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Federal Highway Administration

Transportation/Air Quality
Issues in Rural Areas

Final Report
April 2003

Prepared by
Dye Management Group, Inc.
500 108th Avenue NE, Suite 1700
Bellevue, WA 98004



Federal Highway Administration

Transportation/Air Quality Issues in Rural Areas

Table of Contents

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I. Introduction

A. Background
B. Approach
C. Report Structure
II. Summary of Findings
III. Identification of Isolated Rural Areas
IV. Survey Results
A. Carbon Monoxide
B. Ozone
C. Particulate Matter-10

Appendix A: Survey A-1



Federal Highway Administration

Transportation/Air Quality Issues in Rural Areas

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I. Introduction

Although air quality has been mainly an urban concern, it is beginning to become an issue that rural areas will also have to manage. Several rural counties have exceeded the national standard for one or more air pollutants. The purpose of this study is to increase understanding of how many rural areas are facing this problem and to identify the main causes for their exceeding air quality standards. The study also focuses on transportation's contribution to the air quality problems in rural areas and how these areas are meeting certain Clean Air Act requirements related to motor vehicle emission sources. In order to build this understanding, the research identified rural nonattainment and maintenance areas: how many are there, where are they, and are they isolated rural areas or donut areas? (These two different types of areas are defined in Section III.) Once the delineation of areas was accomplished, the study's in-depth evaluation of air quality and transportation conformity issues was restricted to only isolated rural areas.

The research reported in this paper accomplished the following:

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A. Background

The conformity provisions of the Clean Air Act are intended to integrate transportation and air quality planning in areas that are designated by the US Environmental Protection Agency (EPA) as nonattainment or maintenance.1 The transportation conformity process establishes a connection between transportation planning and the emissions levels for transportation sources that are established in the SIP. These emissions levels (or "budgets") in the SIP represent the maximum amount of emissions that can be generated from on-road transportation sources (e.g., cars, trucks, public transit) and still allow the area to attain or maintain the air quality standards. Under the CAA, nonattainment and maintenance areas must demonstrate through the conformity process that emissions projected from their transportation investments, strategies, and programs will be at or below the emissions budgets in the SIP. In order to comply with the National Ambient Air Quality Standards, federal, state, and local governments must take action. These actions, or control measures, are typically identified in the SIP. Depending on the classification and severity of the air quality problem, some areas may find that they need to reduce emissions from transportation sources. One option for reducing emissions for on-road mobile sources is to limit vehicle miles traveled (VMT). VMT is the sum of distances traveled by all motor vehicles in a specified region. In order to address VMT, some states have included Transportation Control Measures (TCMs) as strategies that are specifically identified and committed to in the SIP. TCMs are strategies that are listed in Section 108 of the Clean Air Act and include projects such as public transit and ride-share programs. Areas might also invest in other technology-based strategies that will reduce transportation-related emissions such as inspection and maintenance and fuels programs.


1 A nonattainment area is a region that does not meet (or that contributes to ambient air quality in a nearby area that does not meet) the national primary or secondary ambient air quality standard for the pollutant. The area must take specified actions within a certain time frame to reduce emissions and attain the National Ambient Air Quality Standards (NAAQS). A maintenance area is a region previously designated as nonattainment, and subsequently redesignated to attainment.

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B. Approach

To meet the objectives of this study, research was conducted to determine the classification of areas. A comprehensive survey was designed, administered, and analyzed. The entire process was overseen by officials from the FHWA and EPA Office of Transportation and Air Quality (OTAQ).

  1. Oversight

    Study oversight was provided by officials from the FHWA and EPA-OTAQ. The following officials were involved in the study oversight:

    The oversight group provided input and validated the study at key points, including study inception, survey design, and presentation of findings.

  2. Research and Analysis

    August 2001 data on rural nonattainment and maintenance areas was compiled from the EPA Greenbook website (http://epa.gov/oar/oaqps/greenbk/). The EPA Greenbook data included information on all nonattainment and maintenance areas in the United States for six pollutants: ozone, carbon monoxide, nitrogen dioxide, sulfur dioxide, particulate matter, and lead. The data also distinguished between nonattainment and maintenance areas that are part of a Metropolitan Planning Organization (MPO) and those that are not. In this research, the three transportation-related pollutants examined were carbon monoxide, ozone, and particulate matter-10 (PM-10). Although nitrogen dioxide is also a pollutant emitted from transportation sources, there are no isolated rural areas violating the nitrogen dioxide air quality standard. A list of nonattainment and maintenance isolated rural areas was compiled.

