recent developments in transportation conformity beverly chenausky multimodal planning division –...
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Recent Developments in Transportation Conformity
Beverly ChenauskyMultimodal Planning Division – Air Quality
Breakout Session: Transportation Conformity/Air Quality
• Overview of Transportation Conformity
• Recent Changes to Existing Requirements
• Overview of Guidance Documents
• Summary and Additional Resources
Overview
• 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)
Overview Transportation Conformity
Where Transportation Conformity Applies
Transportation Budgets - Nonattainment Plan
Area
Point
Mobile
Other
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.
35 Tons
32 Tons
25 Tons
8 Tons
Emissions Inventory in Anytown's Nonattainment Plan for Any pollutant
MVEB – Motor Vehicle Emissions BudgetSIP – State Implementation Plan
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
SAFETEA-LU Conformity Rule Changes
• 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))
Conformity - State Implementation Plan (SIP)
Summary of Conformity Rule Changes after SAFETEA-LU
§ 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
March 24, 2010 approved changesAugust 13, 2010 proposed changes** New Emissions Model
• 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)
Recent Conformity Rule Changes
• 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
Changes in How a Conformity Analysis is Done
AP-42
CAL3QHCR or AERMOD
Monitoring + Modeling
• 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
Things to Think About
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/
???’s
Breakout Session: Transportation Conformity/Air Quality
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