1

SUPPORTING STATEMENT FOR

EPA INFORMATION COLLECTION REQUEST NUMBER 2130.05

TRANSPORTATION CONFORMITY DETERMINATIONS FOR FEDERALLY 

FUNDED AND APPROVED TRANSPORTATION PLANS, PROGRAMS AND 

PROJECTS 

February 2015
2

Table	of	Contents

1. IDENTIFICATION OF THE INFORMATION COLLECTION........................................ 3

1(a) Title of the Information Collection...................................................................................... 3

1(b) Short Characterization/Abstract........................................................................................... 3

2. NEED FOR AND USE OF THE COLLECTION............................................................... 5

2(a) Need/Authority for the Collection ....................................................................................... 5

2(b) Practical Utility/Users of the Data ....................................................................................... 5

3. NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA5

3(a) Non-Duplication .................................................................................................................. 5

3(b) Public Notice Required Prior to ICR Submission to OMB ................................................. 6

3(c) Consultations........................................................................................................................ 6

3(d) Effects of Less Frequent Collection..................................................................................... 7

3(e) General Guidelines............................................................................................................... 8

3(f) Confidentiality ..................................................................................................................... 9

3(g) Sensitive Questions.............................................................................................................. 9

4. THE RESPONDENTS AND THE INFORMATION REQUESTED................................. 9

4(a) State and Local Respondents/North American Industry Classification System.................. 9

4(b) Information Requested....................................................................................................... 10

5. THE INFORMATION COLLECTED–AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT.................................................. 12

5(a) Agency Activities............................................................................................................... 12

5(b) Collection Methodology and Management........................................................................ 13

5(c) Small Entity Flexibility...................................................................................................... 13

5(d) Collection Schedule ........................................................................................................... 14

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION........................... 14

6(a) Estimating State and Local Respondent Burden and Cost................................................. 14

6(b) Estimating State and Local Respondent Costs................................................................... 29

6(c) Estimating Agency Burden and Costs ............................................................................... 30

6(d) Estimating the Respondent Universe and Total Burden and Costs ................................... 38

6(e) Bottom Line Burden Hours and Cost Tables..................................................................... 38

6(f) Reasons for Change in Burden .......................................................................................... 40

6(g) Burden Statement............................................................................................................... 41

Appendix A: Conformity-Related Research Considered for This ICR ........................................ 42
3

1.	 IDENTIFICATION	OF	THE	INFORMATION	COLLECTION

1(a) Title	of	the	Information	Collection

This information collection request (ICR) is entitled "Transportation Conformity

Determinations for Federally Funded and Approved Transportation Plans, Programs and 

Projects,” ICR number 2130.05. This ICR includes transportation conformity burden anticipated 

for calendar years 2015-2017. 

1(b) Short	Characterization/Abstract

Transportation conformity is required under Clean Air Act section 176(c) [42 U.S.C. 

7506(c)] to ensure that federally supported transportation activities are consistent with (“conform 

to”) the purpose of the state air quality implementation plan (SIP). Transportation activities 

include transportation plans, transportation improvement programs (TIPs), and federally funded 

or approved highway or transit projects. Conformity to the purpose of the SIP means that 

transportation activities will not cause new air quality violations, worsen existing violations, or 

delay timely attainment of the relevant national ambient air quality standards (NAAQS or 

“standards”) or interim milestones. 

Transportation conformity applies under EPA’s conformity regulations at 40 CFR Part 

93, Subpart A, to areas that are designated nonattainment, and those re-designated to attainment 

after 1990 (“maintenance areas” with plans developed under Clean Air Act section 175A) for the 

following transportation-related criteria pollutants: ozone, particulate matter (PM2.5 and PM10), 

carbon monoxide (CO), and nitrogen dioxide (NO2). 

The Environmental Protection Agency (EPA) published the original transportation 

conformity rule on November 24, 1993 (58 FR 62188), and subsequently published several 

revisions. EPA develops the conformity regulations in coordination with the Federal Highway 

Administration (FHWA) and Federal Transit Administration (FTA). 

Transportation conformity determinations are required before federal approval or funding 

is given to certain types of transportation planning documents as well as non-exempt highway

and transit projects.1 In metropolitan nonattainment and maintenance areas, conformity

determinations are required for transportation plan and TIP updates and amendments. A 

metropolitan transportation plan is at least a 20-year planning document that describes the 

policies, strategies and facilities that are proposed by state and local decision-makers for future 

implementation in a metropolitan area. The TIP prioritizes and programs capital highway and 

transit projects for implementation in a metropolitan area over a four-year period, consistent with 

the transportation plan. 

 

1

Projects that are exempt from all or certain conformity requirements include projects listed in 40 CFR 

93.126 (e.g., safety projects, maintenance of current roads), projects that do not impact regional emissions in 40 

CFR 93.127, and traffic signal synchronization projects listed in 40 CFR 93.128. 
4

To meet the Clean Air Act’s conformity requirements, once a SIP is established for a 

given pollutant and NAAQS, projected regional emissions from a nonattainment or maintenance 

area’s transportation system must be at or below the motor vehicle emissions level or “budget” 

for on-road mobile sources in the area’s SIP. Prior to EPA finding a budget adequate2or 

approving a SIP, the conformity rule provides emissions tests that ensure that Clean Air Act 

requirements are met in the interim.

EPA considered the following in developing this ICR:

 Burden estimates for transportation conformity determinations (including both regional 

and project-level) in current nonattainment and maintenance areas for the ozone, PM2.5,

PM10, CO, and NO2 NAAQS;

 Federal burden associated with EPA’s adequacy review process for submitted SIP 

budgets that are to be used in conformity determinations; 

 Efficiencies in areas making conformity determinations for multiple NAAQS;

 Differences in conformity resource needs in large and small metropolitan areas and 

isolated rural areas;

 Burden estimates for the transition from MOVES2010 to MOVES2014.

3

 Reduced burden as a result of areas no longer determining conformity for the 1997 ozone 

NAAQS due to revocation4, anticipated by early 2015; and,

 Reduced burden as a result of areas completing 20 years of maintenance for PM10 and 

CO NAAQS, at which time transportation conformity is no longer required.

This ICR does not include burden associated with the general development of 

transportation planning and air quality planning documents for meeting other federal 

requirements. There are other ICRs that capture associated burdens for these non-conformity

planning requirements and are prepared by other organizations within EPA and DOT. 