    In order to differentiate between the isolated rural areas and the donut areas, many sources of information were used. (The two types of rural areas are defined in Section II.) The Association of Metropolitan Planning Organizations (AMPO) was consulted for determining which geographic areas MPOs covered. Organizational websites (where available) were used to determine the exact coverage area of the MPO; an organization without a website was contacted by phone. The MPO areas were mapped out, as were the nonattainment and maintenance areas, to determine if the area was a donut or an isolated rural area. The regional EPA offices were contacted by phone to verify the list of isolated rural nonattainment/maintenance areas and the donut areas. The Code of Federal Regulations was consulted to determine the current air quality classification of the area and to incorporate any updates since the Greenbook data was last updated in August 2001. The analysis and survey conducted was based on designations as of mid January 2002.

  3. Survey

    In conjunction with the EPA and the FHWA, a survey was developed to determine how isolated rural areas designated as nonattainment or maintenance for one or more national ambient air quality standards are addressing air quality and transportation conformity requirements. The survey specifically addresses Ozone, Carbon Monoxide, and PM-10 isolated rural areas. The main questions addressed in the survey are:

    The survey was e-mailed to the state department of transportation and state air quality agency for each area. In addition, regional FHWA and regional EPA offices were also e-mailed a survey. The consultant team answered survey respondents' questions and encouraged those who had not completed a survey to do so.

  4. Interviews

    One jurisdiction from each pollutant nonattainment or maintenance area -- Presque Isle, Maine; Fairbanks, Alaska; and Greenbrier County, West Virginia -- was selected for a follow-up interview. These focused discussions were used to clarify how the area has used the conformity process and to identify the practical issues associated with different aspects of the process. The interviews confirmed the conclusions the study team reached from the survey data.

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C. Report Structure

This report is organized into the following sections:

II. Summary of Findings. This section presents the general findings from the surveys collected for all the isolated rural nonattainment and maintenance areas that responded.

III. Identification of Isolated Rural Areas. This section identifies which rural areas are isolated and which areas are donut areas.

IV. Survey Results. This section presents a detailed summary of the survey responses for isolated rural areas organized by pollutant.

V. Appendix A: Survey. This appendix contains the text of the survey administered by Dye Management Group, Inc. in June 2002.

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II. Summary of Findings

The following summarizes the major findings of a study that assessed the process and techniques that isolated rural nonattainment and maintenance areas have used to address the requirements of the conformity process. More details and definitions can be found in the body of this report.


2 The remaining four survey respondents did not answer the survey question related to non-exempt transportation projects. While these could be areas that did not have non-exempt projects, it is possible that the survey respondent did not know the answer to the question.

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III. Identification of Isolated Rural Areas

Federal regulations separate rural areas into two types: isolated rural areas and donut areas. For purposes of this survey, the distinction between an isolated rural area and a "donut" area is as follows. An isolated rural area is an area that is not part of the emissions analysis of any Metropolitan Planning Organization's (MPO) transportation plan or transportation improvement program (TIP). A "donut" area, on the other hand, is an area that is inside a non-attainment or maintenance area boundary, but is outside the metropolitan planning boundary (40CFR93.109(g)).

The following tables show the rural areas currently (March 2003) in non-attainment status.

Exhibit III-1: Carbon Monoxide Nonattainment or Maintenance Rural Areas
(March 2003)
State EPA Region Isolated Rural Areas Donut Areas
Alaska 10 Fairbanks  
Oregon   Grants Pass
Klamath Falls
 


Exhibit III-2: Ozone Nonattainment or Maintenance Rural Areas (March 2003)
State EPA Region Isolated Rural Areas Donut Areas
Connecticut 1 Windam County (Greater Connecticut Area)  
Maine 1 Hancock & Waldo Counties Cumberland County (Greater Portland Area)
Knox & Lincoln Counties  
New Hampshire 1 Cheshire County  
New York 2 Essex County
Jefferson County
Montgomery and Greene Counties (Albany-Schenectady-Troy Area)
Maryland 3 Kent & Queen Anne's Counties Calvert and Charles Counties (Washington, DC-MD-VA)
Virginia 3 White Top Mountain (Smith County)  
Delaware 3 Sussex County  
Pennsylvania 3 Crawford County
Franklin County
Juanita County
Lawrence County
Northumberland County
Schuylkill County
Snyder County
Susquehanna County
Warren County
Wayne County
 
Virginia 3 White Top Mountain (Smith County)  
West Virginia 3 Greenbrier County  
Georgia 4   Coweta, Forsyth and Paulding Counties (Atlanta Area)
Kentucky 4 Edmonson County Portion of Hancock County (Owensboro area)
Paducah (Livingston and Marshall Counties) Scott County (Lexington Area)
South Carolina 4 Cherokee County  
Tennessee 4   Rutherford, Sumner, Williamson and Wilson Counties (Nashville area)
Michigan 5 Allegan County  
  Muskegon
Ohio 5 Clinton County Ashtabula and Portaqe Counties (Cleveland-Akron-Lorain area)
Columbiana County  
Preble County  
  Delaware and Licking Counties (Columbus area)
  Greene and Miami Counties (Dayton-Springfield area)
  Stark County (Canton area)
Louisiana 6 Grant Parish
Lafourche Parish
St. James Parish
St. Mary Parish
 


