intro to air quality

INTRO TO AIR QUALITY

Table of Contents

2

8-16

17-22

23-29

30-42

4-7 Introduction to Air Quality

Criteria Pollutants

Mobile Source Air Toxics (MSAT)

Project Level Compliance

Project-Level Transportation Conformity

Hot-Spot Analysis

Carbon Monoxide Traffic Air Quality Analysis (CO TAQA)

1

2

3

4

5

6

7

43-54

55-66

Table of Contents

3

79-91

92-97

98-102

103-110

67-78 MSAT Analysis

Congestion Management Process (CMP) Analysis

Construction Emissions

Texas Commission on Environmental Quality (TCEQ) MOU

New Guidance

8

9

10

11

12

111 Q & A 13

Intro to Air Quality

“By three methods we may learn wisdom: First, by reflection, which is noblest;

Second, by imitation, which is easiest; and third by experience, which is the

bitterest.”

Confucius

4


Goals of this Training Course

Discuss pollutants of concern for transportation projects

Identify laws, rules, regulations, and guidance that apply to air quality for transportation projects

Understand the specific air quality analyses and elements needed for transportation projects

Locate and understand the structure of the air quality toolkit and associated guidance

5


Acronyms

6

Appendix A


Transportation Related Air Pollutants

Criteria Pollutants

Mobile Source Air Toxics (MSAT)

7

Criteria Pollutants

8

Criteria Pollutants

9

Criteria Pollutants The Clean Air Act (CAA) establishes 6 criteria pollutants, 4 of which are associated

with transportation activities

Ozone (O3)

Nitrogen Dioxide (NO2)

Carbon Monoxide (CO)

Particulate Matter (PM)

Lead (Pb)

Sulfur Dioxide (SO2)

Ozone (O3)

Nitrogen Dioxide (NO2)

Carbon Monoxide (CO)

Particulate Matter (PM)

Lead (Pb)

Sulfur Dioxide (SO2)

Criteria Pollutants Transportation Related Not Transportation Related

Criteria Pollutants

National Ambient Air Quality Standards (NAAQS)

The Environmental Protection Agency (EPA) has developed standards for the criteria pollutants, these are called NAAQS

Primary NAAQS are based on levels expected to be protective of human health

Secondary NAAQS are based on levels expected to be protective of public welfare (e.g., visibility, animal life, vegetation, buildings)

EPA will designate areas as nonattainment if they exceed a NAAQS EPA will designate areas as being in attainment-maintenance status if they

no longer exceed the applicable NAAQS

10

Criteria Pollutants

11

Nonattainment and Maintenance Area (NA/MA) in Texas

Area Name Counties Pollutant Classification

Houston-Galveston-Brazoria (HGB)

Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty,

Montgomery, Waller Ozone Marginal Nonattainment

Dallas/Fort Worth (DFW)

Collin, Dallas, Denton, Tarrant, Ellis, Johnson, Kaufman, Parker, Rockwell,

Wise Ozone Moderate Nonattainment

El Paso Portion of El Paso PM10 Moderate Nonattainment

El Paso Portion of El Paso CO Attainment-Maintenance

Collin County Portion of Collin County Lead Nonattainment

This table is only showing NA/MAs for the 2008 ozone NAAQS since transportation conformity no longer applies to the 1997 ozone NAAQS. Lead is not a transportation related pollutant.

Criteria Pollutants

State Implementation Plan (SIP) A SIP identifies how a state or area will attain or maintain compliance with

the NAAQS Some areas have specific provisions which are part of Texas’ overall SIP The Texas Commission on Environmental Quality (TCEQ) maintains Texas’ SIP An area’s SIP may have a Motor Vehicles Emission Budget (MVEB)* The MVEB establishes the maximum allowable emissions associated to

transportation activities For an action to conform to the purpose of a SIP it cannot cause or

contribute to a new violation, increase the severity of an existing violation, or delay timely attainment or interim emission reductions of the area.

* Or another emissions test under certain circumstances

12

Criteria Pollutants

Transportation Conformity Overview

Metropolitan Planning Organizations (MPOs) in NA/MA areas must establish that their transportation projects will not exceed their area’s MVEB*

As part of the Metropolitan Transportation Plan (MTP) development, MPOs in these NA/MAs will model the air emissions associated with all the regionally significant projects in their network

Based on this analysis, FHWA will make a determination as to whether the MTP conforms to the SIP – this is called the regional conformity determination

Project-level conformity is based on a project being consistent with this regional conformity determination (i.e., consistent with the MTP)

Project-level conformity must also address potential hot-spots in CO or PM NA/MAs

* Or other applicable emissions analysis

13

Criteria Pollutants

14

Conformity

Transportation Conformity

General Conformity

Regional Conformity

Project-Level Conformity

Consistency with

MTP/TIP/STIP

Hot-Spots (only in ELP)

FHWA/FTA Other Federal Lead

MTP/TIP/STIP Projects

Transportation Conformity applies to FHWA/FTA projects Regional Conformity applies to the MTP, TIP, and STIP Project-Level Conformity applies to projects and includes consistency and hot-spots

Criteria Pollutants

15

Trends

Criteria Pollutant

Nat’l Average Date Range

Nat’l Average % Change

Regional Average Date Range

Regional Average % Change Method

Ozone 1980-2014 -33% 2000-2014 -24%

annual 4th maximum of daily max 8-hr

average

CO 1980-2014 -85% 2000-2014 -67% annual 2nd maximum

8-hr average

NO2 1980-2014 -57% 2000-2014 -27%

annual 98th percentile of daily max

1-hr average

SO2 1980-2014 -80% 2000-2014 -70%

annual 99th percentile of daily max

1-hr average

PM 2000-2014 -35% 2000-2014 -29% seasonally-weighted

annual average

Lead 1980-2014 -98% - - annual maximum 3-

month average Source: EPA. http://www.epa.gov/airtrends/index.html Regional Average based on EPA South Region.

Both nationally and regionally, there has been a trend of decreasing concentrations of all of the criteria pollutants. In terms of air quality, areas may be in poor health but not declining health.

http://www.epa.gov/airtrends/index.html

Criteria Pollutants

Summary There are six criteria pollutants, four of which are transportation related (ozone, CO,

PM, and NO2)

EPA has developed health-based standards for criteria pollutants called NAAQS

BMT, DAL, FTW, and HOU have nonattainment areas (NA) for ozone; and ELP has a NA for PM10 and a maintenance area (MA) for CO

Transportation conformity rules apply to FHWA/FTA projects and regionally significant non-federal roadway projects. General conformity applies to projects with a federal lead other than FHWA/FTA.

Transportation conformity includes conformity of the MTP and TIP (regional conformity) and conformity of specific projects (project-level conformity)

There is a trend of decreasing criteria pollutant concentrations over time

16

MSAT

17

MSAT

MSAT Background

The CAA mandated that EPA regulate 188 air toxics EPA identified a group of 93 of these air toxics that had mobile sources EPA further identified 7 of these MSAT as national and regional-scale cancer

risk drivers In their interim guidance, FHWA identifies those 7 MSAT to be the priority

MSAT EPA has not established health-based air quality standards for MSAT like they

have for the criteria pollutants

18

All MSAT are associated to transportation

MSAT

19

Mobile Source Air Toxics FHWA considers these 7 air toxics as the priority MSAT. All MSAT are transportation related pollutants, even though other non-transportation

sources emit them as well.

Acrolein

Benzene

1,3-butadiene

Diesel PM

Formaldehyde

Naphthalene

Polycyclic Organic Matter (POM)

Acrolein

Benzene

1,3-butadiene

Diesel PM

Formaldehyde

Naphthalene

Polycyclic Organic Matter (POM)

Priority MSAT Transportation Nexus No Transportation Nexus

MSAT

FHWA Interim MSAT Guidance

Has been updated several times, with the latest being in December of 2012 Provides a national qualitative assessment of MSAT Identifies three methods for addressing MSAT in a National Environmental

Policy Act (NEPA) context – no analysis – qualitative analysis – quantitative analysis

Provides a threshold for determining which MSAT disclosure method is appropriate

Provides a discussion of information that is incomplete and unavailable for localized modeling of MSAT

20

Diesel PM Benzene, Formaldehyde

Acrolein, Butadiene, Naphthalene, Polycyclics

MSAT Trends

Each of the priority MSAT is expected to decrease in the future until about 2030, even with a substantial increase in VMT (~102%)

Even with a slight uptick in concentrations after 2030 for some of the MSAT, the future MSAT concentrations are still expected to be significantly lower than today.

These charts do not yet include the revised CAFE standards.

Take Away

MSAT

21

01234567

020,00040,00060,00080,000

100,000120,000140,000

2010

2015

2020

2025

2030

2035

2040

2045

2050

VMT

(trill

ion/

yr)

MSA

T Em

issi

ons

(tons

/yr)

Diesel PM Trillions VMT

01234567

0

5,000

10,000

15,000

20,000

2010

2015

2020

2025

2030

2035

2040

2045

2050

VMT

(trill

ion/

yr)

MSA

T Em

issi

ons

(tons

/yr)

Benzene Formaldehyde Trillions VMT

01234567

0500

1,0001,5002,0002,5003,0003,500

2010

2015

2020

2025

2030

2035

2040

2045

2050

VMT

(trill

ion/

yr)

MSA

T Em

issi

ons

(tons

/yr)

Acrolein Butadiene NaphthalenePolycyclics Trillions VMT

Source: FHWA. Interim Guidance Update on MSAT Analysis in NEPA. December 6, 2012

MSAT

Summary

There are seven priority MSAT all of which are transportation related

EPA has NOT developed health-based standards (i.e., NAAQS) for MSAT

FHWA has developed interim guidance for MSAT which recommends either no analysis, a qualitative analysis, or a quantitative analysis for MSAT

MSAT emissions show a decreasing trend over time

22


23


Air Quality Analyses in Transportation Projects

Conformity Hot-Spots CO Traffic Air Quality Analysis (TAQA) MSAT Analysis Congestion Management Process (CMP) Construction Emissions Texas Commission on Environmental Quality (TCEQ) Memorandum of Understanding (MOU)

24


25

Relating the pollutants of concern to the project level analyses Except for the MSAT analysis, all project level analyses deal with criteria pollutants. Construction emissions include both PM (criteria pollutant) and diesel PM (MSAT).

Conformity

Hot-Spots

CO TAQA

MSAT Analysis

CMP


Conformity

Hot-Spots

CO TAQA

CMP


MSAT Analysis


Project Level Analyses Related to Criteria Pollutants Related to MSAT


Statutes and Law Clean Air Act (CAA)

– Conformity – Hot-Spots

National Environmental Policy Act (NEPA)

– CO TAQA – MSAT – Construction Emissions

Transportation Code

– CMP

State Transportation Code – TCEQ MOU

26


27

AQ Analysis Statue/Law Implementing Rule or Guidance Procedural or Substantive

Conformity CAA – 42 USC 7506(c) 40 CFR 93, 30 TAC 114.260 Substantive

Hot-Spots CAA – 42 USC 7506(c) 40 CFR 93, 30 TAC 114.260 Substantive

CO TAQA NEPA - 42 USC 4332 FHWA Technical Advisory T 6640.8A Substantive*

MSAT NEPA - 42 USC 4332 Interim Guidance Update On Mobile Source

Air Toxic Analysis In NEPA Documents (12/12)

Procedural

Construction Emissions NEPA - 42 USC 4332 FHWA Technical Advisory T 6640.8A Procedural

CMP Transportation Code - 23 USC 134(k)(3)

and 134(m) 23 CFR 450.320 Substantive

TCEQ MOU State Transportation Code – 201.607 43 TAC 2.301 Procedural

* Even though this is a NEPA analysis, and NEPA is a procedural law, the CAA does not allow for an exceedance of the NAAQS.

Procedural requirements only require that you go through a process to comply Substantive requirements dictate specific requirements or thresholds to comply


Project-Level Compliance Thresholds

Appendix B

28


Summary

Various air quality analyses for transportation projects includes conformity, hot-spots, CO TAQA, MSAT, CMP, and construction emissions

Each analysis is associated with either criteria pollutants, MSAT, or both

The CAA, NEPA, and Transportation Code and the associated rules and guidance dictate the necessary air quality elements for specific projects

Various thresholds have been established for when each air quality element may be required for a specific project

29


30


Description

Project-level conformity is a determination from FHWA that a project conforms to the SIP.

– For non-assigned projects, this determination is combined with FHWA’s NEPA

approval. – For NEPA assigned projects, this determination is separate from and must be

obtained prior to the NEPA decision.

31


32

Old Process

Disclose Project is Consistent with MTP, TIP, STIP

Project-level conformity determination used to be combined with NEPA decision With NEPA approval being delegated, a project-level conformity determination must

be obtained from FHWA prior to the NEPA decision

Complete any Hot-Spot Requirements

Project-level conformity determination combined with

FHWA NEPA decision

Complete any Hot-Spot Requirements

NEPA Assignment Process

Fill out Conformity Report Form

Coordinate with ENV/FHWA to obtain Project-Level Conformity

Determination

NEPA decision


33







Procedural






Conformity is a CAA requirement EPA’s conformity rule (40 CFR 93) is the implementing rule for this CAA requirement

Regulatory Background


Applicability*

Transportation conformity applies if all of the following apply: – Project located in a NA/MA for ozone, CO, NO2, or PM – FHWA/FTA project OR non-FHWA/FTA project if regionally significant – NOT otherwise exempt from conformity

* Please note that these are transportation conformity requirements. General conformity requirements are not discussed here.

