or rebuild, which
was assumed to occur after 200,000 to 300,000 miles of service. 1
In December 2000, EPA adopted a NOX standard of 0.20 gm/ bhp- hr and a PM standard
of 0.01 gm/ bhp- hr for new on- road heavy- duty diesel engines. This PM standard went
into effect for the 2007 model year, while the NOX standard was to be phased in between
2007 and 2010 on a percent- of sales basis. 1,2
The 2007 emissions standards introduce additional steady state tests partly to ensure that
defeat devices like those that led to the 1998 consent decree will no longer be possible.
The 2007 regulations also require control of crankcase vent emissions from all diesel
engines. 1 Previously, engines with turbo- chargers were allowed to vent their crankcase
emissions, therefore, these emissions are not included in the exhaust limits.
Due to the much slower turnover of on- road heavy- duty fleet vehicles as compared to
light- duty fleet, there are still significant numbers of vehicles with unregulated or
marginally regulated pre- 1990 engines on the road. Even so, over the next 15 years
current and pending EPA regulations will begin to have a significant effect. Based on
normal fleet turn- over, EPA estimates that annual emissions will continue to decline
despite projected growth in annual vehicle miles traveled.
2.3 Diesel Engine Technology
Over the past 20 years, diesel engine technology has improved dramatically. EPA
regulations have reduced the NOX and fine particulate matter of size 2.5 microns or less
( PM2.5) emissions from new on- road diesel truck and bus engines by 80% and 90%,
respectively. 2 To comply with more stringent emissions standards, engine manufacturers
have modified diesel engines and equipped these vehicles with exhaust " after- treatment"
equipment. Stricter standards that take effect between 2007 and 2010 will further reduce
allowable NOX and PM2.5 emissions by 90% and are driving additional changes —
primarily the use of even more effective after- treatment technologies.
While much progress has been made to reduce diesel engine emissions over the past
decade, there is a large volume of older diesel engines in use on roads and highways
today. Many of these engines were made before diesel emissions standards went into
effect. Diesel trucks and buses can stay in service for 20 years, while some non- road
equipment can last more than 40 years.
The on- road heavy- duty vehicle sector is composed of a wide variety of vehicles, from
18- wheel tractor- trailer combinations, to school and transit buses, to dump trucks and
refuse haulers. These vehicles can be found in large numbers on major highways as well
as on urban streets. The vast majority are powered by diesel engines.
Heavy- duty vehicles are categorized by weight class ( see Table 2). 1 In terms of numbers
of vehicles, and especially fuel used annually, the heaviest ( Class 8) vehicles dominate.
In 2002 there were over 2,082,600 Class 8 trucks on the road in the U. S. which used over
17 billion gallons of diesel fuel
The majority of these Class 8 trucks are long- haul tractor- trailers used to move goods
over the nation's highways. Other Class 8 vehicles include transit buses and refuse
Table 2: Heavy Duty Truck Classification and Statistics1
Classification Statistics
Class GVW Rating ( lb) No of Trucks
( x1,000)
( million miles)
Fuel Use
( million gal)
3 10,001 – 14,000 621.1 8,428.6 1,075.1
4 14,001 – 16,000 287.3 4,184.2 533.7
5 16,001 – 19,500 291.1 3,949.2 503.7
6 19,501 – 26,000 855.8 11,361.3 1,449.1
7 26,001 – 33,000 419.1 5,726.7 995.9
8 > 33,000 2,082.6 100,167.0 17,420.3
VMT – vehicle miles traveled
Truck traffic in the U. S. is growing. The number of miles traveled annually by Class 8
trucks is expected to increase by approximately 40% through 2020.1 While future
emissions regulations will mitigate the air quality impacts of increased miles traveled,
heavy duty on road vehicles are, and will remain, a significant contributor to PM2.5 and
other particulate emissions.
While the number of heavy- duty trucks on the road is significantly smaller than the
number of light- duty gasoline- fueled cars, their air quality impact is greater because
current diesel vehicles emit significantly more PM2.5 and NOX for each gallon of fuel
burned than gasoline vehicles. This is partly due to the nature of diesel combustion as
well as to a lag in EPA emissions regulations for diesel engines. As discussed earlier,
heavy- duty diesel vehicles and engines have a longer service life than light- duty gasoline
vehicles and engines. Therefore, it takes longer for more stringent regulations to have a
significant impact.
The vast majority of direct PM2.5 emissions and PM2.5- precursor emissions from heavy-duty
on- road vehicles comes from the combustion of diesel fuel in diesel engines. Almost
all of the PM emissions in the exhaust of these vehicles is PM2.5. Gasoline powered
heavy- duty vehicles do exist, but they account for less than 3% of PM2.5 and 6% of NOX
emissions from on- road sources. In addition, tire wear and brake wear together account
for less than 2% of PM2.5 emissions from heavy- duty vehicles. 1
About a quarter of the PM emissions from tire wear is PM2.5, and close to half of the PM
emissions from brake wear is PM2.5. Exhaust from heavy- duty diesel vehicles accounts
for about 65% of direct PM2.5 emissions from on- road vehicles ( Table 3) 4. This is less
than 2% of the total inventory of direct PM2.5 emissions, including stationary sources and
non- road vehicles. However, the hazardous nature of diesel exhaust and the proximity of
diesel exhaust sources to sensitive populations, particularly in urban areas, magnify the
health impact. Diesel exhaust is known to contain over 40 substances listed by EPA as
hazardous air pollutants, 15 of which have been listed by the International Agency for
Research on Cancer as known, probable or possible human carcinogens. Many of these
substances are adsorbed onto emitted diesel exhaust particles. For this reason, the
California Air Resources Board ( CARB) has formally designated diesel PM as a toxic air
contaminant. 4
Table 3: Diesel Truck and Bus Emissions ( 2002) 4
Category PM2.5
( tons/ year)
( tons/ year)
( tons/ year)
Heavy- duty diesel vehicles
( highway)
97,000 105,000 3,378,000
% of highway vehicle
65% 38% 46%
% of total mobile source
22% 15% 29%
SO2 – sulfur dioxide
Exhaust from heavy- duty diesel engines also accounts for about 50% of NOX emissions
from on- road vehicles and about 20% of all NOX emissions, including those from
nonroad diesel and stationary sources. 4,5 All mobile sources, including light- and heavy-duty
onroad vehicles and nonroad equipment, produce about 2 to 4% of total SO2
emissions nationally. Mobile source SO2 emissions were reduced further beginning in
2006, when allowable fuel sulfur levels for both gasoline and diesel fuel declined by over
90%. 4
2.4 Remote Sensing Technology
A brief overview of remote sensing technology and its usage as a measurement tool for
vehicular exhaust pollution from moving vehicles is provided. This information reflects
how this technology is used in the United States with conventional emissions testing
2.4.1 Measurement Techniques
Non- dispersive Infrared ( NDIR): Although different types of remote sensing technology
are being used and studied, the most frequently used technology is the well- proven and
established NDIR technology. NDIR has been used for more than 20 years in thousands
of emissions analyzers in fixed facilities, performing more than 30 million CO and
carbon dioxide ( CO2) measurements in new vehicle certification systems using the US
Federal Test Procedure ( FTP). NDIR is a well- proven method of measuring HC, CO and
CO2 in both fixed location analyzers and remote sensing applications. In fixed location
analyzers, the exhaust is captured in a small tube, through which the infrared is passed
from a low power source to the optically filtered detector. Remote sensing has added
complexities such as the long, open path length that requires a higher power source, and
favorable weather conditions.
Infrared Tunable Lasers: The near- IR ( NIR) low power, tunable lasers operate at a lower
wavelength where there is less CO and CO2 absorption. However, there is negligible HC
and NO absorption in the range of the NIR tunable laser, so it is practical for remote
sensing of CO and CO2. In summary, tunable lasers can and are being used for remote
sensing applications, however, there are significant cost and implementation penalties
associated with measuring gases other than CO and CO2.
Ultra- Violet ( UV) Light: The wavelengths of HC and NOX are measurable in remote
sensing applications by UV spectroscopy over a broad frequency spectrum. This enables
higher accuracy since the measurements are taken over a range of wavelengths. As with
NDIR, this is a well- proven and practical technology that has been used and perfected in
remote sensing applications during the past seven years.