Exhibit III-3: PM-10 Nonattainment or Maintenance Rural Areas (2003)
State EPA Region Isolated Rural Areas Donut Areas
Maine 1 Presque Isle (Aroostook County)  
Illinois 5 Oglesby (La Salle County)  
Indiana 5 Vermillion County  
New Mexico 6   Anthony (Dona Ana County)
Colorado 8 Telluride (San Miquel County)
Pagosa Springs (Archuleta County)
Canon City (Fremont County)
Aspen (Pitkin County)
Lamar (Prowers County)
Steamboat Springs (Routt County)
 
Montana 8 Columbia Falls (Flathead County)
Whitefish and vicinity (Flathead County)
Kalispell (Flathead County)
Polson (Lake County)
Libby (Lincoln County)
Lame Deer (Rosebud County)
Thompson Falls and vicinity (Sanders County)
Ronan area (Lake County)
Butte (Silver Bow County)
Ronan
Wyoming 8 Sheridan County  
Arizona 9 Douglas (Coachise County)
Paul Spur (Coachise County)
Hayden/Miami (Gila and Pinal Counties)
Payson (Gila County)
Mohave County
Nogales (Santa Crus County)
 
California 9 Mammoth Lake (Mono County)
Owens Valley (Inyo County)
Mono Basin (Mono County)
 
Alaska 10 Juneau  
Idaho 10 Sandpoint (Bonner County)
Shoshone County (excluding Pinehurst)

Pinehurst (Shoshone County)
 
Oregon 10 Lake County
Grants Pass (Josephine County)
LaGrande (Union County)
Klamath County (Klamath Falls area)
 
Washington 10 Wallula (Walla Walla County)  

The study team surveyed a sample of the isolated rural areas identified in the exhibit.

IV. Survey Results

The survey was administered to a sample of the carbon monoxide, ozone, or PM-10 nonattainment or maintenance isolated rural areas. The survey was sent to 41 isolated rural areas: 2 carbon monoxide nonattainment or maintenance areas, 6 ozone nonattainment or maintenance areas, and 34 PM-10 nonattainment areas. (Grant's Pass, Oregon is both a carbon monoxide maintenance area and a particulate matter nonattainment area.) For each area, the survey was sent to the corresponding:

A total of 18 surveys were completed, for an overall response rate of 43 percent. However, response rates differed according to pollutant: 100 percent for ozone; 50 percent for carbon monoxide; and 32 percent for particulate matter-10. Below are general conclusions from all surveys, as well as conclusions drawn for each of the pollutants.

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A. Carbon Monoxide

Only one of the two carbon monoxide maintenance or nonattainment areas responded to the survey, as shown in Exhibit IV-1.

Exhibit IV-1: Carbon Monoxide Nonattainment and Maintenance Isolated Rural Areas
State County Area Name Status Class EPA Region Completed Survey
Alaska Fairbanks Ed Fairbanks Nonattainment Serious 10 No
Oregon Josephine Grants Pass Maintenance N/A 10 Yes

Over 50 percent of Grants Pass's carbon monoxide emissions is caused by on-road mobile sources. VMT is projected to grow 0.8 percent per year between 1993 and 2015, as determined by a model developed in collaboration between the Rogue Valley Council of Governments and the Oregon Department of Transportation. Grants Pass has a maintenance SIP, which contains one transportation control measure: wintertime oxygenated fuel. The survey respondents also indicated that the one federal action that has helped the area maintain air quality standards is improved vehicle emissions standards on new cars.

Grants Pass used the less than 1990 test and the build/no-build test in its last conformity determination. For years beyond the timeframe of the SIP, Grants Pass uses the budget test and demonstration using air quality modeling. It is not clear from the survey responses why Grants Pass appears to have used both the budget test and an air quality modeling demonstration for conformity in years past the SIP.

Grants Pass, like all Oregon local jurisdictions, is required to develop a transportation system plan (TSP) and receives financial support to do so. This requirement has likely led to an improved capacity to handle planning efforts such as the conformity process.

While the sample size for carbon monoxide nonattainment and maintenance areas is small, there may be opportunity for Fairbanks to learn from Grants Pass. Since both areas are in EPA Region 10, EPA officials could coordinate a meeting between officials in both areas.

  1. Comments on the Process

    A survey respondent from the FHWA Division office made the following comment:

    The FHWA Division must rely heavily on the Oregon DEQ and USEPA for information on how and when areas are designated as non-attainment or maintenance areas and how conformity needs to be addressed in each. If new guidance were developed, the most useful would be something that could make it easier to track the status of each specific area. Often when changes in requirements are published in the Federal Register, it can be difficult and time consuming to determine which areas are impacted and the actions that may be needed.

