600 NE Grand Ave. www.oregonmetro.gov

Portland, OR,97232-2736

Metro ^ Making a great place RECEIVED ON:

JAN 17 2014

January 13, 2014

EPA Region 10

Office of the Regional Administrator

Dennis McLerran

U.S. Environmental Protection Agency, Region 10

1200 Sixth Avenue

Seattle, Washington 98101

Dear Mr. McLerran:

We are writing to concur with the action taken by the Oregon Environmental Quality Commission

(EQC) on December 11, 2013, to adopt a substitute transportation control measure (TCM) for the

Portland metropolitan areas

Metro, the Oregon Department of Environmental Quality (DEQ) and EPA Region 10 agreed to

initiate a TCM substitution process at the end of 2012 due to the potential for the region to miss the

target of an existing control measure. After a year-long process, which included the identification of

a substitute measure, collaboration with state and local partners, and an extensive public comment

period, both the Joint Policy Advisory Committee on Transportation (JPACT) and the Metro Council

took action in December 2013 to adopt the substitute TCM. Further detail regarding JPACT and the

Metro Council's action on the substitute TCM is attached to this letter, with technical details

available in the EQC adoption package.

Thank you for the support your agency has provided over the past year; it was invaluable in

successfully adopting the substitute control measure.

Sincerely,

Torn Hughes

Metro Council President

Carlotta Collette

JPACT Chair; Metro Councilor, District 2

OW -NE 6taud. .Aye. wwww:oregontne

Portland, CSR 9723 2731

oar

Metros .Age4cla

Meeting:

Date:

Time:

Place:

Metro Council

Thursday, Dec. 19, 2013

2 p.m.

Metro, Council Chamber

CALL TO ORDER AND ROLL CALL

1. INTRODUCTIONS

2. CITIZEN COMMUNICATION

3. CONSENT AGENDA

3.1 Consideration of the Council Minutes for

Dec. 12, 2013

3.2 Resolution No. 13-4485, For the Purpose of

Confirming the Appointment of Members of the

Nature in Neighborhoods Capital Grants Review

Committee.

3.3 Resolution No. 13-4487, For the Purpose of

Metro Council's Acceptance of the Results of the

Independent Audit for Financial Activity During

Fiscal Year 2012-13.

3.4 Resolution No. 13-4491, For the Purpose of

Confirming the Council President's Appointment

of Carol Gossett, Mychal Tetteh, and Steve White

as Citizen Representatives to the Transportation

Policy Alternatives Committee (TPAC).

RESOLUTIONS 4.

4.1 Resolution No. 13-4486, For the Purpose of Kathleen Brennan-Hunter, Metro

Confirming Eligibility of Projects on Metro Lands

for the Nature in Neighborhoods Capital Grants

Program.

4.2 Resolution No. 13-4489, For the Purpose of Carlotta Collette, Metro Council

Endorsing a Regional Position on Federal

Transportation Policy.

4.3 Resolution No. 13-4490, For the Purpose of Torn Kloster, Metro

Adopting the Substitute Transit Transportation Grace Cho, Metro

Control Measure (TCM) as Part of the State Air

Quality Strategy and Regional Air Quality

Conformity Determination.

4.4 Resolution No. 13-4492, For the Purpose of Kathryn Harrington, Metro Council

Allowing the Beaverton School District to File an Craig Dirksen, Metro Council

Application for a Major Amendment to the Urban

Growth Boundary.

Continued on back...
5. CHIEF OPERATING OFFICER COMMUNICATION

6. COUNCILOR COMMUNICATION

ADJOURN

Please Note: The Metro Council will be on recess from Dec. 20, 2013 to )an. 3, 2014.

Television schedule for Dec. 19. 2013 Metro Council meeting

Clackamas, Multnomah and Washington

counties, and Vancouver, WA

Channel 30 - Community Access Network

Web site: www.tvctv.org

Portland

Channel 30 - Portland Community Media

Web site: www.pcmtv.org

Ph: 503-288-1515

Date: Sunday, Dec. 22, 7:30 p.m.

Date: Monday, Dec. 23. 28, 9 a.m.

Ph: 503-629-8534

Date: Thursday, Dec. 19

Gresham

Channel 30 - MCTV

Web site: www.metroeast.ore

Washington County and West Linn

Channel 30- TVC TV

Web site: www.tvctv.org

Ph: 503-629-8534

Date: Saturday, Dec. 21, 11 p.m.

Date: Sunday, Dec. 22, 11 p.m.

Date: Tuesday, Dec. 24, 6 a.m.

Date: Wednesday, Dec. 25, 4 p.m.

Ph: 503-491-7636

Date: Monday, Dec. 23, 2 p.m.

Oregon City and Gladstone

Channel 28 - Willamette Falls Television

Web site: http://www.wftvmedia.org/

Ph: 503-650-0275

Call or visit web site for program times.

PLEASE NOTE: Show times are tentative and in some cases the entire meeting may not be shown due to length.

Call or check your community access station web site to confirm program times. Agenda items may not be

considered in the exact order. For questions about the agenda, call the Metro Council Office at 503-797-1540. Public

hearings are held on all ordinances second read. Documents for the record must be submitted to the Regional

Engagement and Legislative Coordinator to be included in the meeting record. Documents can be submitted by e-mail, fax

or mail or in person to the Regional Engagement and Legislative Coordinator. For additional information about testifying

before the Metro Council please go to the Metro web site www,oregonmetro.gov and click on public comment

opportunities.

Metro's nondiscrimination notice

Metro respects civil rights. Metro fully complies with Title VI of the Civil Rights Act of 1964 that bans discrimination on

the basis of race, color or national origin. For more information on Metro's civil rights program, or to obtain a Title VI

complaint form, visit www.oregonmetro.gov/civilrights or call 503-797-1536. Metro provides services or

accommodations upon request to persons with disabilities and people who need an interpreter at public meetings. All

Metro meetings are wheelchair accessible. If you need a sign language interpreter, communication aid or language

assistance, call 503-797-1536 or TDD/TTY 503-7974804 (8 a.m. to 5 p.m. weekdays) 7 business days in advance of the

meeting to accommodate your request. For up-to-date public transportation information, visit TriMet's website at

www.trimet.org.
r 7n PJC ara 3 www;or-e onme roe oit

Po3tf r OR %-

,Ag'ehda,

Meeting:

Date:

Joint Policy Advisory Committee on Transportation ()PACT)

Thursday, Dec. 12, 2013

Time:

Place:

7:30 to 9 a.m.

Metro Regional Center, Council Chamber

7:30 AM

7:32 AM

7:35 AM

1.

2.

3.