 

2

Per the transportation conformity rule, submitted SIP budgets are appropriate to use prior to EPA’s 

approval of the SIP when EPA declares them adequate for transportation conformity purposes (40 CFR 93.118(e) 

and (f)).

3

In this document, “MOVES2010” refers to all of the MOVES2010 models: MOVES2010, MOVES2010a, 

and MOVES2010b. 

4

 See 78 FR 34178 (June 3, 2013).
5

2. NEED	FOR	AND	USE	OF	THE	COLLECTION

2(a) Need/Authority	for	the	Collection

The Clean Air Act gives EPA the statutory authority to establish the criteria and 

procedures for determining whether transportation activities conform to the SIP. EPA 

promulgated the transportation conformity regulations under the authority of Clean Air Act 

section 176(c). The federal government needs information collected under these regulations to 

ensure that metropolitan planning organization (MPO)5and federal transportation actions are 

consistent with state air quality goals.

2(b) Practical	Utility/Users	of	the	Data

Federal, state, and local transportation agencies use information collected under the 

conformity regulation to ensure that federally funded or approved transportation actions conform 

to SIPs for attaining and maintaining clean air. Specifically, transportation agencies use 

information they collect to demonstrate that:

 Regional emissions and/or project-level analysis requirements are satisfied; 

 Transportation control measures (TCMs) in approved SIPs are implemented in a timely

manner;

 State, local, and federal transportation and air quality agencies consult and resolve issues 

related to conformity determinations; and,

 Public comments are considered and responses to comments are documented prior to 

conformity actions.

3.	 NON-DUPLICATION,	CONSULTATIONS,	AND	OTHER	COLLECTION	

CRITERIA

3(a) Non-Duplication

EPA wrote the transportation conformity regulation and subsequent revisions, in 

coordination with FHWA and FTA, to avoid duplicating the collection efforts required by other 

regulatory programs. The conformity regulation works with existing transportation and air 

quality planning requirements from the Clean Air Act, Title 23 of United States Code and other 

 

5 MPO means the policy board of an organization created and designated to carry out the metropolitan 

transportation planning process (40 CFR 93.101).
6

federal highway laws, Federal Transit Laws, and the National Environmental Policy Act 

(NEPA). 

The conformity regulation relies on but does not duplicate DOT’s transportation planning 

regulations for developing transportation plans, TIPs, and projects. Many nonattainment and 

maintenance areas can rely on travel, economic, or other forecasts that are already available for 

other planning purposes to complete regional conformity analyses. In addition, the conformity

regulation does not create any new fiscal constraint or public participation requirements. The 

regulation simply relies upon existing transportation planning requirements. 

Localized air quality analyses (or “hot-spot” analyses) are generated for certain projectlevel conformity determinations for certain criteria pollutants. When project-level analyses are 

required for both conformity approvals and NEPA, project sponsors may rely on the same 

analysis, assuming that it meets all necessary air quality requirements. Finally, although 

transportation actions are compared to SIP budgets for conformity determinations when they are 

available, SIPs are required to be submitted for other Clean Air Act purposes, and are not 

required by the conformity provisions.

3(b) Public	Notice	Required	Prior	to	ICR	Submission	to	OMB

In compliance with the 1995 Paperwork Reduction Act (PRA), any agency developing a 

non-rule related ICR must solicit public comments for a 60-day period prior to submitting the 

ICR to OMB. These comments, which are used partly to determine realistic burden estimates for 

respondents, must be considered when completing the final Supporting Statement that is 

submitted to OMB. 

The announcement of a public comment period for this renewal ICR has been made in 

the Federal Register under Docket ID No. EPA-HQ-OAR-2007-0269.

6

 

3(c) Consultations

To prepare this ICR, EPA relied upon the previous ICR for information on the number of 

hours required to complete the following:

 Developing transportation plan, TIP, and project conformity determinations;

 Consulting with state, local, and federal agencies on conformity determinations;

 Performing regional and hot-spot analyses;

 

6To maintain the integrity of the ICR docket and all the associated ICR renewal records, the original docket 

number and date from the previous ICR continue to be used. For this renewal, a new Phase of the original docket 

number has been opened.
7

 Documenting that TCMs in approved SIPs are implemented on time;

 Conducting other miscellaneous activities (e.g., reviewing conformity documents, 

responding to conformity-related public comments, etc.); and,

 Training new state and local government staff to perform conformity-related duties (for 

those nonattainment areas without previous conformity experience).

EPA also consulted with FHWA and FTA headquarters and field offices. 

Individuals/staff consulted: 

 Karen Perritt, (202) 366-9066, Department of Transportation, Federal Highway

Administration; and, 

 Adam Stephenson, (202) 366-5183, Department of Transportation, Federal Transit 

Administration, Office of Planning and Environment.

EPA also requested information from EPA Regional Offices. 

Finally, EPA relied upon existing research completed on the transportation conformity

process that indicated the number of hours associated with making conformity determinations in 

isolated rural areas.

7

 See Appendix A – Conformity Related Research Considered for this ICR.

3(d) Effects	of	Less	Frequent	Collection

The Clean Air Act requires conformity for transportation plans and TIPs to be determined 

every four years in metropolitan nonattainment and maintenance areas. This statutory

requirement is typically satisfied when an area updates its long-range transportation plan to meet 

the four-year planning requirement for DOT’s transportation planning regulations. The Clean 

Air Act and DOT’s transportation planning regulations require TIPs to be updated every four 

years, and as a result, conformity determinations are also done for TIPs every four years.8 The 

Clean Air Act also requires conformity for transportation plans and TIPs within two years of a 

new SIP motor vehicle emission budget being established.

9

Conformity determinations are required in isolated rural nonattainment and maintenance 

 

7

Isolated rural nonattainment and maintenance areas are areas that do not contain nor are part of any 

metropolitan planning areas as designated under the transportation planning regulations. Isolated rural areas do not 

have federally required metropolitan transportation plans or TIPs and do not have projects that are part of the 

emissions analysis of any MPO’s metropolitan transportation plan or TIP. Projects in such areas are instead 

included in statewide transportation improvement programs. These areas are distinct from donut areas (40 CFR 

93.101).