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B. Ozone

All six isolated rural areas in nonattainment or maintenance for ozone, in the survey sample, completed the survey. The areas are listed in Exhibit IV-2.

Exhibit IV-2: 2002 Ozone Nonattainment and Maintenance Isolated Rural Areas
State County Area Name Status Class EPA Region Completed Survey
Delaware Sussex Sussex County Nonattainment Marginal 3 Yes
Kentucky Edmonson Edmonson County Maintenance N/A 4 Yes
Livingston and Marshall Paducah Maintenance N/A 4 Yes
New York Essex Essex County Nonattainment Marginal 2 Yes
Virginia Smyth White Top Mountain Nonattainment Marginal 3 Yes
West Virginia Greenbrier Greenbrier County Nonattainment N/A 3 Yes

Four ozone nonattainment or maintenance areas have SIPs; two areas (White Top Mountain and Sussex County) do not. For emissions dealing with ozone, areas list precursors: nitrogen oxides (NOx) and/or hydrocarbons (VOC). On-road mobile sources of NOx ranged from 0 percent for White Top Mountain to 87 percent for Greenbrier County. On-road mobile sources of VOC ranged from 0 percent for White Top Mountain to 53 percent for Greenbrier County. Exhibit IV-3 shows the full results of the survey.

Exhibit IV-3: Percentage of Emissions from On-road Mobile Sources
Area Name NOx VOC
Sussex County 21% 22%
Edmonson County 63% 36%
Paducah, Kentucky 33% 3%
Essex County N/A N/A
White Top Mountain 0% 0%
Greenbrier County 87% 53%
Notes: N/A = not reported

Sussex County, White Top Mountain, and Greenbrier County use 1990 data. Paducah and Edmonson County use 2002 data.

Using historical data from the federal Highway Performance Monitoring System (HPMS), VMT growth in Edmonson County is determined to be 2.28 percent annually from 2000 to 2020. HPMS data was also used to determine the annual increase of VMT in Paducah, which is 2.05 percent for Marshall County and 2.11 percent for Livingston County. None of the other areas reported VMT information, and none of the four areas with a SIP employ transportation control measures. However, several areas listed federal actions that have helped the area attain or maintain the air quality standards. Exhibit IV?4 lists those effective federal measures cited by the areas.

Exhibit IV-4: Effective Federal Measures for Attaining or Maintaining Air Quality Standards
Area Name Measures Cited
Sussex County None.
Edmonson County All measures, including federal vehicle emission controls and fleet turnover.
Paducah Fleet turnover, non-road rules, the national low emission vehicle program (NLEV), and heavy duty diesel program.
Essex County Section 126 rule for NOx transport.
White Top Mountain None.
Greenbrier County Federal Motor Vehicle Control.Program (FMVCP), Heavy Duty Diesel Rule, and small spark ignition gasoline engines.

For those areas with SIPs, Exhibit IV-5 lists conformity tests used both in their conformity determination and in the years beyond the timeframe of the SIP. (Only two areas provided information.)

Exhibit IV-5: Conformity Tests
Area Last Determination Determinations in Years Beyond Timeframe of SIP
Budget test Less than 1990 test Build/no build test No-greater-than 1990 test Budget test Less than 1990 test Build/no build test No-greater-than 1990 test Demonstration using air quality modeling
Edmonson County X       X        
Paducah X       X        
Total Number 2       2        

Both Edmonson County and Paducah reported having non-exempt transportation projects in the past five years. Edmonson determined conformity for its project in 1999. Paducah failed in 1998 to determine conformity due to an increase in VMT, but eventually the area was able to make a conformity determination in Spring 2002 after revising its SIP to incorporate new data.

  1. Comments on the Process

    A state transportation engineer commented on the survey: "A recent ruling that an isolated rural area need only do conformity when adding a new project will help." The same engineer noted that "It doesn't seem appropriate to be spending so many resources and creating local headaches over adding a minor amount of VMT when the mobile contribution to pollution in the area is so small anyway. For most isolated rural areas, the primary contribution is likely coming from outside the area, so why not focus attention and resources on the real problem?"

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C. Particulate Matter-10

Only 11 of the 34 PM-10 nonattainment and maintenance areas, in the survey sample, completed the survey, as shown in Exhibit IV-6.