CALL TO ORDER, DECLARATION OF A

QUORUM & INTRODUCTIONS

CITIZEN COMMUNICATIONS ON JPACT

ITEMS

UPDATES FROM THE CHAIR & COMMITTEE

MEMBERS

• Southwest Washington Regional

Transportation Council Executive

Director Selected

• May 14-16, 2014: Women's

Transportation Seminar (WTS)

International Conference in Portland,

Oregon

• March 5-6, 2014: Annual JPACT Lobby

Trip in Washington, DC

Carlotta Collette, Chair

Carlotta Collette, Chair

Jack Burkman, City of Vancouver

7:40 AM 4. ** CONSIDERATION OF THE MINUTES FOR

NOVEMBER 14, 2013

5. ACTION ITEMS

7:42 AM 5.1 ** Concur Substitute Strategy to Reflect the

Region's Investment in Transit when Making

Air Quality Conformity Findings: Resolution

No. 13-4490 - APPROVAL REQUESTED

Nina DeConcini, DEQ

Grace Cho, Metro

7:52 AM 5.2 * Endorsing a Regional Position on Federal

Transportation Policy: Resolution No. 13-

4489 - APPROVAL REQUESTED

Andy Cotugno, Metro

8 AM 5.3 * Letter of Support to Congressman Blumenauer

for Introducing HR 3636 - The UPDATE Act --

APPROVAL REQUESTED

Andy Cotugno, Metro

6. INFORMATION / DISCUSSION ITEMS

8:15 AM 6.1 * Climate Smart Communities Scenarios Project:

First Look at Results Part 2- INFORMATION/

Kim Ellis, metro

Jerry Lidz, Land Conservation and

DISCUSSION Development Commission

Continued on back...
8:45 AM 6.2 * Greater Portland Export Initiative's Westside Sean Robbins, Greater Portland Inc

Freight Access and Logistics Analysis - Chris Maciejewski, DKS Associates

INFORMATION Scott King, Port of Portland

9 AM 7. ADJOURN Carlotta Collette, Chair

Upcoming JPACT meetings:

• January 9, 2014 - regular JPACT meeting

• February 13, 2014 - regular JPACT meeting

* Material available electronically.

** Material will be distributed in advance of the meeting.

For agenda and schedule information, call Kelsey Newell at 503-797-1916, e-mail: kelsey.newell(oregonrnetro.gov . To check

on closure or cancellations during inclement weather please call 503-797-1700.

Metro's nondiscrimination notice: Metro respects civil rights. Metro fully complies with Title VI of the Civil Rights Act

of 1964 that bans discrimination on the basis of race, color or national origin. For more information on Metro's civil rights

program, or to obtain a Title VI complaint form, visit www.oregonmetro.gov/civilrights or call 503-797-1536. Metro

provides services or accommodations upon request to persons with disabilities and people who need an interpreter at

public meetings. All Metro meetings are wheelchair accessible. if you need a sign language interpreter, communication aid

or language assistance, call 503-797-1536 or TDD/TTY 503-797-1804 (8 a.m. to 5 p.m. weekdays) 7 business days in

advance of the meeting to accommodate your request For up-to-date public. transportation information, visit TriMet's

website at www.trimetorg.
BEFORE THE METRO COUNCIL

FOR THE PURPOSE OF ADOPTING THE

SUBSTITUTE TRANSIT TRANSPORTATION

CONTROL MEASURE (TCM) AS PART OF THE

STATE AIR QUALITY STRATEGY AND

REGIONAL AIR QUALITY CONFORMITY

DETERMINATION

WHEREAS, clean air contributes to the health of Metro residents and their quality of life; and

WHEREAS, the federal Clean Air Act and other federal laws, including Code of Federal

Regulations (CFR) 93.100 through CFR 93.128 contain air quality standards designed to ensure that

federally supported activities meet air quality standards, and these federal standards apply to on-road

transportation plans, programs and activities in the Metro area; and

WHEREAS, Chapter 340, Division 252, Transportation Conformity, of Oregon Administrative

Rules was adopted to implement section 176(c) of the federal Clean Air Act, as amended, and these rules

also apply to Metro area on-road transportation plans, programs and activities; and

WHEREAS, these federal and state regulations require an air quality conformity determination in

order for metropolitan planning organizations (MPOs) to conduct its transportation planning and

programming activities; and

WHEREAS, the federal Clean Air Act Section 176(c)(8) allows regions to replace adopted

transportation control measures (TCMs) when the MPO, state air quality agency, and the U.S.

Environmental Protection Agency find it necessary; and

WHEREAS, the second Portland Area Carbon Monoxide Maintenance Plan, as part of the State's

air quality strategy, also provides a mechanism to substitute an existing TCM with a new proposed TCM

when the MPO, the state air quality agency, and the U.S. Environmental Protection Agency agree to

conduct a substitution; and

WHEREAS, Metro, the MPO for the Portland region, the Oregon State Department of

Environmental Quality (DEQ), and EPA Region TO agreed to initiate a TCM substitution process at the

end of 2012 due to the potential of not meeting one of the existing TCMs; and

WHEREAS, Metro worked in coordination with DEQ, the Tri-County Metropolitan

Transportation District (Tri-Met), the Oregon State Department of Transportation (ODOT), the U.S.

Environmental Protection Agency, and local jurisdictions to develop the preferred TCM substitution

through a collaborative process; and

WHEREAS, Metro and DEQ reviewed federal and state requirements and have determined all

criteria have been met with the preferred substitute transit TCM being presented to replace the existing

transit TCM; and

RESOLUTION NO. 13-4490

Introduced by Chief Operating Officer Martha

Bennett in concurrence with Council

President Tom Hughes
WHEREAS, the Transportation Policy Alternatives Committee (TPAC) took action May 31,

2013 approving the proposed TCM substitution and permitting. Metro and DEQ to continue to move

forward with the TCM substitution process; and

WHEREAS, DEQ undertook a 30-day public comment period and public bearing to provide

community members the opportunity to provide feedback regarding the preferred substitute transit TCM;

and

WHEREAS, the Environmental Quality Commission (EQC) reviewed the preferred TCM

substitute and approved the substitute TCM on December 11, 2013; and

WHEREAS, Joint Policy Advisory Committee on Transportation approved the legislation at the

December 12, 2013 meeting; now therefore

BE IT RESOLVED that the Metro Council hereby adopts the substitute transit TCM as part of the

state air quality strategy and regional air quality conformity determination.

ADOPTED by the Metro Council this _ i day of December 2013.

Allison R. Kean, Metro Attorney
STAFF REPORT

IN CONSIDERATION OF RESOLUTION NO. 13-4490, FOR THE PURPOSE OF ADOPTING THE

SUBSTITUTE TRANSIT TRANSPORTATION CONTROL MEASURE (TCM) AS PART OF THE

STATE AIR QUALITY STRATEGY AND FOR REGIONAL AIR QUALITY CONFORMITY

DETERMINATION

Date: December 5, 2013 Prepared by: Grace Cho

BACKGROUND

In previous decades the Portland region failed to meet national air quality standards for carbon monoxide .

pollution and was designated a non-attainment area. As a result, the region is required to develop and

implement strategies to reduce carbon monoxide emissions in order to conform to the federal Clean Air

Act. To ensure compliance, federal regulations require the Joint Policy Advisory Committee on

Transportation (JPACT), the metropolitan planning organization (MPO) board, to adopt an air quality

plan with each Regional Transportation Plan (RTP) and Metropolitan Transportation Improvement

Program (MTIP). The air quality plan includes a budget of transportation-related emissions and a series of

ongoing "transportation control measures" (TCMs), which serve as strategies to reduce carbon monoxide

emissions. For the Portland region, the TCMs are: 1) Increasing transit service; 2) Expanding the bicycle

network; and 3) Building pedestrian connections. Until 2017, the region is expected to implement TCMs

and demonstrate each MTIP and RTP conform to the provisions of the air quality plan to be eligible to

receive federal funds for transportation projects within the region.

Recent transit service cuts due to the economic recession have endangered the region's ability to meet the

performance standard set forth by the transit service TCM. Under the existing method for evaluating the

transit service increase TCM the region is projected to fall short of the performance standard. Failure to

meet a TCM performance standard can result in an air quality conformity lapse, which jeopardizes the

region's ability to program federal transportation funds.