34


Exemptions

Attainment or Unclassifiable Areas

Non-FHWA/FTA projects that are also NOT regionally significant

Projects listed in 40 CFR 93.126 & 93.128

Projects listed in 40 CFR 93.127, if a hot-spot does NOT apply

35


Required Coordination

FHWA/FTA must make the final project level conformity determination

The conformity report should be coordinated at least 60 days prior to the project decision

36

Upload Conformity Report Form in ECOS

Assign review to ENV Air Specialist

ENV Air Specialist will review and coordinate with FHWA

If approved, ENV will upload to ECOS

ENV Air Specialist will notify District

60 days


37

If a project is exempt from conformity, then no conformity determination is required. A federal project includes any that has federal funding or decision (e.g., IAJ required) A state-only project includes any project without federal funding and does not

require a federal action on the environmental decision (e.g., no IAJ)

Documentation that project is exempt from conformity

Federal project: Project-level conformity determination from FHWA prior to NEPA decision

State-only project: Validation of project conformity prior to the NEPA decision

Exempt Projects Non-Exempt Projects

Compliance Requirement


38

A project level conformity determination must be obtained prior to the NEPA decision. Recommend coordination of the conformity report form at least 60 days prior to

decision

Mandatory: prior to NEPA decision.

Mandatory: prior to NEPA decision.

Recommended: Coordination of Conformity Report Form with ENV and FHWA at least 60 days prior to NEPA decision.


Timing


Modeling

NOT APPLICABLE

39


40

A federal project includes any that has federal funding or decision (e.g., IAJ required) A state-only project includes any project without federal funding and does not

require a federal action on the environmental decision (e.g., no IAJ) NO TXDOT PROJECT DECISION CAN LEGALLY BE MADE FOR A PROJECT SUBJECT TO CONFORMITY W/O A PROJECT LEVEL CONFORMITY DETERMINATION FROM FHWA

Documentation that project is exempt from conformity

scope development tool,

risk assessment form, or

environmental review document

Federal project: Conformity Report Form signed by ENV and FHWA (which includes applicable hot-spot documentation)

State-only project: Conformity Report Form signed by ENV

Summary statement in the environmental review document


Documentation Requirement


Example

Appendix C

41


Summary

Project-level conformity is a determination from FHWA/FTA that a project conforms to the SIP (i.e., consistency with current MTP and TIP)

There is a new process for obtaining a project-level conformity determination under NEPA assignment

All non-exempt projects in a NA/MA must have a project-level conformity determination prior to environmental clearance

A conformity report form is the tool for coordinating and documenting a project-level conformity determination

42

Hot-Spot Analysis

43

Hot-Spot Analysis

Description

A hot-spot analysis is a quantitative analysis of localized CO or PM concentrations associated with a transportation project to demonstrate that air quality will either not exceed the applicable NAAQS or will at least be better than the no-build alternative.

Requires complex emissions and dispersion modeling to be performed.

Only required for the preferred alternative but potentially for the no-build alternative as well.

44

Hot-Spot Analysis

45







Procedural






Hot-spots are a CAA requirement EPA’s conformity rule (40 CFR 93) is the implementing rule for this CAA requirement


Hot-Spot Analysis

Applicability*

A hot-spot analysis applies if all of the following apply: – Project located in a NA/MA for CO or PM – FHWA/FTA project – NOT otherwise exempt from hot-spot requirements

– Consultation Partners determine that it is a “project of air quality concern”

* Hot-spots are a part of project level conformity

46

Hot-Spot Analysis

Exemptions

Attainment or Unclassifiable Areas for CO and PM

Non-FHWA/FTA projects

Projects listed in 40 CFR 93.126 & 93.128

47

Hot-Spot Analysis


The Consultation Partners* make a determination as to whether this is a “project of air quality concern” (POAQC)

The Consultation Partners must approve the analysis methodology before a hot-spot analysis is prepared

The Consultation Partners will review the final hot-spot analysis

Any public comments on a hot-spot analysis should be distributed to the Consultation Partners

• The Consultation Partners include EPA, TCEQ, FHWA, TxDOT, the MPO, etc…

48

Coordinate with Consultation Partners to determine if project is a POAQC

Perform appropriate public involvement

Prepare analysis methodology (pre-analysis consensus form).

Coordinate analysis methodology with Consultation Partners.

Coordinate analysis results with Consultation Partners

Perform hot-spot analysis.

Is a POAQC.

Not

a P

OA

QC

.

Coordinate any public comments on hot-spot with Consultation Partners.

Hot-Spot Analysis

49

The Consultation Partners determine that this is NOT a POAQC

Decision had appropriate public involvement

Project-level conformity determination from FHWA

Summary of decision in environmental document

A hot-spot analysis has been prepared which demonstrates that the project will either:

Not cause or contribute to a violation of the NAAQS, or

Will have less emissions than the no-build

Written mitigation commitments, if applicable

Analysis had appropriate public involvement

Project-level conformity determination from FHWA

Analysis summary in environmental document

NOT A POAQC POAQC


Documentation that the project is exempt from hot-spot requirements

Exempt from Hot Spot Req.

Remember: For NEPA assigned projects, a project-level conformity determination must be obtained from FHWA prior to the NEPA decision.

Hot-Spot Analysis

50

Mandatory: Traffic data must be available prior to coordination with the Consultation Partners. Consultation Partner coordination and public involvement must be complete prior to the coordination of the conformity determination .

Recommended: Combine hot-spot public involvement with NEPA public involvement.

Mandatory: Hot-spot analysis and public involvement must be complete prior to the coordination of the conformity determination.

Recommended: Get FHWA approval of the hot-spot analysis approximately 60 days prior to a project’s public hearing, if applicable.

Recommended: Combine hot-spot public involvement with NEPA public involvement.

NOT A POAQC POAQC

Timing

• All hot-spot requirements have to be completed prior to obtaining a conformity determination from FHWA.

• Hot-spot public involvement should be combined with NEPA public involvement whenever possible.

Hot-Spot Analysis

Applicable Models

Emissions Model – MOVES

Dispersion Model – CAL3QHCR or AERMOD

51

Hot-Spot Analysis

52

Conformity Report Form signed by ENV and FHWA

Summary of POAQC decision in environmental review document

Hot-spot analysis technical report

Conformity Report Form signed by ENV and FHWA

Written mitigation commitments , as applicable

Summary of POAQC decision and hot-spot analysis in environmental review document

NOT A POAQC POAQC


Documentation that the project is exempt from hot-spot requirements




Exempt from Hot Spot Req.

Remember: • Since hot-spots are a subset of project-level conformity, hot-spot requirements

must be documented in the Conformity Report Form prior to FHWA /FTA making a project-level conformity determination

Hot-Spot Analysis

Example

Appendix D

53

Hot-Spot Analysis

Summary

A hot-spot analysis is a localized analysis of CO or PM impacts

It is necessary to show project-level conformity in a CO or PM NA/MA

Currently only applies to ELP

All non-exempt projects in a NA/MA for CO or PM must have coordination with Consultation Partners to receive a determination as to whether a hot-spot is required

A hot-spot technical report would document the analysis

54

CO TAQA

55

CO TAQA

Description

A CO TAQA is a quantitative analysis of worst-case CO concentrations associated with a transportation project to demonstrate that these concentrations should never exceed the CO NAAQS.

This analysis requires both emissions and dispersion modeling to be performed; however, ENV often has lookup tables available, which can potentially prevent the need for the emissions modeling.

When a CO TAQA is applicable, all build alternatives would be modeled.

56

CO TAQA

57







Procedural






The CO TAQA is considered a NEPA requirement. The CO TAQA requirement is in FHWA guidance, rather than rule.


CO TAQA

Applicability

A CO TAQA analysis applies if all of the following apply: – Project adds capacity – Design year* Annual Average Daily Traffic (AADT) > 140,000 vehicles per day (vpd)

* The design year correlates to the out year of the MTP (e.g., 2035 for the 2035 MTP or 2040 for the 2040 MTP)

58

CO TAQA

Exemptions

Projects that do NOT add capacity

Projects with a design year AADT < 140,000 vpd

59

CO TAQA


NOT APPLICABLE

60

CO TAQA

61

Additional Information: The CO TAQA is a worst-case analysis, so it uses highly conservative data inputs. No CO TAQA has ever indicated a potential exceedance of the CO NAAQS. The CO TAQA is not to be confused with a CO hot spot analysis, which is substantially

more complex and resource intensive.

Documentation that project is exempt from a CO TAQA

A CO TAQA technical report which shows the project will not cause or contribute to an exceedance of the applicable CO NAAQS


Exempt from a CO TAQA CO TAQA Req’d


CO TAQA

Timing

Mandatory – Prior to a public hearing, if required – Included in a Draft Environmental Impact Statement (DEIS)

Recommended: – Start the analysis immediately after availability of the traffic data.

62

CO TAQA

Applicable Models

Traffic Data – Transportation Planning and Programming Division (TPP) traffic data

Emissions Model* – MOVES

Dispersion Model – CALINE3 for free-flow conditions, except in El Paso – CAL3QHC for congested intersections, and in El Paso

*A table of applicable CO emission rates may be available from TxDOT ENV, preventing the need for MOVES modeling.

63

CO TAQA

64

• A CO TAQA technical report is now required.

Documentation that project is exempt from a CO TAQA




A CO TAQA technical report

A summary of the analysis incorporated into the environmental review document

Exempt from a CO TAQA CO TAQA Req’d


CO TAQA

Example

Appendix E

65

CO TAQA

Summary

A CO TAQA is a localized analysis of CO under worst-case conditions

It is a NEPA requirement rather than a CAA requirement (i.e., not a hot-spot analysis)

Required for all added capacity projects over 140,000 AADT.

Documented using a CO TAQA technical report

66

MSAT Analysis

67

MSAT Analysis

Description

An MSAT analysis can typically take one of two forms: – Qualitative MSAT Analysis

• Template language based a national MSAT analysis performed by FHWA • Provides analysis of all alternatives • Includes MSAT Background, Project-Specific Information, Incomplete and

Unavailable Information, and Conclusion – Quantitative MSAT Analysis

• Analysis identifies emission changes of a project over time • Identifies the projects impacts across an entire network, rather than a localized

analysis • Includes the qualitative MSAT analysis • Quantitative analysis should support the national analysis trend of decreasing

MSAT over time. • Requires MPO to adjust their TDM to provide traffic data for the analysis

68

MSAT Analysis

69







Procedural






MSAT is considered a NEPA requirement. The MSAT requirement is in FHWA guidance, rather than rule.


MSAT Analysis

Applicability

A qualitative MSAT analysis applies if all of the following apply: – Project adds capacity – A quantitative MSAT analysis is not otherwise required – Not otherwise exempt from a MSAT analysis

A quantitative MSAT analysis applies if all of the following apply: – It is a FHWA/FTA project – Any of the following apply:

• Adds capacity and design year* AADT > 140,000 vpd • Affects a major intermodal facility • Public concern over air quality

– Determined to need a quantitative analysis during MSAT conference call – Not otherwise exempt from a MSAT analysis

* The design year correlates to the out year of the MTP (e.g., 2035 for the 2035 MTP or 2040 for the 2040 MTP)

70

MSAT Analysis

Exemptions

Projects listed in 40 CFR 93.126

Other projects with no meaningful MSAT impacts – Not adding capacity, and – Not expected to significantly increase diesel-fueled traffic vs the no-build

71

MSAT Analysis


MSAT conference call* is required to establish: – Whether a quantitative analysis is required – Which models to use – The appropriate base and design years – If an interim year is necessary – The methodology for determining the affected network (i.e., +/- 5% volume

change) – Which Travel Demand Model (TDM) network years to use

* Participants should include the ENV air specialist, district coordinator, contractor performing the analysis, the MPO, and the FHWA air specialist (cannot participate for NEPA assigned projects)

72

MSAT Analysis

73

Qualitative MSAT analysis template language

A quantitative MSAT technical report

Analysis summary in environmental document which includes the qualitative MSAT analysis

Qualitative MSAT Quantitative MSAT


Documentation that the project is exempt from MSAT requirements

Exempt from MSAT

• An MSAT analysis can either be qualitative or quantitative • A quantitative MSAT analysis includes and incorporates the qualitative MSAT

analysis

MSAT Analysis

74

• As a NEPA requirement, potential MSAT impacts should be disclosed to the public during applicable NEPA public involvement activities

• For Environmental Impact Statements (EISs), a qualitative MSAT analysis can be included in the Draft EIS, with the quantitative MSAT included in the Final EIS

Mandatory:

- Prior to public hearing, if required

- Prior to NEPA decision

Mandatory:

- CEs and EISs: Prior to NEPA decision

- EAs: Prior to public hearing, if required

Recommended:

- Qualitative MSAT analysis in DEIS for all alternatives with quantitative MSAT analysis in FEIS for preferred alternative


Timing

MSAT Analysis

75

• No project level modeling is required for the qualitative MSAT analysis • Both the MPO’s TDM and emissions modeling are required for a quantitative MSAT

analysis • ENV maintains a table of MSAT emission rates to prevent the need for running the

emission model separately.