2.4.2 Using Remote Sensing
Road Set- Up: Remote sensing of emissions provides an analysis of the exhaust of a
particular vehicle as it passes by on the road. To correlate the emissions readings with the
specific vehicle a video capture of the vehicle license plate can be part of the setup if
desired. In addition to reading the license plate and taking the emissions readings, vehicle
speed and acceleration are measured for the vehicle- specific power calculation. A typical
remote sensing road set- up for light- duty vehicles is shown in Figure 1.6
Figure1: Illustration of On- road Remote Sensing Set- up6
Most vehicle emission tests ( including the Inspection and Maintenance ( I& M) 240 Test
and the FTP that is used in the U. S. to certify new vehicles) measure vehicle performance
over a range of speeds and accelerations. It is the combination of speed and acceleration
that defines the specific power output of the vehicle engine. It is critical to know the
specific power output of the engine at the time the vehicle's exhaust is measured to
properly evaluate the vehicle's exhaust emissions. In an on- road situation, the road grade
must also be taken into account as a component of specific power. Road grade, vehicle
speed, and vehicle acceleration are used to compute the specific power for each measured
vehicle and to validate the emissions readings.
Weather Considerations: Inclement weather can affect the productivity, but not the
accuracy of remote sensing systems. Adverse weather conditions do not compromise the
quality of the data collected, but rain and fog can affect the measurement productivity of
remote sensing by lowering the valid measurement capture rate. 6
Vehicle Identification: As vehicles pass the remote sensing system, a digital video photo-graph
of the vehicle license plate is taken, correlated with the emissions readings and
stored on a computer hard drive. At the end of each day's testing, the digital video images
and emissions data are converted to data files using a patented post- processing method
called Tag EditTM. Personnel read the license plate from the video image ( digital photo-graph)
and enter it at a keyboard. The Tag Edit ™ software ensures that all valuable
information is extracted from a vehicle record. Figure 2 shows an example of a Tag
EditTM screen. 6
Figure 2: Example of a Tag Edit ™ Computer Screen6
Data Processing: The software creates a machine- readable version of the emissions data
received from the field and stores it in a Vehicle Data File (". VDF"). The VDF file can
be exported to a database or spreadsheet ( Access, Paradox, dBase, Excel, Quattro Pro,
Lotus, etc.) by creating a text file with the file extension of ". TXT". A text file can be
created for just about any field measured.
Certification and Quality Assurance: The only existing certification standard for remote
sensing is that available from the California Bureau of Automotive Repair ( BAR). 6
Quality assurance to ensure continuous improvement of equipment, operation and data is
essential to the success of any remote sensing program. To minimize equipment
downtime and to ensure data quality, the remote sensing software uses a statistical
database with information from the operators, data processors, and auditors.
2.5 Cross Border Programs
Air quality along the 1,952- mile international border that separates the United States and
Mexico is of great concern due to its effect on public health. All or parts of several major
metropolitan areas do not meet EPA's standards for maximum allowable levels of one of
three air pollutants: ozone ( O3), CO and PM10. The U. S. Department of Transportation's
( USDOT) Bureau of Transportation Statistics ( BTS) reports that passenger vehicle
crossings into the U. S. increased by about 38% between 1995 and 2004, from 66.4
million to 91.3 million. BTS estimates that between 1995 and 2004, truck crossings from
Mexico to the U. S. rose by about 57%, from 2.86 million to 4.5 million. 7
2.5.1 State Programs
The North American Free Trade Agreement ( NAFTA) was implemented on January 1,
1994.8 In preparation for its implementation, the State of California enacted legislation
( Senate Bill 270, Chapter 727, Statutes of 1998) that requires CARB to maintain inspect-tion
operations at two California- Mexico border crossings ( i. e., Otay Mesa in the San
Diego region and Calexico in Imperial County), and to perform random roadside inspect-tions
in the border area. This inspection program is referred to as heavy duty vehicle
inspection program ( HDVIP). These two stations have been on- line since 1999 and have
tested over 13,000 vehicles. The opacity test failure rate in the border region has consis-tently
been higher than throughout the rest of the state, which lends credence to the
generally held assumption that Mexican commercial vehicles are older and dirtier than
those registered in California. CARB prepared a report for the California Legislature
( January 2006) 9, to address specific air quality concerns relating to the implementation of
the transportation provisions of NAFTA, and to address specific questions from the
California Legislature.
Enactment of NAFTA is largely responsible for this increase in vehicle and truck
crossings. NAFTA is a regional agreement between the governments of Canada, the
United Mexican States and the United States of America to implement a free trade area. 8
The agreement between the three countries became effective on January 1, 1994 and all
provisions are be fully implemented by 2008. This agreement removes most barriers to
trade and investment among the United States, Canada, and Mexico.
In its January 2005 report, CARB provides a summary of the anticipated emissions and
air quality impacts of increased Mexican commercial vehicle travel into the U. S. 10:
• It is estimated that approximately 30,000 additional trucks will cross daily into the
four border states— Texas, New Mexico, Arizona and California— based on
projections from current border crossing activity and surveys of Mexican fleets.
For the calendar year ending December 31, 2006, the largest crossings for each
LPOE is reported: commercial trucks - 1,526,623 at Laredo, TX, buses - 99,057 at
San Ysidro, CA, and privately owned vehicles ( POV) – 17,073,761 at San Ysidro
followed by 15,837,947 POVs at El Paso. [ Note: 2006 data provided by the
ADOT Mariposa LPOE Operations Management Reporting System.]
• Currently, 3,500 trucks cross into California each day ( approximately 3,000 at
Otay Mesa and 500 at Calexico/ Mexicali). These trucks are limited to travel in a
20- mile commercial zone. These crossings could increase two to five times to
7,000 to 17,500 per day if the 20- mile commercial zone limit is lifted.
• Increased crossings at the California/ Arizona border on Interstate 8 are anticipated
as Mexican trucks from the Nogales region and beyond plus trucks from Texas
and New Mexico come west to use the Port of Los Angeles. Baja California does
not have a comparable large shipping port. In anticipation of this increased traffic,
and increased shipping demand from the Asian market, the Port of Los Angeles is
undergoing significant expansion and will double its capacity in the next two to
five years. It is already the second largest and busiest port in the U. S. The
surrounding freeways that service this port ( Interstate 110 and Interstate 710) are
already severely impacted by truck traffic.
It is important to note that the above impacts are from various studies and many
assumptions underlie them. Actual emissions and air quality impacts will be determined
once NAFTA is fully implemented.
The CARB report also provides a profile of the Mexican Truck Fleet and the country's
emissions standards:
• 66% of the Mexican truck fleet is 1993 model year and older ( 1993 was when the
diesel engine fleet was close to 100% electronic conversion. Engines built in 1993
and later typically use electronic fuel injection and computer controls to reduce
emissions, improve performance and fuel economy).
• 25% of the Mexican truck fleet is pre- 1980 model year ( these engines emit very
high levels of NOX and PM emissions on average).
• Mexican diesel engine emission standards were aligned with EPA's standards for
the 1994 to 2003 model years. Mexico has not revised its emission standards to
reflect recent U. S. standards which require a 50% reduction in NOX for 2004-
2007 engines and a 90% reduction in NOX and PM for 2007 and subsequent
model year engines. The 2007 engine standards also require the use of ultra low
sulfur diesel fuel ( 15 parts per million ( ppm) sulfur), which is not yet required in
The actual increases in emissions resulting from free commercial- vehicle travel between
the United States and Mexico as a result of NAFTA implementation are unknown. Cross-border
travel has been limited to the restricted commercial zone with the exception of the
preliminary or test registration program that allows a limited number of large Mexican
trucks to travel beyond the 20 mile zone. This test registration program began in
September 2007. CARB conducted a survey of heavy- duty commercial vehicles in the
California- Mexico border region to determine the certification profile of the engines that
will be subject to the regulations. Using these preliminary fleet characteristics as well as
assumptions from existing studies and models, CARB estimates that implementation of
HDVIP regulations would potentially prevent emission increases of NOX and PM in the
following concentrations9:
• Statewide: 2.9 tons/ day NOx, 0.12 tons/ day PM
• South Coast Air Basin: 1.1 tons/ day NOx , 0.04 tons/ day PM
As the HDVIP regulation was under development, emission reductions were modeled for
NOX and PM based on the projected fleet profile for 2010. The model assumed that 100%
compliance would yield 14 tons/ day emission reductions of NOX ( statewide) and 3.2
tons/ day reductions of PM. Extrapolating from these modeled reductions, and assuming
that 27% of all inspections take place at the ports and in the border areas, 100%
compliance ( i. e., all vehicles that failed the inspection were repaired and all citations
were cleared) would yield 3.8 tons/ day emission reductions in NOX and 0.86 tons/ day of
PM. In reality, of the vehicles tested in border regions and at the ports, approximately
50% of the citations remain delinquent ( i. e., the engines have not been repaired and the
citations have not been cleared). A 50% rate of " full compliance" would yield emission
reduction estimates of 1.9 tons/ day NOX and 0.43 tons/ day of PM for the border regions
and ports.
