Air Quality, Transportation Conformity, and the FSTIP FTIP/FSTIP Workshop February 9, 2016

The Linkage between Air Quality and Transportation Health-based National Ambient Air Quality Standards (NAAQS) established for CO, Ozone, NO2, SO2, PM10 and PM2.5 (criteria pollutants) ▫On road motor vehicles contribute significant amounts of the emissions inventory ▫US EPA designates areas that violate a NAAQS as nonattaiment. Areas that do not meet the NAAQS are subject to planning requirements under the Clean Air Act including…. 2

Transportation Conformity Section 176(c) Clean Air Act Conformity: A basic definition Decisions on federal aid or approval for transportation plans, programs and projects must support achievement of federal air quality standards (i.e. NAAQS) 3

Transportation Conformity A metropolitan planning organization (MPO) may not adopt its transportation plan or program until: ▫ Regional emissions are shown to be consistent with SIP estimates (i.e. emissions budgets) and necessary reductions ▫ Transportation plan/program provide for timely implementation of transportation control measures 4

Transportation Conformity: A recipient of federal funds may not approve a project unless ▫ It is specifically defined in a conforming transportation plan and program, and ▫ It has not changed significantly (i.e. “the project’s concept and scope”) since the plan and program were found to conform and, ▫ It creates no “hotspots” (carbon monoxide, PM) 5

Who Does What? MPOs: ▫Prepares and adopts its plan and program according to federal transportation law ▫Conformity determination part of adopted plan and program U.S. DOT (Federal Highways, Federal Transit) ▫Approves the MPO determination Air Agencies ▫Develops the SIP and its budgets U.S. EPA ▫Consultation, develops regulations and guidance. 6

State Implementation Plan (SIP) EPA designates areas as meeting (attainment) or not meeting (nonattainment) a NAAQS. The Clean Air Act (CAA) requires states to develop a general plan to attain and maintain the NAAQS in all areas of the country, and For nonattainment areas, a specific plan to attain the standards. ▫The SIP contains all the plans and rules necessary to meet the requirements of the CAA. 7

The SIP (continued) Types of SIPs ▫Includes infrastructure, attainment, maintenance, others. ▫Conformity focuses on attainment and maintenance plans  An attainment plan demonstrates through modeling that an area will make progress towards and attain the NAAQS in the timeframe established by the CAA  A maintenance plan demonstrates how an area will continue to attain the NAAQS for at least 20 years. 8

Attainment and Maintenance Plans Both contain an emissions inventory (EI) ▫The EI contains emissions from all sources, including motor vehicles ▫Levels of emissions reflect the controls necessary for attainment or maintenance ▫Used by the air quality models to demonstrate attainment/maintenance. ▫On road vehicle portion of the EI is the emissions budget 9

What has to happen? The criteria for Conformity Prepare a regional emissions analysis. ▫Budget comparison or interim test. Must use latest planning assumptions. RTP must give priority to Transportation Control Measures (TCMs) in an approved SIP. Interagency consultation and public participation. Plan and program must be fiscally constrained. 10

Interagency Consultation (40 CFR ) A collaborative process between organizations on key elements of transportation and air quality planning Includes: US DOT (FHWA and FTA), U.S.EPA, CalTrans, ARB, MPO, local transportation, transit and air agencies 11

Interagency Consultation (con’t) Goals of Interagency Consultation ▫Ensures all agencies meet regularly and share information ▫Identifies key issues early in the process ▫Strives for well-coordinated schedules for TIP/plan conformity determinations and SIP development ▫Allows collaborative decisions on methodologies, assumptions, conformity test selection, regional significance, etc. 12

Latest Planning Assumptions (LPA) In Statute: Section 176(c)(1): “…most recent estimates of emissions…” Findings based on future population, employment and travel estimates approved by the MPO Latest information on transit service, fares, ridership and control measure effectiveness Assumptions specified in conformity documentation Includes emission model assumptions (e.g. EMFAC) Includes fleet characteristics such as model year/age distribution. Does NOT include numbers of Vehicles, VMT, Trips 13

Why Would I Worry About EMFAC? What is EMFAC? ▫ARB’s “EMission FACtor” model ▫EMFAC used for regional RTP and RTIP analysis in California, and produces:  Emission Rates: grams per unit of vehicle activity by location  Emissions: Calculated with rates using regional traffic data, either default or user supplied EMFAC includes what FHWA & EPA consider “latest planning assumptions” 14

LPA (continued): FHWA/U.S. EPA Joint Guidance ▫Establishes 5 year “lifespan” for LPA ▫Motor vehicle fleet characteristics explicitly discussed ▫Use of data older than 5 years must be justified. ▫Impact on EMFAC LPA established through interagency consultation 15

Air Quality and the TIP Process Introduction ▫TIPs are a 2-4 year RTP subset  If a TIP comes entirely from a conformity Plan, the TIP is assumed to conform. ▫Detailed regional air quality analysis is generally done for RTPs, not TIPs ▫A Conformity Determination is needed for the FSTIP and (in CA) its regional FTIP components 16

What’s Needed for TIP Conformity? In principle, if the TIP is in fact a subset of the RTP, simply point that out If projects change, are added (including any regionally significant project regardless of funding), or deleted during TIP development (i.e. outside the RTP), RTP must be amended and conformity redetermined In most cases just need to show TIP-RTP consistency ▫Non-MPO areas may be exception 17

My Project(s) Changed, Now What? MPO areas: determine whether or not changes are exempt from conformity ▫40 CFR list – fully exempt ▫40 CFR list – exempt from regional analysis If exempt – say so in the TIP amendment letter ▫No significant RTP or conformity changes If not exempt, amend RTP to match TIP ▫If changes affect design concept, scope, or schedule may need new RTP conformity analysis NO CEQA FOR TIPs – applies only to RTPs and projects 18

A Few More Considerations All of the region’s latest planning assumptions should be discussed as part of the interagency consultation process when a regional conformity determination is needed. Be sure to know the analysis/milestone years associated with the region’s conformity budgets. Project changes that cross over milestone years may result in the need for new conformity analyses. Conformity Test Options: ▫Budget Test ▫Build/No Build ▫Less than Baseline 19

So... ARB updates EMFAC at not more than 5 years intervals (usually 3-4 years recently) ▫Ensures that Planning Assumptions don’t get too old ▫Allows incorporation of effects of new fleet assumptions and emission rule changes regularly Cases have occurred where an older EMFAC wasn’t replaced soon enough ▫FHWA may “lock down” conformity if this happens ▫Lockdown prevents TIP and RTP updates, and can cause conformity lapse 20

As a Practical Matter... If TIPs are consistent with the current RTP, conformity issues are unlikely unless the area is “locked down” or “conformity freeze” or in a conformity lapse MPOs do conformity; Caltrans incorporates MPO actions by reference for the FSTIP If TIPs or TIP amendments are NOT consistent with the RTP regarding non-exempt projects, new regional conformity analysis is needed – and use of latest planning assumptions 21

Questions?