None

Traffic Data - Travel Demand Model data obtained from MPO

Emissions Model - MOVES

Dispersion Model - None Required


Applicable Models

MSAT Analysis

76

Qualitative MSAT analysis template language

A quantitative MSAT technical report




Documentation that the project is exempt from a MSAT analysis




Exempt from MSAT

• A quantitative MSAT technical report is now a requirement. • If there is no environmental review document, qualitative MSAT language should be

uploaded into ECOS.

MSAT Analysis

Example

Appendix F

77

MSAT Analysis

Summary An MSAT analysis can either be qualitative or quantitative.

The quantitative analysis is not localized but it does capture the project

specific emissions

Added capacity FHWA projects with an AADT over 140,000 vpd will require a quantitative analysis. Projects with potential litigation risk and specific public concern regarding air quality may also be subject to a quantitative analysis

MSAT conference call is required when a quantitative analysis is anticipated

A qualitative analysis is documented in the environmental review document or project-file. A MSAT technical report documents a quantitative analysis.

78

CMP

79

CMP

Description

The Congestion Management Process (CMP) discussion is a disclosure that applicable projects come from the MPOs CMP, and identification of reasonable travel demand reduction and operational management strategies in the corridor to be incorporated into the project or committed to by the State and MPO for implementation.

80

CMP

81







Procedural






CMP is a requirement of the Transportation Code and not NEPA. It is a substantive requirement that applicable projects come from a CMP.


CMP

Applicability

A CMP analysis applies if all of the following apply: – FHWA/FTA project – In a nonattainment area for ozone or CO – Adds capacity – Within a Transportation Management Area (TMA)

82

CMP

83

Identifying areas where a project level CMP analysis is required: Dallas, Fort Worth, and Houston all require project level CMP analyses. El Paso is not listed because it only has a MA for CO and is attainment for ozone.

Dallas

Fort Worth

Houston

Dallas-Fort Worth-Arlington Houston San Antonio Austin El Paso McAllen Denton—Lewisville Corpus Christi Conroe—The Woodlands Lubbock Laredo Killeen Brownsville

Dallas

Fort Worth

Houston

Nonattainment Area Districts for Ozone or CO TMAs in Texas Districts in Which a CMP

Analysis Applies

Geographic Applicability

CMP

Exemptions

Not a FHWA/FTA project

NOT located within a nonattainment area for ozone and CO

NOT adding capacity

NOT located within a TMA

84

CMP


If the MPO does not have a process in place to look this information up, then coordinate with the MPO to: – Identify any reasonable travel demand reduction and operational management

strategies that may be applicable to the project – Identify other operational improvements within the corridor – Obtain a CMP waiver if it is not included in the MPO’s CMP

85

CMP


The project must come from an MPO’s approved CMP.

“All identified reasonable travel demand reduction and operational management strategies shall be incorporated into the SOV project or committed to by the State and MPO for implementation.”1

1 Quotes from 23 CFR 450.320

86

CMP

Timing

Mandatory - Prior to the NEPA decision

87

CMP

Applicable Models

NOT APPLICABLE

88

CMP

89

• If there is no environmental review document, the CMP disclosure language should be uploaded into ECOS.

Documentation that project is exempt from a CMP




The applicable CMP disclosure language.

Exempt from a CMP CMP Req’d


CMP

Example

Appendix G ITEMs 21 & 22

90

CMP

Summary

A project-level CMP analysis is simply a disclosure statement identifying that a project comes from an MPO’s CMP and also identifies operational improvements in the corridor.

It is required for added capacity FHWA projects that are located in a NA for ozone or CO and that are also located within an area large enough to be identified as a TMA (i.e., DAL, FTW, and HOU)

The CMP disclosure statement should be documented in either the environmental review document or the project-file

91


92


Description

Potential construction emissions and any proposed mitigation measures have to be disclosed in NEPA documents. Standard disclosure language is available to address this requirement.

93


94







Procedural






Construction Emission disclosure is considered a NEPA requirement. The requirement is in FHWA guidance, rather than rule.



95

This is a procedural requirement, so we only need to disclose potential impacts. Dust suppression is built into our construction specs, so an EPIC is not needed. TERP only applies to NA/MAs or near-nonattainment areas.

Applicability: All projects that will have a construction component.

Exemptions: None.

Coordination: None.

Timing: Prior to NEPA decision.

Modeling: None.

In the environmental review document:

Identify any anticipated construction related emissions

PM

Diesel PM

Identify any mitigation measures to be utilized during construction

Dust suppression

TERP

Applicability and Exemptions Coordination, Timing,, & Modeling

Compliance and Documentation


Example

Appendix G Item 23

96


Summary

Is simply the disclosure of potential construction emissions and mitigation

It is required for any project which requires an environmental review document (i.e., all EAs and EISs).

The construction emission disclosure statement should be documented in the environmental review document

97

TCEQ MOU

98

TCEQ MOU

Description

Coordination of an environmental review document with TCEQ. ENV project delivery generally performs this coordination.

99

TCEQ MOU

100







Procedural






It is Texas law that requires a MOU with resource agencies. The MOU is located in TxDOT’s environmental rules.


TCEQ MOU

101

Coordination is typically performed by ENV-PD after document is complete. Coordination can be performed early using an air quality tech report to summarize.

Applicability: All EIS documents and all EA documents that are adding capacity in a NA/MA.

Exemptions: CEs.

Coordination: TCEQ.

Timing: Prior to NEPA decision.

Modeling: None.

Documentation of coordination activity in the project file.

• Letter to TCEQ

• Possible response from TCEQ

Applicability and Exemptions Coordination, Timing,, & Modeling

Compliance and Documentation

TCEQ MOU

Summary

The coordination of an EA or EIS with TCEQ for an air quality review

ENV-PD will usually perform the coordination after document completion

Documentation of the coordination should be in the project file

102

New Guidance

103

New Guidance

104

Comparison of the old air quality (AQ) guidance to the new AQ guidance The environmental handbook will now be the primary document for identifying how

to achieve compliance. New Standard Operating Procedures (SOPs) will provide step-by-step instructions. New document standards and review standards will allow for consistency among

various documents and the review of those documents.

AQ SOP

AQ SOU

2006 AQ Guidelines

Environmental Handbook

AQ Toolkit

7 SOPs

4 Document Standards

4 Review Standards

Misc. Forms

Old ENV Guidance New ENV Guidance

New Guidance

Guidance Structure The Environmental Handbook will provide the actual compliance regulations

and requirements. The AQ Toolkit will provide the supplemental guidance to support the

environmental manual compliance activities and will include the following: – SOPs – Document Standards – Review Standards

SOPs will include step-by-step instructions for completing a specific air quality analysis or documentation.

Document Standards will provide a specific format and content requirements for documents to support air quality analyses. – In the case of conformity, the document standard is a specific form.

Review Standards will provide a checklist to help reviewers identify whether documents are complete and correct.

105

New Guidance

106

Note that there is a specific report form or technical report required for each air quality element except CMP and Construction Emissions The SOP for Air Quality Statements contains disclosure language for each of the air

quality analyses for the environmental review document or project file.

Conformity

Hot-Spots

CO TAQA

MSAT Analysis

CMP


Air Quality Statements

Conformity Report Form

Hot-Spot Technical Report

CO TAQA Technical Report

Quantitative MSAT Technical Report

Conformity Report Form

Hot-Spot Technical Report

CO TAQA Technical Report

Quantitative MSAT Technical Report

SOPs Document Standards Review Standards

New Guidance

107

SOPs for Individual AQ Analyses

Technical Reports & Forms

Each SOP is the starting point for each air quality element The SOP will identify applicable technical reports and forms required The SOP on AQ Statements is the final SOP to use to identify appropriate language

and analysis summations for environmental review documents.

Environmental Handbook or Scope Development Tool

SOP on AQ Statements

New Guidance

New process for conformity

SOPs – step-by-step instructions

New forms – Conformity Report Form – Hot-Spot Forms

108

Required Tech Reports – CO TAQA – Quantitative MSAT

Documentation standards for: – Hot-Spots – CO TAQAs – Quantitative MSAT

What’s ?

New Guidance

Example

Appendix H

109

New Guidance

Summary

Environmental handbooks are now the compliance guidance documents

The air quality handbook and other associated compliance tools are located in the Air Quality Toolkit (http://www.txdot.gov/inside-txdot/division/environmental/compliance-toolkits/air-quality.html).

The air quality toolkit consists of the air quality handbook, SOPs, documents standards, and review standards

Whereas the handbook provides overall compliance requirements, the SOPs have specific detailed procedures on how to comply and when to perform analyses and how to document them

110

http://www.txdot.gov/inside-txdot/division/environmental/compliance-toolkits/air-quality.html








Q&A

Any Questions?

Tim Wood TxDOT ENV Air Specialist 512-416-2659 [email protected]

111

mailto:[email protected]

Acronyms AADT – Annual Average Daily Traffic

AERMOD – current EPA approved steady-state dispersion model

AQ – Air Quality

BMT – Beaumont District

CAA – Clean Air Act

CAFÉ – Corporate Average Fuel Economy

CAL3QHC(R) – current EPA approved dispersion model to incorporate intersections

CALINE – current EPA approved line source dispersion model

CE – Categorical Exclusion

CFR – Code of Federal Regulations

CMP – Congestion Management Process

CO - Carbon Monoxide

DAL – Dallas District

DEIS – Draft EIS

DFW – Dallas/Fort Worth

EA – Environmental Assessment

ECOS – Environmental Compliance Oversight System

EIS – Environmental Impact Statement

ELP – El Paso District

ENV – TxDOT Environmental Affairs Division

EPA – Environmental Protection Agency

FEIS – Final EIS

FHWA – Federal Highways Administration

FTA – Federal Transit Administration

FTW – Fort Worth District

HGB – Houston-Galveston-Brazoria

HOU – Houston District

IAJ – Interstate Access Justification

MA – EPA designated maintenance area

MOU – Memorandum of Understanding

MOVES – current EPA emissions model

MPO – Metropolitan Planning Organization

MSAT – Mobile Source Air Toxics

MTP – Metropolitan Transportation Plan

MVEB – Motor Vehicles Emissions Budget

NA – EPA designated nonattainment area

NAAQS – National Ambient Air Quality Standards

NEPA – National Environmental Policy Act

NO2 – nitrogen dioxide

O3 – ozone

Pb – lead

PD – ENV’s Project Delivery Section

PM – particulate matter

PM10 – particulate matter 10 microns or less

POAQC – Project of Air Quality Concern

Q&A – Questions and Answers

SIP – State Implementation Plan

SO2 – sulfur dioxide

SOP – Standard Operating Procedure

SOU – Standard of Uniformity

SOV – Single Occupancy Vehicle

STIP – Statewide Transportation Improvement Program

TAC – Texas Administrative Code

TAQA – Traffic Air Quality Analysis

TCEQ – Texas Commission on Environmental Quality

TDM – Travel Demand Model

TERP – Texas Emission Reduction Plan

TIP – Transportation Improvement Program

TMA – Transportation Management Area

TPP – TxDOT Transportation Planning and Programming Division

TxDOT – Texas Department of Transportation

vpd – vehicles per day

Transportation Conformity Report Form

Form Version 2 TxDOT Environmental Affairs Division 210.01.FRM Effective Date: October 2015 Page 1 of 8

Project Facility Name:

MPO Project IDs:

Project CSJ Numbers:

Project Limits

From:

To:

Project Sponsor:

Project Description1:

Date of anticipated environmental decision/re-evaluation:

Let Year:

ETC2 Year:

Conformity Year3:

Total Project Cost:

Adding Capacity? Yes No

Counties:

Project Classification: CE EA EIS Re-evaluation

Important Information

A determination of project-level conformity is not permanent. It is recommended that conformity be checked early and often in the project development process, but that this specific form be coordinated within 60 days of the anticipated environmental decision to avoid coordinating the form more than once. The following events would require a project’s conformity determination to be reevaluated.

1. Changes to the project’s design concept, scope, limit, funding, or estimated time of completion (ETC) year

2. Changes to the project’s listing in the MTP, TIP, or STIP related to design concept, scope and limits; funding or ETC year

3. New conformity determinations on the applicable MTP, TIP, or STIP (even if it occurs after the FHWA/FTA project-level conformity determination has been made)

1 Project description, project details, and other project information should include enough detail in order to make a

determination of project consistency with the MTP, TIP, STIP, and corresponding transportation conformity determination.

2 The ETC or estimated time of completion year is the date the entire project as described in the environmental review document will be open to traffic.

3 If this project is NOT considered regionally significant by the MPO, enter “N/A – non-regionally significant”. In addition, note that the conformity year is sometimes referred to as the network year. When a MTP identifies a specific timeframe during which a project will be operational, the last year of that timeframe is the conformity year.