CARB is an active participant in the Border 2012 U. S.- Mexico Environmental Program
( Border 2012), a 10- year environmental cooperation program launched in 2003 by the
governments of Mexico and the U. S. in response to the continuing environmental and
public health problems in the region. CARB has secured a $ 100,000 grant from the EPA
to characterize the Mexican truck fleets operating in California. Current estimates of the
impact of Mexico's trucks on California's air quality rely heavily upon assumptions
regarding the size and composition of the Mexican commercial fleet that will travel
through the state, how these vehicles will be driven, and how far north into the state these
vehicles will travel. CARB is designing a study to better estimate the impact of these
vehicles on the state's air quality. Information will be collected from roadside surveys,
vehicle inspections, fuel samples, and from databases maintained by Immigration and
Customs Enforcement ( ICE) - a Division of the U. S. Department of Homeland Security,
the ports of Los Angeles and Long Beach, and the California Highway Patrol. 9
CARB is also a major partner in the West Coast Diesel Collaborative, a consortium of
federal, state and local government agencies, non- profits and industry working together
to find voluntary solutions, incentives and shared approaches to reducing diesel pollution
along the west coasts of Canada, the United States, and Mexico. Through the West Coast
Diesel Collaborative, US EPA awarded the San Diego County Air Pollution Control
District $ 150,000 for a demonstration project on the feasibility and effectiveness of diesel
retrofit technologies on heavy- duty diesel vehicles that operate in the San Diego- Tijuana
region. The West Coast Diesel Collaborative's goal is to ultimately secure $ 100 million
through public/ private partnerships to address and solve the diesel pollution problems
along the west coast. 10
In addition, CARB has actively participated in the U. S.- Mexico Air Policy Forum ( APF),
one of the coordinating bodies under Border 2012, which is responsible for prioritizing
federal policies on border- wide air quality issues. CARB, along with air quality agencies
from other border states, has successfully advocated for the recognition of cross- border
heavy duty diesel truck emissions as one of the issues requiring ongoing dialogue
between the two countries, and which should be at the forefront of the APF's funding
priorities. CARB plans to seek funds allocated through the APF's prioritization process to
address the impact of Mexico's commercial vehicles on the state's air quality.
The San Diego Union- Tribune reported that 50 tons of smog will be produced by the
additional trucks, which is the equivalent of 2.2 million cars. Air quality within the area is
expected to be seriously impacted, and emissions reductions in non- attainment areas will
have to come form other local sources. 11 Mexico has stated that it will require the use of
low- sulfur diesel fuel starting in 2007 in the border regions, and countrywide by 2009.
Environmental officials south of the border expect that long- haul trucks are more likely
to be newer and cleaner than vehicles that only operate within the 20- mile zone around
the border. The article also refers to inspection stations that were set- up in 1998 for
Mexican trucks in California near Otay Mesa and Calexico. No specific information on
the type of emissions testing was provided nor was data provided for implementation or
New Mexico reports that it has no current plans for additional emissions testing along its
border because the state has so little border traffic. 12 Similarly, a spokesperson for the
Texas Commission on Environmental Quality ( TCEQ), indicated that it is not pursuing
heavy duty remote sensing or other related emissions testing at its border, and is waiting
to receive more information from EPA before pursuing a course of action. 13 However, the
El Paso Metropolitan Planning Authority ( MPA), states that Texas currently performs
safety inspections at the commercial ports of entry and they will continue. These
inspections currently do not involve any tests or checks for emissions. Most likely this
will change if new cross- border emissions requirements are promulgated. At the MPA
level, they are proposing to retrofit 30 diesel engines using Congestion Mitigation and
Air Quality Improvement Program ( CMAQ) funds. 14
2.5.2 U. S. Mexico Border Programs
The document, Advancing US- Mexico Border 2012 Air Policy Forum Priorities15, sets
forth the current priorities relating to air quality: reducing emissions from diesel sources,
increasing the availability of ultra low sulfur diesel in the border region, and conducting
training sessions on I& M programs. Two HDRS projects are discussed: a study led by the
Texas Transportation Institute ( TTI) at Texas A& M University and the Nogales, AZ,
border study. The TTI study focused on quantifying emissions from trucks in the idle and
creep drive cycles which is typical of border crossings. The Nogales, AZ, study, although
not identified as such, uses HDRS for measurement of emissions from commercial
trucks, along with corroborating measurements from portable emissions monitors ( PEM)
and opacimeters. The APF planned a workshop on truck emissions at border crossings,
including use of opacimeters, portable emissions monitors ( PEMs), remote sensing
technology, and retrofit technology.
In its ninth report, the Good Neighbor Environmental Board7 suggests the following
recommendations to both retain good air quality and support transportation activities
along the U. S.- Mexico border:
• Bolster stations and transportation infrastructure – bolster infrastructure,
technology, personnel and related activities through substantial new funding, and
intensify long- range planning and coordination at the bi- national, national, state
and local levels to cope with the congestion at border crossings, and thus reduce
air pollution.
• Emissions – harness new and emerging technologies and fuels to reduce
emissions from diesel trucks, buses, municipal and private fleets and passenger
vehicles, and identify private/ public funding sources to accelerate the process.
• Public transit and alternatives to single occupant driving – encourage public
transportation, ridesharing, biking and walking in border cities so that fewer
people will drive alone, thus reducing motor vehicle trips and the emissions of
This document includes information on a project called Cyber Port at the Nogales
Mariposa LPOE. The program seeks to improve the flow of trade from the point of
origin to the point of destination. It features innovations in intelligent transportation
systems that monitor trucks through the federal and state inspection processes, as well as
" Super- Booths" where federal and state officials work side- by- side to perform primary
inspection of trucks.
Section 3
Literature Review Summary
In this section, diesel emissions measurement studies and related research that utilized
Remote Sensing Devices ( RSDs) or other equipment are summarized in Table 4 along
with the measured pollutant( s). If available, vendor and product information are also
provided in Table 4.
The review of the literature identified emission measurement studies in the U. S. as well
as international locations. 16, 17, 18, & 19 Several studies occurred within the southwest,
including Arizona. Two studies have taken place at the U. S.- Mexico border: San Diego,
CA ( 1997) and Nogales, AZ ( 2005). The primary emissions of concern are CO/ CO2, HC,
and NOX, followed by PM and Hazardous Air Pollutants ( HAPs)
These studies represent a combination of existing and emerging technologies capable of
measuring in- use vehicle emissions. HDRSD is still an emerging technology although
significant advances have been made over the last 10 years. During the recent 2005
Nogales, AZ border study, HDRSD technology performed well as an emissions screening
tool, and demonstrated the capability to capture emissions and vehicle data snapshots
from a large number of trucks in a short time frame. Identifying deployment and set- up
strategies for varying truck traffic continues to be a challenge.
Numerous vendors of emissions measuring equipment are available in the market place.
However, when the criteria is narrowed to vendors providing remote sensing equipment,
especially instruments designed to measure emissions from heavy duty diesel engines, the
field is narrowed to a handful of suppliers. Those vendors found from a review of the
literature are:
• University of Denver – Remote Sensing Unit
• Santa Barbara Research Center – Smog Dog
• Banner Engineering Corporation – Ultra Beam and Maxi- Beam Sensors
• MD Laser Tech – Remote Sensing Unit
• ESP – AccuScan RSD 3000 ™ & 4000 ™ units
Although the Desert Research Institute ( DRI – Las Vegas, NV) has developed and
patented several equipment prototypes, this equipment may not be readily available for
purchase or long- term use. For the purposes of this cost study, the research team only
reviewed " off- the shelf products" ( products that can be purchased and are readily
available in the market place).