8 Additional plan/TIP amendments are completed on a voluntary basis beyond the required plan/TIP update 

cycles. These are not addressed in this ICR.

9 EPA assumed that conformity determinations occur infrequently for this scenario and therefore no burden 

was included in this ICR.
8

areas only when a new project needs federal funding or approval. The Clean Air Act’s minimum 

four-year frequency requirement for transportation plans and TIPs and two year SIP- related 

conformity requirements do not apply in these areas. Therefore, these areas are not required to 

demonstrate conformity on a regular basis as in metropolitan areas. Conformity determinations 

before project approvals are made in isolated rural areas and are necessary to meet the goals of 

the Clean Air Act.

Information collection occurs less frequently in isolated rural nonattainment and 

maintenance areas compared to metropolitan areas, as these areas do not have as many large 

transportation projects as metropolitan areas. However, because of the statutory language, the 

periodic collection of information for metropolitan nonattainment and maintenance areas cannot 

be reduced, as these minimum periodic reporting requirements were established to achieve and 

maintain clean air. 

Information collection would cease in areas that reach the end of their 20-year

maintenance period. Once an area has attained the NAAQS for a criteria pollutant, the state may

submit a request to the EPA for the redesignation of the nonattainment area for that pollutant 

under Clean Air Act section 175A(a). 

In general, actions on metropolitan transportation plans, TIPs, and FHWA/FTA projects 

taken on or after the date that is 20 years after the effective date of redesignation will not require 

a conformity determination for the applicable pollutant.10

Finally, reduced information collection will also occur through EPA’s final rule that 

addresses revocation for the 1997 ozone NAAQS as part of the Implementation Rule for the 

2008 ozone NAAQS. The rule is anticipated to be effective early in 2015.11 Therefore, 

transportation conformity for the 1997 ozone NAAQS will stop applying on the final rule’s 

effective date, and ozone conformity continues to apply only for 2008 ozone NAAQS 

nonattainment and maintenance areas.

3(e) General	Guidelines

This ICR adheres to the guidelines stated in the 1995 Paperwork Reduction Act,

OMB’s implementing regulations, and EPA’s Information Collection Request Handbook. None

of these reporting or record keeping requirements violate any of the regulations established by

OMB in 5 CFR 1320.5.

 

10

 40 CFR 93.102(b)(4) and Transportation Conformity Guidance for Areas Reaching the End of the 

Maintenance Period (EPA-420-B-14-093, October 2014).

11 The proposed rule can be found at 78 FR 34178 (June 3, 2013)
9

3(f) Confidentiality

Respondents for the transportation conformity regulation do not submit confidential 

information for approval. All information collected and submitted in a conformity determination 

is already publicly available, pursuant to 40 CFR 93.105(e) of the conformity regulation and 23 

CFR 450.316(a) of the transportation planning regulations.

3(g) Sensitive Questions

No questions of a sensitive nature are included in any of the information collection 

requirements for the transportation conformity regulation. Examples of sensitive information 

include information concerning sexuality or religious beliefs. 

4.	 THE	RESPONDENTS	AND	THE	INFORMATION	REQUESTED

4(a) State	and	Local	Respondents/North	American	Industry	

Classification	System		

In the transportation conformity process, the respondent is either a state or local agency. 

Depending upon the type of conformity determination and the type of area involved, the state or 

local agency may vary. For instance, in metropolitan nonattainment and maintenance areas, 

MPOs are the primary local respondent for transportation plan and TIP conformity

determinations. Clean Air Act section 176(c)(1) states that “... No metropolitan planning 

organization designated under section 134 of Title 23, shall give its approval to any project, 

program, or plan which does not conform to an implementation plan approved or promulgated 

under section 7410 of this title....”

In metropolitan areas, each MPO must formally make a conformity determination on its 

transportation plan and TIP prior to submitting them to DOT for an independent review and a 

conformity determination. State or local air agencies also provide technical assistance in 

supplying air quality data or performing emissions factor modeling for transportation plan and 

TIP regional conformity analyses.

State and local respondents for conformity determinations for projects within 

metropolitan areas can vary depending upon who the project sponsor is. A project sponsor 

within a metropolitan area may be the state department of transportation, local transit agency, or 

other state or local agency, depending upon the individual project. Developing conformity

determinations for projects outside metropolitan boundaries is also typically the responsibility of 

the project sponsor, which is usually the state department of transportation.
10

The transportation conformity rule also requires that state, local and federal transportation 

and air quality agencies develop interagency consultation procedures for discussing and 

resolving issues related to conformity determinations. Such agencies include the MPO, local 

transit agency, state department of transportation, state and local air agencies, EPA, FHWA, and 

FTA. Federal respondents for conformity determinations are discussed further in Section 5 of 

this ICR.

The following is a representative list of North American Industry Classification System 

(NAICS) codes for the government agencies that would be affected by the transportation 

conformity regulation: 

485111 Mixed Mode Transit System

485210 Interurban and Rural Bus Transportation

488490 Other Support Activities for Road Transportation

924110 Administration of Air and Water Resources and Solid Waste Management Programs

925120 Administration of Urban Planning and Community and Rural Development

926120 Regulation and Administration of Transportation Programs

4(b) Information	Requested

(i) Data Items, Including Record Keeping Requirements

Section 4(b)(ii) describes the information requested for and roles conducted by state and 

local respondents for conformity determinations. Some of the information used in conformity

determinations is also used for other transportation and air quality planning purposes. Specific 

roles of state and local agencies will vary from area to area. 

(ii) Respondent Activities

Metropolitan Planning Organizations

MPOs are the lead agency in making transportation plan and TIP conformity

determinations in metropolitan nonattainment and maintenance areas. The level of information 

collection requirements for completing such determinations will vary with the size of the area 

and complexity of the air quality problem. The following list includes MPO activities for 

transportation plan and TIP conformity determinations:

 Conduct regional emissions analyses using the latest planning assumptions and models to 

determine whether the emissions from the proposed transportation system are consistent 

with state air quality goals; 

 Ensure timely implementation of TCMs in approved SIPs;

 Consult with other state, local, and federal transportation and air quality agencies throughout 
11

the conformity process; 

 Circulate draft plan/TIP conformity determinations for interagency review and public 

comment and respond to any comments on plan/TIP conformity determinations; and,

 Provide travel activity or other data for hot-spot analyses.