In particular, if there is a planned MTP update/amendment and associated transportation conformity determination expected to be completed on or near the time of project approval, it is recommended that the project sponsor prepare this conformity determination after the plan update/amendment and associated transportation conformity determination is completed, if the update/amendment will affect the project as specified in item 1 above. Consult with ENV air specialist if further assistance is needed.

Instructions

Check the appropriate box for each question, using the most current information available, and be aware that the answers will dictate which questions must be answered for each specific project. Start with Step One, and follow the instructions included in each step, if any additional instructions are provided.

The information displayed between carets, <like this> represents a field that should be customized with project specific information. In the electronic file, these fields are highlighted in grey. Content prompts, like Choose an item, represent dropdown menus, which also must be customized with project specific information.

If the form requires the preparer to “STOP” because something is lacking, then it is recommended that the time it would take to make the necessary changes to the MTP, TIP, or project should be re-evaluated against the project’s proposed letting date (i.e., letting date may need to be adjusted).

Step 1: Is this a federal project with a federal lead other than FHWA/FTA?

Yes – STOP. Transportation conformity does not apply to the project, however, general conformity may apply.

Consult the ENV air specialist regarding this project and potential general conformity requirements.

No – Continue to Step 2.

Step 2: Is this a FHWA/FTA project4?

Yes – Proceed to Step 4.


Step 3: Is this project considered regionally significant5 in accordance with 40 CFR 93.101 or 30 TAC 114.260(d)(2)(iv)?

Yes – Continue to Step 4.

No – STOP. In accordance with 40 CFR 93.102(a)(2), a project level transportation conformity determination is not required for non-regionally significant, non-FHWA/FTA projects.

4 Note that this includes projects which may not have federal funding but would otherwise require federal approval. 5 If a project is on the MPO’s NON-regionally significant project list, it is not regionally significant. Each MPO may

have different criteria for designating a project as regionally significant.

http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&SID=a9efb3c6603e31c121420aff467f9195&rgn=div5&view=text&node=40:21.0.1.1.7&idno=40#40:21.0.1.1.7.1.1.2

https://texreg.sos.state.tx.us/public/readtac$ext.TacPage?sl=R&app=9&p_dir=&p_rloc=&p_tloc=&p_ploc=&pg=1&p_tac=&ti=30&pt=1&ch=114&rl=260

https://texreg.sos.state.tx.us/public/readtac$ext.TacPage?sl=R&app=9&p_dir=&p_rloc=&p_tloc=&p_ploc=&pg=1&p_tac=&ti=30&pt=1&ch=114&rl=260



Step 4: Is the project located in a nonattainment or maintenance area6 for ozone7, nitrogen dioxide (NO2), carbon monoxide (CO), particulate matter (PM2.5 or PM10)?

Yes – Transportation conformity rules apply. The project is located in the EPA designated <insert area's name> <insert area's classification>8 area for <insert appropriate NAAQS>. Continue to Step 5.

No – STOP. Transportation conformity does not apply to the project.

Step 5: Is the project exempt9 from conformity in accordance with 40 CFR 93.12610 or 40 CFR 93.12811?

Yes – STOP. Transportation conformity does not apply to the project. This project falls under the following exemption: Choose an item.


Step 6: Is the project exempt from the regional conformity analysis in accordance with 40 CFR 93.127?

Yes – The project is exempt from regional conformity requirements. This project falls under the following exemption: Choose an item. Proceed to Step 16.


Step 7: Does the project fall within the boundaries12 of an MPO?



6 If unsure about the nonattainment or maintenance status, it can be checked in multiple locations, including: the EPA

Greenbook, the TCEQ website, or the applicable table in the Air Quality toolkit. 7 Note the 1997 ozone standard was revoked by EPA. 8Area classifications can be either maintenance, marginal nonattainment, moderate nonattainment, serious

nonattainment, severe nonattainment, or extreme nonattainment 9 Most added capacity projects will not be exempt, whereas most non-added capacity projects will be exempt. 10 Ultimately, the interpretation of what projects types meet these exemption criteria is under the purview of the

federal lead agency. For example, although it could be interpreted to meet some of the exemption project types, a project changing from general purpose to managed lanes is NOT considered to be exempt from conformity.

11 Grouped CSJ projects, by rule, must be exempt under these criteria. 12 i.e., within a Metropolitan Planning Area (MPA)


http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&SID=1bc04b70706402f409a527b0f12490fd&rgn=div5&view=text&node=40:21.0.1.1.7&idno=40#40:21.0.1.1.7.1.1.29

http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&SID=1bc04b70706402f409a527b0f12490fd&rgn=div5&view=text&node=40:21.0.1.1.7&idno=40#40:21.0.1.1.7.1.1.29


http://www.epa.gov/airquality/greenbook/

http://www.epa.gov/airquality/greenbook/

http://www.tceq.state.tx.us/airquality/sip/




Step 8: Is the project design concept, scope and limits, conformity analysis year, and funding consistent with an approved13 regional conformity analysis for an isolated rural area that meets the requirements of 40 CFR 93.109?

Yes – The project is consistent with an approved regional conformity determination that meets the requirements of 40 CFR 93.109 for isolated rural areas. Proceed to Step 16.

No – STOP. The project is not consistent with a regional conformity determination for an isolated rural area. TxDOT will not take final action until the project is consistent with an approved regional conformity determination that meets the requirements of 40 CFR 93.109 for isolated rural areas.

Do not sign this form. Please ensure that the project is included in and consistent with an approved regional conformity determination then reevaluate the project using this form.

Step 9: Are all of the project phases14 for the entire project described in the environmental document included in the fiscally constrained portion of the MTP?


No – STOP. The project was not included in the area’s regional conformity determination, and, therefore, is not consistent with it. The MTP needs to be amended to include this project and a new conformity determination needs to be made on the MTP before consistency can be determined for the project, or the project needs to be revised to be consistent with the existing MTP.

Consult with the district TP&D and MPO on how to proceed.

Step 10: Is at least one phase of the project beyond the NEPA study (corridor study) included in either the appropriate year of the conforming TIP15 or in Appendix D (if will not be let within the timeframe of the TIP)?


No – STOP. The project is not included in the conforming TIP and is therefore not consistent with it. At least one phase of the project must be added to the conforming TIP before consistency can be determined.


13 The consultation partners are responsible for approving regional conformity analyses. 14 A project phase is a separate portion of a project such as: NEPA study, ROW acquisition, final design,

construction, and/or partial construction. 15 In Texas, a conforming TIP is one that has been included into the STIP, so projects must be in the STIP in order to

show that they come from a conforming TIP.




Step 11: Are the current project limits the same16 or do they fall within the project limits listed in the MTP and STIP?


No – STOP. The project is not consistent with the conforming MTP and TIP. Either the MTP and TIP, or the project needs to be revised before consistency can be determined.


Step 12: Is the activity being proposed the same as that in the MTP and STIP project description in both type17 of facility and number18 of lanes?


No – STOP. The project is not consistent with the conforming MTP and TIP. Either the MTP and TIP, or the project needs to be revised before consistency can be determined.


Step 13: Does the project’s ETC year fall between its identified conformity year19 in the MTP and the previous conformity year identified in the MTP?


No – STOP. The project is not consistent with the conforming MTP and TIP. Either the MTP and TIP or the project needs to be revised before consistency can be determined.


N/A – This project is non-regionally significant. Continue to Step 14.

Step 14: Is the estimated total project cost or the cost identified in the MTP greater than $1,500,000?


No – Fiscal constraint requirements do not apply. This project is consistent with the currently conforming MTP and TIP. Proceed to Step 16.

16 The limits are considered the same if the logical termini noted in the environmental document fall within the limits of

the project noted in the MTP or the logical termini noted in the environmental document are not significantly greater (~1mile) than the limits noted in the MTP due to transition areas for safety or other factors required to be considered when establishing logical termini for environmental document purposes.

17 The type of activity refers to the type of enhancement, such as: main lanes, frontage roads, HOV lanes, direct connectors, bridge replacement, etc…

18 The number refers to the amount of each activity type, such as: number of main lanes or number of frontage lanes. 19 For the purposes of this determination, the term conformity year is synonymous with the network analysis year for

the MTP.



Step 15: Does the estimated project cost exceed what is contained in the MTP by more than 50%20?

Yes – STOP. The project is not consistent with the MTP and TIP because it is not fiscally constrained. Either the MTP and TIP, or the project needs to be revised before consistency can be determined or a case-by-case decision will need to be made by FHWA.


No – This project is consistent with the currently conforming MTP and TIP. Continue to Step 16.

Step 16: Is the project located in either a CO, PM2.5, or PM10 nonattainment or maintenance area?21


No – Hot-spot conformity requirements do not apply. Proceed to Step 21.

Step 17: Is this a state or local project with NO federal funding and NO federal decision required?

Yes – Hot-spot conformity requirements do not apply. Proceed to Step 21.

No – Hot-spot conformity requirements apply. Request the local MPO to initiate a consultation call with the Consultation Partners.

Fill out the Hot-Spot Analysis Data for a Consultation Partner Decision Form to present the project data to the Consultation Partners for review prior to the consultation call.

Continue to Step 18.

Step 18: Did the consultation partners determine that this is a project of air quality concern (POAQC)?

Yes – A hot-spot analysis is required and must be approved by the consultation partners.

Conduct a hot-spot analysis in accordance with the methodology approved by the consultation partners, and use the applicable EPA hot-spot guidance.


No – A hot-spot analysis is not required because the project is not a POAQC. The consultation partners made this determination on <insert date>.

Proceed to Step 21.

20 Multiply the MTP cost by 1.5. The current estimated total project cost should not exceed this amount. 21 Note that this currently only applies to projects in El Paso.

http://www.epa.gov/otaq/stateresources/transconf/projectlevel-hotspot.htm



Step 19: Does the approved hot-spot analysis verify that the project will not cause, contribute to, or worsen a violation of applicable CO, PM2.5, or PM10 NAAQS or that the project will at least improve conditions from that of the no-build alternative?

Yes – The project is not anticipated to cause, contribute to, or worsen a violation of the applicable NAAQS. Continue to Step 20.

No – STOP. The project, as it is currently presented, does not comply with conformity requirements because it is anticipated to cause, contribute to, or worsen a violation of the applicable NAAQS.

Identify and get consultation partner agreement upon mitigation measures to offset project impacts to air quality. Reevaluate this project using this form once these mitigation measures have been identified and committed to.

Step 20: Have all the agreed upon mitigation measures as well as any applicable SIP control measures received a written commitment?


No – STOP.

Do not proceed until there are written commitments to implement all the agreed upon mitigation measures and any applicable SIP control measures. Reevaluate this project using this form once these commitments have been made in writing.

N/A because no mitigation is required and there are no applicable SIP control measures which affect this project, Continue to Step 21.

Step 21: The transportation conformity evaluation is complete.

Attach applicable pages of the MTP and TIP, or the STIP, project schematics, typical sections, hot-spot analyses and determinations, and any conformity related public comment and response. Implement the following processing instructions as applicable.

This is a regionally significant State-only project with no FHWA/FTA action required (the answer to Steps 3 is yes); therefore:

Submit this form to the ENV air specialist. If ENV concurs that all project level conformity requirements have been met, ENV shall sign the form below. Coordination with FHWA/FTA is not required.

Retain this form in the project file.

This is a FHWA/FTA non-exempt project (the answer to Steps 2 and 4 is yes, and the answer to Steps 5 and 6 is no); therefore:

Submit this form to the ENV air specialist. After ENV air specialist review, ENV will coordinate this form with FHWA/FTA for a project level conformity determination. If FHWA/FTA agrees that all project level conformity requirements have been met, they shall sign the project level conformity determination line below. A project level conformity determination is not complete and project clearance cannot be given until FHWA/FTA signs this form.

Retain this form and any coordination with FHWA/FTA in the project file.



TxDOT ENV Transportation Conformity Validation Complete:

Project CSJ Numbers: <Enter CSJ Number>

Signature ____________________________________________________________

Name:

Title:

Date:

FHWA/FTA Determination of the Project-level Conformity:

Signature ____________________________________________________________

Name: _________________________________________________________________

Title: _________________________________________________________________

Date: _____________________________________

Hot-Spot Analysis Data for a Consultation Partner

Form Version 1 TxDOT Environmental Affairs Division 210.03.FRM Release Date: 2/2014 Page 1 of 4

This form is filled out by the project sponsor and is sent to the consultation partners immediately after an MPO schedules a conference call with the consultation partners. The data recorded using this form is necessary for the consultation partners to decide whether the proposed project is a “project of air quality concern.”

I. Project Details Project Element Describe

CSJs

Location -County/City/Roadway Name/Mile-Post Attach a map showing the proposed project site.

Project Type

Project Sponsor

Traffic Analysis Results If there was a traffic analysis study done for this project, provide information on the scope and who performed the analysis, and attach the results.