Table 4 - Summary of Diesel Emissions Measurement Technology and Equipment
Application CO/ CO2 HC NOx PM HAPs Vendor/ Product
Southern California
Study - 1994
UV UV -- -- -- University of Denver/
Remote Sensing Unit
US Mexico Border,
San Diego - 1997
UV UV UV Opacity Meter -- University of Denver/
Austin- San Marcos,
UV UV UV Opacity Meter -- Unknown
Los Angeles – 1999 IR IR IR – Laser -- -- SBRC/ Smog Dog &
US & European
Truck Study: 1997-
Light Duty Trucks rr- IR rr- IR NDIR/ DUV -- -- University of
Denver/ FEAT
Heavy Duty
rr- IR rr- IR NDIR/ DUV -- -- Banner Engineering
Oregon DEQ Three
City Study – 2003
IR IR UV -- -- MD Laser Tech
Remote Sensor
Remote Sensing
Clean Screen
Program in Arizona:
1995- 2000
IR- Laser IR- Laser UV- Laser -- -- SBRC/ Smog Dog
Southern Nevada Air
Quality Study
EPA On- road Test
Facility, since 2000
Colorado Rapid
Screen Testing
Program - 2003
IR- Laser IR- Laser UV- Laser -- -- EnviroTest Systems –
/ Remote Testing Unit
Phoenix Multi- Year
Remote Sensing
Study ( Initiated in
NDIR NDIR DUV -- -- University of Denver/
Remote Sensing Unit
EPA/ ADEQ Cross
Border Pilot Study,
March 2005
IR- Laser IR- Laser UV- Laser Opacity Meter -- ESP/ AccuScan
RSD4000, Robert H.
Wager/ Opacimeter
Phoenix Remote
Sensing Study –
November 2005
NDIR NDIR DUV -- -- University of Denver/
Remote Sensing Unit
Auckland Vehicle
Study – April 2003
NDIR NDIR DUV -- -- University of Denver/
Remote Sensing Unit
NJDEP Clean Bus
Study – Initiated in
' 06
NDIR NDIR DUV Opacity Meter -- ESP/ AccuScan
EPA Instrumented
Heavy Duty Diesel
Trucks Study,
FTIR FTIR FTIR -- FTIR Various Vendors
Limited Studies or
-- Patented by DRI
( remote sensing for
Limited Studies or
-- -- -- LII -- Patented by DRI
Limited Studies or
PA Analyser -- Patented by DRI
( detects and quantifies
light absorbing
particles in real time)
Table 4 - Summary of Diesel Emissions Measurement Technology and Equipment
Study CO/ CO2 HC NOx PM HAPs Vendor/ Product
Various Studies or
-- -- -- TEOM, QCM -- Several Vendors
produce this
Various Studies or
-- -- -- Aetholometer,
laser- end
and Fast FID
-- Various vendors in the
market place
manufacture these
instruments for the
measurement of PM
or Opacity
FEAT was first patented and used by the University of Denver. It is now produced by ESP.
Section 4
Data Collection Plan
Using the findings from the literature review and the summary of remote sensing studies
identified in Section 3, an HDRS data collection system or plan was developed for
ADOT that can be used along one or more LPOEs at the Arizona- Mexico border. The
data collection plan includes sufficient detail to identify the ideal components of an
HDRS system. The detail in the data collection plan is also sufficient to provide the
necessary input for operating a successful program.
Prior to the development of the data collection plan, the Contractor visited the Mariposa
LPOE in Nogales, Arizona. This LPOE was chosen because of its accessibility and
relatively short distance from the Phoenix metropolitan area. The facility borders
Nogales, Sonora and supports pedestrian, passenger vehicle, and commercial vehicle
crossings. The Nogales- Mariposa LPOE also has the largest volume of traffic for all
Arizona- Mexico border crossings.
4.1 Nogales- Mariposa LPOE Visit
The site visit to the Nogales- Mariposa LPOE occurred on Monday, November 6, 2006.
Vi Brown, study director, and Darcy Anderson, principal researcher, met with Scott
Williams, Automatic Commercial Environment ( ACE) Ambassador, and Jesus T. Cruz,
Customs and Border Protection ( CBP) Chief Cargo Officer. A tour of the facility was
provided. The current facility was designed for 600 trucks per day and completed in
1975. The volume of commercial vehicles entering the LPOE in 2007 is greater than
291,000 and peak truck traffic is about 1400 trucks per day. Truck, bus, and private
vehicle traffic data for each U. S.- Mexico southern border LPOE is provided in
Appendix 1.
Some of the government agencies operating at the Nogales- Mariposa LPOE are Federal
Motor Carrier Safety Administration ( FMCA), Department of Public Safety ( DPS),
Federal Aviation Administration ( FAA), ADOT Motor Vehicle Division ( MVD), and
Food and Drug Administration ( FDA). Each truck entering the LPOE goes through some
level of inspection. Some trucks are tagged for additional inspection. The current facility
does not promote efficiency of inspections between agencies. Winter traffic ( between
October and May) represents the busiest season for the LPOE. The majority of the trucks
transport produce from Mexico.
The proposed renovation of the Nogales- Mariposa LPOE was also discussed during this
visit. The General Services Administration's ( GSA) Property Development Division
estimates construction and renovation costs to expand and modernize the LPOE at $ 100-
to $ 150 million. Construction is scheduled to begin in 2009 and to be completed in
2013.20 The September 2007 proposed layout for the construction project is provided in
Figure 3.21
Figure 3: Illustration of Proposed Expansion Layout for Nogales- Mariposa LPOE
( September 2007) 18
While touring the facility, the Contractor's team scanned the site for a suitable location to
set up a heavy duty monitoring station keeping in mind that the facility is proposed for
renovation and expansion. After considerable discussion about the objectives of a HDRS
monitoring site for cross border trucks, the directional flow of truck traffic into and
through the LPOE, and incorporating proposed expansion plans, it was agreed that the
ideal location for HDRS equipment would be on the perimeter road north of the facility
and near the exit for the facility. The exit road is also the entry point into the U. S. It has a
slight uphill grade. This location also works well for emissions measurement purposes.
4.2 Data Collection System
There are many configurations that were considered and discussed, with the fundamental
goal of measuring the key pollutants identified in Scenario 1 ( HC, CO, NOX and PM).
The systems described below and the cost estimates included in Section 5 are designed to
give ADOT a summary of options considered relevant for the project.
One of the outcomes of the literature review was the identification of two instruments
that will provide the type of HDRS emissions measurements that meet the project goals
and objectives. The two are ESP's AccuScan ™ products and FTIR instruments
( available through several manufacturers). Both instruments provide optical- based
measurements with near real- time output. The AccuScan ™ products are the only
instruments specifically designed for this type of deployment. The cost estimates in
Section 5 are based on the Accuscan ™ RSD system.
Arcadis was recently contracted by the EPA to test FTIR instruments in the Phoenix area.
The firm was contacted about the potential for use of FTIR for HDRS emissions
measurement. They responded that it is possible to custom- design an application using
commercially available FTIR instruments. The commercially available FTIR instruments
are less expensive than the ESP AccuScan ™ instruments, but are not specifically
designed for the type of application needed at a border crossing. 22 DRI also has
developed several custom- designed instruments that may be available and appropriate to
test at the border crossing. The fully- integrated system that is discussed later in this
section is designed to allow flexibility for testing and comparing additional
Three alternatives for HDRS equipment measurement systems are included in the cost
study. For each system presented below, the instruments selected will need to be
connected to a data- logger or computer, and the data will need to be transmitted – ideally
by high speed internet or a T- 1 line, but also possibly by modem from a land line or
mobile phone. Each of the HDRS systems described below includes one operating and
one spare remote- sensing device to minimize down time associated with equipment
failure or malfunction.
4.2.1 Basic HDRS Emissions Measurement System
The most basic HDRS emissions measurement system would consist of:
• two remote sensing transmitter units ( one operating and one spare) mounted on a
• a receiver and computer ( inside a basic shelter) mounted on a tower on the
opposite side of the Commercial Roadway exit for the Nogales- Mariposa LPOE
This system would require power ( 110 volts, separate circuits) on each side of the
roadway, and space for mounting towers high enough to send a beam through the truck
exhaust. The towers could potentially accommodate additional equipment if desired for
routine measurement or special studies.
4.2.2 Intermediate HDRS Emissions Measurement System
The intermediate HDRS emissions measurement system builds on the basic model. It
consists of:
• two remote sensing transmitter units ( one operating and one spare) mounted on a
• a receiver and computer ( inside a basic shelter) mounted on a tower on the
opposite side of the Commercial Roadway exit.
• a continuous particulate monitor ( PM10 or a modification to measure PM2.5)
• an aethalometer, that provides continuous measurement of diesel particulate
matter ( black carbon).