Exhibit IV-6: 2002 PM-10 Isolated Rural Nonattainment and Maintenance Areas
State County Area Name Status Class EPA Region Completed Survey
Maine Aroostook Presque Isle Maintenance N/A 1 Yes
Colorado San Miguel Telluride Maintenance N/A 8 No
Archuleta Pagosa Springs Maintenance N/A 8 No
Fremont Canon City Maintenance N/A 8 No
Pitkin Aspen Nonattainment Moderate 8 No
Prowers Lamar Nonattainment Moderate 8 No
Routt Steamboat Springs Nonattainment Moderate 8 No
Montana Flathead Columbia Falls Nonattainment Moderate 8 No
Flathead Flathead County; Whitefish and vicinity Nonattainment Moderate 8 No
Flathead Kalispell Nonattainment Moderate 8 No
Lake Polson Nonattainment Moderate 8 No
Lincoln Libby Nonattainment Moderate 8 No
Rosebud Lame Deer Nonattainment Moderate 8 No
Sanders Sanders County (part); Thompson Falls and vicinity Nonattainment Moderate 8 No
Silver Bow Butte Nonattainment Moderate 8 No
Wyoming Sheridan Sheridan Nonattainment Moderate 8 Yes
Arizona Cochise Douglas Nonattainment Moderate 9 No
Cochise Paul Spur Nonattainment Moderate 9 No
Gila Hayden/Miami Nonattainment Moderate 9 No
Gila Payson Nonattainment Moderate 9 No
Mohave Mohave County Nonattainment Moderate 9 No
Pinal Hayden/Miami Nonattainment Moderate 9 No
Santa Cruz Nogales Nonattainment Moderate 9 No
California Mono Mammoth Lake Maintenance N/A 9 Yes
Inyo Owens Valley Nonattainment Serious 9 Yes
Inyo Searless Valley Nonattainment Moderate 9 Yes
Mono Mono Basin Nonattainment Moderate 9 Yes
Alaska Juneau Ed Juneau Nonattainment Moderate 10 No
Idaho Bonner Sandpoint Nonattainment Moderate 10 Yes
Shoshone Pinehurst Nonattainment Moderate 10 Yes
Oregon Lake Lake County Nonattainment Moderate 10 Yes
Josephine Grants Pass Nonattainment Moderate 10 Yes
Union LaGrande Nonattainment Moderate 10 Yes
Washington Walla Walla Wallula Nonattainment Serious 10 No

All 11 PM-10 nonattainment or maintenance areas reported having a SIP. The contribution of emissions from on-road mobile sources to the areas' air quality problem varied and was difficult to determine in some areas. For Presque Isle, Maine, on-road mobile-sources, including road dust, was estimated to be 61% of the area's total PM inventory in 1994; more recent estimates show that the percentage of direct emissions only is estimated at 7.3 percent. For Mammoth Lakes, direct emissions from transportation sources has been determined to be less than 1%, however, emissions from resuspended road dirt and cinders is estimated to be 56.1% of the areas' emissions inventory. Unfortunately, survey information did not indicate what percentage of the resuspended road dirt was from roads versus what percentage is from cinders. Exhibit IV-7 illustrates the percentage of on-road mobile emissions by area.

Exhibit IV-7: Percentage of Emissions from On-road Mobile Sources
Area Name Year of Inventory PM-10
Presque Isle (Maine) 1994 61*
Sheridan (Wyoming) 1988 N/A
Mammoth Lake (California) 1988 Less than 1
Owens Valley (California) 1995 Less than 1
Searless Valley (California) N/A Less than 1
Mono Basin (California) N/A Less than 1
Sandpoint (Idaho) 1994 3
Pinehurst (Idaho) 1988 2
Lake County (Oregon) N/A N/A
Grants Pass (Oregon) 1986 10
LaGrande (Oregon) 1986 5
Notes: N/A = not available

An interview with Presque Isle revealed problems with the 1994 measurement, which included road sand with on-road mobile sources. The percentage of direct emissions from on-road mobile sources is 7.3 percent.

However, several areas listed TCMs, shown in Exhibit IV-8.

Exhibit IV-8: Transportation Control Measures
Area Name TCM Cited
Presque Isle (Maine) Removing de-icing and anti-icing materials as soon as possible from roads.
Sheridan (Wyoming) Limiting sand and gravel usage and removing them as soon as possible from a road after snow.
Mammoth Lake (California) Restricting parking, increasing transit ridership, and reducing vehicle traffic.
Owens Valley (California) None.
Searless Valley (California) None.
Mono Basin (California) None.
Sandpoint (Idaho) Aggressive street sweeping program and anti skid material specs.
Pinehurst (Idaho) None.
Lake County (Oregon) Paving gravel roads.
Grants Pass (Oregon) None.
LaGrande (Oregon) Controlling fugitive dust (winter road sanding, paving gravel streets, etc.).

Interestingly, the most frequently listed TCMs do not fit the commonly used definition of TCM, which includes actions to adjust traffic patterns or reduce vehicle use. Only three of the 11 areas that responded to the survey noted effective federal measures relating to VMT and tailpipe emissions, as reflected in Exhibit IV-9.