Ready to Let Date

Letting Date

Proposed Hearing Date

Proposed Start of Construction Date

Target Completion Date

Other

II. Reasons for a Determination from the Consultation Partners Check any boxes that apply in the first 4 rows.

1 FHWA/FTA funded project or project that requires FHWA/FTA action (e.g. interstate access) 2 The proposed project is located within a PM10 non-attainment or maintenance area. 3

The proposed project is located within a PM2.5 non-attainment or maintenance area. Note: None currently in Texas.

4 The proposed project is located within a CO non-attainment or maintenance area.

Hot-Spot Analysis Data for a Consultation Partner Decision


5 Applies

to Criteria

6 PM New/expanded highway project with a significant number of diesel vehicles 7 PM New exit ramp or other highway facility improvement project to connect a highway

or expressway to a major freight, bus, or intermodal terminal 8 PM Affects an intersection that is at or will change to a Level-of-Service D, E, or F with

significant number of diesel vehicles 9 PM New/expanded bus or rail terminal or transfer point with a significant number of

diesel vehicles congregating at a single location 10

PM In or affects a location, area, or category of site identified in the applicable PM State Implementation Plan or Implementation Plan submission, as a site of violation or possible violation

11 PM Other: 12 CO Affects locations, areas, or categories of sites identified in the applicable CO State

Implementation Plan as sites of violation or possible violation 13 CO Affects intersections that are at Level-of-Service D, E, or F, or those that will

change to Level-of-Service D, E, or F because of increased traffic volumes related to the project

14 CO Affects one or more of the top three intersections in the nonattainment or maintenance area with highest traffic volumes, as identified in the applicable State Implementation Plan

15 CO Affects one or more of the top three intersections in the nonattainment or maintenance area with the worst level of service, as identified in the applicable State Implementation Plan

16 CO Other:

Explanation Provide a more detailed explanation of how this project meets or does not meet the above criteria in rows 6-11 for PM nonattainment or maintenance areas and 12-16 for CO nonattainment or maintenance areas, so Consultation Partners can make a decision if the project is or is not a project of air quality concern. If needed, contact ENV air specialist for assistance.

<Enter Explanation >



III. Available Network Section Traffic Data for the Project Use all available traffic data to fill out the table, and include a reference to the source of the traffic data in the field below the table. This information should be provided for each intersection and interchange and for each section of the proposed project delineated in the traffic analysis.

DATA TYPE

<Insert Section,

Intersection, Interchange>

<Insert Base Year>

Existing

<Insert ETC Year> No-Build

<Insert Base Year> Build

<Insert Design Year>

No-Build

<Insert Design Year> Build

Annual average daily traffic (AADT)

Peak-hour traffic volume (% of AADT)(k)

Directional split in peak-hour (D)

Truck percentage, daily or peak-hour (T)

Average speed (most likely for peak-hour)

Level of Service

Other

Source of Information, Key Assumptions, and Method

Attach any additional traffic data and analyses to this document.



Appendix A The following table shows the revision history for this guidance document.

Revision History

Effective Date Month, Year Reason for and Description of Change

Documentation Standard for a Hot-Spot Analysis Technical Report

Standard Version 1

TxDOT Environmental Affairs Division 210.01.DS Release Date: 2/2014 Page 1 of 4

Use this document standard for developing a hot-spot analysis technical report, which must include the

components outlined below. The documentation standard is a tool used to state the requirements

necessary for a document to be classified as a certain type of document. Documentation standards are

used by technical experts as they write environmental review documents and environmental reports.

I. Project Description

The hot-spot analysis technical report must include the following components related to the project description.

A. An identification of the project location

B. A brief explanation of the current facility

C. A brief explanation of the proposed facility

D. An identification of estimated time to completion (ETC) year

E. An identification of the design year of the project

II. Background Information

The hot-spot analysis technical report must include the following components related to background

information on hot-spot compliance.

A. An identification of the Clean Air Act (CAA) as the law requiring project-level conformity

determinations

B. An identification of the conformity rule (40 CFR 93) as the implementing rule for conformity

determinations and hot-spot requirements

C. A brief description of project types that are subject to hot-spot analysis (i.e., “projects of air quality

concern”)

D. An identification of the current attainment status of the project area.

III. Consultation Partner Decision

The hot-spot analysis technical report must include the following components related to the Consultation

Partner decision regarding whether this is a “project of air quality concern.”

A. An identification of who the Consultation Partners are

B. An identification of the date of initial Consultation Partner coordination

C. A statement that the Consultation Partners determined that this is a “project of air quality

concern”

D. An identification of the reason that the Consultation Partners made this determination


Standard Version 1


IV. Analysis Methodology

The hot-spot analysis technical report must include the following components related to the hot-spot

analysis methodology.

A. A description of the overall methodology being used

B. A description of the methodology for determining background concentrations

C. A description of other area sources included in the analysis

D. An identification of the future years analyzed in the analysis

E. An identification of receptor locations used in the analysis, including a map showing the receptor

locations

F. An identification of the specific models used in the analysis

G. An identification of the source of the input data (e.g., TCEQ meteorological data, TPP traffic data,

MPO fleet and fuel data, etc…)

H. A table identifying the specific traffic data used for each year and alternative analyzed

I. A table identifying the background concentrations used in this analysis

J. An identification of the specific months analyzed in the analysis

K. An identification of any other input data that would be considered significant to disclose

L. A statement identifying when coordination was performed with the Consultation Partners

regarding this analysis methodology

M. A concluding statement that the Conformity Consultation Partners reviewed and approved the

analysis methodology

V. Analysis Results

The hot-spot analysis technical report must include the following components related to the hot-spot

analysis results.

A. A table of the emission results at each receptor for each alternative analyzed and for each year

analyzed

B. A statement that the emission results presented include background concentrations and other

point-source contributions that were analyzed as part of this analysis

C. A statement identifying what mitigation measures, if any, were included as part of the analysis


Standard Version 1


D. A summary of the analysis results, which indicates that the project emissions (including any

associated mitigation measures, if needed) either will remain below the applicable National

Ambient Air Quality Standard (NAAQS) or the build alternative emissions will be lower than the

no-build alternative emissions

VI. Mitigation Commitments

The hot-spot analysis technical report must include the following components related to the mitigation

commitments.

A. A list of any SIP required mitigation requirements

B. A list of any mitigation measures that were assumed in the analysis

C. A signed statement from the project sponsor committing to implementation of each of these

mitigation measures

VII. Public Involvement

The hot-spot analysis technical report must include the following components related to the public

involvement requirements.

A. A statement identifying that Consultation Partner decisions require public involvement

B. A statement identifying the specific public involvement* that will be used

* The hot-spot public involvement requirements can and should be combined with NEPA public

involvement, except in the case that no further NEPA public involvement is anticipated.


Standard Version 1


Appendix A

The following table shows the revision history for this guidance document.

Revision History

Effective Date

Month, Year Reason for and Description of Change

Draft Traffic Air Quality Analysis (TAQA) The primary pollutants from motor vehicles are volatile organic compounds (VOCs), carbon monoxide (CO,) and nitrogen oxides (NOx). Volatile organic compounds and nitrogen oxides can combine under the right conditions in a series of photochemical reactions to form ozone. Because these reactions take place over a period of several hours, maximum concentrations of ozone are often found far downwind of the precursor sources. Thus, ozone is a regional problem and not a localized condition. The modeling procedures of ozone require long-term meteorological data and detailed area-wide emission rates for all potential sources (industry, business, and transportation) and are normally too complex to be performed within the scope of an environmental analysis for a highway project. However, concentrations for carbon monoxide are readily modeled for highway projects and are required by federal regulations. Topography and meteorology of the area in which the project is located will not seriously restrict dispersion of the air pollutants. The traffic data used in the analysis were obtained from TxDOT’s Transportation Planning and Programming division. The maximum Average Annual Daily Traffic (AADT) projected for the main lanes and frontage roads for the 2035 design year is estimated to be approximately 209,800 vehicles per day. Carbon monoxide concentrations for the Build Alternative were modeled using the worst case scenario (adverse meteorological conditions and sensitive receptors at the right of way line) in accordance with the TxDOT Air Quality Guidelines. The FHWA- and TxDOT-preferred CALINE3 roadway air quality computer model and MOVES2010b emission factors were used in the analysis. Local concentrations of carbon monoxide are not expected to exceed National Ambient Air Quality Standards (NAAQS) at any time. The following Table 1 summarizes the results of the analysis:

Table 1 Project Carbon Monoxide Concentrations

Year One-Hour Standard* Eight-Hour Standard*

Concentration (ppm)

NAAQS (ppm)

Percent of NAAQS

Concentration (ppm)

NAAQS (ppm)

Percent of NAAQS

2018 4.8 35 13.7% 3.0 9 33.3% 2035 4.5 35 12.9% 2.8 9 31.1%

* Analysis includes a one hour background concentration of 3.7 ppm and an 8-hour background concentration of 2.3 ppm.

Documentation Standard for a CO TAQA Technical Report

Standard Version 1

TxDOT Environmental Affairs Division 220.02.DS Effective Date: September 2015 Page 1 of 4

Use this document standard (DS) to prepare a carbon monoxide traffic air quality analysis (CO TAQA)

technical report, which must include the components outlined below. Each section of this DS represents a

required.

I. Project Description

The CO TAQA technical report must include the following components related to the project description.

A. An identification of the project location

B. A brief explanation of the current facility

C. A brief explanation of the proposed facility

D. An identification of each of the build alternatives modeled

E. An identification of estimated time to completion (ETC) year*

F. An identification of the design year** of the project

* Date the entire project as described in the environmental review document as the date the facility

will be open to traffic.

** Typically, the design year for CO analyses is either the out-year (last year) of the current

Metropolitan Transportation Plan (MTP) when a quantitative Mobile Source Air Toxics (MSAT)

analysis is also performed, or the ETC year + 20 years in the rare instances when an MSAT is

not also performed.

II. Background Information

The CO TAQA technical report must include the following components related to background information.

A. A brief explanation of project types that are subject to a CO TAQA

B. An identification of why this particular project is subject to a CO TAQA

III. Analysis Methodology

The CO TAQA technical report must include the following components related to the analysis

methodology.

A. An explanation of the overall methodology being used

B. An identification of the specific models used in the analysis

C. An identification of the 1-hr and 8-hr CO background concentrations* that were used

D. An identification of the source** of the traffic data used


Standard Version 1


E. A table identifying the specific annual average daily traffic (AADT) volume and design hour

volume (DHV) used for each roadway segment analyzed for both the ETC year and design year

F. An identification of the emission rates used

G. An identification of the source of the emission rates (i.e., emission rate table vs MOVES

modeling)

H. An identification of the atmospheric stability class*** used

I. An identification of the mixing height*** used

J. An identification of the wind speed*** used

K. An identification of the wind directions*** modeled

L. An identification of the projected vehicle speeds in the future years analyzed

M. An identification that the input and output files have been submitted to the District for inclusion in

the project files to the extent practicable

* The background concentrations must be consistent with Appendix B of the SOP for Producing a

CO TAQA.

** The traffic data must come from or be otherwise approved by the Transportation Planning and

Programming Division (TPP).

*** These must be consistent with a worst case scenario, as identified in Appendix D of the SOP for

Producing a CO TAQA.

IV. Receptor Locations

The CO TAQA technical report must include the following components related to receptor locations.

A. An aerial map showing the receptor locations for each alternative analyzed

B. Project schematics showing the receptor locations for each alternative analyzed and roadway

geometry

C. A table with a description of all of the receptors analyzed for each alternative analyzed (including

but not limited to distance from roadway, ROW width, traffic volume traffic speed, DHV)

D. An identification of the specific receptors that represent the highest traffic volumes for each

alternative analyzed


Standard Version 1


V. Analysis Results

The CO TAQA technical report must include the following components related to the analysis results. If

the analysis results indicate that CO concentrations at any location are expected to exceed the applicable

CO NAAQS, consult with the ENV air specialist.

A. A table identifying the 1-hr and 8-hr CO emissions at each receptor for both the ETC and design

year

B. An identification of the 1-hr and 8-hr background concentrations for CO and their source

C. An identification of the applicable 1-hr and 8-hr CO NAAQS

D. A brief summary of the analysis results in comparison to the applicable CO NAAQS

E. An identification of any required mitigation (only if the analysis indicates that the project will

exceed the CO NAAQS))


Standard Version 1


The following table shows the revision history for this document.

Revision History

Effective Date


September 2015 Version 1 was released.