SUBSTITUTION OF TRANSPORTATION CONTROL MEASURES (TCMs)

Two provision, Section 176(c)(8) of the Clean Air Act and Appendix D9-2 of the second Portland Area

Carbon Monoxide Maintenance Plan allows regions to employ a "substitution" when air quality

conformity cannot be met with the TCMs identified in the statewide and regional air quality plans. A

TCM substitution allows an existing TCM to be replaced with a proposed,TCM that provides equal or

greater pollution reduction. In accordance with federal and state rules, a TCM substitution may be

initiated by the MPO, the relevant state air quality agency and U.S. Environmental Protection Agency

(EPA). t In November 2012, the three agencies (Metro, Oregon Department of Environmental Quality,

and EPA) elected to initiate a TCM substitution for the transit service TCM to prevent a conformity lapse.

TRANSPORTATION CONTROL MEASURE (TCM) SUBSTITUTION PROCESS

To initiate and develop a preferred TCM substitution, Metro and DEQ consulted the Transportation

Policy Alternatives Committee (TPAC), whose membership represents local jurisdictions, regional and

state partners, and community members. At the January 4, 2013 TPAC meeting, DEQ and Metro raised

the issue of the region potentially not meeting the performance standard of the transit TCM identified in

the adopted regional air quality plan. 2 Both agencies underscored the importance of implementing the

TCMs with each MTIP and RTP; otherwise the region will risk repercussions of violating federal

mandates, which affect all local agencies and projects that receive federal transportation dollars.

The Oregon Department of Environmental Quality (DEQ) in conjunction with Metro, developed a TCM substitution

mechanism that was codified with the adoption of the Portland Area Carbon Monoxide Maintenance Plan in the State

Implementation Plan (SIP). The TCM substitution mechanism was adopted prior to the federal TCM substitution provision,

therefore the Portland Metropolitan area is subject to federal and state TCM substitution regulations.

2 Metro. "TPAC Meeting Summary." January 4, 2013. http:11www.oregonmetro.govlindex.cfm/go/by.web/id=31965

Staff Report to Resolution No. 13-4490 Page 1 of 4
Subsequently at the January 25, 2013 TPAC meeting, members recommended Metro undertake a TCM

substitution process to resolve the possibility of not meeting the transit service TCM and outlined several

different TCM substitution options? The following TCM substitutions were considered:

• Combine the three TCMs into a single TCM. This substitution would combine the projected

emissions reductions associated with each separate TCM performance standard together into a

single emissions-related performance standard, and assess the collective result of the region's

progress in meeting each TCM.

• Change the Calculation Method for the Transit Service Increase TCM. This substitution would

change the calculation method for the performance standard of the Transit Service Increase TCM.

As stated in the existing transit service TCM, a 5-year rolling average of actual transit service

hours is used.

• Rewrite the Performance Standard of the TCMs. This substitution would modify the existing

performance standards for the three TCMs.

• An alternative aspro osed by TPAC. This substitution would explore a proposal identified by

TPAC.

At the January 25, 2013 meeting, members of TPAC selected a preferred TCM substitution, but EPA

recommended to Metro, DEQ, and TriMet to pursue a different TCM substitution option during

consultation of the preferred TCM. After further discussions, Metro, DEQ, and TriMet returned to TPAC

at the April 26, 201,3 meeting and recommended changing the calculation method for the transit TCM as

the proposed substitution .4 The main reason provided was that the change in the calculation method

would provide a better reflection of the region's long-term commitment to transit. At the April 26, 2013

meeting, TPAC members agreed to move forward with the proposal to change the calculation method and

directed staffto conduct the required analysis of the preferred TCM substitution.

Table 1. Existing Transit TCM and Preferred Substitute Transit TCM

ison lritService m trc se

TCM

1 re erred Substitute Transit Service

increase TC141

"Regional transit service revenue hours

(weighted by capacity) shall be

increased 1.0% per year. The increase

shall be assessed on the basis of a 5 year

rolling average of actual hours for

assessment conducted between 2006-

2017. Assessments made for the period

through 2008 shall-include the 2004 -

opening of Interstate MAX."

"Regional transit service revenue hours

(weighted by capacity) shall be increased

1.0% per year. The increase shall. be assessed

on the basis of cumulative average of actual

hours for assessment conducted for the entire

second ten-year Portland Area Carbon

Monoxide Maintenance Plan (2007 - 2017).

Transit service increase will- be assessed on

the basis of fiscal year (July 1= June 30)

beginning with FY 2008."

Geography Portland Metropolitan Region

7C1l^1is

Applicable

Implementing TriMet

Agency

At the May 31, 2013 TPAC meeting, Metro staff presented an analysis demonstrating the proposed TCM

substitution met the following EPA and DEQ criteria for implementing a TCM substitution:

The substitute TCM(s) must achieve equal or greater emissions reductions;

' Metro."TPAC Meeting Summary." January 25, 2013. httpa/www.oregonmetro.govIindex.cfmlgo/by.web/id=31965

Metro. "TPAC Meeting Summary." April 26, 2013. http:/lwww.oregonmetro.gov/index.cfinlgo/by.weblid =31965

Staff Report to Resolution No. 13-4490 Page 2 of 4
The substitute TCM(s) must be implemented on a schedule that is consistent with the

schedule for the TCM(s) being removed from the SIP;

• The substitute TCM(s) must be accompanied by evidence of adequate personnel, and funding

and authority under state or local law to implement, monitor and enforce the TCM(s);

The substitute TCM(s) must be developed through a collaborative process that includes

participation by all affected jurisdictions (state and local air pollution control agencies and state and

local transportation agencies such as the MPO, state DOT, and transit providers); consultation with

EPA; and reasonable notice and opportunity for public comment; and

• The equivalency of the substitute TCM(s) must be concurred on by the state air pollution

control agency, the MPO and EPA. That is, EPA, the state air agency, and the MPO must all agree

that on the estimated emissions reductions from the substitute TCM(s) and agree that the estimated

emissions reductions equal or surpass those that would have resulted from the original TCM(s) in the

approved SIP. 5

The preferred TCM substitution analysis and presentation demonstrated the following results:

Table 2. Preferred TCM Substitution Demonstration of Criteria Being Met

Transportation COIRI-ul MeaSirrc

(TCM)

Calculatipn of

TCM Emissions

Reduction Benefit

Implementation

Schedule

Funding,

1 ersonnel

4uthority

Collaboration

on Substitution

Development

Public

Comment

Increase transit service (Existing

TCM)

Regional transit service revenue

hours (weighted by capacity) shall

be increased 1.0% per year. The

increase shall be assessed on the

basis of a 5-year rolling average of

actual hours for assessments

conducted between 2006 and 2017.

406.7 pounds per

day

2006-2017

TriMet

TPAC meetings

January May

2013

Public comment

opportunities at

all TPAC

meetings;

formal DEQ

public comment

period; public

hearing on

August 15,

2013G

Increase transit service (Proposed

TCM Substitution)

Regional transit service revenue

hours (weighted by capacity) shall

be increased 1.0% per year. The

increase shall be assessed on the

basis of cumulative average of

actual hours for assessment

conducted for the entire Second

Portland Area Carbon Monoxide

Maintenance Plan (2007 - 2017).

Transit service increase will be

assessed on the basis of fiscal year

(July 1- June 30) beginning with

FY 2008.

2007-2017

s US Environmental Protection Agency. Guidance for Implementing the Clean Air Act Section 176(c)(8) Transportation Control

Measure Substitution and Addition Provision. January 2009, page 5.

6 Following TPAC action on May 31, 2013, DEQ lead a separate process to accept public comment on the preferred TCM

substitution. The process ran from July 2013-August 2013.

