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Federal Highway Administration

Transportation/Air Quality Issues in Rural Areas

Table of Contents



I. Introduction [1](#introduction)

A. Background [1](#background)

B. Approach [2](#approach)

C. Report Structure [4](#report-structure)

II\. Summary of Findings [4](#summary-of-findings)

III\. Identification of Isolated Rural Areas
[7](#identification-of-isolated-rural-areas)

IV\. Survey Results [10](#survey-results)

A. Carbon Monoxide [11](#carbon-monoxide)

B. Ozone [12](#ozone)

C. Particulate Matter-10 [14](#particulate-matter-10)

Appendix A: Survey A-[1](#appendix-a-survey)

Federal Highway Administration

Transportation/Air Quality Issues in Rural Areas



# Introduction

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

The research reported in this paper accomplished the following:

-   Determined if transportation is generating the pollutants in each
    isolated rural area or if another source is primarily responsible
    for the pollutant.

-   Identified what analysis rural areas have conducted to meet the
    Clean Air Act requirements for transportation conformity and the
    control measures they have undertaken to address
    transportation-related sources of pollutants.

-   Assessed the resources and planning capabilities of isolated rural
    areas to address the issue of conformity between transportation
    plans for their areas and State Implementation Plans (SIPs).

## Background

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

## Approach

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

### Oversight

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

-   Bob Gorman, FHWA

-   Dee Spann, FHWA

-   Cecelia Ho, FHWA

-   Angela Spickard, EPA-OTAQ

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

### Research and Analysis

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

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

### Survey

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

The main questions addressed in the survey are:

-   Why are these isolated rural areas in nonattainment or maintenance
    (i.e., what are the main sources of their air quality problems)?

-   How are these air quality problems being addressed by the different
    agencies involved?

-   How are these areas meeting the transportation conformity
    requirements?

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

### Interviews

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

## Report Structure

This report is organized into the following sections:

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

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

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

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

# Summary of Findings

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

-   **There are few isolated rural nonattainment or maintenance areas
    compared to the total nonattainment or maintenance areas for each
    pollutant.**

Isolated rural nonattainment or maintenance areas represent a small
percentage of the total nonattainment or maintenance areas, as shown in
Exhibit II-1.

Exhibit II‑1: Number of Isolated Rural Nonattainment\
or Maintenance Areas Relative to\
Total Nonattainment or Maintenance Areas in 2001

  --------------------- ---------------- ------------ ---------------------
  **\                   **Isolated Rural **Total      **Percent Isolated
  Pollutant**           Areas**          areas**      Rural**

  Carbon Monoxide       3                121          2

  Ozone                 31               420          7

  PM-10                 37               106          35
  --------------------- ---------------- ------------ ---------------------

The exhibit reinforces a predominant view that air quality is primarily
an urban concern. However, the portion of PM-10 areas that are isolated
rural areas is significant.

-   **In only two cases were more than 5 percent of the PM-10 emissions
    attributed to on-road mobile sources.**

Survey results indicated that in most of the isolated rural areas the
PM-10 problem in an area are attributable to sources other than on-road
mobile sources such as point source (e.g., factories or power plants).
Consequently, transportation-related strategies did not really help
these areas to attain the PM-10 standard.

Experience with PM-10 problems in other areas, confirmed through the
survey and telephone follow up with the isolated rural areas, indicates
that more frequent street sweeping, changing deicing materials or other
fugitive dust control measures can be effective in reducing PM-10
emissions. In the case of Presque Isle, Maine, (a PM-10 nonattainment
isolated rural area) switching from a native sanding material to calcium
chloride was very effective in reducing PM-10 emissions. However, the
cost of using the chemical in place of the sand had prevented the local
maintenance crews from switching for many years.

-   **The isolated rural areas have limited staff resources to
    understand and address the implications of nonattainment status.**

In general the isolated rural areas do not have professional air quality
and transportation planning staff. Local jurisdictions' responsibilities
are typically addressed through their public works department or county
engineer depending upon their organizational structure. They also rely
on the expertise of State Department of Transportation staff in
addressing conformity issues.

-   **There is typically limited local data and planning information to
    perform conformity analysis.**

The survey results indicate that in those few cases where analysis is
performed, traffic data and growth estimates are derived from traffic
counts and other traffic monitoring data reporting such as HPMS. Few
areas indicated that they collected local data.

-   **Interagency consultation is helpful when needed, but most survey
    respondents have never held a meeting of all federal, state, and
    local agencies because they have not had transportation projects,
    and therefore, have not needed to determine conformity.**

Ten of the 18 survey respondents stated that there had never been a
meeting among all agencies for the area, while two respondents explained
that they have not needed consultation because the area has had no new
projects. Three respondents did not provide any information about
consultation for their isolated rural area.