Power and mounting requirements are similar to the basic system. The towers and the
shelter could potentially accommodate additional equipment for future monitoring
4.2.3 Fully- Integrated HDRS Emissions Measurement Systems
The fully- integrated HDRS emissions measurement system builds on the intermediate
design and includes:
• two remote sensing transmitter units ( one operating and one spare) mounted on an
exterior column of a pole barn ( roadway canopy), or mounted from the inside
roof beams of the pole barn that would be built across the Commercial Roadway
• a third remote sensing unit would be placed inside a mobile equipment shelter and
deployed at a specific distance from the units in the pole barn to capture exhaust
under acceleration
• a continuous particulate monitor ( PM10 or PM2.5)
• rack mounted and portable aethalometers that provide continuous measurement of
diesel particulate matter ( black carbon)
• a continuous nitrogen oxides ( NOX) monitor
• a continuous sulfur dioxide ( SO2) monitor
• the option for measuring speciated hydrocarbons as needed
The intermediate system requires 110 volts of power on each side of the roadway. Space
is required to mount the transmitter and receiver high enough to send a light beam
through the truck exhaust. Equipment can be mounted either from vertical beams on the
side of the pole barn, or from the inside ceiling of the structure. Roof options are
discussed in more detail in Section 5. A sample collection hood could also be mounted
from the ceiling of the pole barn to capture truck exhaust for more extensive component
measurement ( e. g. air toxics or HAPs). The building could easily accommodate
additional equipment and personnel, if desired, for special studies.
A cost estimate for each system is presented in Section 5.
Section 5
Cost Estimate
One of the requirements for this research study is to develop a conceptual cost estimate of
an ideal HDRS testing program for cross- border truck emissions at a LPOE. This section
provides information on the cost estimating methodologies that were used for this study,
identifies some of the assumptions and decisions that were utilized, and provides a cost
estimate for each data plan that was discussed in Section 5.
5.1 Cost Estimating Methodology
In the field of cost engineering, there are several types of cost estimates. In most cases,
the type of estimate reflects the amount of data and other information that is available at
the time. A brief description is provided of three cost estimating techniques that were
considered for this study, and are used uniformly within the engineering and construction
industries. Two other cost estimating techniques were also reviewed - budget cost
estimate and detailed construction estimate - however, they are beyond the scope of this
project. The cost descriptions were provided by Industrial Cost Engineering23.
5.1.1 Order- of- Magnitude or Ball Park Estimate
A limited amount of information is used to develop this type of " ball park estimate." The
estimate is prepared from in- house data available from past jobs or similar projects. From
these actual jobs, the proposed plant or equipment is scaled to derive new cost data sets
that are then adjusted for inflation. A cost estimate determined in this way is only valid
for a similar plant or equipment. The accuracy of this type of estimate is highly
dependent upon the scope and time allotted to its preparation. This estimate has a
probable accuracy of about - 50% to + 50%, or worse.
5.1.2 Factored Estimate
A factored estimate requires the identification of a price for each process or individual
type of analytical equipment. This estimate is produced by taking the cost of individual
types of equipment, and multiplying it by an " installation factor" to arrive at the Total
Direct Equipment Cost. The process installation factors include all subcontracted costs
plus all of the associated direct field labor and bulk materials that are required to install
these items. These " installation factors" produce the Total Direct Equipment Costs only.
Adjustments must be made to the estimate for offsite facilities, extensive piling, unusual
site conditions, long runs of interconnecting piping/ conduit, etc. The accuracy of this type
of estimate depends on the definition of scope, equipment costs, and known equipment
and site factors. This estimate has a probable accuracy of - 25% to + 30%.
5.1.3 Study or Preliminary Estimate
This type of cost estimate is prepared after the technical staff has completed the
conceptual design, the equipment list by size and category, the preliminary process flow
diagrams, and engineering design is 1% to 10% complete. The following documents
serve as the basis for this type of estimate:
• reasonably defined equipment list by size and category, including onsite and
offsite equipment.
• preliminary overall plot- plans.
• known general site conditions such as location, utility requirements, site survey,
utility distribution ( sewers, power feeders, etc.), labor productivity, availability of
skilled workers, and availability of construction materials.
• overall process flow diagrams.
Industrial building estimates are derived from quotations or approximated from their size
and type of construction. Equipment is priced via cost curves or six- tenths factors. If the
cost information is not available, outside price quotations are solicited from vendors by
telephone or correspondence. The total direct cost of the project is derived from
quotations or in- house information on equipment and bulk material costs including labor
hours and costs. The total indirect cost is determined by applying a factor to the direct
cost. Labor and installation of material costs are obtained from ratios based upon
experience from past projects of similar type. To arrive at the total project cost, the
following items must be added: start- up, land, supervision and overhead, escalation,
adjustment for labor productivity, building, and site development, if applicable. In some
cases, it's not possible to use factors for offsite facilities. A more detailed estimate will be
The accuracy of this type of estimate depends upon the definition of scope and the time
allotted to its preparation and is most probably between - 15% to + 20%.
5.2 Cost Information, Assumptions, and Issues
Price quotes for the analytical equipment were obtained from established vendors in the
emissions measurement equipment market and by contacting a consultant who performed
a similar and recent study near the Arizona- Mexico border. Installed costs were either
included with equipment cost ( based on previous study), or a dollar value for labor cost is
provided separately for equipment installation.
5.2.1 Operation and Maintenance Costs
Capital equipment for an HDRS emissions measurement system must be installed,
commissioned, and maintained to ensure the quality of the data that is captured and
integrity of the operating system. Each of the HDRS emissions measurement systems that
are proposed require a trained technician to operate. Each system will require more labor
the first year of installation and commissioning.
Outside of the installation and commissioning stage, ongoing operations for an HDRS
Emissions Measurement System will require the knowledge and skill of experienced
employee( s) or contractor( s). At this time, due to the limitations of staff with the
specialized skills and experience within ADOT, and the limited activity at the border by
ADEQ personnel, a contractor may be the most likely choice to fill this position. For each
alternative considered, a contract labor rate of $ 75.00 per hour per full- time- equivalent
( FTE) is assumed.
Each system will also require electricity, phone or other data communications medium,
calibration gases, travel related expenses, and other expenses such as stationery and
office supplies to maintain operations.
5.2.2 Cost for Roadway Steel Structure
Two renderings of a proposed design for the pole barn or roadway ramada are provided
in Appendix 2. The Orlando Ramada has a gable roof ( two- sided). The Mesa Ramada
has a hip roof ( four- sided). Either structure can be used for the installation. However, the
Mesa Ramada appears to provide additional depth in the roof section by raising the height
that equipment can be mounted from. This design also provides for better venting of the
diesel exhaust through the center and top of the roof.
The Mesa Ramada is about 20% more expensive to construct than the Orlando Ramada.
5.3 Data Plan Cost Estimates
Stated earlier, a conceptual cost estimate is required for this research study. However,
numerous elements of the data gathering process for the development of a cost estimate
are more reflective of the " study estimate" defined in Section 5.1. Price quotes were
obtained from equipment vendors. A former contractor for an ADEQ emissions study
was consulted, and ADEQ's emissions monitoring unit staff were consulted for input in
developing the cost estimates.
5.3.1 Basic HDRS Emissions Measurement System Cost Estimate
The cost estimate for the Basic HDRS Emissions Measurement System is based on the
use of an AccuScan ™ 4000 at the Nogales- Mariposa LPOE. This option proposes to test
all heavy duty diesel vehicles ( HDDV) that cross the border five ( 5) days per week for 50
weeks per year with a fixed RSD installation or station. It is proposed that the emissions
measurement system and monitoring station be placed near the exit of the Commercial
Road for the proposed expansion layout of the Nogales- Mariposa LPOE ( Figure 3).
One spare RSD will be maintained at the site to maximize the up- time of the monitoring
station. This option assumes one contracted full- time equivalent ( FTE) will work an 8-
hour day five days per week for 50 weeks each year. One- half FTE from ADEQ is
recommended to ensure that the department has familiarity with the equipment, site
operations and issues, and regularly reviews the data and other information collected as a
part of the State of Arizona's monitoring network. It is also assumed that the maximum
level of effort in labor hours will be required by ADEQ and contract personnel during the
first year of installation, start- up, and operation of all proposed monitoring systems.
Operations and maintenance ( O& M) costs were developed based on similar activities for
the Cross Border In- Use Emissions Study for Heavy Duty Vehicles, Nogales, Arizona24
and operating costs reported by ADEQ staff for air quality monitoring stations.
