Transportation Conformity and Development of Emission Budgets

We will cover the following topics:

CAA Transportation Conformity Regulations

Development of Emission Budgets

What are our objectives?

What Is Conformity?

• Established by the Clean Air Act

• Requires governments to evaluate emissions from planned federal or federally funded projects BEFORE they are built

• Applies in ozone, CO, PM-10 and NO2 areas designated as nonattainment or maintenance

Conformity: Transportation vs. General

• Transportation conformity applies to federal highway and transit actions

• General conformity applies to all other federal actions (e.g. airports and railroads)

Transportation Conformity: What pollution does it address?

StationarySources

Transportation/On-Road Mobile Sources

AreaSources

Off-Road Mobile Sources

Transportation Conformity…covers just one piece of the pie...

• Transportation conformity addresses air pollution from on-road mobile sources.

• On-road mobile sources are emissions created by cars, trucks, and transit.

What Transportation Actions are Subject to Conformity?

• Transportation plans (20-year timeframe)

• Transportation improvement programs (TIP) (3-year timeframe)

• “Federal” projects

– projects receiving federal funding

– projects receiving FHWA/FTA approval

• Regionally significant State projects are partially affected

Transportation Conformity: A Link Between Air Quality and Transportation

Planning

State Implementation Plan (SIP)

Transportation Plan andTransportation Improvement

Program (TIP)

Conformity

SIP Elements

• Inventory of emissions estimates for each sector (stationary, area, mobile)

• Air quality modeling

• Demonstration of SIP’s purpose

• Specific list of controls

• Contingency measures (maintenance areas)

• SIPs contain motor vehicle emissions budgets (“budgets”)

• SIP budgets based on area’s motor vehicle inventory and control measures

• Budgets important for conformity because used in regional emissions analysis

• Budget test: emissions from planned transportation system < budget– budget = ceiling on emissions of that pollutant /

precursor

SIP MV Budgets

Adequacy Review of Budgets

• SIP budgets must be adequate before used for conformity

• Conformity rule (93.118(e)(4)) describes adequacy criteria– these criteria are similar to those for SIP

approval• Positive adequacy finding does not guarantee

approvability of SIP

Adequacy Criteria

Governor EndorsementPublic Hearing Interagency consultation and full documentation EPA concerns addressedControl measures achieve air quality goals (RFP,

attainment, maintenance)

Adequacy Criteria

Emissions budget(s) clearly identified and precisely quantified in the SIP

Budget is consistent with emissions inventory/control measures

Revisions to previously submitted SIPs are explained

EPA will review public comment from state’s public hearing

Adequacy Process

• Approximately 90 day process• State submits SIP to EPA • EPA announces receipt of SIP on website, 30-day public

comment period started• EPA makes adequacy/inadequacy finding

• Respond to any comments

• Send letter to state

• Post finding on web

• Issue a Federal Register notice (FRN)

• Finding effective 15 Days after FRN in most cases