The three respondents that endorsed interagency consultation stated that
the process has been helpful in facilitating cross-functionality
training and resolving conformity issues. According to the Chief of EPA
Region 4's Air Planning Branch, interagency consultation has been very
effective in Edmonson County, Kentucky:

Effective interagency consultation was the key to resolving this issue
and could have been used as the means to prevent any delay from
occurring. Because of this area's limited experience with conformity and
the nature of how transportation conformity is implemented in isolated
rural areas (i.e., until projects are seriously contemplated there is no
need to do conformity analysis), planning parties may not have allowed
time for any resolution to potential issues, and may not have
effectively consulted with parties who could work to resolve issues
until there was no choice but for delay. In this case, it was not until
the area ran the conformity analysis and was not able to demonstrate
conformity to a budget developed with the Mobile 4.1 emissions model
that the area realized that it would be beneficial for them to have
mobile emissions budgets developed with the new Mobile 5 emissions
model. The efforts for developing new emissions budgets is not extremely
burdensome but does require planning, review and approval on the part of
various agencies that may not have been alerted to this situation until
it was too late.

The Kentucky Transportation Cabinet and air quality partners in the
Edmonson County have gained a lot from their interagency coordination
and communicate on at least a monthly basis on this area and other areas
in Kentucky, even though the area has successfully demonstrated
conformity. The partners are taking a more proactive approach and
discuss any upcoming projects that may be considered for Edmonson
County. In fact, this interagency consultation discussion prevented KYTC
(the Kentucky Transportation Cabinet) from performing conformity
analysis unnecessarily for Edmonson County in the beginning of 2002.
KYTC was under the impression that conformity determinations for
isolated rural areas have a three year expiration just as in
metropolitan areas. When this topic was discussed on the monthly
interagency consultation call, Kentucky transportation and air quality
partners were able to discuss and resolve this issue prior to KYTC
beginning work for this conformity determination.

In this area, interagency consultation has been very beneficial. We all
have a better understanding of the role of each consultation partner
with regard to conformity. The air quality agencies are gaining more
knowledge of the transportation planning process, and the transportation
agencies are gaining more knowledge of the air quality process.

-   **Most areas reported no new Federal non-exempt transportation
    projects in the past five years.**

Consistent with their rural nature, 11 areas indicated no regionally
significant projects. Only three survey respondents reported non-exempt
transportation projects requiring conformity analysis over the past five
years.[^2] Each of the three areas only had one such project.

-   **Two areas used an analysis period shorter than the required
    analysis period in their conformity determination.**

Although conformity analysis requires a 20-year analysis period, two
areas reported a shorter timeframe. One area reported analysis 10 years
into the future; another reported analysis 15 years into the future.

# Identification of Isolated Rural Areas

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

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

Exhibit III‑2: Carbon Monoxide Nonattainment or Maintenance Rural Areas\
(March 2003)

+----------+-----------+-----------------------+----------------------+
| *        | **EPA     | **Isolated Rural      | **Donut Areas**      |
| *State** | Region**  | Areas**               |                      |
+==========+===========+=======================+======================+
| Alaska   | 10        | Fairbanks             |                      |
+----------+-----------+-----------------------+----------------------+
| Oregon   |           | Grants Pass           |                      |
|          |           |                       |                      |
|          |           | Klamath Falls         |                      |
+----------+-----------+-----------------------+----------------------+

Exhibit III‑3: Ozone Nonattainment or Maintenance Rural Areas (March
2003)