1.0 BACKGROUND

Controlling air toxic emissions became a national priority with the passage of the Clean Air Act Amendments (CAAA) of 1990, whereby Congress mandated that the U.S. Environmental Protection Agency (EPA) regulate 188 air toxics, also known as hazardous air pollutants. The EPA has assessed this expansive list in their latest rule on the Control of Hazardous Air Pollutants from Mobile Sources (Federal Register, Vol. 72, No. 37, page 8430, February 26, 2007), and identified a group of 93 compounds emitted from mobile sources that are listed in their Integrated Risk Information System (IRIS) (http://www.epa.gov/iris/). In addition, EPA identified seven compounds with significant contributions from mobile sources that are among the national and regional-scale cancer risk drivers from their 1999 National Air Toxics Assessment (NATA) (http://www.epa.gov/ttn/atw/nata1999/). These are acrolein, benzene, 1,3-butadiene, diesel particulate matter plus diesel exhaust organic gases (diesel PM), formaldehyde, naphthalene, and polycyclic organic matter. While FHWA considers these the priority mobile source air toxics, the list is subject to change and may be adjusted in consideration of future EPA rules. The 2007 EPA Mobile Source Air Toxics (MSAT) rule mentioned above requires controls that will dramatically decrease MSAT emissions through cleaner fuels and cleaner engines. Based on an FHWA analysis using EPA’s MOVES2010b model, as shown in Figure 1 and Table 1, even if vehicle-miles travelled (VMT) increases by 102% as assumed from 2010 to 2050, a combined reduction of 83% in the total annual emissions for the priority MSAT is projected for the same time period.

FIGURE 1: Projected National MSAT Emission Trends 2010 – 2050 For Vehicles Operating on Roadways Using EPA’s MOVES2010b Model

Source: Table 1 below. Note: Trends for specific locations may be different, depending on locally derived information representing vehicle-miles travelled, vehicle speeds, vehicle mix, fuels, emission control programs, meteorology, and other factors.

0

1

2

3

4

5

6

7

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

2010 2015 2020 2025 2030 2035 2040 2045 2050

VMT

(tril

lion/

yr)

MSA

T Em

issi

ons

(ton

s/yr

)

Diesel PM Benzene Formaldehyde AcroleinButadiene Naphthalene Polycyclics VMT

TABLE 1 Projected National MSAT Emission Trends 2010 – 2050

For Vehicles Operating On Roadways Using EPA’s MOVES2010b Model

Pollutant / VMT

Pollutant Emissions (tons) and Vehicle-Miles Traveled (VMT) by Calendar Year % Change

2010 2015 2020 2025 2030 2035 2040 2045 2050 2010

to 2050

Acrolein 1,244 805 476 318 258 247 264 292 322 -74 Benzene 18,995 10,195 6,765 5,669 5,386 5,696 6,216 6,840 7,525 -60 Butadiene 3,157 1,783 1,163 951 890 934 1,017 1,119 1,231 -61 Diesel PM 128,847 79,158 40,694 21,155 12,667 10,027 9,978 10,942 11,992 -91 Formaldehyde 17,848 11,943 7,778 5,938 5,329 5,407 5,847 6,463 7,141 -60 Naphthalene 2,366 1,502 939 693 607 611 659 727 802 -66 Polycyclics 1,102 705 414 274 218 207 219 240 262 -76 Trillions VMT 2.96 3.19 3.5 3.85 4.16 4.58 5.01 5.49 6.0 102 Source: EPA MOVES2010b model runs conducted during May – June 2012 by FHWA. Air toxics analysis is a continuing area of research. While much work has been done to assess the overall health risk of air toxics, many questions remain unanswered. In particular, the tools and techniques for assessing project-specific health outcomes as a result of lifetime MSAT exposure remain limited. These limitations impede the ability to evaluate how the potential health risks posed by MSAT exposure should be factored into project-level decision-making within the context of the National Environmental Policy Act (NEPA). The FHWA, EPA, the Health Effects Institute, and others have funded and conducted research studies to try to more clearly define potential risks from MSAT emissions associated with highway projects. The FHWA will continue to monitor the developing research in this emerging field. Added Capacity projects with FHWA involvement that have a high potential for meaningful MSAT impacts within the existing right of way (a project of MSAT concern), or have an annual average daily traffic (ADT) volume of over 140,000 vehicles are required to complete a quantitative MSAT analysis. The I-30 frontage road project is an added capacity project with federal involvement, and is therefore subject to a quantitative MSAT analysis. The process for completing a quantitative MSAT analysis begins with an MSAT conference call between TxDOT, FHWA and the relevant MPO. The call establishes the parameters for the analysis, including the base year, the design year and whether an interim year should be included in the modeling. The call also determines the schedule for the analysis including the availability of the relevant travel demand model to be used to establish the transportation network affected by the proposed project. Once the appropriate traffic and other data are available, modeling is conducted to determine the potential MSAT emissions that would be expected from the proposed project. For the proposed I-30 frontage road project, the MSAT conference between TxDOT, FHWA and the North Central Texas Council of Governments (NCTCOG)—the MPO for the Dallas-Ft. Worth area—was held on October 23, 2013.

2.0 PROJECT SPECIFIC MSAT INFORMATION

The methodology employed by NCTCOG to determine the affected network for the quantitative MSAT modeling effort involved identifying those roadway links in the 2035 MTP transportation network that experienced a change of +/- 5% in the traffic volume between the no build and build alternatives. This affected network was then used as input for the project-specific MOVES2010b model along with emission rates derived through a separate, regional MOVES modeling effort undertaken by NCTCOG. For the I-30 frontage road MSAT modeling, a base year of 2013 and a design year of 2035 were used; no interim year was chosen for analysis. The numeric results of the MSAT modeling are shown below in Table 2. These results are represented graphically in Figure 2, which shows emissions for each primary MSAT for each affected network (i.e., base year and design year for build and no build scenarios), and Figure 3, which shows total MSAT emissions as compared to total vehicle miles traveled (VMT) for each affected network.

Table 2 MSAT Emissions by Alternative (Tons/Year)

Compound Year/Scenario % Difference 2013-2035

2013 Base Year 2035 Design Year

No Build Build No Build Build

Diesel Particulate Matter (DPM) 4.961 0.8666 0.8502 -82.5 -82.9

Benzene 0.446 0.330 0.332 -25.9 -25.6 Formaldehyde 0.318 0.2494 0.2490 -21.5 -21.6 Butadiene 0.0548 0.0485 0.0488 -11.5 -11.0 Acrolein 0.0241 0.0111 0.0110 -54 -54.2 Polycyclic Organic Matter 0.0015 0.0011 0.0012 -21.4 -20.7 Napthalene 0.068 0.073 0.073 8 8 Total MSAT (Tons) 5.359 1.177 1.160 -78 -78.4 Total VMT (Miles/Year) 133,454,359 265,482,968 268,662,893 99 101 Source: NCTCOG data (2014)

Figure 2: Projected Changes In MSAT Emissions By Project Scenario Over Time

Source: NCTCOG data and Project Study Team (2014). The analysis indicates a decrease in total MSAT emissions can be expected for both the build and No Build Alternatives (2035) relative to the base year (2013). Emissions of total MSAT are predicted to decrease by approximately 78 percent in the 2035 Build Alternative compared with 2013 levels. Of the seven priority MSAT compounds, DPM contributes the most to the emissions total in 2013 as well as in 2035 (see Table 2 and Figure 2). In future years, a substantial decline in DPM is anticipated (82.9% reduction from 2013 to 2035 Build Alternative; 82.5% reduction from 2013 to 2035 No Build). The amount of benzene is expected to decrease by 25.6% for the 2035 Build Alternative and 25.9% for the 2035 No Build. When total emissions are plotted over time, a substantially decreasing level of MSATs can also be seen (Figure 3) while overall VMT continues to rise. The 2035 Build Alternative is expected to generate a 78% decrease in total MSAT emissions while the total VMT increases 101%; the 2035 No Build Alternative has a similar 78% decrease in total MSAT and a 99% increase in VMT.

0.00

1.00

2.00

3.00

4.00

5.00

6.00

Base 2013 Build 2035 No-Build 2035

DPM

Benzene

Formaldehyde

Butadiene

Acrolein

Polycyclic OrganicMatterNaphthalene

Figure 3: Total MSAT Emissions and Vehicle Miles Traveled By Alternative (Tons/Year)

Source: NCTCOG Data and Project Study Team (2014).

3.0 INCOMPLETE OR UNAVAILABLE INFORMATION FOR PROJECT-SPECIFIC MSAT HEALTH IMPACTS ANALYSIS

In FHWA’s view, information is incomplete or unavailable to credibly predict the project-specific health impacts due to changes in MSAT emissions associated with a proposed set of highway alternatives. The outcome of such an assessment, adverse or not, would be influenced more by the uncertainty introduced into the process through assumption and speculation rather than any genuine insight into the actual health impacts directly attributable to MSAT exposure associated with a proposed action.

The U.S. Environmental Protection Agency (EPA) is responsible for protecting the public health and welfare from any known or anticipated effect of an air pollutant. They are the lead authority for administering the Clean Air Act and its amendments and have specific statutory obligations with respect to hazardous air pollutants and MSAT. The EPA is in the continual process of assessing human health effects, exposures, and risks posed by air pollutants. They maintain the Integrated Risk Information System (IRIS), which is “a compilation of electronic reports on specific substances found in the environment and their potential to cause human health effects” (EPA, http://www.epa.gov/iris/). Each

0

50,000,000

100,000,000

150,000,000

200,000,000

250,000,000

300,000,000

0

1

2

3

4

5

6

Base 2013 Build 2035 No-Build 2035

VMT

(mile

s/Ye

ar)

MSA

T (T

ons/

year

)

Year/Scenario

Total MSAT(tons/year)

VMT

report contains assessments of non-cancerous and cancerous effects for individual compounds and quantitative estimates of risk levels from lifetime oral and inhalation exposures with uncertainty spanning perhaps an order of magnitude.

Other organizations are also active in the research and analyses of the human health effects of MSAT, including the Health Effects Institute (HEI). Two HEI studies are summarized in Appendix D of FHWA’s Interim Guidance Update on Mobile source Air Toxic Analysis in NEPA Documents. Among the adverse health effects linked to MSAT compounds at high exposures are; cancer in humans in occupational settings; cancer in animals; and irritation to the respiratory tract, including the exacerbation of asthma. Less obvious is the adverse human health effects of MSAT compounds at current environmental concentrations (HEI, http://pubs.healtheffects.org/view.php?id=282) or in the future as vehicle emissions substantially decrease (HEI, http://pubs.healtheffects.org/view.php?id=306).

The methodologies for forecasting health impacts include emissions modeling; dispersion modeling; exposure modeling; and then final determination of health impacts – each step in the process building on the model predictions obtained in the previous step. All are encumbered by technical shortcomings or uncertain science that prevents a more complete differentiation of the MSAT health impacts among a set of project alternatives. These difficulties are magnified for lifetime (i.e., 70 year) assessments, particularly because unsupportable assumptions would have to be made regarding changes in travel patterns and vehicle technology (which affects emissions rates) over that time frame, since such information is unavailable.

It is particularly difficult to reliably forecast 70-year lifetime MSAT concentrations and exposure near roadways; to determine the portion of time that people are actually exposed at a specific location; and to establish the extent attributable to a proposed action, especially given that some of the information needed is unavailable.

There are considerable uncertainties associated with the existing estimates of toxicity of the various MSAT, because of factors such as low-dose extrapolation and translation of occupational exposure data to the general population, a concern expressed by HEI (http://pubs.healtheffects.org/view.php?id=282). As a result, there is no national consensus on air dose-response values assumed to protect the public health and welfare for MSAT compounds, and in particular for diesel PM. The EPA (http://www.epa.gov/risk/basicinformation.htm#g) and the HEI (http://pubs.healtheffects.org/getfile.php?u=395) have not established a basis for quantitative risk assessment of diesel PM in ambient settings.

There is also the lack of a national consensus on an acceptable level of risk. The current context is the process used by the EPA as provided by the Clean Air Act to determine whether more stringent controls are required in order to provide an ample margin of safety to protect public health or to prevent an adverse environmental effect for industrial sources subject to the maximum achievable control technology standards, such as benzene emissions from refineries. The decision framework is a two-step process. The first step requires EPA to determine an “acceptable” level of risk due to emissions from a

source, which is generally no greater than approximately 100 in a million. Additional factors are considered in the second step, the goal of which is to maximize the number of people with risks less than 1 in a million due to emissions from a source. The results of this statutory two-step process do not guarantee that cancer risks from exposure to air toxics are less than 1 in a million; in some cases, the residual risk determination could result in maximum individual cancer risks that are as high as approximately 100 in a million. In a June 2008 decision, the U.S. Court of Appeals for the District of Columbia Circuit upheld EPA’s approach to addressing risk in its two step decision framework.

Information is incomplete or unavailable to establish that even the largest of highway projects would result in levels of risk greater than deemed acceptable. Because of the limitations in the methodologies for forecasting health impacts described, any predicted difference in health impacts between alternatives is likely to be much smaller than the uncertainties associated with predicting the impacts. Consequently, the results of such assessments would not be useful to decision makers, who would need to weigh this information against project benefits, such as reducing traffic congestion, accident rates, and fatalities plus improved access for emergency response, that are better suited for quantitative analysis.

4.0 CONCLUSION

In this document, a quantitative MSAT assessment of MSAT emissions relative to the various alternatives has been provided acknowledging that both the Build and No Build Alternatives may result in increased exposure to particular MSAT emissions in certain locations, although DPM would decrease substantially between 2013 and 2035 under either alternative. The concentrations and duration of exposures are uncertain, however, and because of this uncertainty, the health effects from these emissions cannot be estimated. Overall, total MSAT emissions for the project are expected to decrease 78% between the base year 2013 and the design year 2035, for both the Build and No Build Alternatives, and therefore mitigation strategies for further reductions are not proposed.