State Departments of Transportation

State departments of transportation are typically the lead agency in developing 

conformity determinations for projects in isolated rural nonattainment and maintenance areas. 

They can also be the lead agency for project-level conformity determinations in metropolitan 

areas. The following list includes state department of transportation activities for conformity

determinations:

 Assist the MPOs or conduct the regional emissions analyses for the MPO, using the 

latest assumptions and models to determine whether the emissions from the proposed 

transportation system change is consistent with state air quality goals;

 Conduct regional emissions analyses on projects in isolated rural areas and donut areas12

using the latest assumptions and models to determine whether the emissions from the 

proposed transportation system change is consistent with state air quality goals;

 Ensure timely implementation of TCMs in approved SIPs;

 Conduct hot-spot analyses for projects when required;

 Comment on draft transportation plan and TIP conformity determinations;

 Consult with other state, local, and federal transportation and air quality agencies 

throughout the conformity process; and

 Circulate draft project conformity determinations for interagency review and public 

comment and respond to any comments as appropriate.

Local Transit Agencies

Local transit agencies in metropolitan areas are typically the lead agency in developing 

project-level conformity determinations for transit projects in metropolitan areas. The 

following list includes local transit agency activities for project-level conformity

determinations:

 

12 Donut areas are geographic areas outside a metropolitan planning area boundary, but inside the boundary 

of a nonattainment or maintenance area that contains any part of a metropolitan area(s). These areas are not isolated 

rural nonattainment and maintenance areas (40 CFR 93.101).
12

 Conduct hot-spot analyses for transit projects when required;

 Comment on draft transportation plan and TIP conformity determinations;

 Consult with other state, local, and federal transportation and air quality agencies 

throughout the conformity process; and,

 Circulate draft project conformity determinations for interagency review and public 

comment and respond to any comments as appropriate.

State and Local Air Quality Agencies

State and local air quality agencies may provide technical assistance to transportation 

agencies in the development of conformity determinations. The following list includes possible 

state and local air agency activities for conformity determinations:

 Provide air quality data or perform emissions factor modeling for regional emissions 

analyses for transportation plans and TIPs in metropolitan areas and projects in isolated 

rural areas; 

 Provide similar assistance for hot-spot analyses for projects as appropriate;

 Consult with state, local, and federal agencies throughout the conformity process; and,

 Comment on draft conformity determinations. 

5. THE	INFORMATION	COLLECTED–AGENCY	ACTIVITIES,	COLLECTION	

METHODOLOGY,	AND	INFORMATION	MANAGEMENT

5(a) Agency	Activities

(i) FHWA and FTA Activities

The FHWA Division Office and the FTA Regional Office are involved in several 

aspects of the transportation conformity process:

 Making conformity determinations for transportation plans, TIPs, and projects;

 Reviewing the relevant materials that are submitted to support the conformity

determinations including the travel, emissions, or air quality modeling performed to 

support a conformity determination and comments submitted by the EPA Regional 

Office; and,
13

 Issuing a letter to the appropriate MPO, state department of transportation, or other 

project sponsor indicating that they have made a conformity determination.

FHWA and FTA field offices also participate in the interagency consultation process for 

nonattainment and maintenance areas. The interagency consultation process is used to discuss 

and resolve issues during the development of transportation plan, TIP, and project conformity

determinations. The frequency of meetings varies from area to area. FHWA Resource Centers 

and FHWA/FTA Headquarters provide technical assistance as needed.

(ii) EPA Activities

The EPA Headquarters and Regional Offices are involved in several aspects of the 

transportation conformity process:

 Participating in the interagency consultation process in nonattainment and 

maintenance areas; 

 Reviewing and commenting on conformity determinations for transportation plans, 

TIPs and projects, including the travel, emissions, or air quality modeling performed 

to support a conformity determination; 

 Making adequacy findings for submitted SIP motor vehicle emissions budgets. 

EPA’s adequacy review is separate from EPA’s review of the SIP for completeness 

or approval; and,

 Providing technical assistance as needed.

5(b) Collection	Methodology	and	Management

Federal agencies review conformity determinations in accordance with the Clean Air 

Act section 176(c) and 40 CFR Part 93, Subpart A. The interagency consultation process is 

used to discuss any outstanding issues on the accuracy or quality of data used in conformity 

analyses and determinations. The general public reviews MPO conformity determinations for 

transportation plans and TIPs, and federal agencies review MPO responses to these comments. 

The federal agencies will need to maintain records of their actions, in accordance with other 

federal record retention requirements. No special machines or processing technologies are 

employed in reviewing conformity determinations. 

5(c) Small	Entity	Flexibility

A regulatory flexibility analysis is not required because the rule does not affect a 

significant number of small entities. However, the rule does affect some isolated rural 

nonattainment and maintenance areas which are considered to be small entities because they
14

have populations less than 50,000. EPA has taken steps in the conformity rule to reduce the 

burden placed on these areas. For example, isolated rural areas are required to demonstrate 

conformity only when they have a new non-exempt federally funded or approved highway or 

transit project. In contrast, metropolitan nonattainment and maintenance areas are required to 

demonstrate conformity at least every four years.

5(d) Collection	Schedule

The information collections described in this ICR must be completed before a 

transportation plan, TIP or project conformity determination is made. DOT’s planning 

regulations require that transportation plans and TIPs be updated at least every four years, and 

the Clean Air Act requires that a conformity determination on the transportation plan and TIP in 

metropolitan areas be completed at least every four years.

13 Conformity determinations on 

projects in metropolitan and isolated rural areas are required on an as-needed basis, as 

previously described in Section 4, The Respondents and the Information Requested. 

6.	 ESTIMATING	THE	BURDEN	AND	COST	OF	THE	COLLECTION

6(a) Estimating	State	and	Local	Respondent	Burden	and	Cost

(i) Overview

This section of the ICR includes background information on the number of 

nonattainment and maintenance areas that are subject to transportation conformity regulations. 

For these areas, EPA has estimated potential burden for the following:

 Transportation plan and TIP conformity determinations for nonattainment and 

maintenance areas;

 Project-level conformity determinations for nonattainment and maintenance areas, 

including burden associated with quantitative PM hot-spot analyses;

 The transition from MOVES2010 to MOVES2014; and 

 Areas designated nonattainment for the 2008 ozone NAAQS.