+----------+-----------+-----------------------+----------------------+
| *        | **EPA     | **Isolated Rural      | **Donut Areas**      |
| *State** | Region**  | Areas**               |                      |
+==========+===========+=======================+======================+
| Con      | 1         |                       | Windam County        |
| necticut |           |                       | (Greater Connecticut |
|          |           |                       | Area)                |
+----------+-----------+-----------------------+----------------------+
| Maine    | 1         | Hancock & Waldo       | Cumberland County    |
|          |           | Counties              | (Greater Portland    |
|          |           |                       | Area)                |
+----------+-----------+-----------------------+----------------------+
|          |           | Knox & Lincoln        |                      |
|          |           | Counties              |                      |
+----------+-----------+-----------------------+----------------------+
| New      | 1         | Cheshire County       |                      |
| H        |           |                       |                      |
| ampshire |           |                       |                      |
+----------+-----------+-----------------------+----------------------+
| New York | 2         | Essex County          | Montgomery and       |
|          |           |                       | Greene Counties      |
|          |           | Jefferson County      | (Albany-Schenectady- |
|          |           |                       | Troy Area)           |
+----------+-----------+-----------------------+----------------------+
| Maryland | 3         | Kent & Queen Anne's   | Calvert and Charles  |
|          |           | Counties              | Counties             |
|          |           |                       | (Washington,         |
|          |           |                       | DC-MD-VA)            |
+----------+-----------+-----------------------+----------------------+
|          |           |                       |                      |
+----------+-----------+-----------------------+----------------------+
| Virginia | 3         | White Top Mountain    |                      |
|          |           | (Smith County)        |                      |
+----------+-----------+-----------------------+----------------------+
| Delaware | 3         | Sussex County         |                      |
+----------+-----------+-----------------------+----------------------+
| Penn     | 3         |                       |                      |
| sylvania |           |                       |                      |
+----------+-----------+-----------------------+----------------------+
|          |           | Crawford County       |                      |
+----------+-----------+-----------------------+----------------------+
|          |           | Franklin County       |                      |
+----------+-----------+-----------------------+----------------------+
|          |           | Juanita County        |                      |
+----------+-----------+-----------------------+----------------------+
|          |           | Lawrence County       |                      |
+----------+-----------+-----------------------+----------------------+
|          |           | Northumberland County |                      |
+----------+-----------+-----------------------+----------------------+
|          |           | Schuylkill County     |                      |
+----------+-----------+-----------------------+----------------------+
|          |           | Snyder County         |                      |
+----------+-----------+-----------------------+----------------------+
|          |           | Susquehanna County    |                      |
+----------+-----------+-----------------------+----------------------+
|          |           | Warren County         |                      |
+----------+-----------+-----------------------+----------------------+
|          |           | Wayne County          |                      |
+----------+-----------+-----------------------+----------------------+
| Virginia | 3         | White Top Mountain    |                      |
|          |           | (Smith County)        |                      |
+----------+-----------+-----------------------+----------------------+
| West     | 3         | Greenbrier County     |                      |
| Virginia |           |                       |                      |
+----------+-----------+-----------------------+----------------------+
| Georgia  | 4         |                       | Coweta, Forsyth and  |
|          |           |                       | Paulding Counties    |
|          |           |                       | (Atlanta Area)       |
+----------+-----------+-----------------------+----------------------+
| Kentucky | 4         | Edmonson County       | Portion of Hancock   |
|          |           |                       | County (Owensboro    |
|          |           |                       | area)                |
+----------+-----------+-----------------------+----------------------+
|          |           | Paducah (Livingston   | Scott County         |
|          |           | and Marshall          | (Lexington Area)     |
|          |           | Counties)             |                      |
+----------+-----------+-----------------------+----------------------+
| South    | 4         | Cherokee County       |                      |
| Carolina |           |                       |                      |
+----------+-----------+-----------------------+----------------------+
| T        | 4         |                       | Rutherford, Sumner,  |
| ennessee |           |                       | Williamson and       |
|          |           |                       | Wilson Counties      |
|          |           |                       | (Nashville area)     |
+----------+-----------+-----------------------+----------------------+
| Michigan | 5         | Allegan County        |                      |
+----------+-----------+-----------------------+----------------------+
|          |           |                       | Muskegon             |
+----------+-----------+-----------------------+----------------------+
| Ohio     | 5         | Clinton County        | Ashtabula and        |
|          |           |                       | Portaqe Counties     |
|          |           |                       | (Cl                  |
|          |           |                       | eveland-Akron-Lorain |
|          |           |                       | area)                |
+----------+-----------+-----------------------+----------------------+
|          |           | Columbiana County     |                      |
+----------+-----------+-----------------------+----------------------+
|          |           | Preble County         |                      |
+----------+-----------+-----------------------+----------------------+
|          |           |                       | Delaware and Licking |
|          |           |                       | Counties (Columbus   |
|          |           |                       | area)                |
+----------+-----------+-----------------------+----------------------+
|          |           |                       | Greene and Miami     |
|          |           |                       | Counties             |
|          |           |                       | (Dayton-Springfield  |
|          |           |                       | area)                |
+----------+-----------+-----------------------+----------------------+
|          |           |                       |                      |
+----------+-----------+-----------------------+----------------------+
|          |           |                       | Stark County (Canton |
|          |           |                       | area)                |
+----------+-----------+-----------------------+----------------------+
| L        | 6         | Grant Parish          |                      |
| ouisiana |           |                       |                      |
+----------+-----------+-----------------------+----------------------+
|          |           | Lafourche Parish      |                      |
+----------+-----------+-----------------------+----------------------+
|          |           | St. James Parish      |                      |
+----------+-----------+-----------------------+----------------------+
|          |           | St. Mary Parish       |                      |
+----------+-----------+-----------------------+----------------------+

