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Breakout Session: Transportation Conformity/Air Quality Recent Developments in Transportation Conformity Beverly Chenausky Multimodal Planning Division – Air Quality Overview • • • • Overview of Transportation Conformity Recent Changes to Existing Requirements Overview of Guidance Documents Summary and Additional Resources Overview Transportation Conformity • Clean Air Act section 176(c) – Requires that federally supported transportation projects in nonattainment and maintenance areas cannot: • Cause or contribute to new air quality violations, • Worsen existing violations, or • Delay timely attainment of the NAAQS or interim milestones (National Ambient Air Quality Standards) • Transportation conformity rule (40 CFR Part 93) Where Transportation Conformity Applies Transportation Budgets - Nonattainment Plan Emissions Inventory in Anytown's Nonattainment Plan for Any pollutant 8 Tons 25 Tons 35 Tons 32 Tons This piece of pie becomes the “budget” for transportation plans. The RTP/TIP must show if implemented emissions will not be greater than 35 tons. Area Point Mobile Other MVEB – Motor Vehicle Emissions Budget SIP – State Implementation Plan SAFETEA-LU Conformity Rule Changes Clean Air Act Section 176 (40 CFR Part 93) Changes Jan 24, 2008 • • • • • Conformity redetermination Frequency of conformity determinations Time Horizons for Conformity Conformity Lapse Substitution of Transportation Control Measures (TCMs) Inclusion of criteria and procedures Conformity - State Implementation Plan (SIP) • Describes how a state will meet the requirements of the Conformity Rule. • At a minimum, the conformity SIP must include three requirements of the conformity rule: – Consultation procedures (40 CFR 93.105) – Written commitments to control measures (40 CFR 93.122(a)(4)(ii)) – Written commitments to mitigation measures (40 CFR 93.125(c)) Summary of Conformity Rule Changes after SAFETEA-LU March 24, 2010 approved changes August 13, 2010 proposed changes ** New Emissions Model § 93.101 Definitions. § 93.105 Consultation. § 93.109 Criteria and procedures for determining conformity of transportation plans, programs, and projects: General. § 93.111 Criteria and procedures: Latest emissions model. ** § 93.116 Criteria and procedures: Localized CO, PM10, and PM2.5 violations (hot-spots). § 93.118 Criteria and procedures: Motor vehicle emissions budget. § 93.119 Criteria and procedures: Interim emissions in areas without motor vehicle emissions budgets. § 93.121 Requirements for adoption or approval of projects by other recipients of funds designated under title 23 U.S.C. or the Federal Transit Laws Recent Conformity Rule Changes • Proposed Rule: Transportation Conformity Rule Restructuring Amendments - August 13, 2010 – Streamlines definitions to be applicable to all NAAQS – Restructures two sections of the conformity rule, 40 CFR 93.109 and 93.119 – Expand clean data flexibility to all NAAQS where EPA has clean data regulations or policies – Includes hot-spot conformity tests for PM10, PM2.5, CO – Would require consistency with budgets for budget years, and each year that a regional emissions analysis is done – Would remove specific baseline years and change definition for “baseline year” and future baseline years in proposed 93.119(e) Changes in How a Conformity Analysis is Done • Latest Emissions Models § 93.111 • EPA introduced MOtor Vehicle Emission Simulator (MOVES) to replace Mobile6.2 prior emissions model released March 2, 2010 for regional conformity required March 2, 2012. – There may be a one year extension unknown at this time?? – MOVES requires different sources of data that may not currently be available, consultation on data assumptions is critical. – Example: In MOBILE6.2, emission factors were expressed in grams per mile and related to VMT. In MOVES emissions are related to the population of vehicles in an area. Because vehicle population directly determines start and evaporative emission, users must develop local data for this input. Changes in How a Conformity Analysis is Done • MOVES official use for quantitative CO, PM2.5, and PM10 hot-spot analyses released December 20, 2010 required by December 20, 2012. – Prior PROJECT level analysis for PM did not require a quantitative analysis or modeling see EPA hot-spot analysis guidance for both CO and PM10/2.5. • EPA also approved use of new emission factors for transportation conformity. AP 42, Fifth Edition, Volume I Chapter 13.2.1 Reintrained Road Dust emissions for Paved Roads released February 4, 2011 required by February 4, 2013. – Significantly lowers emissions from older version – Unpaved roads Chapter 13.2.2 has not changed since 2006. Changes in How a Conformity Analysis is Done Draft PM hot-spot guidance released for public comment May 26, 2010 What is a hot-spot analysis? • An estimation of likely future localized pollutant concentrations and a comparison to the relevant NAAQS – Required for certain projects in PM2.5, PM10, and CO nonattainment and maintenance areas. – The area substantially affected by the project (the “project area”) • In general, a PM hot-spot analysis compares Air Quality concentrations with the proposed project (the build scenario) to Air Quality concentrations without the project (the no-build scenario) – In practice “quantitative” analysis is a complex process AP-42 Monitoring + Modeling CAL3QHCR or AERMOD Things to Think About • Does current process meet all the requirements? – Learn the guidance documents and regulations • Does current staff have necessary tools and resources to meet these requirements? – Training for internal staff or additional costs for external help • Where can data gaps be improved? – Regional vehicle classification or count programs http://www.epa.gov/otaq/stateresources/ http://www.epa.gov/otaq/stateresources/transconf/index.htm MVEB http://www.fhwa.dot.gov/environment/air_quality/conformity/ Breakout Session: Transportation Conformity/Air Quality ???’s