Staff Report to Resolution No. 13-4490 Page 3 of 4
Greater detail regarding the preferred transit TCM substitution analysis and the documentation for

meeting the TCM substitution criteria can be found in Attachment 1. Documentation of methodology

and assumptions to conduct the TCM substitution emissions reductions equivalency analysis can be found

in Attachment 2.

At the May 31, 2013 meeting TPAC determined all the criteria were met for the preferred transit TCM

substitution and approved the process continue to move forward for public comment and adoption by

Metro, DEQ, and EPA.'

TRANSPORTATION CONTROL MEASURE (TCM) SUBSTITUTION - DEQ PROCESS

After approval by TPAC, the process moved forward with DEQ taking on the next steps to have the

substitute transit TCM adopted by the Environmental Quality Commission (EQC). DEQ announced a

formal public comment period from July 15, 2013 - August 19, 2013 and scheduled a public hearing on

August 15, 2013. All public comments and staff recommendations in light of public comments were

placed into a report to be sent to the EQC for consideration at the December 11, 2013 meeting. At the

December 1 I, 2013 meeting, the EQC will decide whether the preferred transit TCM substitution.

FINAL ACTIONS

Upon EQC approval and adoption, the existing transit TCM will be rescinded. The preferred TCM

substitution will return to JPACT and Metro Council for a concurrence action: Following JPACT, and

Metro Council actions, DEQ and Metro will submit documentation to EPA for concurrence.

ANALYSIS/INFORMATION

1. Known Opposition: The proposed TCM substitution has received some opposing comments during

the DEQ public comment period. See DEQ authored public comment report for full record of

comments received.

Legal Antecedents:

Federal regulations include:

• Clean Air Act, as amended [42 U.S. C. 7401 and 23 U.S.C. 109(j)], as amended].

• US EPA transportation conformity rules (40 CFR, parts 51 and 93)

• US EPA Guidance for Implementing the Clean Air Act Section 176(c)(8) Transportation

Control Measure Substitution and Addition Provision.

State regulations include:

• Oregon Administrative Rules for Transportation Conformity, (OAR Chapter 340, Division

252).

• 2006 State Implementation Plan (SIP).

• 2006 Portland Area Carbon Monoxide Maintenance Plan and 2007 Portland Area Ozone

Maintenance Plan.

2. Anticipated Effects: Adoption of this resolution allows for the substitute transit TCM to go into

replace the existing transit TCM and go into effect immediately for implementing the region's air

quality plan and conformity purposes. The funding of proposed transportation projects in the 2015-

2018 MTIP and the update of the 2014 Regional Transportation Plan update will be able to continue

as scheduled.

7 Metro. "TPAC Meeting Summary." May 31, 2013. http://www.oregonmetro.gov/index.cfiu/go/by.web/id =3I965

Staff Report to Resolution No. 13-4490 Page 4 of 4
3. Budget Impacts: None directly by this action. Upon approval of this action, projects included in the

2015-2018 Metropolitan Transportation Improvement Program and the 2014 RTP update will be able

to move forward with implementation.

RECOMMENDED ACTION

Metro staff recommends the approval of Resolution No. 13-4490.

Staff Report to Resolution No. 13-4490 Page 5 of 4
Attachment 1 to Resolution 13-4490

May 31, 2013

TPAC and Interested Parties

Tom Kloster, Transportation Planning Manager

Grace Cho, Assistant Transportation Planner

Subject: Air Quality Conformity - Transportation Control Measures (TCMs) Substitution -

Analysis Results Summary

Date:

To:

From:

Introduction

As an EPA designated maintenance area for carbon monoxide (CO), the Portland Metropolitan

region is required to develop and implement strategies to reduce the amount of criteria pollutants

released from transportation sources. The Portland Area Carbon Monoxide Maintenance Plan has

three strategies which are designated as transportation control measures (TCMs). Those measures

entail: 1) Increasing transit service; 2) Expanding the bicycle network; and 3) Building pedestrian

connections. 1

Recent transit service cuts have endangered the region's ability to meet the performance standard

of Transit Service Increase TCM. Under the existing method for evaluating the Transit Service

Increase TCM the region is projected to fall short. Failure to meet a TCM performance standard can

result in an air quality conformity lapse, which jeopardizes the region 's ability to program federal

transportation funds.

An EPA policy allows regions to substitute an equivalent or greater pollution reduction TCM to

replace an existing TCM implemented by a region when a Metropolitan Planning Organization,

relevant air quality agency and EPA determine that a change is appropriate. 2 The Oregon

Department of Environmental Quality (DEQ), in conjunction with Metro, developed a TCM

substitution process that was codified with the adoption of the Portland Area Carbon Monoxide

Maintenance Plan. 3 In accordance with the DEQ and EPA rules for a TCM substitution, consultation

was conducted with the Transportation Policy Advisory Committee (TPAC). Through consultation

the region elected to undergo a TCM substitution for the Transit Service Increase TCM to prevent a

conformity lapse.

i Oregon Department of Environmental Quality, "Portland Area Carbon Monoxide Maintenance Plan ." State

Implementation Plan. Volume 2 Section 4.58 Appendix D9-3.

2 U.S. Environmental Protection Agency, "Guidance for Implementing the Clean Air Act Section 176(c)(8)

Transportation Control Measure Substitution and Addition Provision." Page 1.

3 Oregon Department of Environmental Quality, "Portland Area Carbon Monoxide Maintenance Plan ." State

Implementation Plan. Volume 2 Section 4.58 Appendix D9-2.
Attachment I to Resolution 13-4490

Per EPA and DEQ policy, Metro must demonstrate the proposed TCM substitution:

• Demonstrates a collaborative process that includes participation by all affected jurisdictions

(state and local air pollution and state and local transportation agencies such as the MPO,

state DOT, and transit providers); consultation with EPA; and reasonable notice and

opportunity for public comment;

• Can be implemented on a schedule that is consistent with the schedule for the existing TCM

being removed;

• Presents evidence of adequate personnel, funding and authority under state or local law to

implement, monitor and enforce the TCM;

• Provides equal or greater carbon monoxide emissions reductions; and

• Is concurred by DEQ, Metro, and EPA. 4

The following memorandum summarizes the analysis which demonstrates the proposed substitute

TCM meets DEQ and EPA requirements.

Preferred TCM Substitution Demonstration

Processof Developing the PreferredSubstituteTCM and Concurrence by Metro, DEQ, and EPA

Metro and DEQ identified the Transportation Policy Advisory Committee (TPAC) as the

consultation body for TCM substitution process as the membership represents jurisdictions,

regional and state partners, and community members affected by a conformity lapse. At the January

4, 2013 TPAC, DEQ and Metro staff raised the issue of the region potentially not meeting the

performance standard for one of the transportation control measures (TCM) identified in the

adopted regional air quality plan. 5 Under federal requirements, the region is expected to implement

TCMs and demonstrate each MTIP and RTP conform to the provisions of the air quality plan or risk

repercussions of violating federal mandates, which affect all local agencies and projects that receive

federal transportation dollars.

Subsequently at the January 25, 2013 TPAC, members recommended Metro staff and DEQ

undertake a TCM substitution process to resolve the potential issue of the region not meeting the

Transit Service Increase TCM. 6 In giving approval to move forward, DEQ and Metro staff presented

several different TCM substitution options at the February and April TPAC meetings. The following

TCM substitutions were considered:

• Combining the three TCMs into a single TCM. This substitution would combine the

projected emissions reductions associated with each separate TCM threshold together into

a single threshold, and assess the collective result of the region's progress in meeting each

TCM.