Assumptions related to the development of the O& M costs are provided as follows:
− Contract Labor: One contractor at 2,080 hours per year for Year 1 is assumed. For
Years 2 through 5, it is assumed that the contractor will utilize 80% of the hours in
Year 1. An escalation factor of 3.5% was added to the contract labor for Years 3
through 5.
− Contractor Expenses: $ 30,000 for Year 1, 80% of the cost for Year 2, and a cost
escalation factor of 3.0% for Years 3 through 5.
− Electricity and telephone: $ 1,200 or $ 100 per month in Year 1, and a 3% cost
escalation factor for Years 2 through 5.
− Miscellaneous/ Incidental Costs: $ 1,000 for Years 1 and 2, a 10% escalation in cost
or $ 1,100 for Years 3 and 4, and a 20% escalation in cost for Year 5 or $ 1,200.
The total costs for the Basic HDRS Emissions Measurement System are estimated at
$ 1,389,254. Data for the cost estimate is provided in Table A- 2.
5.3.2 Intermediate HDRS Emissions Measurement System Cost Estimate
The cost estimate for the Intermediate HDRS Emissions Measurement System is based
on the use of an AccuScan ™ 4000 RSD at the Nogales- Mariposa LPOE. The operations
for the intermediate system are very similar to the basic system, except that two
additional pieces of equipment have been added to the monitoring station: a PM10
monitor and an aethalometer. A cost estimate for the Intermediate HDRS Emissions
Measurement System was prepared and is provided in Table A- 3. Total costs for the
intermediate system are estimated at $ 1,804,017. The annual contracted labor is projected
to increase from 1.0 to 1.2 FTE. Similar assumptions used in the basic system were used
to project O& M costs for the intermediate system.
5.3.3 Fully- Integrated HDRS Emissions Measurement System Cost Estimate
This alternative proposes to test all HDDVs five days per week for 50 weeks per year. A
roadway ramada ( or pole barn) is included with this option and will be used to mount
monitoring equipment from the roof of the structure. This system also includes several
portable structures: an equipment shelter, a portable equipment unit for mobile
monitoring, and an office building for personnel.
The system design proposes the use of two fixed RSDs, one as a spare unit, installed to
enhance capture and characterization of each passing vehicle. More than likely this
equipment will be mounted from the roof of the pole barn. A PM10 monitor and a fixed
aethalameter will also be included in the equipment inventory. With the increase in
equipment, an additional data- logger has been added as a backup and to ensure data
capture for all emissions that will be measured.
The fully- integrated system includes the use of one mobile unit for part- time use at
remote locations. The mobile unit will include an RSD, a portable aethalometer, a NOX
analyzer and an SO2 analyzer. The addition of an office building has also been done to
assist the onsite workers in completing their data gathering and analysis, record keeping,
and communication tasks.
This option assumes the use of 1.5 contract FTEs working eight hours per day, five days
per week for 50 weeks per year. As expected, with more equipment and personnel, the
fully- integrated monitoring station is the most costly of the three proposed HDRS data
collection systems. A cost estimate for the Fully- Integrated HDRS Emissions
Measurement System was prepared and is provided in Table A- 4. Total costs for the
intermediate system are estimated at $ 2,280,025.
5.4 Present Worth Costs
The total cost for each alternative – the present capital equipment costs and projected
annual O& M costs for Years 1 through 5 – was provided in Section 5.3. The present
worth of the total cost was developed for each alternative and is provided in Table 5. The
present worth reflects the equivalent value of each alternative in today's dollars. An
interest rate of 3% is assumed.
Table 5: HDRS Emissions Measurement Systems – Present Worth Cost
HDRS Emissions
Measurement System
Capital Cost and
O& M Costs
( Years 1 to 5)
Present Worth
Basic System $ 1,389,254.00 $ 1,320,828.00
Intermediate System $ 1,804,017.00 $ 1,699,646.00
Fully- Integrated System $ 2,280,025.00 $ 2,177,467.00
As expected, the present worth cost for each HDRS emissions measurement alternative is
less than the projected total cost
5.5 Future Cost Projections
A cost estimate has been developed for the three alternative systems. However, it is
beyond the scope of work for this research study to identify specific future costs for a yet
to be determined program date. It is not known if the project will be funded, and if so
when. In the event that ADOT decides to fund this program, the actual installation and
operation may occur one, two, five or more years into the future.
Some basic assumptions were made in developing future cost projections for each HDRS
emissions measurement system for one-, two-, and five- years out from Calendar Year
2008. Table 6 shows the impact of the cost of capital over time.
Table 6: HDRS Emissions Measurement Systems – Future Cost Projections
HDRS Emissions
Present Worth
( 2008)
1- Year
( 2009)
2 Years
( 2010)
Five Years
( 2013)
Basic System
Equipment $ 564,808.00 $ 564,808.00 $ 564,808.00 $ 649,529.00
O& M Costs 756,020.00 782,481.00 809,868.00 897,515.00
Total $ 1,320,828.00 $ 1,347,289.00 $ 1,374676.00 $ 1,547,044.00
Equipment $ 613,008.00 $ 613,008.00 $ 613,008.00 $ 704,959.00
O& M Costs 1,086,638.00 1,124,670.00 1,164,034.00 1,290,585.00
Total $ 1,699,646.00 $ 1,737678.00 $ 1,777,042.00 $ 1,995,544.00
Fully- Integrated
Equipment $ 1,044,524.00 $ 1,042,524.00 $ 1,042,524.00 $ 1,198,903.00
O& M Costs 1,132,943.00 1,172,596.00 1,213,637.00 1,345,581.00
Total $ 2,177,467.00 $ 2,215,117.00 $ 2,256,161.00 $ 2,544,484.00
The following assumptions were made in developing the future cost projections:
Years 1 & 2 - no change in equipment cost
- a cost escalation factor of 3.5% was added to O& M costs
Year 5: - an escalation factor of 15% was added to equipment cost
- an escalation factor of 3.5% was added to O& M costs
Historically, cost for analytical equipment does not vary from year to year. In many cases,
these costs may decrease as current technology ages or new technology is introduced. The
general assumptions in projecting future costs for the proposed alternatives is that the current
technology will be the same two years from now; however, equipment upgrades are expected
beyond that time. Labor and utility costs are expected to rise annually. A level of uncertainty
always exists in projecting future costs since the future is not here yet.
5.6 Alternate Cost Analysis - Employee Labor
At the request of the TAC, the research team developed a similar cost analysis using internal
employees in place of contractors to operate and maintain each of the three HDRS systems
proposed in Sections 6.3 to 6.5. An administrator of ADEQ was contacted to identify a
projected salary for a highly skilled FTE that would be capable of operating the sophisticated
remote sensing equipment along with the other monitors and computer systems. A projected
annual salary of $ 90,000 was quoted, which includes employee benefits, and is based on the
2008 calendar year. 25
5.6.1 Alternate Cost Analysis - Basic HDRS Emissions Measurement System
The alternate cost estimate for the Basic HDRS Emissions Measurement System proposes the
same equipment and operating schedule as in Section 6.3.1. One FTE will be used to operate
and maintain the monitoring station, with an assumed work schedule of 8- hour day, five ( 5)
days per week for 50 weeks each year. The FTE may be an employee of ADOT or ADEQ.
Some oversight by ADEQ is recommended to ensure that the department has familiarity with
the equipment, site operations and issues, and regularly reviews the data and other
information collected as a part of the State of Arizona's monitoring network.
O& M costs were developed based on similar activities for the Cross Border In- Use
Emissions Study for Heavy Duty Vehicles, Nogales, Arizona24 and operating costs reported
by ADEQ staff for air quality monitoring stations. Assumptions related to the development of
the O& M costs are provided:
− Employee Labor: One FTE at $ 90,000 per year for Year 1 is assumed. For Years 2
through 5, a 4% escalation factor is added for labor costs.
− Contractor Expenses, Electricity and Phone, and Miscellaneous/ Incidental Costs: no
changes are projected for these expenses.
The total costs for the Basic HDRS Emissions Measurement System utilizing in- house
employees are $ 1,194,198.
5.6.2 Alternate Cost Analysis - Intermediate HDRS Emissions Measurement System
The alternate cost estimate for the Intermediate HDRS Emissions Measurement System is
$ 1,363,176 using internal employees. The annual labor is projected to increase from 1.0 to
1.2 FTE. Similar assumptions for O& M costs that are defined in the basic system are applied
to the intermediate system.