This ICR covers only the time period of 2015 to 2017, and EPA has attributed the 

amount of burden to the above categories during that time period. Further specifics are 

addressed as each are discussed below. Please refer to Section 6(b) for additional assumptions 

used in estimating respondent cost.

 

13 These are minimum requirements are reflected in the ICR, additional plan/TIP amendments that are done 

on a voluntary basis beyond the required plan/TIP update cycles are not addressed in this ICR.
15

Designations for the 2015 ozone NAAQS have not been made yet and therefore no 

burden is included in this ICR renewal for conformity determinations for this NAAQS. 

(ii) State and Local Respondent Burden and Costs for Nonattainment and 

Maintenance Areas 

Background on Nonattainment and Maintenance Areas

As stated earlier, this ICR includes the burden associated with implementing conformity

requirements with respect to nonattainment and maintenance areas for transportation-related 

criteria pollutants: ozone, CO, PM10, PM2.5, and NO2. The following table illustrates the number 

of areas currently subject to transportation conformity requirements, using data from EPA’s 

Green Book for the number of nonattainment and maintenance areas:14

Table 1:

Number of Areas Subject to Transportation Conformity Requirements

Pollutant/NAAQS

Number of Metropolitan 

Nonattainment/Maintenance 

Areas

Number of Isolated Rural 

Nonattainment/Maintenance 

Areas

2012 PM2.5

15 12 2

2008 ozone16 39 7

CO 50 2

PM10 48 36

1997 PM2.5

17 38 1

2006 PM2.5

18 29 3

1971 NO2

19 1 0

2010 NO2

20 0 0

 

14 http://www.epa.gov/air/oaqps/greenbk/index.html

15

 The PM2.5 areas referred to in this row were designated nonattainment for 2012 PM2.5 NAAQS on 

January 15, 2015 (80 FR 2206). Transportation conformity starts applying April 15, 2016.

16

 The ozone areas referred to in this row were designated nonattainment for the 2008 ozone NAAQS on 

May 21, 2012 (77 FR 30088) and June 11, 2012 (77 FR 34221).

17

 The PM2.5 areas referred to in this row were designated nonattainment for the 1997 PM2.5 NAAQS on 

January 5, 2005 (70 FR 944). 

18 The PM2.5 areas referred to in this row were designated nonattainment for the 2006 PM2.5 NAAQS on 

November 13, 2009 (74 FR 58688). 

19 This entry is for the 1971 annual NO2 NAAQS. 

20

 The NO2 areas referred to in this row were designated attainment/unclassifiable for the 2010 NO2

NAAQS on February 17, 2012 (77 FR 9532). No nonattainment areas for this NAAQS were designated at that time. 
16

This ICR reflects the burden associated with determining conformity for all of these 

pollutants/NAAQS; however, EPA’s estimates reflect efficiencies realized when metropolitan 

areas are nonattainment or maintenance for two or more pollutants/NAAQS since there is often 

an overlap of time spent in consultation, regional emissions analysis and other miscellaneous 

activities for these areas in determining conformity for two or more pollutants. 

As discussed further below, EPA also has identified the number of nonattainment and 

maintenance areas with multiple MPOs that are subject to transportation conformity for one or 

more pollutants/NAAQS, since many metropolitan nonattainment and maintenance areas have 

more than one MPO (and consequently, more than one transportation plan or TIP conformity 

determination). The number of MPOs estimated in the following tables is based upon 

information collected from EPA Regional Offices, EPA’s Green Book, and from other sources.21

Finally, EPA assumes that the conformity resource burden will differ among:

 Larger metropolitan nonattainment and maintenance areas (urbanized area populations 

over 200,000);

 Smaller metropolitan nonattainment and maintenance areas (urbanized area populations 

between 50,000-200,000); and,

 Isolated rural nonattainment and maintenance areas (populations under 50,000). 

Since conformity requirements, complexity of air quality issues and geographic size can 

vary depending on an area’s population, number of MPOs, and number of pollutants involved, 

EPA believes it is appropriate to account for these differences in calculating the conformity 

burden in nonattainment and maintenance areas. For donut areas, the burden is assumed to be 

included in the MPO burden estimates. 

Transportation Plan and TIP Conformity Determinations in Metropolitan Nonattainment and 

Maintenance Areas

EPA is relying on information from several sources for this ICR’s estimated state and 

local burden hours for conformity determinations: 

 As described in Section 3(c), EPA requested burden information from EPA Regions and 

DOT that regularly work with state and local organizations responsible for making 

conformity determinations for transportation plans and TIPs; 

 EPA has reviewed the conformity burden hour estimates for previous ICRs for the 

transportation conformity program and the burden hours assumed in DOT’s ICR for the 

 

21 Federal Register Vol. 67, No. 84, May 1, 2002, Department of Commerce, Bureau of the Census, 

Qualifying Urban Areas for Census 2000 and Federal Register Vol. 67, No. 130, July 8, 2002, Department of 

Transportation, Federal Transit Administration/Federal Highway Administration Designation of Transportation 

Management Areas. 
17

transportation planning regulations; and,

 EPA reviewed existing conformity research studies for conformity burden in current rural 

nonattainment and maintenance areas. These research studies are listed in Appendix A of 

this ICR.

The following paragraphs describe estimated state and local burden hours for conformity 

determinations in experienced metropolitan nonattainment and maintenance areas. The ICR 

assumes that all conformity determination work is completed by state and local employees, 

although in practice some work may be completed by consultants. EPA again notes that 

transportation plan and TIP burden hour estimates are based on demonstrating conformity for 4-

year transportation plan and TIP updates as required by statute and regulation, rather than more 

frequent plan and TIP revisions or amendments which are not required by the Act. This ICR 

captures the burden associated with meeting the minimum transportation conformity 

requirements.

EPA has calculated the burden associated with transportation plan and TIP conformity

determinations by considering the number of MPOs that are subject to conformity, the size of 

these MPOs, and the number of pollutants that apply. To estimate burden hours that MPOs 

incur to determine conformity for just one pollutant/NAAQS, EPA and DOT field offices were 

asked for estimated state and local respondent burden for the various tasks involved in a 

transportation plan or TIP conformity determination. For burden hours associated with each 

additional pollutant, EPA relied on data from ICR 2130.04 for incremental burden hours 

associated with performing transportation plan and TIP conformity determinations for each 

additional pollutant/NAAQS, which were based on federal survey responses.