Exhibit III‑4: PM-10 Nonattainment or Maintenance Rural Areas (2003)

+----------+-----------+-----------------------+----------------------+
| *        | **EPA     | **Isolated Rural      | **Donut Areas**      |
| *State** | Region**  | Areas**               |                      |
+==========+===========+=======================+======================+
| Maine    | 1         | Presque Isle          |                      |
|          |           | (Aroostook County)    |                      |
+----------+-----------+-----------------------+----------------------+
| Illinois | 5         | Oglesby (La Salle     |                      |
|          |           | County)               |                      |
+----------+-----------+-----------------------+----------------------+
| Indiana  | 5         | Vermillion County     |                      |
+----------+-----------+-----------------------+----------------------+
| New      | 6         |                       | Anthony (Dona Ana    |
| Mexico   |           |                       | County)              |
+----------+-----------+-----------------------+----------------------+
| Colorado | 8         | Telluride (San Miquel |                      |
|          |           | County)               |                      |
+----------+-----------+-----------------------+----------------------+
|          |           | Pagosa Springs        |                      |
|          |           | (Archuleta County)    |                      |
+----------+-----------+-----------------------+----------------------+
|          |           | Canon City (Fremont   |                      |
|          |           | County)               |                      |
+----------+-----------+-----------------------+----------------------+
|          |           | Aspen (Pitkin County) |                      |
+----------+-----------+-----------------------+----------------------+
|          |           | Lamar (Prowers        |                      |
|          |           | County)               |                      |
+----------+-----------+-----------------------+----------------------+
|          |           | Steamboat Springs     |                      |
|          |           | (Routt County)        |                      |
+----------+-----------+-----------------------+----------------------+
| Montana  | 8         | Columbia Falls        | Ronan                |
|          |           | (Flathead County)     |                      |
+----------+-----------+-----------------------+----------------------+
|          |           | Whitefish and         |                      |
|          |           | vicinity (Flathead    |                      |
|          |           | County)               |                      |
+----------+-----------+-----------------------+----------------------+
|          |           | Kalispell (Flathead   |                      |
|          |           | County)               |                      |
+----------+-----------+-----------------------+----------------------+
|          |           | Polson (Lake County)  |                      |
+----------+-----------+-----------------------+----------------------+
|          |           | Libby (Lincoln        |                      |
|          |           | County)               |                      |
+----------+-----------+-----------------------+----------------------+
|          |           | Lame Deer (Rosebud    |                      |
|          |           | County)               |                      |
+----------+-----------+-----------------------+----------------------+
|          |           | Thompson Falls and    |                      |
|          |           | vicinity (Sanders     |                      |
|          |           | County)               |                      |
|          |           |                       |                      |
|          |           | Ronan area (Lake      |                      |
|          |           | County)               |                      |
+----------+-----------+-----------------------+----------------------+
|          |           | Butte (Silver Bow     |                      |
|          |           | County)               |                      |
+----------+-----------+-----------------------+----------------------+
| Wyoming  | 8         | Sheridan County       |                      |
+----------+-----------+-----------------------+----------------------+
| Arizona  | 9         | Douglas (Coachise     |                      |
|          |           | County)               |                      |
+----------+-----------+-----------------------+----------------------+
|          |           | Paul Spur (Coachise   |                      |
|          |           | County)               |                      |
+----------+-----------+-----------------------+----------------------+
|          |           | Hayden/Miami (Gila    |                      |
|          |           | and Pinal Counties)   |                      |
+----------+-----------+-----------------------+----------------------+
|          |           | Payson (Gila County)  |                      |
+----------+-----------+-----------------------+----------------------+
|          |           | Mohave County         |                      |
+----------+-----------+-----------------------+----------------------+
|          |           | Nogales (Santa Crus   |                      |
|          |           | County)               |                      |
+----------+-----------+-----------------------+----------------------+
| Ca       | 9         | Mammoth Lake (Mono    |                      |
| lifornia |           | County)               |                      |
+----------+-----------+-----------------------+----------------------+
|          |           | Owens Valley (Inyo    |                      |
|          |           | County)               |                      |
+----------+-----------+-----------------------+----------------------+
|          |           | Mono Basin (Mono      |                      |
|          |           | County)               |                      |
+----------+-----------+-----------------------+----------------------+
| Alaska   | 10        | Juneau                |                      |
+----------+-----------+-----------------------+----------------------+
| Idaho    | 10        | Sandpoint (Bonner     |                      |
|          |           | County)               |                      |
|          |           |                       |                      |
|          |           | Shoshone County       |                      |
|          |           | (excluding Pinehurst) |                      |
|          |           |                       |                      |
|          |           | Pinehurst (Shoshone   |                      |
|          |           | County)               |                      |
+----------+-----------+-----------------------+----------------------+
| Oregon   | 10        | Lake County           |                      |
+----------+-----------+-----------------------+----------------------+
|          |           | Grants Pass           |                      |
|          |           | (Josephine County)    |                      |
+----------+-----------+-----------------------+----------------------+
|          |           | LaGrande (Union       |                      |
|          |           | County)               |                      |
|          |           |                       |                      |
|          |           | Klamath County        |                      |
|          |           | (Klamath Falls area)  |                      |
+----------+-----------+-----------------------+----------------------+
| Wa       | 10        | Wallula (Walla Walla  |                      |
| shington |           | County)               |                      |
+----------+-----------+-----------------------+----------------------+