5.6.3 Alternate Cost Analysis - Fully- Integrated HDRS Emissions Measurement System
This alternative proposes to test all HDDVs crossing the border five days per week for 50
weeks per year. All equipment identified in Section 5.3 is included in this cost analysis.
This option assumes the use of 1.5 FTEs working eight hours per day, five days per week for
50 weeks per year. Total costs for the intermediate system are estimated at $ 2,004,296.
5.7 Alternate Cost Analysis - Present Worth
The total cost for each HDRS system – the present capital equipment costs and projected
annual O& M costs utilizing employees of ADOT, ADEQ, or a combination of the two
agencies for Years 1 through 5 – was provided in Section 5.6. The present worth of the
total cost was developed for each system and is provided in Table 7. The present worth
reflects the equivalent value of each alternative in 2008 dollars. An interest rate of 3% is
Table 7: HDRS Emissions Measurement Systems
Alternate Cost Analysis - Present Worth
HDRS Emissions
Measurement System
Capital Cost and
O& M Costs
( Years 1 to 5)
Present Worth
Basic System $ 1,194,198.00 $ 1,140,349.00
Intermediate System $ 1,363,176.00 $ 1,298,892.00
Fully- Integrated System $ 2,004,296.00 $ 1,923,247.00
As expected, the present worth costs for each HDRS emissions system is less than the
total costs for capital equipment and O& M costs for Years 1 to 5.
Also, utilizing employees of the agency to perform some of the installation and all of the
O& M labor lowers the costs for each proposed HDRS system.
5.8 Alternate Cost Analysis - Future Projections
An alternate cost analysis was also performed to project the future cost, or the cost of
waiting, for each HDRS emissions measurement system for one-, two-, and five- years out
from Calendar Year 2008. Table 8 shows the impact of the cost of capital over time.
Table 8: HDRS Emissions Measurement Systems
Alternate Cost Analysis – Future Projections
HDRS Emissions
Present Worth
( 2008)
1- Year
( 2009)
2 Years
( 2010)
Five Years
( 2013)
Basic System
Equipment $ 564,308.00 $ 564,308.00 $ 564,308.00 $ 648,954.00
O& M Costs 576,041.00 596,203.00 617,070.00 684,156.00
Total $ 1,140,349.00 $ 1,160,511.00 $ 1,181,378.00 $ 1,333,110.00
Equipment $ 611,308.00 $ 611,308.00 $ 611,308.00 $ 703,004.00
O& M Costs 687,584.00 711,650.00 736,557.00 816,634.00
Total $ 1,298,892.00 $ 1,322,958.00 $ 1,347,865.00 $ 1,519,638.00
Fully- Integrated
Equipment $ 1,056,524.00 $ 1,056,524.00 $ 1,056,524.00 $ 1,215,003.00
O& M Costs 866,723.00 897,058.00 928,455.00 1,029,395.00
Total $ 1,923,247.00 $ 1,953,582.00 $ 1,984,979.00 $ 2,244,398.00
The same assumptions that are used in Section 5.5 apply here.
Section 6
Conclusions and Recommendations
Research of HDRS emissions measurement equipment and technology was undertaken to
develop a design and cost estimate for an emissions monitoring station at an Arizona
LPOE. Field tests of HDRS emissions measurement equipment and data were reviewed
and cost data were requested from several equipment vendors. ADEQ staff and
consultants were also contacted for cost data and other information.
6.1 Conclusions
Emissions measurement systems and programs for light- duty vehicles are well defined in
the literature and demonstrated within the Arizona, nationally and globally. Most of these
systems rely on an I& M program that is tied to a vehicle registration program. In the
U. S., most states use the SAE J1667 snap- acceleration test to measure gaseous pollutants
and opacity. A cup- like device is used to capture emissions from the vehicle's exhaust
prior to screening by equipment.
Unlike I& M programs, remote sensing is the measurement or acquisition of information
about an object by a recording device that is not in contact with the object. An RSD can
be designed to estimate emissions from heavy duty vehicles. As an example, the HDRS
technology used for the Nogales, AZ border study utilized both ultraviolet and infrared
light beams to instantaneously measure HC, CO, NOX, and PM2.5 from heavy duty truck
exhaust. Although HDRS emissions measurement is not used on a large scale, the
technology has been around for about 15 years and its efficiency continues to improve.
HDRSD is still an emerging technology although significant advances have been made
over the last 10 years. HDRSD technology has performed well as an emissions screening
tool, but has not been used as a primary emissions program. Identifying deployment and
set- up strategies for varying truck traffic continues to be a challenge. One such challenge
is the varying height and location of the exhaust muffler on many heavy duty diesel
The review of the literature identified numerous vendors of emissions measuring
equipment in the market place. However, when the criteria is narrowed to vendors
providing remote sensing equipment, especially instruments designed to measure
emissions from heavy duty diesel engines, the field is narrowed to a handful of suppliers.
Three alternatives were developed for a HDRS emissions measurement system data plan:
− Basic: this is a bare- bones monitoring system that includes HDRS emissions
measurement equipment with data collection and communication.
− Intermediate: this system builds on the basic system by including particulate
monitoring equipment and an aethalometer to measure diesel particulates.
− Fully- integrated: this system is the most robust of the alternatives and provides for a
stationary monitoring system ( proposed in the basic and intermediate set- up) as well
as a portable monitoring unit.
Cost data were developed for each alternative and includes figures for capital equipment
installation and five years of O& M expenses. The present worth costs for each data plan
utilizing contract labor ranged from $ 1,320,828 to $ 2,177,467. If employees of ADOT or
ADEQ are used, the present worth costs range between $ 1,140,349.00 and $ 1,923,247.
While it is obvious that the use of employees is less expensive than contract labor, the
agency could find it difficult to attract highly skilled employees for a proposed HDRS
emissions measurement program at the Arizona- Mexico border.
ADOT has not stated that it will install an HDRS emissions monitoring station at an
Arizona LPOE. However, traffic has increased at the border for all vehicle types: POVs,
buses, and large trucks. The increase in border crossings over the years along with the
need for more secure border stations has prompted the federal GSA to approve a
modernization and renovation construction project for the Nogales- Mariposa LPOE. Bids
are being solicited for the construction project, estimated at $ 100 to $ 150 million.
Construction is expected to begin in 2009.
6.2 Recommendations
6.2.1 Partner with ADEQ
ADOT can partner with ADEQ to determine if an HDDV monitoring program is
warranted at the border at this time. ADEQ has an established air quality monitoring
program throughout the state and has trained staff, equipment, and facilities to support
the program. Also ADEQ may have planned or mandated needs to measure air quality at
or near the U. S.- Mexico border as a part of the State Implementation Plan ( SIP). A
partnership between the two agencies will provide for coordinated work efforts, possibly
shared costs for equipment and staffing, and better use of resources within each agency.
ADEQ, or ADEQ and ADOT jointly, may be eligible for grant funding to establish a new
monitoring program at the Arizona border.
More than likely truck traffic across all U. S- Mexico LPOEs will increase. In February
2007, the Secretary of the U. S. DOT announced the beginning of a cross- border trucking
pilot program between the United States and Mexico. Since 1982, Mexican trucks have
been restricted to the border commercial zones in California, Arizona, New Mexico, and
Texas. 26 The new cross- border pilot program has been vocally opposed by a number of
groups, however as of this report's date, the program is still in- place. Increased traffic at
the LPOEs will lead to increased pollution.
ADEQ is responsible for the state's motor vehicle I& M program. Adding a vehicle
emissions monitoring station at the border, other than as a pilot program for clean
screening, would need to adhere to the existing regulations, policies and procedures that
are in- place. Utilizing an HDRS emissions measurement system as a gross emitter
screening program may also be an effective control strategy although the current program
is based on Arizona license plates only.
6.2.2. Implement Screening Program
Due to current limitations with the emerging HDRSD technology, ADOT may consider
pursuing an emissions screening program for heavy duty diesel trucks at one of its
LPOEs. The proposed screening program may operate during the peak season ( October to
May) when truck traffic is at its maximum. In this way, enough trucks are screened, but
not all trucks are screened. Continued screening and testing of HDRSD technology and
equipment by ADOT, ADEQ, and other organizations will eventually resolve many of
the current challenges associated with the deployment and set- up strategies for varying
truck traffic. Improved emissions measurement is certainly expected to be one objective
of an HDRSD program.