Exhibit IV-9: Effective Federal Measures for Attaining or
Maintaining Air Quality Standards
Area Name Measures Cited
Presque Isle (Maine) None.
Sheridan (Wyoming) None.
Mammoth Lake (California) VMT cap, phase out of non-certified wood stoves and fireplaces, mandatory wood burning curtailment.
Owens Valley (California) N/A
Searless Valley (California) N/A
Mono Basin (California) N/A
Sandpoint (Idaho) Tier II, CAFE standards, OBD etc. -- improving fuel economy and emission rates.
Pinehurst (Idaho) Tier II, CAFE standards, OBD etc. -- improving fuel economy and emission rates.
Lake County (Oregon) CMAQ funds used to pave gravel roads (to reduce transportation-related fugitive dust).
Grants Pass (Oregon) N/A
LaGrande (Oregon) Reducing transportation-related fugitive dust by paving gravel roads.
Notes: N/A = not available

Only three PM-10 nonattainment areas reported having ever made a conformity determination, and only one of these areas has done so within the last five years. All three cited the build/no build test in their latest determination, and two of the three noted the build/no build test in years beyond the timeframe of their SIP. Exhibit IV-10 summarizes the responses.

Exhibit IV-10: Conformity Tests
Area Last Determination Conformity in YearsBeyond Timeframe of SIP
Budget test Less than 1990 test Build/no build test No-greater-than 1990 test Budget test Less than 1990 test Build/no build test No-greater-than 1990 test Demonstration using air quality modeling
Sandpoint (Idaho)     X       X    
Pinehurst (Idaho)     X       X    
Grants Pass (Oregon)   X X           X
Total Number   1 3       2   1

Only Sandpoint reported having a non-exempt transportation project in the past five years. It determined conformity for its project in 2000.

  1. Comments on the Process

    According to a Division FHWA Transportation Engineer who completed the survey:

    Rural areas by their very nature (small, sparsely populated, relatively low traffic volumes and densities, and infrequent capacity expansion projects) should have minimal transportation related air quality problems. To the extent that the above generalization is accurate, it begs the question of why a regional level analysis is currently expected for such areas. Perhaps consideration should be given to evaluating, and as necessary, analyzing such areas at the project level, only. Since there is no PM-10 modeling process, this would effectively limit the analysis to CO.

    According to a state environmental agency transportation specialist who completed the survey:

    One of the biggest holes in modeling transportation emissions for conformity purposes is VMT and speeds. Transportation and Air Quality agencies often must rely on minimal or spotty data to base speed and VMT assumptions. As an example, the statewide transportation emissions inventory is based on VMT extrapolated from Federal Highways Statistics. The conformity process and the quality of associated air quality analysis would be vastly improved with consistent and reliable VMT and speed data. Rural areas would greatly benefit if FHWA could expand the monitoring done for the Federal Highways Statistics.

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Appendix A: Survey

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This appendix contains a copy of the survey used to collect the data for this report.

FHWA Transportation/Air Quality Issues in Rural Areas

Background

FHWA is interested in assessing how isolated rural areas that have been designated non-attainment or maintenance for one or more air quality standards are addressing their transportation conformity related issues. FHWA has assigned Dye Management Group, Inc. the task of identifying and describing current practices. FHWA and EPA are considering developing additional guidance on how to conduct conformity determinations in these areas, so your responses are important to us. As part of this effort, we are seeking your collaboration to participate in a survey.

The three main questions we hope to answer through this survey are:

The attached questionnaire, a product of the substantial collaboration from the Federal Highway Administration (FHWA) and Environmental Protection Agency (EPA), was designed to gather information on the identified issues of interest. For each isolated rural area a questionnaire will be sent to the corresponding state department of transportation (DOT), the state and/or local air agency, the Division FHWA and Regional EPA offices, and any other applicable state or local agency.

Rural Areas Defined

By definition, an isolated rural non-attainment or maintenance area is not part of, or contiguous to, a metropolitan area having a population of 50,000 or more. In other words, if an area is inside a non-attainment or maintenance area boundary, but is outside of the metropolitan planning boundary, then it is considered a "donut area," not an isolated rural area (see 40 CFR 93.109(g)). An isolated rural area's transportation projects are not part of the emissions analysis of any MPO's transportation plan or TIP (see 40 CFR 93.109(g)). Isolated rural areas are not required under federal regulation to establish a Metropolitan Planning Organization (MPO) or to develop transportation plans and transportation improvement programs (TIP) as a result of their population size.


FHWA Transportation/Air Quality in Rural Areas
Questionnaire

Name: _______________________________________________________________

Position: _____________________________________________________________

Organization: _________________________________________________________

Telephone: __________________ E-mail:___________________________________

  1. General

    [Area Name] has been designated as a [nonattainment area or maintenance area] for [ozone, carbon monoxide, or particulate matter-10].