Documentation Standard for a Quantitative MSAT Technical Report

Standard Version 1


Use this document standard (DS) to prepare a quantitative MSAT technical report, which must include

the components outlined below. Each section of this DS represents a required section of the report.

I. Background Information

The quantitative MSAT technical report must include the following components related to background information.

A. The project location and limits

B. A description of the project

C. A brief explanation of project types that are subject to a quantitative MSAT analysis

D. An identification of why this particular project is subject to a quantitative MSAT analysis

E. An identification of the date of the MSAT conference call

II. Qualitative MSAT Analysis

The quantitative MSAT technical report must include the following language related to the qualitative

MSAT analysis.

A. The most current MSAT Background language

B. The most current Project-Specific MSAT Information language

C. The most current Incomplete or Unavailable Information for Project-Specific MSAT Health

Impacts Analysis language

III. Analysis Methodology

The quantitative MSAT technical report must include the following components related to the analysis

methodology, and must be consistent with the meeting minutes from the MSAT consultation call.

A. An identification of the methodology for determining the affected network (e.g., +/- 5% change in

traffic volumes between build and no-build alternatives)

B. An identification of the emission model used in the analysis

C. An identification of the emission rates used

D. An identification of the source of the emission rates (i.e., emission rate table vs MOVES

modeling)

E. An identification of the current MTP and Travel Demand Model (TDM) from which the affected

links were determined (e.g., 2035 RTP Update-2013 Amendment)

Quantitative MSAT Technical Report Documentation Standard

Standard Version 1


F. Maps that show the affected network links

G. An identification of the base year, interim year (if applicable), and design year that were analyzed

IV. Analysis Results

The quantitative MSAT technical report must include the following components related to the analysis results.

A. A table identifying the total MSAT emissions for each primary MSAT and total VMT for each

affected network (i.e., base year, interim year no-build, interim year build, design year no-build,

design year build)

B. A bar chart showing the emissions for each primary MSAT for each affected network and with the

VMT charted on a secondary y-axis.

C. A bar chart showing the total MSAT emissions (aggregate of all primary MSAT) for each affected

network and with the VMT charted on a secondary y-axis

D. A brief analysis of the modeling results

V. Conclusion

The quantitative MSAT technical report must include the following components related to the analysis

conclusion. If the analysis results indicate that total MSAT emissions in the interim or design year are

expected to exceed the applicable total MSAT emissions in the base year, consult with the ENV air

specialist.

A. A statement identifying whether the total MSATs are expected to decrease in the future years

analyzed regardless of the whether the build vs no-build alternative is implemented

Quantitative MSAT Technical Report Documentation Standard

Standard Version 1



Revision History

Effective Date


September 2015 Version 1 was released.

SOPs for Preparing Air Quality Statements

Procedure Version 1 TxDOT Environmental Affairs Division 200.01.SOP Release Date: 7/2015 Page 16 of 23

(http://pubs.healtheffects.org/getfile.php?u=395) have not established a basis for quantitative risk assessment of diesel PM in ambient settings.

There is also the lack of a national consensus on an acceptable level of risk. The current context is the process used by the EPA as provided by the Clean Air Act to determine whether more stringent controls are required in order to provide an ample margin of safety to protect public health or to prevent an adverse environmental effect for industrial sources subject to the maximum achievable control technology standards, such as benzene emissions from refineries. The decision framework is a two-step process. The first step requires EPA to determine an “acceptable” level of risk due to emissions from a source, which is generally no greater than approximately 100 in a million. Additional factors are considered in the second step, the goal of which is to maximize the number of people with risks less than 1 in a million due to emissions from a source. The results of this statutory two-step process do not guarantee that cancer risks from exposure to air toxics are less than 1 in a million; in some cases, the residual risk determination could result in maximum individual cancer risks that are as high as approximately 100 in a million. In a June 2008 decision, the U.S. Court of Appeals for the District of Columbia Circuit upheld EPA’s approach to addressing risk in its two step decision framework.

Information is incomplete or unavailable to establish that even the largest of highway projects would result in levels of risk greater than deemed acceptable. Because of the limitations in the methodologies for forecasting health impacts described, any predicted difference in health impacts between alternatives is likely to be much smaller than the uncertainties associated with predicting the impacts. Consequently, the results of such assessments would not be useful to decision makers, who would need to weigh this information against project benefits, such as reducing traffic congestion, accident rates, and fatalities plus improved access for emergency response, that are better suited for quantitative analysis.

Conclusion

In this document, a qualitative MSAT assessment has been provided relative to the various alternatives of MSAT emissions and has acknowledged that <some, all, or identify by alternative> of the project alternatives may result in increased exposure to MSAT emissions in certain locations, although the concentrations and duration of exposures are uncertain and, because of this uncertainty, the health effects from these emissions cannot be estimated.

20. This project is <select one of the following: “within an attainment or unclassifiable area for ozone and CO”, “not an FHWA/FTA project”, “not adding capacity”, or “not in a TMA”>; therefore a project level CMP analysis is not required.

21. The congestion management process is a systematic process for managing congestion that provides information on transportation system performance and on alternative strategies for alleviating congestion and enhancing the mobility of persons and goods to levels that meet state and local needs. The project was developed from the <insert MPO’s name>’s CMP, which meets all requirements of 23 CFR 450.320 and 500.109, as applicable. The CMP was adopted by <insert MPO’s name> on <insert date of adoption and latest amendment date>.

The region commits to operational improvements and travel demand reduction strategies at two levels of implementation: program level and project level. Program level commitments are inventoried in the regional CMP, which was adopted by <insert MPO’s name>; they are included in the financially constrained MTP, and future resources are reserved for their implementation.



The CMP element of the plan carries an inventory of all project commitments (including those resulting from major investment studies) that details type of strategy, implementing responsibilities, schedules, and expected costs. At the project’s programming stage, travel demand reduction strategies and commitments will be added to the regional TIP or included in the construction plans. The regional TIP provides for programming of these projects at the appropriate time with respect to the single occupancy vehicle (SOV) facility implementation and project-specific elements.

Committed congestion reduction strategies and operational improvements within the study boundary will consist of <insert committed congestion reduction strategies for this project (e.g. signal timing, intersection improvements, pedestrian facilities, etc...)>. Individual projects are listed in Table <Insert Table ID>.

Table <insert Table ID> - Congestion Management Process Strategies

Operational Improvements in the Travel Corridor

Location Type Implementation Date

In an effort to reduce congestion and the need for SOV lanes in the region, TxDOT and <insert MPO’s name> will continue to promote appropriate congestion reduction strategies through the Congestion Mitigation and Air Quality Improvement (CMAQ) program, the CMP, and the MTP. The congestion reduction strategies considered for this project would help alleviate congestion in the SOV study boundary, but would not eliminate it.

Therefore, the proposed project is justified. The CMP analysis for added SOV capacity projects in the TMA is on file and available for review at <insert MPO’s name>.

22. In July 2013, the RTC also adopted a policy that requires the review and application of congestion mitigation strategies to correct corridor deficiencies identified in the CMP when performing corridor and environmental studies and report findings back to NCTCOG. Therefore, NCTCOG has developed a project level CMP analysis. The analysis requires completion of the Project Implementation Form, and, if warranted, the Roadway Corridor Deficiency Form and Corridor Analysis Fact Sheet. The results of this analysis are attached in Appendix <insert Appendix ID>.

23. During the construction phase of this project, temporary increases in PM and MSAT emissions may occur from construction activities. The primary construction-related emissions of PM are fugitive dust from site preparation, and the primary construction-related emissions of MSAT are diesel particulate matter from diesel powered construction equipment and vehicles.

The potential impacts of particulate matter emissions will be minimized by using fugitive dust control measures contained in standard specifications, as appropriate. The Texas Emissions Reduction Plan (TERP) provides financial incentives to reduce emissions from vehicles and equipment. TxDOT encourages construction contractors to use this and other local and federal incentive programs to the

Click on the pushpin

to copy this table.



fullest extent possible to minimize diesel emissions. Information about the TERP program can be found at: http://www.tceq.state.tx.us/implementation/air/terp/.

However, considering the temporary and transient nature of construction-related emissions, the use of fugitive dust control measures, the encouragement of the use of TERP, and compliance with applicable regulatory requirements; it is not anticipated that emissions from construction of this project will have any significant impact on air quality in the area.

Air Quality Toolkit Home > Inside TxDOT > Divisions > Environmental Affairs > Environmental Compliance Toolkits

The Clean Air Act (CAA), the National Environmental Policy Act (NEPA) and the Federal‐Aid Highways Codproposed transportation projects on air quality in Texas.

Use the following tools to document project‐level compliance with laws, regulations and guidance.

Questions? Contact the Air Quality Section of the Environmental Affairs Division at (512) 416‐2659.

You may download the software (Tools and Plug‐Ins) needed to access forms or view frequently asked qu

General Tools Transportation Conformity Hot‐Spot Analysis Mobile Source Air Toxics (MSAT) Carbon Monoxide (CO) Traffic Air Quality Analysis (TAQA) Congestion Management Process (CMP) Construction Emissions Additional Resources

Date General Tools Description

07/14 Air Quality Compliance Process Outlines the steps to comply with the CAA, in regards to potential project effects on ai

01/16 Environmental Handbook for Air Quality Outlines the steps to comply with the CAA,in regards to potential project effects on ai

08/15 Standard Operating Procedure for Preparing Air Quality Statements

Contains the applicable finding and negativair quality compliance with applicable laws,

Date Transportation Conformity Description

10/15 Standard Operating Procedure for Complyingwith Conformity Requirements

Explains how to prepare and coordinate a c

02/14 Review Standard for a Conformity Report Verifies that a project‐level conformity repo

11/15 Transportation Conformity Report Form Used to prepare the conformity report

Page 1 of 4Air Quality Toolkit

2/22/2016http://www.txdot.gov/inside-txdot/division/environmental/compliance-toolkits/air-quality....

09/15 Texas Air Quality Nonattainment or Attainment‐Maintenance Areas and Counties – Sept. 14, 2015

Provides tabular information on nonattainmtransportation plan conformity dates

Date Hot‐Spot Analysis Description

02/14 Standard Operating Procedure for Complying with Hot‐Spot Requirements

Explains when and how to prepare and coo

02/14 Review Standard for a Hot‐Spot Analysis Technical Report

Verifies that a Hot‐Spot Analysis report me

02/14 Documentation Standard for a Hot‐Spot Analysis Technical Report

Lists the required sections and components

02/14 Hot‐Spot Pre‐Analysis Consensus Form After an air quality concern has been identito the consultation partners during the initpartners use the data to decide whether thappropriate.

02/14 Hot‐Spot Analysis Data for a Consultation Partner

After a metropolitan planning organization project sponsor completes and sends this foproposed project is "of air quality concern"

Date Mobile Source Air Toxics (MSAT) Description

11/15 Standard Operating Procedure: Complying with MASAT Analysis Requirements

Assists project sponsors comply with NEPA source air toxics (MSAT) emissions at the p

02/14 Mobile Source Air Toxics (MSAT) Analysis Quick‐Start Guide

Provides an overview of the quantitative Mreferences to FHWA MSAT workshop mate

The Missing MSAT – Diesel Particulate Matter Provides FHWA guidance on adding diesel panalysis for MOBILE6.2

07/14 Emissions Table Provides tabular MSAT emission rates, incluthrough 2040

09/14 Documentation Standard for Quantitative MSAT Technical Report

Used to prepare a quantitative MSAT techn

09/15 Review Standard for Quantitative MSAT Technical Report

Used by TxDOT to review a quantitative MS

Date Carbon Monoxide (CO) Traffic Air Quality Analysis (TAQA)

Description



09/15 Standard Operating Procedure for Complying with CO TAQA Requirements

Explains how to comply with CO TAQA requproject sponsors determine when and howtechnical report

09/15 Documentation Standard for a CO TAQA Technical Report

Used to prepare a CO TAQA technical repor

09/15 Review Standard for CO TAQA Technical Report Used by TxDOT to review a CO TAQA techn

Date Congestion Management Process (CMP) Description

09/15 Standard Operating Procedure for Complying with CMP Requirements

Used to assist project sponsors in documenthe project level

Date Construction Emissions Description

09/15 Standard Operating Procedure for Complying with Construction Emission Requirements

Provides project sponsors a clear explanatioconstruction emission requirements

Date Additional Resources Description

Aviation Emissions and Air Quality Handbook Explains Federal Aviation Administration (FAfor projects involving civilian airports and airagency

Determining Conformity of Federal Actions to State or Federal Implementation Plans (40 CFR 93)

EPA‐administered code implementing Sectiothe related requirements of 23 USC 109(j) anprocedures to demonstrate and ensure projeplan developed pursuant to Section 110 and

Supplement to Jan. 28, 2008 Transportation Planning Requirements and their Relationship to NEPA Process Completion (02/09/11) Distribution Memo

Provides a detailed description of how transprocess (i.e., project‐level consistency and co

