Even as the U.S. EPA distances itself from enforcement of the Employee Commute Options requirements of the Clean Air Act, Metropolitan Planning Organizations (MPOs) face an interesting challenge in designing and implementing transportation control measures that will not only clean the air and reduce traffic congestion, but will also satisfy the ambient air quality standards of the Clean Air Act.
To reduce the air pollution contribution of mobile sources, several metropolitan planning organizations are turning to employer-based trip reduction measures patterned after California’s Regulation XV, partly because it is available “off-the-shelf,” partly because of claims regarding its success made by some Southern California regulators, and partly because the EPA has only recently backed away from enforcement of Employee Commute Options requirements, and it was only one of a few historically acceptable methods of satisfying that requirement. The full story of Regulation XV’s failings is still being written, however, and many metropolitan planning organizations with similar transportation control measures in the pipeline are unaware of the regulation’s dysfunctionality, high cost, and unpopularity.
Fortunately, the path blazed by Regulation XV is not the only path available to metropolitan planning organizations trying to reduce commuter vehicle emissions. Thanks to recent EPA statements regarding Employee Commute Options, and the flexibility that EPA has promised to apply in consideration of Employee Commute Option satisfaction, metropolitan planning organizations can avoid the mistakes of the past and implement transportation control measures such as congestion pricing, parking cash-out, paratransit deregulation, and fleet cleanup, each of which carry far more promise than Regulation XV ever did.
In some cases, EPA’s newly defined flexibility allows metropolitan planning organizations to implement regional measures that may minimize or alleviate the need for Employer Trip Reduction measures akin to Regulation XV altogether. In cases where such measures are still required, EPA’s newly declared flexibility allows implementation in ways that can produce vastly superior performance while providing greater flexibility to both employers and employees with regard to commuting behavior.