Request for Input on Potential Transportation Control Measures: Part of a Reasonably Available Control Measures Process for the Sacramento Federal Ozone Non-Attainment Area
August 3-August 12, 2022


SACOG is requesting ideas for potential Transportation Control Measures (TCMs) that could be implemented in the SACOG nonattainment area for ozone. TCMs are strategies to reduce motor vehicle trips, vehicle miles traveled, or vehicle idling and the associated air pollutant emissions. Identification of control measures is a requirement of reasonably available control measures (RACM) under the Federal Clean Air Act, §172(c)(1) and is required for nonattainment areas with an ozone classification of moderate nonattainment and above. Potential RACM measures submitted to SACOG will be considered in nonattainment area planning for the 2015 eight-hour ozone national ambient air quality standards. The deadline to submit TCM-RACM ideas is August 12, 2022.

When submitting ideas:

  • Describe technical and economic feasibility for each RACM idea;
  • Provide as much detail and technical information as possible;
  • Specify whether the measure is a volatile organic compounds (VOC), nitrogen oxides (NOX), or VOC and NOX strategy;
  • Provide a copy, Web link, or citation for suggested rules when possible;
  • Identify any confidential information; and 
  • Explain feasibility information provided on a dollar per ton of pollutant basis.

Submit ideas to Renee DeVere-Oki at

What is RACM?

Under the Clean Air Act, all areas designated Severe nonattainment for the 2015 8-hour ozone standard are required to implement RACM for point, area, off-road, and on-road source categories. SACOG conducts a RACM process/analysis in conjunction with the regional air districts and focuses on on-road sources. RACM implementation is necessary so attainment can be demonstrated as expeditiously as practicable. The purpose of the RACM process/analysis is to determine if implementation of all the measures, cumulatively, could advance the attainment date by a year. Control measures that have been implemented at the federal level, in other states, and in other local air districts must be considered. The general approach to RACM includes the following steps:

  1. Identify potential control measures
  2. Evaluate control measures to determine if they are feasible
  3. Determine if implementation of all control measures could advance attainment by a year.

 A RACM analysis determines potential control measures for each source category considering the following requirements:

  • Technological feasibility of the control measure
  • Economic feasibility of the control measure
  • If the control measure would cause substantial widespread and long-term adverse impacts
  • If the control measure is absurd, unenforceable, or impracticable
  • If the control measure can advance the attainment date by at least one year



Based on comprehensive review and analysis, the TCMs that were determined to be feasible are either being implemented or have been implemented in the SACOG Region. The TCMs determined to be infeasible did not meet the criteria for RACM because of the individual reasons provided in the analysis. All feasible TCMs in SACOG region are included in our metropolitan planning organization’s Metropolitan Transportation Plan (MTP) and Federal Transportation Improvement Program (FTIP). Thus, their emissions reductions are already included in the baseline emissions used for the AQMD/SIP modeling. SACOG may not claim emission reductions separately from TCMs that have already been included in the SACOG MTP and FTIP unless there are substantive changes in scope or timing.