Report PDF - US Environmental Protection Agency

We believe it was clear in our proposal that this estimate considered the potential for reducing emissions.
Emissions estimates were calculated, as directed by EPA's grant solicitation, using the Diesel Emissions
Quantifier. We assumed one truck per parking space for each of the proposed electrified parking spaces (e.g.,
100 parking spaces provides the opportunity to reduce emissions from 100 trucks per day x an estimated 250
days per year). We believe this is a reasonable estimate of the potential emissions that could be reduced
through truck stop electrification.
As noted in the OIG draft report, upon EPA's request, TDOT updated expected project results in its Final
Report using the actual number of TSE spaces installed and the same assumptions used to calculate the initial
estimated outcomes under the Cooperative Agreement. EPA accepted TDOT’s final report on March 19, 2012.
As TDOT noted in the final report, actual emission reductions will depend on the idling emission rate of
heavy-duty truck engines and the hours of truck idling that are avoided through truckers' use of the TSE
equipment.
TDOT understands OIG's concern about the accuracy of calculating emissions benefits based on the use of
installed facilities rather than operable facilities. For the purposes of the Final Report, however, we believe that
including installed TSE spaces in the calculations of potential emissions reductions was reasonable.
As recommended by the OIG, TDOT is willing to work with EPA staff to modify the estimates of
project results based on actual usage or a revised assumption of anticipated usage.
OIG Response 9: The OIG acknowledges TDOT’s comments and understands the basis for
the calculations. However, the OIG continues to maintain that unless TDOT can demonstrate
a significant increase in usage of TSE facilities, project results will remain significantly
If overstated. you have any The questions, OIG commends please feel TDOT’s free to willingness contact me to at 615-741-6832 work with EPA or staff at alan.jones@tn.gov.
to modify the
estimates based on actual usage or a revised assumption of anticipated usage.
Sincerely,
Alan D. Jones
Manager, Policy Office
Long Range Planning Division
cc:
Brian Carroll
Chris Christianson
Tanisha Hall
Mel Marcella
Toks Omishakin
John Reinbold
Linda Tidwell
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