For each burden hour estimated, EPA assumed that state and local agencies work only

on conformity-related activities. This ICR does not include burden for the general development 

of transportation plans, TIPs, projects, or motor vehicle emissions budgets, since these 

documents are developed to meet other requirements. EPA is assuming that some data 

collection for transportation planning or SIP purposes could also be used in conformity without 

additional conformity-related burden. 

The following tables illustrate the burden hours and cost associated with meeting the 

conformity requirements for a transportation plan and TIP update in metropolitan nonattainment 

and maintenance areas that are designated for one or more pollutants/NAAQS. These MPOs 

and metropolitan areas have experience with the conformity process, have established 

interagency consultation procedures and have developed models for conducting plan and TIP 

conformity determinations. 

While transportation plan and TIP updates are now able to be done with the same 

frequency (at least every 4 years), EPA estimates that it is only those MPOs serving smaller 

populations (50,000-200,000 populations) that will perform conformity determinations for 

transportation plans and TIPs at the same time, thus leading to efficiencies in burden hours and 

cost. In contrast, MPOs in larger areas may choose not to align transportation plan and TIP 

update conformity determinations as regularly, since these areas are expected to have more 
18

complex transportation planning considerations. 

Therefore, for purposes of this analysis, EPA assumes that conformity determinations 

for transportation plans and TIPs will always occur at different times in large metropolitan areas 

(Tables 2 through 5) and that conformity determinations for transportation plans and TIPs will 

occur at the same time in small metropolitan areas (see Tables 6 and 7). 

.

Table 2: State and Local Burden Hours 

Each Transportation Plan Conformity Determination

by MPO – Population of 200,000 or More 

MPO Demonstrating Conformity For Consultation

Regional 

Emissions 

Analysis22

Other 

Activities

Total 

Burden 

Hours

One Pollutant/NAAQS 55 280 45 380

Two Pollutants/NAAQS 72 375 60 507

Three or More Pollutants/NAAQS 88 465 75 628

Table 3: State and Local Annual Cost

Transportation Plan Conformity Determinations 

by MPO – Population of 200,000 or More

MPO

Demonstrating Conformity For

Burden 

Hours 

No. of 

MPOs

Frequency 

of Action

Total 

Annual 

Burden 

Hours

Cost 

Per

Hour

Total 

Annual 

Cost

One Pollutant/NAAQS 380 26 4 years 2,470 $59.4023 $146,718

Two Pollutants/NAAQS 507 22 4 years 2,788 $59.40 $165,607

Three or More Pollutants/NAAQS 628 39 3 years 8,164 $59.40 $484,942

Total for All Transportation Plan Actions: 13,422 hours/year x $59.40/hour = $797,267/year

 

22 The burden for regional emissions analyses is framed in this ICR as an MPO responsibility but we 

recognize that some State DOTs or other agencies may also perform the analyses, in cooperation with or instead of 

the MPO.

23 See Section 6(b) Estimating State and Local Respondent Costs, for a description of how the Cost per 

Hour was calculated.
19

Table 4: State and Local Burden Hours 

Each TIP Conformity Determination

by MPO – Population of 200,000 or More

MPO

Demonstrating Conformity For Consultation

Regional 

Emissions 

Analysis Other Activities

Total 

Burden 

Hours

One Pollutant/NAAQS 44 280 45 369

Two Pollutants/NAAQS 55 375 60 490

Three or More Pollutants/NAAQS 66 465 75 606

Table 5: State and Local Annual Cost

TIP Conformity Determinations 

by MPO – Population of 200,000 or More

MPO

Demonstrating Conformity For

Burden 

Hours

No. of 

MPOs

Frequency 

of Action

Total 

Annual 

Burden 

Hours

Cost 

Per 

Hour

Total 

Annual 

Cost

One Pollutant/NAAQS 369 26 4 years 2,399 $59.40

$142,501

Two Pollutants/NAAQS 490 22 4 years 2,695 $59.40 $160,083

Three or More Pollutants/NAAQS 606 39 4 years 5,909 $59.40 $350,994

Total for All TIP Actions: 11,003 hours/year x $59.40 /hour = $653,578/year 
20

Table 6: State and Local Burden Hours 

Each Transportation Plan and TIP Conformity Determination

by MPO – Population Between 50,000-200,000

MPO

Demonstrating Conformity For Consultation

Regional 

Emissions 

Analysis Other Activities

Total 

Burden 

Hours

One Pollutant/NAAQS 50 120 30 200

Two Pollutants/NAAQS 61 160 40 261

Three or More Pollutants/NAAQS 77 200 50 327

Table 7: State and Local Annual Cost

Transportation Plan and TIP Conformity Determinations 

by MPO – Population Between 50,000-200,000

MPO

Demonstrating Conformity For

Burden 

Hours 

No. of 

MPOs

Frequency 

of Action

Total 

Annual 

Burden 

Hours

Cost 

Per 

Hour

Total 

Annual 

Cost

One Pollutant/NAAQS 200 24 4 years 1,200 $59.40 $71,280

Two Pollutants/NAAQS 261 8 4 years 522 $59.40 $31,007

Three or More Pollutants/NAAQS 327 7 3 years 763 $59.40 $45,322

Total for All Transportation Plan and TIP Actions: 2,485 hours/year x $59.40/hour = $147,609/year 

In addition, EPA has also estimated the state and local start-up burden associated with 

the transition to EPA’s latest emissions model, MOVES2014. During the previous ICR cycle, 

the burden included training/workshops plus additional time to transition from the emissions 

model called MOBILE6.2 to the new MOVES emissions model. The transition started in 

December 2009 with the release of MOVES2010. In this ICR time period, state and local 

agencies have some start-up burden associated with the latest version of MOVES, but not as 

much as in the previous period. MOVES2014 was released in July 2014. For this ICR, EPA 

has again assumed that half of the MPOs have already taken a MOVES training class and have 

experience working with MOVES2010. EPA included a reduced amount of burden for training 

for a smaller percentage of staff to account for turn-over as well as transition time to convert 

input data between MOVES2010 and MOVES2014. The burden hours for consultation 

remained the same. The start-up burden for MOVES2014 is shown in Tables 8 and 9.
21

EPA published a Notice of Availability and corresponding grace period in the Federal 

Register (79 FR 60343), after the release of MOVES2014. The Notice includes a grace period 

before MOVES2014 is required in regional emissions analysis. EPA also issued policy

guidance on the use of this model.24

.