• Change the Calculation Method for the Transit Service Increase TCM. This substitution

would change the calculation method for the performance standard of the Transit Service

'Increase TCM. As stated in the existing transit service TCM, a 5-year rolling average of

actual transit service hours is used.

4 U.S. Environmental Protection Agency, "Guidance for Implementing the Clean Air Act Section 176(c)(8)

Transportation Control Measure Substitution and Addition Provision." Page 1. & Oregon Department of

Environmental Quality, "Portland Area Carbon Monoxide Maintenance Plan ." State Implementation Plan.

Volume 2 Section 4.58 Appendix D9-2.

5 Metro. "TPAC Meeting Summary." January 4, 2013.

http://www.oregonmetro.gov/index.cfm/go/by.web/id=31965

6 Metro."TPAC Meeting Summary." January 25, 2013.

http://www.oregonmetro.gov/index.cfm/go/by.web/id=31965

2
Attachment 1 to Resolution 13-4490

• Rewriting the Performance Metrics of the TCM. This substitution would modify the existing

performance standards for the three TCMs.

• An alternative as proposed by TPAC. This substitution would explore a proposal identified

by TPAC.

At the January 25, 2013 meeting, members of TPAC selected combining the three TCMs into a single

TCM Substitution. However, consultation with EPA recommended Metro, DEQ and TriMet pursue a

different TCM substitution option. After several discussions, Metro, DEQ, and TriMet returned to

TPAC at the April 26, 2013 meeting outlining the circumstances and recommended readjusting the

calculation method for the Transit Service Increase TCM as the proposed substitution.? At the April

26, 2013 meeting, TPAC members agreed to move forward readjustment method and allowed staff

to develop the preferred TCM substitution method identified below.

Table 1. Existing TCM and Preferred Substitute TCM

Existing Fraiisi mice Increase

TCM

Preferred Substitute raiisit Service

inc^ ease TCl4f. :.

"Regional transit service revenue

hours (weighted by capacity) shall be

increased 1.0% per year. The

increase shall be assessed on the

basis of a S year rolling average of

actual hours for assessment

conducted between 2006-2017.

Assessments made for the period

through 2008 shall include the 2004

opening of Interstate MAX. "

"Regional transit service revenue hours

(weighted by capacity) shall be increased

1.0% per year. The increase shall be

assessed on the basis of cumulative

average of actual hours for assessment

conducted for the entire second ten-year

Portland Area Carbon Monoxide

Maintenance Plan (2007 - 2017). Transit

service increase will be assessed on the

basis of fiscal year (July 1- June 30)

beginning with FY 2008."

Geography Portland Metropolitan Region Portland Metropolitan Region

_

TCM rs=

Applicable

Implementing TriMet TriMet

Agency

With approval from TPAC, staff has undertaken an analysis to demonstrate the proposed TCM

substitution will meet EPA and DEQ requirements. Upon approval by TPAC that the TCM

substitution analysis satisfactorily meets the DEQ and EPA requirements, the TCM substitution

process will move forward with DEQ taking on the process to have the substitute TCM adopted by

the Environmental Quality Commission (EQC). Upon EQC adoption, the existing TCM will be

rescinded. The adoption process entails public comment, which would occur through summer

2013. In fall 2013, the TCM substitution will return to Metro for TPAC, JPACT and Metro Council

action. Following TPAC, JPACT, and Metro Council actions, the EQC will take action to adopt the

substitute 'TCM. DEQ and Metro will submit documentation to EPA for concurrence. For more

information, see Attachment A for the TCM substitution timeline.

ImplementationSchedule

Under the existing Transit Service Increase TCM, the language identifies an annual implementation

schedule from 2006-2017. The beginning year, 2006, of the annual implementation schedule is one

year prior to the approved second ten-year Portland Area Carbon Monoxide Maintenance Plan. The

7 Metro. '"I'PAC Meeting Summary." April 26, 2013.

http://www.oregonmetro.gov/index.cfm/go/by.web/id=31965

3
Attachment 1 to Resolution 13-4490

preferred TCM substitution identifies an annual implementation schedule for the entire second tenyear Portland Area Carbon Monoxide Maintenance Plan. The second ten-year Portland Area Carbon

Monoxide Maintenance Plan is in effect from November 2007 - October 2017. Since the time frame

for existing and proposed substitute TCM overlap the same ten-year period, the implementation

schedule of the proposed substitute TCM is consistent with the existing TCM.

Evidence of Financial Ability and Authority to Implement the Preferred TCM Substitution

TriMet is a municipal corporation of the State of Oregon. Through enabling legislation ORS 267,

TriMet has broad powers to provide mass transportation on behalf of the district. B Therefore,

TriMet, as a transit service provider, has the authority to implement the proposed TCM

substitution.

TriMet staff has confirmed expansions to date, budget forecast, and financial projections from now

through 2017 to determine the following year-to-year service changes. 9 Though TriMet expects to

reduce structural costs and identify additional resources to increase service well beyond these

levels in the long-term, the projections TriMet has used for these calculations are the more

conservative financial plan projections underlying its approved FY2014 budget. 1 ° The following

table showing the year-to-year change in transit service illustrates .that under the proposed TCM

substitution the Transit Service Increase TCM performance standard has been met in previous

years and that the projected future years annual transit service increase is expected to meet the

proposed TCM substitution performance standard.

Fro tedConnotative ralrsitlnerSease (TESU ettnn58iiijure io ensCLshowtherasrufa6ve.averago.anniii15 " s

Periiand Area Caibcret Monoude'M ipeenai rr P iwdis, vinfN Ttb Y 1, 2S►ij7 L?cfa e► ^, 1111

E erceni;

grange year

to-yea fiscal Year

20

5.3%

1.0%

48%

'flfl9,`

5:4% 5

2C

i:49b

3:3%

2009

2015

2011

?0i7 P1IOJ

3.1

2220 332%

:34% 1.24"..r_

1 .20% f... 1.26%

E. ;e% .5% 116%

1-1 1 . 1:1_% } .13 1.13% 1_13% 1

17'# ". '7% .11 1.17% t.17% 117% 1.17% 117%

1 u 1+H^t 1 r%?`16

I-52% 1. Y2% 1.5 s:% 1.52% 1.50%

1.4%

4.a%

B State of Oregon. Oregon Statute Chapter 267 - Mass Transit.

9 TriMet. Annual Budget and Financial Forecast, 2013.

kO Ibid.

4
Attachment 1 to Resolution 13-4490

Additionally, see Attachment B, a letter of commitment from TriMet in support of the TCM

substitution and the substitution process.

Demonstration of Equivalent Carbon MonoxideEmissions ReductionBenefit for Preferred TCM

Substitution

To demonstrate the preferred substitute TCM provides equal or greater carbon monoxide

emissions reduction benefit, the same methodology was applied in calculating the emissions

reduction benefit for the existing TCM to the preferred substitute TCM. The inputs to calculate the

existing and proposed substitute TCM reflect the latest planning assumptions and the new

MOVES2010 carbon monoxide emissions rate. More details regarding TCM substitutions technical

analysis methodology and assumptions can be found in Attachment C.

Table 2. Preferred TCM Substitution Demonstration of Equivalent or Greater Carbon

Monoxide Emissions Reduction Benefits

TransIortation

Control

Measure (TCM)

Performance Standard Calculation of TCM Emissions

Reduction Benefit

Original

TCM

Emissions

Reduction

Benefit

Regional transit service

revenue hours (weighted

Additional Trips Generated Per

Day: 3,221

Increase transit

service (Existing

by capacity) shall be

increased 1.0% per year.