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

# Survey Results

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

-   State department of transportation (DOT).

-   State and/or local air quality agency.

-   FHWA Division and EPA Regional offices.

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

## Carbon Monoxide

Only one of the two carbon monoxide maintenance or nonattainment areas
responded to the survey, as shown in Exhibit IV-5.

Exhibit IV‑5: Carbon Monoxide Nonattainment and Maintenance Isolated
Rural Areas

  ----------- ------------- ------------- --------------- ----------- ---------- -------------
  **State**   **County**    **Area Name** **Status**      **Class**   **EPA      **Completed
                                                                      Region**   Survey**

  Alaska      Fairbanks Ed  Fairbanks     Nonattainment   Serious     10         No

  Oregon      Josephine     Grants Pass   Maintenance     N/A         10         Yes
  ----------- ------------- ------------- --------------- ----------- ---------- -------------

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

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

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

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

### Comments on the Process

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

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

## Ozone

All six isolated rural areas in nonattainment or maintenance for ozone,
in the survey sample, completed the survey. The areas are listed in
Exhibit IV-6.

Exhibit IV‑6: 2002 Ozone Nonattainment and Maintenance Isolated Rural
Areas

  ----------- ------------ --------------- --------------- ----------- ---------- -------------
  **State**   **County**   **Area Name**   **Status**      **Class**   **EPA      **Completed
                                                                       Region**   Survey**

  Delaware    Sussex       Sussex County   Nonattainment   Marginal    3          Yes

  Kentucky    Edmonson     Edmonson County Maintenance     N/A         4          Yes

              Livingston   Paducah         Maintenance     N/A         4          Yes
              and Marshall                                                        

  New York    Essex        Essex County    Nonattainment   Marginal    2          Yes

  Virginia    Smyth        White Top       Nonattainment   Marginal    3          Yes
                           Mountain                                               

  West        Greenbrier   Greenbrier      Nonattainment   N/A         3          Yes
  Virginia                 County                                                 
  ----------- ------------ --------------- --------------- ----------- ---------- -------------

Four ozone nonattainment or maintenance areas have SIPs; two areas
(White Top Mountain and Sussex County) do not. For emissions dealing
with ozone, areas list precursors: nitrogen oxides (NOx) and/or
hydrocarbons (VOC). On-road mobile sources of NOx ranged from 0 percent
for White Top Mountain to 87 percent for Greenbrier County. On-road
mobile sources of VOC ranged from 0 percent for White Top Mountain to 53
percent for Greenbrier County. Exhibit IV-7 shows the full results of
the survey.

Exhibit IV‑7: Percentage of Emissions from On-road Mobile Sources

  ----------------------------------------- -------------- --------------
  **Area Name**                             **NOx**        **VOC**

  Sussex County                             21%            22%

  Edmonson County                           63%            36%

  Paducah, Kentucky                         33%            3%

  Essex County                              N/A            N/A

  White Top Mountain                        0%             0%

  Greenbrier County                         87%            53%
  ----------------------------------------- -------------- --------------

Notes: N/A = not reported

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

Using historical data from the federal Highway Performance Monitoring
System (HPMS), VMT growth in Edmonson County is determined to be 2.28
percent annually from 2000 to 2020. HPMS data was also used to determine
the annual increase of VMT in Paducah, which is 2.05 percent for
Marshall County and 2.11 percent for Livingston County.[^3] None of the
other areas reported VMT information, and none of the four areas with a
SIP employ transportation control measures. However, several areas
listed federal actions that have helped the area attain or maintain the
air quality standards. Exhibit IV-8 lists those effective federal
measures cited by the areas.