Table 8: State and Local Burden Hours

One-time Start-up 

For Transition to MOVES2014 for Regional Emissions Analyses

Action Total Burden Hours

Training 30

Transition 50

Total burden hours for State and Local Respondents for Start-up of MOVES Analysis: 80 hours

Table 9: State and Local Costs

One-time Start-up 

For Transition to MOVES2014 for Regional Emissions Analyses

Training/Transition

Hours No. of MPOs

Total Burden 

Hours Cost Per Hour Total Cost

80 63 5,040 $59.40 $299,376

Total cost for State and Local Respondents for Transition to MOVES2014: 5,040 x $59.40/hour= $299,376

Project-Level Conformity Determinations in Metropolitan Nonattainment and Maintenance 

Areas

Tables 10 and 11 estimate the burden and cost associated with making conformity

determinations for projects in metropolitan nonattainment and maintenance areas. These tables 

are intended to illustrate burden associated with a typical project-level conformity

determination. 

To calculate burden for state and local agencies in preparing project-level conformity

determinations for these areas, EPA polled its regional offices and DOT which typically work 

with state and local agencies in project-level conformity determinations. EPA headquarters 

estimated the time necessary to conduct the hot-spot analyses based on the guidance documents 

for these analyses and professional experience. State and local burden hours for consultation 

and conducting the hot-spot analyses in Table 10 reflect averages of the responses received. 

EPA calculated the average number of annual actions based upon survey responses from EPA 

Regional Offices and DOT offices that are responsible for working with state and local 

 

24 Policy Guidance on the Use of MOVES2014 for State Implementation Plan Development, Transportation 

Conformity, and Other Purposes, (EPA-420-B-14-008 July 2014).
22

respondents in making project-level conformity determinations.

Conformity determinations for projects in metropolitan ozone and NO2 nonattainment 

and maintenance areas are fairly straightforward, because projects only need to come from a 

conforming transportation plan and TIP to meet all conformity requirements. A hot-spot 

analysis is not required for project determinations in these nonattainment and maintenance 

areas. Alternatively, conformity determinations for all non-exempt federal projects in CO areas 

must include either a qualitative or quantitative hot-spot analysis (depending on the type of 

project).

25

 In PM2.5 and PM10 areas, project-level conformity determinations must include a 

hot-spot analysis if the project is of local air quality concern.26 

With the release of MOVES (and EMFAC in California) in December of 2010 and the 

end of the subsequent conformity grace period, all required PM hot-spot analysis must now be 

quantitative.27 EPA has also issued policy guidance on the use of these models. The use of the 

MOVES model is required for PM hot-spot analyses and other purposes.

28

The total burden estimates for project-level conformity determinations represent 50% of 

total state and local burden for a PM or CO hot-spot analysis. We are assuming that the 

analysis would also be used for satisfying NEPA requirements, so only half of the burden would 

be included in the conformity ICR. These numbers include scoping the project analysis, 

emissions modeling, air quality modeling, determining background concentrations, calculating 

design values, quality assurance, and preparing the final documentation. 

The state and local burden hours for completing both qualitative CO and quantitative 

PM and CO hot-spot analyses are shown in Table 10. EPA calculated the average number of 

annual actions based on past experience and input given by the EPA Regional Offices and DOT 

Offices that are responsible for working with state and local respondents in making project-level 

conformity determinations. EPA is assuming that some data for hot-spot analyses will already

be available because it is necessary for project development (e.g., traffic data). 

Consultation with other state and local agencies is an important activity for these 

 

25 See the conformity rule (40 CFR 93.123(a)) for the types of projects that require qualitative versus 

quantitative CO hot-spot analyses. 

26Per the conformity rule (40 CFR 93.123(b)(1)), projects of local air quality concern include: “(i) new 

highway projects that have a significant number of diesel vehicles, and expanded highway projects that have a 

significant increase in the number of diesel vehicles ; (ii) projects affecting intersections that are at Level-of-Service 

D, E, or F because of increased traffic volumes from a significant number of diesel vehicles related to the project; 

(iii) new bus and rail terminals and transfer points that have a significant number of diesel vehicles congregating at a 

single location; (iv) expanded bus and rail terminals and transfer points that significantly increase the number of 

diesel vehicles congregating at a single location; and, (v) projects in or affecting locations, areas, or categories of 

sites which are identified in the PM10 or PM2.5 applicable SIP or SIP submission as appropriate, as sites of violation 

or possible violation.” 

27 Notice of Availability: Official Release of the MOVES2010a and EMFAC2007 Motor Vehicle 

Emissions Models for Transportation Conformity Hot-Spot Analyses and Availability of Modeling Guidance, 75 FR 

79370 (December 2010).

28 “Policy Guidance on the Use of MOVES2014 for State Implementation Plan Development, 

Transportation Conformity, and Other Purposes,” EPA-420-B-14-0008 (July 2014).
23

analyses and EPA estimates that on average seven state and local agencies participate in one 

consultation meeting on each transportation project. EPA is assuming that conformity-related 

consultation would be one of many issues discussed through consultation meetings as a project 

proceeds through the NEPA process. 

EPA assumes that the total burden hours for project-level conformity determinations 

would be approximately the same for larger and smaller metropolitan areas because 

requirements for project-level conformity determinations do not differ based upon population 

size served by an MPO. Requirements for project-level conformity determinations are the same 

for large and small metropolitan nonattainment and maintenance areas. 