Transportation Conformity: A Basic Guide for State and Local Officials

Provides FHWA's high‐level overview of tranrequirements relate to transportation investmetropolitan transportation plans, transporttransportation projects

Transportation Conformity Brochure FHWA answers to basic questions about tran

Transportation Conformity Guidance for Qualitative Hot‐Spot Analysis in PM2.5 and PM10 Nonattainment and Maintenance Areas Memorandum

FHWA provides guidance for qualitative PM quality concern” in PM nonattainment/mainstarted prior to December 2012



Transportation Conformity Guidance for Quantitative Hot‐Spot Analyses in PM2.5 and PM10 Nonattainment and Maintenance Areas

EPA guidance for quantitative PM hot‐spot aconcern” in PM nonattainment/maintenancestarted post December 2012

Guidelines for Modeling Carbon Monoxide from Roadway Intersections

EPA guidance on how to model CO at roadw

Using MOVES in Project‐Level Carbon Monoxide Analyses

EPA guidance for using its mobile vehicle emrather than the older MOBILE emissions modanalysis was started post December 2012

FHWA Technical Advisory for Preparing and Processing Environmental and Section 4(f) Documents T 6640A

FHWA guidance on preparing environmentafor performing a CO TAQA and disclosing con

Interim Guidance Update on Mobile Source Air Toxic Analysis in NEPA Memorandum

Provides an update to FHWA guidance on M

A Methodology for Evaluating Mobile Source Air Toxic Emissions Among Transportation Project Alternatives

Detailed guidelines on performing quantitati

Frequently Asked Questions (FAQ) Conducting Quantitative MSAT Analysis for FHWA NEPA Documents

Provides FHWA recommendations for projecanalysis concerning defining the scope of MO‐processing results



Standard Operating Procedure for Complying with Conformity Requirements

Procedure Version 2

TxDOT Environmental Affairs Division 210.02.SOP

Effective Date: October 2015 Page 1 of 7

Approval Authority: Air Quality & Noise Work Leader, Jackie Ploch Effective Date: 10/01/15

Review Authority: Air Specialist, Tim Wood Version: 2

Purpose of This SOP

The purpose of this SOP is to explain clearly how to comply with conformity requirements at the project

level. In particular, it details how to prepare and coordinate a conformity report, which is used to

document that project-level conformity requirements have been met.

Subject Overview

The Clean Air Act (CAA) requires that all federal actions in nonattainment or maintenance areas have to

conform to the State Implementation Plan (SIP), unless otherwise exempt. A project requiring a project-

level conformity determination must receive a FHWA/FTA conformity determination prior to the

environmental decision being made. This SOP was developed to assist project sponsors with preparing

conformity reports and, when applicable, getting a project-level conformity determination from

FHWA/FTA.

A determination of project level conformity is not permanent. It is recommended that conformity be

checked early and often in the project development process, using the Transportation Conformity Report

Form. This form should be coordinated at least 60 days prior to the anticipated environmental decision so

as to avoid having to coordinate it more than once. In particular, if there is a planned MTP

update/amendment and corresponding transportation conformity determination expected to be completed

on or near the time of project approval, then it is recommended that the project sponsor prepare this

conformity determination after the plan update/amendment and corresponding transportation conformity

determination is completed.

Authorities

There is no specific authority or requirement to use this SOP, but it designed to help project sponsors

meet the conformity requirements of the CAA in regards to transportation projects. Correctly following the

procedure outlined in this SOP should ensure the production of a legally sufficient report that meets the

CAA requirements.

Toolkit

The following tools should be used in conjunction with this SOP.


Texas Nonattainment Areas and Counties Table

SOP for Complying with Hot-Spot Requirements

SOP for Preparing Air Quality Statements

Personnel

The audience for this SOP includes project sponsors, contractors, and consultants responsible for

preparing valid documentation that a project complies with CAA conformity requirements.

SOP for Complying with Conformity Requirements

Procedure Version 2



Procedure

1. Determine whether the project is in an area in attainment or unclassifiable for all National Ambient

Air Quality Standards (NAAQS). If so, proceed to Step 10. If not, continue to Step 2.

2. Determine whether the project has a federal lead1 other than FHWA/FTA. If so, consult with the

ENV air specialist, and continue to Step 3. If not, proceed to Step 4.

3. Address potential general conformity requirements by completing Steps 3.1 through 3.6 as

directed.

3.1. Determine whether the project is considered “de minimis” in accordance with 40 CFR

93.153(c)(2). If so, document that the project is “de minimis,” then proceed to Step 10. If not,

continue to Step 3.2.

3.2. Determine whether the project is exempt from a project level conformity determination in

accordance with 40 CFR 93.153(d) or 93.153(e). If so, document that the project is exempt,

and proceed to Step 10. If not, continue to Step 3.3.

3.3. Prepare an analysis methodology to identify the total of direct and indirect emissions

associated with the project. Get approval from the federal lead agency on that methodology

before initiating the analysis. Continue to Step 3.4.

3.4. Perform the analysis. Send the analysis to the ENV air specialist for review. Continue to Step

3.5.

3.5. Determine whether the project’s total of direct and indirect emissions exceed the emission

levels specified in 40 CFR 93.153(b). If so, continue to Step 3.6. If not, document that a

project level conformity determination is not necessary because the project does not exceed

the applicable thresholds, and proceed to Step 10.

3.6. Coordinate with the lead federal agency on how to obtain a project-level conformity

determination2. Once the conformity determination has been obtained, proceed to Step 10.

4. Determine which projects are exempt from a project level conformity determination by completing

Steps 4.1 through 4.6 as directed.

4.1. Determine whether the project is located in a nonattainment or maintenance area (NA/MA)

for ONLY sulfur dioxide and/or lead. If so, proceed to Step 10. If not, continue to Step 4.2.

4.2. Determine whether the project is exempt from conformity in accordance with 40 CFR 93.1263

or 40 CFR 93.128. If so, proceed to Step 10. If not, continue to Step 4.3.

4.3. Determine whether the project is a FHWA/FTA project4. If so, continue to Step 4.4. If not,

proceed to Step 4.5.

1 Such as the Surface Transportation Board or the Federal Railroad Administration

2 The project will need a general conformity determination from the federal lead agency prior to the project’s

approval.

3 Ultimately, the interpretation of what projects types meet these exemption criteria is under the purview of the

federal lead agency. For example, although it could be interpreted to meet some of the exemption project types, a

project changing from general purpose to managed lanes is NOT considered to be exempt from conformity.

http://www.ecfr.gov/cgi-bin/text-idx?SID=837faca03f97773d33eae59cb1f12019&mc=true&node=pt40.20.93&rgn=div5#se40.20.93_1153








Procedure Version 2



4.4. Determine whether the project is located within a nonattainment or maintenance area for

either carbon monoxide (CO) or particulate matter (PM). If so, proceed to Step 5. If not,

continue to Step 4.6.

4.5. Determine whether the project is considered regionally significant5. If so, continue to

Step 4.6. If not, proceed to Step 10.

4.6. Determine if the project is exempt from regional conformity requirements per 40 CFR 93.127.

If so, proceed to Step 10. If not, proceed to Step 6.

5. Follow the procedures in the SOP for Complying with Hot-Spot Requirements in order to address

hot-spot compliance activities. Continue to Step 6.

6. Determine the conformity status of the project by completing Steps 6.1 through 6.4 as directed.

6.1. Complete the Transportation Conformity Report Form as directed by the form and continue to

Step 6.2.

6.2. Determine whether the form directed the preparer to STOP on Steps 8 through 15. If so,

work with the local district Transportation Planning and Development (TP&D) and the local

MPO to address the consistency problem, ensure the appropriate revisions are made, and

then proceed to Step 6. If not, continue to Step 6.3.

6.3. Determine whether the form directed the preparer to STOP on Steps 19 or 20. If so, conduct

coordination with the Consultation Partners to determine the applicable mitigation measures

for the project, provide written commitments to implement these mitigation measures, and

proceed to Step 6. If not, continue to Step 6.4.

6.4. Within at least 60 days prior to the anticipated environmental document decision, coordinate

the Transportation Conformity Report Form and all applicable attachments with the ENV air

specialist for review, and address any comments from the ENV reviewer. The ENV air

specialist will coordinate the Transportation Conformity Form with FHWA/FTA, as applicable.

Continue to step 7.

7. Determine whether the project has received a project level conformity determination by completing

Steps 7.1 through 7.2 as directed.

7.1. Determine whether the ENV air specialist has indicated that FHWA/FTA signed the form,

indicating they made a project-level conformity determination for the project. If so, then

proceed to Step 8. If not, continue to Step 7.2.

7.2. Identify the FHWA/FTA concerns regarding the Transportation Conformity Report Form and

address them as appropriate. Resubmit the revised Transportation Conformity Report Form

with the appropriate documentation to the ENV air specialist who will coordinate it with

FHWA/FTA for a project level conformity determination. Proceed to Step 7.1.

8. Identify the times when it is appropriate to reevaluate the project’s conformity status by completing

Steps 8.1 through 8.3.

4 Either has FHWA/FTA funding or action (such as an Interstate Access Justification)

5 According to the MPO. See the definition of regionally significant in Appendix A.



Procedure Version 2



8.1. Since the completion of the Transportation Conformity Report Form, determine whether there

has been a change in the project’s design concept, scope, financing, or implementation

schedule. If so, proceed to Step 6. If not, continue to Step 8.2.


have been MTP or TIP updates that changed how the project’s design concept, scope,

financing, or implementation schedule is represented in these plans. If so, proceed to Step 6.

If not, continue to Step 8.3.


has been a change to the area’s attainment status. If so, proceed to Step 1. If not, continue

to Step 9.

9. Retain copies of all applicable documentation supporting conformity decisions in the project file,

including but not limited to the Transportation Conformity Report Form, Consultation Partner

decisions, an emissions analysis in support of general conformity decisions, a hot-spot analysis,

copies of the applicable pages of the MTP and TIP, and all coordination regarding conformity.


10. Refer to the SOP for Preparing Air Quality Statements for the applicable conformity disclosure

language to include in the project file.

The procedure is complete.


Procedure Version 2



Appendix A: Acronyms and Definitions

Acronyms

Acronym Full Name

CAA Clean Air Act

CO Carbon Monoxide

ENV TxDOT Environmental Affairs Division

FHWA/FTA Federal Highway Administration/Federal Transit Administration

MPO Metropolitan Planning Organization

MTP Metropolitan Transportation Plan

NAAQS National Ambient Air Quality Standards

NA/MA Nonattainment or Maintenance Area

NO2 Nitrogen Dioxide

PM Particulate Matter

SIP State Implementation Plan

SOP Standard Operating Procedure

STIP Statewide Transportation Improvement Program

TIP Transportation Improvement Program

TP&D Transportation Planning and Development

TxDOT Texas Department of Transportation


Procedure Version 2



Definitions

Term Definition

FHWA/ FTA

Project

A project that has FHWA/FTA funding, needs a FHWA/FTA decision, or that has

been delegated.

Non-Regionally

Significant Project

A project that is not regionally significant. These are often specifically identified by

the Metropolitan Planning Organization (MPO) as being non-regionally significant.

Regionally

Significant Project

Federal definition (40 CFR 93.101): A transportation project (other than an

exempt project) that is on a facility which serves regional transportation needs

(such as access to and from the area outside of the region, major activity centers

in the region, major planned developments such as new retail malls, sports

complexes, etc., or transportation terminals as well as most terminals

themselves) and would normally be included in the modeling of a metropolitan

area's transportation network, including at a minimum all principal arterial

highways and all fixed guideway transit facilities that offer an alternative to

regional highway travel.

State definition (30 TAC 114.260(2)(A)(iv)): Regionally significant projects will

include, at a minimum, all facilities classified as principal arterial or higher, or

fixed guideway systems or extensions that offer an alternative to regional highway

travel. Also, these include minor arterials included in the travel demand modeling

process that serve significant interregional and intraregional travel, and connect

rural population centers not already served by a principal arterial, or connect with

intermodal transportation terminals not already served by a principal arterial. A

significant change in design concept and scope is defined as a revision of a

project in the MTP or TIP that would significantly affect model speeds, vehicle

miles traveled, or network connections. In addition to new facilities, examples

include changes in the number of through lanes or length of project (more than

one mile), access control, addition of major intermodal terminal facilities (such as

new international bridges, park-and-ride lots, and transfer terminals),

addition/deletion of interchanges, or changing between free and toll facilities.

http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&SID=33eb5ff6c56546a9b9f4acfd77451573&rgn=div5&view=text&node=40:21.0.1.1.7&idno=40#40:21.0.1.1.7.1.1.2

http://info.sos.state.tx.us/pls/pub/readtac$ext.TacPage?sl=R&app=9&p_dir=&p_rloc=&p_tloc=&p_ploc=&pg=1&p_tac=&ti=30&pt=1&ch=114&rl=260


Procedure Version 2



Appendix B


Revision History

Effective Date Month, Year

Reason for and Description of Change

February 2014 . Version 1 released

September 2015 Version 2 released in order to clarify the timing, the exemptions, and the ENV air specialist’s intermediary role in the coordination process.