The increase shall be

assessed on the basis of a

Average Transit Trip Length: 6

miles

3,221 trips x 6 miles = 19,326 40631h/day

TCM) 5-year rolling average of

actual hours for

assessments conducted

between 2006 and 2017.

miles

19,326 miles x 9.546 grams per

mile = 184,486 total grams

184,486 total grams/453.592

grams per pound = 406.7 pounds

per day

Regional transit service

revenue hours (weighted

Additional Trips Generated Per

Day: 3,221.

Increase transit

service

by capacity) shall be

increased 1.0% per year.

The increase shall be

assessed on the basis of

cumulative average of

actual hours for

assessment conducted for

Average Transit Trip Length: 6

miles

3,221 trips x 6 miles = 19,326

miles

19,326 miles x 9.546 grams per

mile = 184,486 total grams 406.71b/day (Proposed TCM the entire Second 184,486 total grams/453.592

Substitution) Portland Area Carbon

Monoxide Maintenance

Plan (2007 - 2017).

grams per pound = 406.7 pounds

per day

Transit service increase

will be assessed on the

basis of fiscal year (July 1-

June 30) beginning with

FY 2008.

5
Attachment 1 to Resolution 13-4490

Based on the results of the carbon monoxide emissions reduction benefit analysis, the proposed

TCM substitution will provide equal carbon monoxide reduction benefit as the existing TCM.

Since the proposed TCM substitution is a minor adjustment to the method of calculating the annual

transit service increase (from a rolling average to a cumulative average) to determine if the

performance standard has been achieved no change is observed between the existing TCM and the

proposed substitute TCM in carbon monoxide emissions reduction benefits. This is because the

original methodology assumed a constant ratio between a 1.0 percent annual transit service

increase and the resulting amount of vehicle trips diverted. If a 1.0 percent annual transit service

increase occurred then the TCM and emissions reduction benefits has been achieved. Since the

proposed TCM substitution does not change the performance standard of 1.0 percent annual transit

service increase, but only the method of calculating the service increase, the number of vehicle trips

diverted do not change, This does not end up changing the inputs in calculating the emissions

reduction benefits.

More details regarding TCM substitutions technical analysis methodology can be found in

Attachment C.

While the carbon monoxide emissions reduction benefit analysis complies with EPA's and DEQ's

requirements for the analysis methods, the requirements applied to the methodology limits the

region's ability to show the true nature of emissions reduction benefits gained since the

implementation of the TCM in 2007. The recent economic downtown forced a significant cut to

transit service after several years of high transit service growth. Nonetheless, ridership and

therefore ultimately diverted trips have increased even during the recession. This demonstrates

while transit service may fluctuate, air quality benefits are still gained. The cumulative average

method more accurately reflects the lasting positive benefits and long-term investments the region

has made towards transit, including a reduction of carbon monoxide emissions and overall

improved air quality.

Request

Metro, DEQ and TriMet recommend TPAC approve the proposed TCM substitution analysis

satisfactorily meets all DEQ and EPA requirements and approve the TCM substitution process to

move forward towards EQC adoption.

Next Steps

Metro, DEQ and TriMet staff will provide an update on the status of the TCM substitution process at

the June ]PACT meeting. Following, DEQ will prepare the necessary documentation and undergo a

public comment process to prepare for the EQC adoption. See Attachment A for the TCM

substitution timeline.

6
Attachment 2 for Resolution 13-4490

Attachment B - Technical Analysis of Proposed Transit Service Increase TCM Substitution for

the Portland Metropolitan Region

Background

Clean Air Act section 176(c) (8) allows regions to employ a "substitution," when air quality and

transportation planning agencies find it appropriate to modify or replace the original

transportation control measures (TCMs) in an air quality plan.. The Oregon Department of

Environmental Quality (DEQ), in conjunction with Metro, developed a substitution policy and

process that was codified with the adoption of the Portland Area Carbon Monoxide Maintenance

Plan. 2 A TCM substitution allows an existing TCM to be replaced with another TCM of equal or

greater emissions reduction. To undergo a TCM substitution, the process entails consultation with

regional stakeholders, conducting technical analysis demonstrating equivalent or greater emissions

reduction, public comment, and concurrence from Metro, Oregon State Department of

Environmental Quality (DEQ), and the U.S. Environmental Protection Agency (EPA).3

The Portland Metropolitan region proposed undergoing a TCM substitution due to a potential

shortfall in meeting the Transit Service Increase TCM. The following outlines the process

undertaken to demonstrate the proposed substitute TCM will provide an equal or greater carbon

monoxide emissions reduction benefit.

Portland Metropolitan Region's Transportation Control Measures

As an EPA designated maintenance area for carbon monoxide, the Portland Metropolitan region is

required to develop and implement strategies to reduce the amount of criteria pollutants released

from transportation sources. 4 The region identified and committed to three transportation control

measures (TCMs) to help mitigate impacts of criteria pollutants from transportation sources. S

Metro and regional partners are responsible for implementing all of its TCMs to meet federal and

state requirements. The three TCMs are found in Table 1.

Emissions

Reduction

Bench.

Regional transit service revenue hours (weighted by

capacity) shall be increased 1.0% per year. The increase

shall be assessed on the basis of a 5-year rolling average 246.3 lb/day

of actual hours for assessments conducted between 2006

and 2017.

Jurisdictions and government agencies shall program a

minimum total of 28 miles of bikeways or trails within

the Portland metropolitan area between the years 2006

through 2017. A cumulative average of 5 miles of

. U.S. Environmental Protection Agency, "Guidance for Implementing the Clean Air Act Section 176(c)(8)

Transportation Control Measure Substitution and Addition Provision." Page 1.

2 0regon Department of Environmental Quality, "Portland Area Carbon Monoxide Maintenance Plan ." State

Implementation Plan. Volume 2 Section 4.58 Appendix D9-2.

3 Ibid.

"Oregon Department of Environmental Quality, "Portland Area Carbon Monoxide Maintenance Plan ." State

Implementation Plan. Volume Z Section 4.58 Page 21.

5 Ibid.

Program and

construct bikeways

and trails

Table 1. Transportation Control Measures and Performance Standards

Increase transit

service

170.1 lb/day

1
Attachment 2 for Resolution 13-4490

bikeways or trails per biennium must be funded from all

sources from each MTIP.

Program and

construct

pedestrian paths

Jurisdictions and government agencies shall program at

least nine miles of pedestrian paths in mixed-use centers

between the years 2006 through 2017, including the

funding of a cumulative average of 1 and 1/2 miles in

each biennium from all sources in each MTIP.

.91b/day

Proposed TCM Substitutions

In anticipation the region may not meet the performance standard for the Transit Service Increase

TCM, TPAC recommended Metro, DEQ and TriMet to undergo EPA's TCM substitution process.

Through a collaborative process and in consultation with EPA, the following TCM substitution is

proposed:

Existing Transit Service Increase TCM

Language

Proposed Substitute Transit Service Increase

TCM Language

"Regional transit service revenue hours

(weighted by capacity) shall be increased 1.0%

per year. The increase shall be assessed on the

basis of a 5 year rolling average of actual hours

for assessment conducted between 2006-2017.

Assessments made for the period through 2008

shall include the 2004 opening of Interstate

MAX."