6.2.2 Seek Program Funding.
The results of the research show that installing an HDRS emissions measurement system
at the border is not an inexpensive project. As stated earlier, grant funding may be
available to install and operate a HDDV clean screen program. The Arizona Legislature
may also be petitioned as a funding source for a project of this type.
A vehicle entering the U. S. through an LPOE is assessed a duty or fee. Table A- 5
( Appendix 4) provides a list of current fees at all U. S. border facilities. ADOT should
investigate the option of assessing a fee on HDDVs entering the LPOE, or adding a
surcharge on gross emitting vehicles that enter the U. S.
1. M. J. Bradley & Associate. A Menu of Options: Controlling Fine Particulate Matter
under the Clean Air Act. STAPPA/ ALAPCO, March 2006.
2. United States. Environmental Protection Agency. Office of Transportation and Air
Quality. Regulatory Announcement: Heavy Duty Engine and Vehicle Standards and
Highway Diesel Fuel Sulfur Control Requirements. EPA420- F- 00- 057. Washington,
D. C. , December 2000.
3. GovTrack. us. H. R. 5314 / S 2842-- 108th Congress ( 2004): Clean Trucks Act of
2004, GovTrack. us ( database of federal legislation)
< http:// www. govtrack. us/ congress/ bill. xpd? bill= h108- 5314& tab= related> ( accessed
Sep 29, 2008)
4. United States. Environmental Protection Agency. Office of Transportation and Air
Quality. Voluntary Diesel Retrofit Program. www. epa. gov/ otaq/ retrofi
t/ retroverifiedlist. htm. Last viewed March 11, 2007.
5. United States. Environmental Protection Agency. " 1970- 2002 Average Annual
Emissions, All Criteria Pollutants," National Emissions Inventory ( NEI) Air
Pollutant Emissions Trends Data, July 2005.
www. epa. gov/ ttn/ chief/ trends/ index. html, last viewed march 11, 2007.
6. Cross, Thomas, " Remote Sensing Technology" presented at the Better Air Quality
Motor Vehicle Control & Technology Workshop, 2000.
7. The Good Neighbor Environmental Board. Ninth Report to the Good Neighbor
Environmental Board to the President and Congress of the United
States. Washington, D. C., March 2006.
8. School of Law website, Duke University – on NAFTA.
http:// www. law. duke. edu/ lib/ researchguides/ nafta. html, last viewed March 11, 2007.
9. California Air Resources Board.). Air Quality Concerns Relating to the North
American Free Trade Agreement ( NAFTA) and Free Commercial Vehicle Travel in
California – Report to the California Legislature. Sacramento, Calif., January 2006.
10. NAFTA/ Mexican Truck Emission Overview. Sacramento, California., November 12,
2004, Revised January 21, 2005.
11. Gardner, Michael. " A surge in smog over the long haul: Coming influx of Mexican
trucks ' serious.'" The San Diego Union- Tribune, March 15, 2006.
12. Phone conversation with staff member at the Air Quality Bureau, New Mexico
Environmental Department, February 2007.
13. Phone conversation with staff member at the Texas Commission on Environment,
February 2007..
14. Phone conversation with staff member at the El Paso Metropolitan Planning
Authority, February 2007.
15. United States. Environmental Protection Agency/ Mexico. Secretaría de Medio
Ambiente y Recursos Naturales. Advancing US- Mexico Border 2012 Air Policy
Forum Priorities. October 7, 2005.
16. Stedman, Donald, H., " On- Road Remote Sensing of CO and HC Emissions in
California", University of Denver, Feb 1994.
17. Kazimi, Camilla; Felipe Cuamea, Juan Alvarez, Alan Sweedler, and Matt Fertig,
" Emissions from Heavy- Duty Trucks at the San Diego – Tijuana Border Crossing",
San Diego State University, Universidad Autonoma de Baja California, 1997.
18. Morris, Jerome, et. al, " On- Road Remote Sensing of Heavy- duty Truck Emissions in
the Austin- San Marcos Area", University of Denver, August 1998.
19. Santa Barbara Research Center, " Smog Sensor Detects Pollution- Prone Cars",
Journal of Air & Waste Management Association ( AWMA), April 1999.
20. General Services Administration, Public Buildings Service, Property Development
Division Pre- solicitation Notice, November 14, 2007. San Francisco, Calif., 2007.
21. AZTEC Engineering Arizona. Nogales Mariposa U. S. Port of Entry: Draft
Environmental Assessment, Nogales, AZ. United States. Government Services
Agency, September 27, 2007.
22. Meeting with Jim Fraser of Arcadis, January 17, 2007, in Tucson, Arizona.
23. Industrial Cost Engineering, " Process Cost Estimating", www. costestimating. com,
last viewed March 11, 2007.
24. Vescio, Nirajan, et. al., " Heavy- Duty Remote Sensing Demonstration Project in
Nogales: Cross Border In- Use Emissions Study for Heavy Duty Vehicles, Nogales,
AZ." prepared for ADEQ and USEPA, Final Report, June 2006.
25. Conversation with Ira Domsky, Deputy Director, Arizona Department of
Environmental Quality, March 19, 2008.
26. U. S. DOT News Release. Cross Border Truck Safety Inspection Program. Remarks
by the Honorable Mary E. Peters, Secretary of Transportation, El Paso, TX,
February 23, 2007.
27. United States Customs and Border Protection, http:// www. cbp. gov, last viewed
March 11, 2007.
Appendix 2
Roadway Steel Structure Design Options
Figure A- 1: Roadway Steel Structure – Orlando Design
Appendix 2
Roadway Steel Structure Design Options
Figure A- 2: Roadway Steel Structure – Mesa Ridge Vent Design
Appendix 3
Cost Data Sheets
Appendix 4
U. S. Custom and Border Patrol Fee Schedule
Table A- 5: Summary of New Fee Rates27
CUSTOMS DUTIES Old Fee Rates
Prior to April 1, 2007
( Unit Fee/ Annual Cap)
New Fee Rates
On/ After April 1, 2007
( Unit Fee/ Annual Cap)
Commercial Vessels $ 397.00/$ 5,955 $ 437.00/$ 5,955
Commercial Trucks $ 5.00/$ 100.00 $ 5.50/$ 100.00
Railroad Cars $ 7.50/$ 100.00 $ 8.25/$ 100.00
Private Aircraft ( Decal) $ 25.00 $ 27.50
Private Vessel ( Decal) $ 25.00 $ 27.50
Commercial Aircraft
Passenger ( User Fee)
$ 5.00 $ 5.50
Commercial Vessel
( User Fee- Non Exempt)
$ 5.00 $ 5.50
Commercial Vessel
$ 1.75 $ 1.93
Dutiable Mail $ 5.00 $ 5.50
Broker Permit $ 125.00 $ 138.00
Barges and other bulk carriers $ 100.00/$ 1,500 $ 110.00/$ 1,500
Reference: United States Customs and Border Protection
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Butterfly's Kiss: Aquamarine Ring
Within the silence of a darkened room you can almost hear the gentle movement of the wings of the butterflies which embellish each shoulder of this late Art Deco ring well suited for a feminine hand. Flattered by a medium pale blue marquise cut aquamarine of an estimated 1.25 carats, the 14k white gold setting harmonizes with the style and design.
Date: Circa 1930.
Measurements: 11/16 of an inch (1.8 cm) in length north to south on the hand and rises just shy of 3/16 of an inch (0.4 cm) in height off the finger. Weight of 2.2 grams (1.4 dwt).
Ring Size: US 6 (UK L-1/2; Euro or Int. Circum. 51.8 mm, Japan 11; Int. Dia. 16.5 mm) and easily can be sized to fit most. Ring sizing information.
Hallmarks: 14k.
Condition: Excellent.
Origin: American.
Note: Stone has not been removed from mount to preserve the integrity of the setting. Stone weight has been approximated by measurement and formula and may vary from actual weight.
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Our Guarantee
If for any reason whatsoever you are not completely satisfied with your purchase, we will refund the FULL purchase price including U.S. shipping if charged. Remember, there is no charge for our regular shipping service!
International Orders - Due to customs and paperwork requirements, return shipping charges cannot be reimbursed.
Return Procedure
- Notify us of your intention to return the item within three (3) days of receipt. You may contact us by email or by telephone.
- Please ship back to us within another two (2) days after we receive notification from you.
- As soon as the item is received, a full refund is issued to you that same day.
More details at Full Guarantee including gift giving options.

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