    Please verify that the designation(s) and pollutant(s) listed above for this area is/are correct. If not accurate please correct as appropriate.

    ____________________________________________________________________________________

    ____________________________________________________________________________________

    ____________________________________________________________________________________

    ____________________________________________________________________________________

  2. State Implementation Plan and Air Quality

    1. Does this area have a SIP? ______Yes ______ No
    2. If this area has a SIP, what control measures in the SIP help the area show attainment?

      ____________________________________________________________________________________

      ____________________________________________________________________________________

      ____________________________________________________________________________________

      ____________________________________________________________________________________

    3. If this area has a SIP, what are the emissions inventories for each source sector (e.g., on-road mobile, stationary, etc.) listed in the isolated rural area's SIP? Please answer this question separately for each pollutant or each precursor of each pollutant for which an area is designated. For your response, please choose the inventory year closest to 2002 and indicate the units for each pollutant / precursor (e.g., tons per day, tons per year). Or, if available, copy and attach a table listing of the emissions inventory.

      Year of Inventory = ___________

      Units of Inventory = ___________

      Sector: Inventory:
      On-road mobile sources _______________________________
      Others? Please list. _______________________________
    4. What federal actions/measures (e.g., federal vehicle emissions controls; fleet turnover) are helping the area attain or maintain the air quality standard(s)?

      ____________________________________________________________________________________

    5. What is the projected population growth in this isolated rural area? Please provide the growth rate and indicate over what period of time this rate applies (e.g., 2000-2020).

      ____________________________________________________________________________________

      ____________________________________________________________________________________

    6. What is the projected growth rate of vehicle miles traveled (VMT) in this isolated rural area? Please indicate the time period for which the VMT rate applies.

      ____________________________________________________________________________________

    7. How is VMT information determined for this isolated rural area?

      ____________________________________________________________________________________

      ____________________________________________________________________________________

      Is speed information determined? If so, how?

      ____________________________________________________________________________________

      ____________________________________________________________________________________

    8. What agency determines the VMT and speed information for this isolated rural area?

      ____________________________________________________________________________________

    9. Have the difficulties in demonstrating conformity ever resulted in the area not being able to implement/approve a new transportation project?

      ___________ Yes ___________No

      If yes, for how long was this project delayed? (If a project has been delayed on more than one occasion, please specify how long for each delayed project.)

      ____________________________________________________________________________________

  3. Transportation Planning and Conformity

    1. Is this isolated rural area implementing any transportation control measures included in the SIP to address its air quality problem?              Yes________ No ________

      If so, what is/are the specific transportation control measures that this area is implementing?

      ____________________________________________________________________________________

    2. Given that before a new Federal non-exempt project can be approved or funded in an isolated rural area, a conformity determination is required. How many non-exempt transportation projects for this isolated rural area in the past 5 years required FHWA/FTA approval?

      2001 ________________________________________

      2000 ________________________________________

      1999 ________________________________________

      1998 ________________________________________

      1997 ________________________________________

      Did you determine conformity in any of these years:

      1997 Yes_____________No, _______ if no, why not? ___________________________________

      1998 Yes_____________No, _______ if no, why not? ___________________________________

      1999 Yes_____________No, _______ if no, why not? ___________________________________

      2000 Yes_____________No, _______ if no, why not? ___________________________________

      2001 Yes_____________No, _______ if no, why not? ___________________________________

    3. How many years into the future were analyzed for the last conformity determination performed for this area?

      ____________________________________________________________________________________

    4. What type of SIP(s) does this isolated rural area have and for what years do they have motor vehicle emissions budgets (if applicable)? Please check all that apply.

      _______

      This area does not have a SIP

      _______

      This area has a SIP, but it does not have motor vehicle emissions budgets (e.g., a limited maintenance plan.)

      _______

      Attainment SIP.

      What are the budget years, if budgets exist: __________________________

      _______

      15 percent SIP.

      What are the budget years, if budgets exist: __________________________

      _______

      9 percent rate of progress SIP.

      What are the budget years, if budgets exist: __________________________

      _______

      Maintenance Plan.

      What are the budget years, if budgets exist: __________________________
    5. Which of the following conformity test(s) did the isolated rural area use in its last conformity determination? Please mark all that apply.

      _______ Budget test.

      _______ Less than 1990 test.

      _______ Build/no-build test.

      _______ No-greater-than 1990 test.

    6. Which method below is being used to determine conformity in the years beyond the timeframe of the SIP?

      _______ Budget test.

      _______ Build/no-build test.

      _______ Less than 1990 test.

      _______ No-greater-than 1990 test.

      _______ Demonstration using air quality modeling (same modeling used in the SIP).

    7. What agency runs the emissions analysis for this isolated rural area? What agency prepares the travel estimates (e.g., estimating VMT)?