Exhibit IV‑8: Effective Federal Measures for Attaining or\
Maintaining Air Quality Standards

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

For those areas with SIPs, Exhibit IV-9 lists conformity tests used both
in their conformity determination and in the years beyond the timeframe
of the SIP. (Only two areas provided information.)

Exhibit IV‑9: Conformity Tests

  ------------------- ----------------- -------- ------------ ------------------- ------------------ -------- ------------ ------------------- -----------------
  **Area**            **Last                                                      **Determinations                                             
                      Determination**                                             in Years Beyond                                              
                                                                                  Timeframe of SIP**                                           

                      **Budget test**   **Less   **Build/no   **No-greater-than   **Budget test**    **Less   **Build/no   **No-greater-than   **Demonstration
                                        than     build test** 1990 test**                            than     build test** 1990 test**         using air quality
                                        1990                                                         1990                                      modeling**
                                        test**                                                       test**                                    

  Edmonson County     X                                                           X                                                            

  Paducah             X                                                           X                                                            

  **Total Number**    **2**                                                       **2**                                                        
  ------------------- ----------------- -------- ------------ ------------------- ------------------ -------- ------------ ------------------- -----------------

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

### Comments on the Process

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

## Particulate Matter-10

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

Exhibit IV‑10: 2002 PM-10 Isolated Rural Nonattainment and Maintenance
Areas

  ----------------------------------------------------------------------------------------------
  **State**    **County**    **Area Name**  **Status**      **Class**   **EPA      **Completed
                                                                        Region**   Survey**
  ------------ ------------- -------------- --------------- ----------- ---------- -------------
  Maine        Aroostook     Presque Isle   Maintenance     N/A         1          Yes

  Colorado     San Miguel    Telluride      Maintenance     N/A         8          No

               Archuleta     Pagosa Springs Maintenance     N/A         8          No

               Fremont       Canon City     Maintenance     N/A         8          No

               Pitkin        Aspen          Nonattainment   Moderate    8          No

               Prowers       Lamar          Nonattainment   Moderate    8          No

               Routt         Steamboat      Nonattainment   Moderate    8          No
                             Springs                                               

  Montana      Flathead      Columbia Falls Nonattainment   Moderate    8          No

               Flathead      Flathead       Nonattainment   Moderate    8          No
                             County;                                               
                             Whitefish and                                         
                             vicinity                                              

               Flathead      Kalispell      Nonattainment   Moderate    8          No

               Lake          Polson         Nonattainment   Moderate    8          No

               Lincoln       Libby          Nonattainment   Moderate    8          No

               Rosebud       Lame Deer      Nonattainment   Moderate    8          No

               Sanders       Sanders County Nonattainment   Moderate    8          No
                             (part);                                               
                             Thompson Falls                                        
                             and vicinity                                          

               Silver Bow    Butte          Nonattainment   Moderate    8          No

  Wyoming      Sheridan      Sheridan       Nonattainment   Moderate    8          Yes

  Arizona      Cochise       Douglas        Nonattainment   Moderate    9          No

               Cochise       Paul Spur      Nonattainment   Moderate    9          No

               Gila          Hayden/Miami   Nonattainment   Moderate    9          No

               Gila          Payson         Nonattainment   Moderate    9          No

  Arizona      Mohave        Mohave County  Nonattainment   Moderate    9          No

               Pinal         Hayden/Miami   Nonattainment   Moderate    9          No

               Santa Cruz    Nogales        Nonattainment   Moderate    9          No

  California   Mono          Mammoth Lake   Maintenance     N/A         9          Yes

               Inyo          Owens Valley   Nonattainment   Serious     9          Yes

               Inyo          Searless       Nonattainment   Moderate    9          Yes
                             Valley                                                

               Mono          Mono Basin     Nonattainment   Moderate    9          Yes

  Alaska       Juneau Ed     Juneau         Nonattainment   Moderate    10         No

  Idaho        Bonner        Sandpoint      Nonattainment   Moderate    10         Yes

               Shoshone      Pinehurst      Nonattainment   Moderate    10         Yes

  Oregon       Lake          Lake County    Nonattainment   Moderate    10         Yes

               Josephine     Grants Pass    Nonattainment   Moderate    10         Yes

               Union         LaGrande       Nonattainment   Moderate    10         Yes

  Washington   Walla Walla   Wallula        Nonattainment   Serious     10         No
  ----------------------------------------------------------------------------------------------