"Regional transit service revenue hours

(weighted by capacity) shall be increased 1.0%

per year. The increase shall be assessed on the

basis of cumulative average of actual hours for

assessment conducted for the entire second tenyear Portland Area Carbon Monoxide

Maintenance Plan (2007 - 2017). Transit service

increase will be assessed on the basis of fiscal

year (July 1- June 30) beginning with FX 2008. "

The proposed substitute TCM uses a cumulative average to-date to determine whether a 1.0

percent annual transit service increase has been achieved. This is similar as the existing TCM, which

requires a 1.0 percent annual transit service increase, but the existing TCM is based on a rolling five

year average of past transit service. Using the new methodology of a cumulative average accounts

for all years-to-date when calculating the whether 1.0 percent service increase has been achieved.

The cumulative average method for the Transit Service Increase TCM provides a longitudinal look

at whether the TCM is being met throughout the life of the maintenance plan rather than a five-year

snapshot.

Methodology, Emissions Model Update, and Latest Planning Assumptions Update for

Calculating the Carbon Monoxide Emissions Reductions Benefit

To employ a TCM substitution, EPA and DEQ requires the new TCM meet or exceed the emission

reduction benefit of the replaced TCM. However, the process requires the demonstration of

equivalent carbon monoxide emissions reductions to use updated planning assumptions. 6

Methodology

Each TCM in the regional air quality plan was assigned a performance standard as a means of

measuring and monitoring the region's commitment to reducing carbon monoxide emissions. The

State Implementation Plan (SIP) which serves as the statewide air quality plan established the

6 U.S. Environmental Protection Agency, "Guidance for Implementing the Clean Air Act Section 176(c](8)

Transportation Control Measure Substitution and Addition Provision." Page 6.

2
Attachment 2 for Resolution 13-4490

methodology to calculate the emission reduction benefits of TCMs.7 Since of premise of the

proposed TCM substitution is a modification to how the TCM annual transit service increase is .

calculated, the emissions reduction benefit methodology was not modified. The same emissions

reduction methodology outlined in the SIP was used to calculate the carbon monoxide emissions

reduction benefit for the updated existing TCM and proposed TCM substitution.

For the Transit Service Increase TCM, the methodology entails:

1) Estimating the number of vehicle trips which are diverted to transit by meeting the

performance standard of the TCM; and

2) Identifying the average length of transit trip. 8

Using the estimated number of diverted vehicle trips, the average transit trip length, and a carbon

monoxide emissions reduction rate, the carbon monoxide emissions reduction benefit is calculated

as follows:

1) X number of diverted vehicle trips from meeting transit performance standard (per day) x

average length of transit trip (in miles) = X number miles diverted per day

2) X number miles diverted x CO rate (in grams per mile) = total CO grams per day

3) X total CO grams per day/453.592 grams per pound = X total CO pounds per day 9

Assumptions

Per EPA and DEQ rules, the latest planning assumptions must be used to when conducting a TCM

substitution analysis. 10 In the methodology of calculating the carbon monoxide emissions reduction

benefit for the existing and the proposed substitute TCM, there are two areas where the latest

planning assumptions can be reflected: the number of diverted vehicle trips and the average transit

trip length.

In 2011, Metro conducted an update to the Oregon Household Activity Survey (OHAS). The OHAS

provides information regarding the region's travel behavior and habits. The 2011 OHAS indicate

the average transit trip length increased from 5.9 miles to 6 miles. il The updated average trip

length was incorporated in the analysis of the carbon emissions reduction benefit for the proposed

substitute TCM and the existing TCM.

The existing Transit Service Increase TCM used 2003 reported revenue hours to determine the

diverted vehicle trips diverted by meeting the Transit Service Increase TCM performance standard

of 1.0% annual service increase. The 2003 revenue hours were not weighted by capacity. TriMet

provided 2012 revenue hours which were used to update and determine the number of vehicle

trips. 12 The 2012 revenues were not weighted by capacity. Table 2identifies the assumptions-in the

diverted vehicle trips and average length used in the analysis.

7 Oregon Department of Environmental Quality, "Portland Area Carbon Monoxide Maintenance Plan ." State

Implementation Plan. Volume 2 Section 4.58 Appendix D9-3.

8 Ibid.

9 Ibid.

1v U.S. Environmental Protection Agency, "Guidance for Implementing the Clean Air Act Section 176(c)(8)

Transportation Control Measure Substitution and Addition Provision." Page 6.

11 Metro. Oregon Household Activity Survey, 2011.

Metro. Oregon Household Activity and Travel Survey, 1994.

12 TriMet. Annual Budget and Financial Forecast, 2012.

3
Attachment 2 for Resolution 13-4490

Table 2. Transit Service Increase TCM Assumptions

Assumption Existing Transit Service Increase

TCM

I. Existing Transit Service Increase

TCM (updatedwith latest

planning assumptions)

and

Proposed Substihite Transit

Service Increase TCM

Diverted Trips TriMet reported 2003 total revenue

hours was 1,677,156 resulted

88,863,600 boardings/trips.

Assuming ratio of revenue hours to

ridership is constant, one percent

change in 2003 reported revenue

hours results in an annual ridership

of 89,751,153. Subtracting the

difference results in an estimate of a

one year increase of yearly ridership

888,553, which on a daily basis

would be an increase of 2,843 riders.

Assuming each rider equates to one

diverted vehicle trip, the daily

diverted trip for meeting the

performance standard is 2,843.

TriMet reported 2012 total revenue

hours was 1,600,132 resulted

101,210,444 boardings/trips.

Assuming ratio of revenue hours to

ridership is constant, one percent

change in 2012 reported revenue

hours results in an annual ridership

of 102,2018,644. Subtracting the

difference results in an estimate of

a one year increase of yearly

ridership 1,008,200, which on a

daily basis would be an increase of

3,221 riders. Assuming each rider

equates to one diverted vehicle trip,

the daily diverted trip for meeting

the performance standard is 3,221.

Average Trip 5.9 miles - 1994 Oregon Household 6.0 miles - 2011 Oregon Household

Length Activity Survey Activity Survey

Model Assumptions

To ensure consistency between the carbon monoxide emissions reduction benefit established with

MOBILE6.2, the MOVES2010 conversion incorporated the same base year assumptions used in

MOBILE6.2. MOVES2010b was run in the emission rates mode at the county scale for the 24-hour

January weekday in 2005 and was configured to produce CO rates for passenger cars and passenger

trucks on urban roads. The County Data Manager was populated with inputs from Metro's most

recent conformity-related MOBILE6.2 run, converted to the formats required by MOVES in

accordance with EPA technical guidance. MOVES was run for three custom counties representing

the various inspection and maintenance regimes that are represented by vehicles traveling in the

Portland metro area: Oregon-inspected, Washington-inspected, and non-inspected. The rates

produced by MOVES were stratified by hour, roadway type (restricted versus non-restricted

access), average speed bin, and I/M area. Using VMT produced by the most recent conformityrelated run of Metro's regional transportation model for 2005, weighted averages were applied to

each of the above strata to arrive at a single CO rate (9.546 grams/mile).