      ____________________________________________________________________________________

    8. How many times since January 1997 has this isolated rural area determined conformity? What were the dates (month and year) on which the conformity determination was made for this area?

      Number of determinations since 1997: _________________________________________

      Dates on which these conformity determinations were made: _________________________________

    9. What triggered the need for these conformity determinations? A new transportation project, or some other reason?

      ____________________________________________________________________________________

      ____________________________________________________________________________________

    10. Has this isolated rural area ever had difficulty demonstrating conformity (i.e., they cold not pass their conformity test as listed above)? If answer to this question is No, please skip to question 3-l below.

      ______ Yes _______ No

      For what analysis years did this area have difficulty demonstrating conformity?

      ____________________________________________________________________________________

      What was the nature of this area's conformity difficulties? Please check all that apply.

      ________ Population grew faster than anticipated.

      ________ New data/information on fleet resulted in higher emissions.

      ________ Control measures ended because of a sunset date. If yes, which measures?

      ____________________________________________________________________________________

      ________ Control measures ended with the end of the SIP. If yes, which measures?

      ____________________________________________________________________________________

      Other? Please explain briefly: ____________________________________________________________

      ____________________________________________________________________________________

    11. Why was this area not able to meet the SIP budget(s)? Please check all that apply.

      ________ SIP was based on an earlier version of emissions factor model.

      ________ SIP was based on older data that was updated for the conformity determination.

      ________ Area was experiencing unanticipated growth.

      ________ A control measure not being implemented; which measure?

      ____________________________________________________________________________________

      Other? Please explain.

      ____________________________________________________________________________________

    12. If this area has experienced conformity difficulties, have the difficulties been successfully addressed and resolved? ______ Yes ______ No.

      If yes, what factors contributed to this outcome? (Choose all that apply from the two categories below: Revision to SIP and Revisions Transportation Projects.)

      Revision to SIP

      _________ Identifying a safety margin and applying some or all of it to the budget.

      _________ Adding transportation control measures in the SIP. Which measures?

      _________ Adding emission reduction control measures. Which measures?

      ____________________________________________________________________________________

      _________ Updating the budget with new data (e.g., population, employment, etc.).

      _________ Updating the budget with a new emissions factor model.

      _________ Other? Please briefly explain:

      ____________________________________________________________________________________

      Revision to Transportation Projects

      _________ Eliminating, changing scope of or delaying transportation projects.

      _________ Adding transportation control strategies (but will not be included in the SIP). Which strategies?

      ____________________________________________________________________________________

      _________ Adding other emissions reduction measures (not already in the SIP). Which measures?

      ____________________________________________________________________________________

      _________ Adjusting assumptions for new federal rules (e.g., Tier 2 new vehicle emissions standards).
                         Which rules?

      ____________________________________________________________________________________

      _________ Other? Please briefly explain:

      ____________________________________________________________________________________

    13. What resources are available, in terms of number of staff, their skill level and the amount of planning funds, at the local level to demonstrate conformity to the SIP?

      ____________________________________________________________________________________

  4. Interagency Consultation

    1. Who actually does the modeling and/or approves the conformity determination for the isolated rural areas?

      ____________________________________________________________________________________

      ____________________________________________________________________________________

    2. What federal, state and local agencies are involved in the consultation process for this isolated rural area?

      ____________________________________________________________________________________

      ____________________________________________________________________________________

    3. What are the consultation procedures for this isolated rural area? Please check all that apply.

      _______

      A meeting among all agencies is held prior to a conformity analysis (i.e., when a new project is initiated).

      _______

      A meeting among all agencies is held after the analysis is performed, but prior to FHWA approval of the conformity determination.

      _______

      A meeting among all agencies is only held if the conformity analysis indicates that the area might have difficulty demonstrating conformity.

      _______

      There has never been a meeting among all agencies for this area.

      _______

      Other? Please explain other consultation procedures applicable to this area.

      ____________________________________________________________________________________

      ____________________________________________________________________________________

      ____________________________________________________________________________________

      ____________________________________________________________________________________

    4. Has the consultation process helped resolve difficulties related to demonstrating conformity for a new project?

      _____ Yes _____ No

      Why or why not? Please briefly explain:

      ____________________________________________________________________________________

      ____________________________________________________________________________________

    5. Other Comments on the Process

      ____________________________________________________________________________________

      ____________________________________________________________________________________

      ____________________________________________________________________________________

      ____________________________________________________________________________________

      ____________________________________________________________________________________

      ____________________________________________________________________________________

      ____________________________________________________________________________________

      ____________________________________________________________________________________

      ____________________________________________________________________________________

      ____________________________________________________________________________________

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