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

Exhibit IV‑11: Percentage of Emissions from On-road Mobile Sources

  ---------------------------------- ----------------------- -------------
  **Area Name**                      **Year of Inventory**   **PM-10**

  Presque Isle (Maine)               1994                    61\*

  Sheridan (Wyoming)                 1988                    N/A

  Mammoth Lake (California)          1988                    Less than 1

  Owens Valley (California)          1995                    Less than 1

  Searless Valley (California)       N/A                     Less than 1

  Mono Basin (California)            N/A                     Less than 1

  Sandpoint (Idaho)                  1994                    3

  Pinehurst (Idaho)                  1988                    2

  Lake County (Oregon)               N/A                     N/A

  Grants Pass (Oregon)               1986                    10

  LaGrande (Oregon)                  1986                    5
  ---------------------------------- ----------------------- -------------

Notes: N/A = not available

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

However, several areas listed TCMs, shown in Exhibit IV-12.

Exhibit IV‑12: Transportation Control Measures

  -----------------------------------------------------------------------
  **Area Name**        **TCM Cited**
  -------------------- --------------------------------------------------
  Presque Isle (Maine) Removing de-icing and anti-icing materials as soon
                       as possible from roads.

  Sheridan (Wyoming)   Limiting sand and gravel usage and removing them
                       as soon as possible from a road after snow.

  Mammoth Lake         Restricting parking, increasing transit ridership,
  (California)         and reducing vehicle traffic.

  Owens Valley         None.
  (California)         

  Searless Valley      None.
  (California)         

  Mono Basin           None.
  (California)         

  Sandpoint (Idaho)    Aggressive street sweeping program and anti skid
                       material specs.

  Pinehurst (Idaho)    None.

  Lake County (Oregon) Paving gravel roads.

  Grants Pass (Oregon) None.

  LaGrande (Oregon)    Controlling fugitive dust (winter road sanding,
                       paving gravel streets, etc.).
  -----------------------------------------------------------------------

Interestingly, the most frequently listed TCMs do not fit the commonly
used definition of TCM, which includes actions to adjust traffic
patterns or reduce vehicle use. Only three of the 11 areas that
responded to the survey noted effective federal measures relating to VMT
and tailpipe emissions, as reflected in Exhibit IV-13.

Exhibit IV‑13: Effective Federal Measures for Attaining or\
Maintaining Air Quality Standards

  -----------------------------------------------------------------------
  **Area Name**        **Measures Cited**
  -------------------- --------------------------------------------------
  Presque Isle (Maine) None.

  Sheridan (Wyoming)   None.

  Mammoth Lake         VMT cap, phase out of non-certified wood stoves
  (California)         and fireplaces, mandatory wood burning
                       curtailment.

  Owens Valley         N/A
  (California)         

  Searless Valley      N/A
  (California)         

  Mono Basin           N/A
  (California)         

  Sandpoint (Idaho)    Tier II, CAFE standards, OBD etc. -- improving
                       fuel economy and\
                       emission rates.

  Pinehurst (Idaho)    Tier II, CAFE standards, OBD etc. -- improving
                       fuel economy and\
                       emission rates.

  Lake County (Oregon) CMAQ funds used to pave gravel roads (to reduce
                       transportation-related fugitive dust).

  Grants Pass (Oregon) N/A

  LaGrande (Oregon)    Reducing transportation-related fugitive dust by
                       paving gravel roads.
  -----------------------------------------------------------------------

Notes: N/A = not available

Only three PM-10 nonattainment areas reported having ever made a
conformity determination, and only one of these areas has done so within
the last five years. All three cited the build/no build test in their
latest determination, and two of the three noted the build/no build test
in years beyond the timeframe of their SIP. Exhibit IV-14 summarizes the
responses.

Exhibit IV‑14: Conformity Tests

  --------------- ----------------- -------- ------------ ------------------- -------------- -------- ------------ ------------------- -----------------
  **Area**        **Last                                                      **Conformity                                             
                  Determination**                                             in Years\                                                
                                                                              Beyond                                                   
                                                                              Timeframe of                                             
                                                                              SIP**                                                    

                  **Budget test**   **Less   **Build/no   **No-greater-than   **Budget       **Less   **Build/no   **No-greater-than   **Demonstration
                                    than     build test** 1990 test**         test**         than     build test** 1990 test**         using air quality
                                    1990                                                     1990                                      modeling**
                                    test**                                                   test**                                    

  Sandpoint                                  X                                                        X                                
  (Idaho)                                                                                                                              

  Pinehurst                                  X                                                        X                                
  (Idaho)                                                                                                                              

  Grants Pass                       X        X                                                                                         X
  (Oregon)                                                                                                                             

  **Total                           **1**    **3**                                                    **2**                            **1**
  Number**                                                                                                                             
  --------------- ----------------- -------- ------------ ------------------- -------------- -------- ------------ ------------------- -----------------

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

### Comments on the Process

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

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

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

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

# Appendix A: Survey {#appendix-a-survey .unnumbered}



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

FHWA Transportation/Air Quality Issues in Rural Areas

**Background**

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

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

-   Why are these isolated rural areas in non-attainment or maintenance
    (i.e., what are the main sources contributing to their air quality
    problems)?