Translating Performance Metrics into Emission Reduction Benefits

Prior to performing the analysis to compare the carbon monoxide emissions reduction benefit of

the existing TCM and the proposed substitute TCM, Metro staff needed to update the emissions

4
Attachment 2 for Resolution 13-4490

reduction benefits of the existing TCM to reflect the latest approved EPA emissions model. 13 In

March 2010, EPA implemented new rules requiring the use of the MOVES2010 emissions model for

all regional air quality conformity and state implementation plan analyses. 14 The carbon monoxide

emissions reduction benefits were derived from the previous carbon monoxide rate which came

from the MOBILE 6.2 emissions model. Using the same methodology established in the SIP to

calculate the emissions reduction benefit for the Transit Service Increase TCM, staff employed the

MOVES2010 carbon monoxide rate to convert the carbon monoxide emissions reduction benefit for

the existing Transit Service Increase TCM. Additionally, the emissions reduction benefit also

employed the latest planning assumptions. Tables 3 - 5 illustrate the results of the conversion.

Diverted Trips Per Day: 2,843

Average Transit Trip Length: 5.9

miles

2,843 trips x 5.9 miles = 16.773.7

miles

16,773.7 miles x 6.66 grams per mile

= 11,712.842 total grams

11,712.842 total grams/453.592

grams per pound = 246.3 lb/day

Table 4. Carbon Monoxide Emission Reduction Benefit Calculation -- MOVES2010 Conversion

without Updated Planning Assumptions

MOVES2010

Carbon

Monoxide (CO

Emission Rate

Diverted Trips Per Day: 2,843

Average Transit Trip Length: 5.9

miles

2,843 trips x 5.9 miles = 16,773.7

miles

16,773.7 miles x 9.546 grams per

mile = 160,121.740 total grams

160,121.740 total grams/453.592

grams per pound = 353.0 lb/day

13 U.S. Environmental Protection Agency, "Guidance for Implementing the Clean Air Act Section 176(c)(8)

Transportation Control Measure Substitution and Addition Provision." Page 6.

14 U.S. Environmental Protection Agency, Policy Guidance on the Use of MOVES2010 and Subsequent Minor

Revisions for State Implementation Plan Development, Transportation Conformity, and Other Purposes."

Table 3. Original Carbon Monoxide Emission Reduction Benefit Calculation - MOBILE6.2

Transportatioii:

Control

Measure (TCM)

MOBILE6.2

Carbon

Moitoxiile (CU )

Emission Rate

Calculation of'I'CM Emissions

Reduction Benefit

Increase transit

service

6.66 CO grams

per mile 246.3 lb/day

Transportation

Control

Measure (TCM)

Increase transit

service

9.546 CO grams

per mile

Calculation ofTCM-EmiSSiO. s

Reduction Benefit (unadjusted)

MOVES2010

Emissions

Reduction Benefit

353.0 lb/day

5
Attachment 2 for Resolution 13-4490

Table 5. Carbon Monoxide Emission Reduction Benefit Calculation - MOVES2010 Conversion

with Updated Planning Assumptions

Transportation

Control

Measure (TCM)

MOVES2010

Carbon

Monoxide (CO)

Emission Rate

Calculation of TCM Emissions

Reduction Benefit (adjusted for

updated planting assumptions

MOVES2010

Emissions

Reduction Benefit

Increase transit

service

9.546 CO grams

per mile

Diverted Trips Per Day: 3,221

Average Transit Trip Length: 6 miles

3,221 trips x 6 miles = 19,326 miles

19,326 miles x 9.546 grams per mile

= 184,486 total grams

184,486 total grams/453.592 grams

per pound = 406.7 lb/day

406.71b/day

TCM Substitution Demonstration of Equivalent Carbon Monoxide Emissions Reduction

Benefit

Demonstration ofCarbonMonoxideEmissionsReduction Benefitsfor Proposed TCM Substitution

Table 5 illustrates the results of the carbon monoxide emission reduction benefit analysis and

compares the emissions reduction benefit for the existing TCM (with updated planning

assumptions) and proposed substitute TCM.

Table 6. TCM Substitution Demonstration of Equivalent Carbon Monoxide Emissions

Reduction Benefit

Transportati

on Control

Measure

(TCM)

Performance Standard Calculation of TCM Emissions

Reduction Benefit

TCM

Emissions

Reduction

Benefit

Increase

transit

service

[Existing

TCM adjusted

for MOVES

and latest

planning

assumptions)

Regional transit service

revenue hours (weighted by

capacity) shall be increased

1.0% per year. The increase

shall be assessed on the

basis of a 5-year rolling

average of actual hours for

assessments conducted

between 2006 and 2017.

Additional Trips Generated Per

Day: 3,221

Average Transit Trip Length; 6

miles

3,221 trips x 6 miles = 19,326

miles

19,326 miles x 9.546 grams per

mile = 184,486 total grams

184,486 total grams/453.592

grams per pound = 406.7 pounds

per day

406.71h/day

6
Attachment 2 for Resolution 13-4490

Regional transit service

revenue hours (weighted by

Additional Trips Generated Per

Day: 3,221

Increase

transit

service

(Proposed

TCM

capacity) shall be increased

1.0% per year. The increase

shall be assessed on the

basis of cumulative average

of actual hours for

assessment conducted for

the entire Second Portland

Area Carbon Monoxide

Average Transit Trip Length: 6

miles

3,221 trips x 6 miles = 19,326

miles

19,326 miles x 9.546 grams per

mile 184,486 total grams

184,486 total grams/453.592

406.7 lb/day

Substitution) Maintenance Plan (2007 -

2017). Transit service

increase will be assessed on

the basis of fiscal year (July

1- June 30) beginning with

FY 2008.

grams per pound 406.7 pounds

per day

Based on the results of the carbon monoxide emissions reduction benefit analysis, the proposed

TCM substitution will provide equal carbon monoxide reduction benefit as the existing TCM.

Since the proposed TCM substitution is a minor adjustment to the method of calculating the annual

transit service increase (from a rolling average to a cumulative average) to determine if the

performance standard has been achieved no change is observed between the existing TCM and the

proposed substitute TCM in carbon monoxide emissions reduction benefits. This is because in the

original methodology assumed a constant ratio that if 1.0 percent annual transit service increase

occurred, the result is a set amount of vehicle trips diverted. Since the proposed TCM substitution

does not change. the performance standard of 1.0 percent annual transit service increase, but only

the method of calculating the service increase, then the vehicle trips diverted do not change. This

does not end up changing the inputs in calculating the emissions reduction benefits. However, the

cumulative average method more accurately reflects the lasting positive benefits and long-term

investments the region has made towards transit. Subsequently this has led to a reduction of

carbon monoxide emissions and overall improved air quality. The cumulative average method

provides a more accurate reflection of the region's commitment to transit over the entire carbon

monoxide maintenance plan.

7
Transportation Control

Measure (TCM)

Substitution

Better reflecting the region's

commitment to improve air quality

and transit.

Nina DeConcini, DEQ

Tom Kloster, Metro
What is a Transportation Control

Measure (TCM)?

• An on-going strategy to improve air quality.
Why are TCMs important to this

region? 6monthsof air quality violations

Cleaner Air

Improved

Public Health

Continue

Federal

Funding

. Capacity for

Economic

Growth
Portland Region -Today

16 years without an air quality violation
Getting to Today

• Jan. 2013 - New transit TCM proposed to DEQ and EPA to

better capture history of regional investment

• Summer 2013 - Public comment on proposed TCM

• Dec. 11-Oregon EQC adopts proposed TCM

• Dec. 12 - JPACT considers proposed TCM for adoption

• Dec. 19 - Metro Council considers proposed TCM for

adoption

• Jan. 2014 -EPA concurrence and new transit TCM in effect

for conforming the RTP and MTIP
What does this mean for JPACT?

• Acknowledges the region's

commitment to transit

• Continue to protect our air

• Achieve regional goals

Basis for demonstrating

conformity for updated RTP

and MTIP