-   Who is involved in the transportation planning and conformity
    processes for these isolated rural areas and what are each agency's
    roles?

-   How are these air quality problems being addressed by the different
    agencies involved?

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

**Rural Areas Defined**

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

**FHWA Transportation/Air Quality in Rural Areas**

> **Questionnaire**

Name:

Position:

Organization:

Telephone: E-mail:

### General

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

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

### State Implementation Plan and Air Quality

a.  Does this area have a SIP? \_\_\_\_\_\_Yes \_\_\_\_\_\_ No

b.  If this area has a SIP, what control measures in the SIP help the
    area show attainment?

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

Year of Inventory =

Units of Inventory =

**Sector: Inventory:**

On-road mobile sources

Others? Please list.

d.  What federal actions/measures (e.g., federal vehicle emissions
    controls; fleet turnover) are helping the area attain or maintain
    the air quality standard(s)?

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

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

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

> Is speed information determined? If so, how?

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

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

Yes No

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

### Transportation Planning and Conformity

a.  Is this isolated rural area implementing any transportation control
    measures included in the SIP to address its air quality problem?
    Yes\_\_\_\_\_\_\_\_ No \_\_\_\_\_\_\_\_

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

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

2001

2000

1999

1998

1997

> Did you determine conformity in any of these years:

1997. Yes\_\_\_\_\_\_\_\_\_\_\_\_\_No, \_\_\_\_\_\_if no, why not?

1998. Yes\_\_\_\_\_\_\_\_\_\_\_\_\_No, \_\_\_\_\_\_if no, why not?

1999. Yes\_\_\_\_\_\_\_\_\_\_\_\_\_No, \_\_\_\_\_\_\_if no, why not?

2000. Yes\_\_\_\_\_\_\_\_\_\_\_\_\_No, \_\_\_\_\_\_\_if no, why not?

2001. Yes\_\_\_\_\_\_\_\_\_\_\_\_\_No, \_\_\_\_\_\_\_if no, why not?

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

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

This area does not have a SIP

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

Attainment SIP.

What are the budget years, if budgets exist:

15 percent SIP.

What are the budget years, if budgets exist:

9 percent rate of progress SIP.

What are the budget years, if budgets exist:

Maintenance Plan.

What are the budget years, if budgets exist:

e.  Which of the following conformity test(s) did the isolated rural
    area use in its last conformity determination? Please mark all that
    apply.

Budget test.

Less than 1990 test.

Build/no-build test.

No-greater-than 1990 test.

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

Budget test.

Build/no-build test.

Less than 1990 test.

No-greater-than 1990 test.

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

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

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

Number of determinations since 1997:

Dates on which these conformity determinations were made:

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

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

\_\_\_\_\_\_ Yes \_\_\_\_\_\_\_ No

> For what analysis years did this area have difficulty demonstrating
> conformity?
>
> What was the nature of this area's conformity difficulties? Please
> check all that apply.

Population grew faster than anticipated.

New data/information on fleet resulted in higher emissions.

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

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

Other? Please explain briefly:

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

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

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

Area was experiencing unanticipated growth.

A control measure not being implemented; which measure?

Other? Please explain.

l.  If this area has experienced conformity difficulties, have the
    difficulties been successfully addressed and resolved? \_\_\_\_\_\_
    Yes \_\_\_\_\_\_ No.

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

**Revision to SIP**

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

Adding transportation control measures in the SIP. Which measures?

Adding emission reduction control measures. Which measures?

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

Updating the budget with a new emissions factor model.

Other? Please briefly explain:

**Revision to Transportation Projects**

Eliminating, changing scope of or delaying transportation projects.

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

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

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

Other? Please briefly explain:

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

### Interagency Consultation

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

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

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

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

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

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

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

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

d.  Has the consultation process helped resolve difficulties related to
    demonstrating conformity for a new project? \_\_\_\_\_ Yes
    \_\_\_\_\_ No

> Why or why not? Please briefly explain:

### Other Comments on the Process

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

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

[^3]: Paducah is made up of all of Marshall County and a portion of
    Livingston County.