Table 10: State and Local Burden Hours

Each Project-level Conformity Determination

Metropolitan Nonattainment and Maintenance Areas

Pollutant

Type of Hotspot Analysis ConsultationHot-spot 

Analysis

Other 

Activities

Total

Burden 

Hours

Ozone, NO2, PM2.5 and 

PM10

29 None 0.5 N/A 0.5 1

PM2.5 or PM10 Quantitative 18 71 3 92

CO Quantitative 6 14 2 22

CO Qualitative 3 2 1 6

 

29 Most projects in PM10 and PM2.5 areas do not require a quantitative hot-spot analysis. In contrast, all 

non-exempt CO projects in CO areas require some type of hot-spot analysis.
24

Table 11: State and Local Annual Cost

Project-level Conformity Determinations

Metropolitan Nonattainment and Maintenance Areas

Metropolitan 

Area/Pollutant

Burden 

Hours 

Per 

Action

Average

No. of 

Actions/year

No. of 

MPOs

Total 

Annual 

Burden 

Hours

Cost Per 

Hour

Total 

Annual

Cost

Project level 

conformity 

determination 

- No Hotspot 

Analysis –

ozone, NO2, 

PM2.5 and 

PM10

Pop. 

200,000+ 1 65 87 5,655 $59.40 $335,907

Pop. 

50,000-

200,000

1 15 39 585 $59.40 $34,749

PM2.5

Hot-spot Analyses 92 0.130 79 727 $59.40 $43,184

PM10

Hot-spot Analyses 92 0.1 48 442 $59.40 $26,255

CO Quantitative 

Hot-spot Analyses 22 5 50 5,500 $59.40 $326,700

CO Qualitative 

Hot-Spot Analyses 6 0.5 50 150 $59.40 $8,910

Total for All Project-level Actions: 13,059/year x $59.40hour= $775,705/year

State and Local Burden Associated with the Transition to MOVES2014 for Project Level 

Requirements

EPA estimated the state and local costs associated with the transition from MOVES2010 

to MOVES2014 for quantitative PM and CO hot-spot analyses in this ICR. The previous ICR 

included costs associated with start-up of quantitative analysis and MOVES2010. Training 

included learning new quantitative PM hot-spot modeling guidance as well as training for 

 

30 The number of average actions per year for PM hot-spot analysis has been reduced, reflecting EPA’s 

experience to date.
25

emissions and air quality modeling.31 EPA anticipates offering MOVES2014 on-site training, as 

well as webinars. For burden estimates, we are anticipating utilizing webinars to present the 

revised guidance for quantitative PM hot-spot guidance using MOVES2014, advanced topics 

via webinars, and training for the use of emissions and air quality models. 

We have also included a one-time start-up burden for learning to use MOVES for 

quantitative CO hot-spot analyses in CO nonattainment and maintenance areas. The burden 

hours per action is less than those in PM nonattainment and maintenance areas as the CO areas 

already perform quantitative analysis and therefore the start-up burden only includes training 

time for MOVES, rather than other aspects of CO hot-spot analyses.

The burden estimates in Tables 12 and 13 reflect only the share of the burden 

attributable to fulfilling transportation conformity requirements for hot-spot analyses (i.e. half 

of the burden hours associated with analyses). 

Table 12: State and Local Burden Hours

One-time Start-up 

For Quantitative Hot-Spot Analysis Using MOVES2014

Action Burden Hours per Action

PM Training and Start-up 30

CO Training and Start-up 10

Table 13: State and Local Costs

One-time Start-up 

For Quantitative Hot-Spot Analysis Using MOVES2014

Pollutant Training Hours 

No. of 

Areas

Total 

Burden 

Hours

Cost Per 

Hour Total Cost

PM2.5 and PM10 30 142 4,260 $59.40 $253,044

CO 10 15 150 $59.40 $8,910

Total cost for State and Local Respondents for Start-up of Quantitative Analysis: 4,410 hours/yr x

$59.40/hour= $261,954/yr

 

31EPA has provided guidance for those areas required to do quantitative hot-spot analysis for PM2.5 and 

PM10 nonattainment and maintenance areas: “Transportation Conformity Guidance for Quantitative Hot-spot 

Analyses in PM2.5 and PM10 Nonattainment and Maintenance Areas”, EPA-420-B-13-053 and “Using MOVES in 

Project-Level Carbon Monoxide Analyses”, EPA-420-B-10-041. 
26

The number of PM areas in Table 13 includes both metropolitan and isolated rural areas. 

Of the 169 PM nonattainment and maintenance areas, 10 MPOs are nonattainment or 

maintenance for both a PM2.5 and PM10 NAAQS and 17 are located in California (where 

MOVES is not used), which reduces the total number of nonattainment and maintenance areas 

to 142. We believe that there will be efficiencies gained for these areas which are not captured 

in the burden estimates. For example, the same MOVES modeling can be used for meeting 

both a PM10 and PM2.5 NAAQS, rather than conduct emissions modeling twice. However, we 

have not reflected these efficiencies in the ICR; we have kept the burden estimates separate for 

PM2.5 and PM10 for these areas.

The number of CO areas in Table 13 includes both metropolitan and isolated rural areas. 

Of the 50 CO nonattainment and maintenance areas, 26 are also nonattainment or maintenance 

for PM and 9 are located in California (where MOVES is not used), which reduces the total 

number of nonattainment and maintenance areas to 15.

Project-Level Conformity Determinations in Isolated Rural Nonattainment and Maintenance 

Areas

Tables 14 through 16 includes the state and local government burden estimated with 

performing regional emissions analysis and project-level conformity determinations in ozone, 

CO, PM2.5 and PM10 isolated rural areas.

32

EPA considered several factors in developing these estimates. EPA assumed that state 

departments of transportation will continue to be the lead agency in preparing project-level 

conformity determinations in all isolated rural areas. Some state air quality agencies may also 

provide emissions modeling assistance to isolated rural areas, as is now done in some areas. 

We also retained the assumption made in the previous ICR (2130.04) supporting 

statement that isolated rural areas that are nonattainment or maintenance for more than one 

pollutant/NAAQS will have additional burden hours, because these areas may be required to 

conduct a regional emissions analysis for an additional year and may have additional technical 

issues to resolve. Therefore, we included more burden hours for consultation, conducting 

regional emissions analysis, and performing other activities in these areas, as in previous ICRs. 

 

32 There are no current NO2 nonattainment or maintenance areas in isolated rural areas. See Table 1 for 

further information.
27

Table 14: State and Local Burden Hours 

Each Project-level Conformity Determination

Regional Emissions Analysis

For Isolated Rural Areas – Population Less Than 50,000

Demonstrating Conformity For Consultation

Regional 

Emissions 

Analysis

Other Misc. 

Activities

Total 

Burden 

Hours

One Pollutant/NAAQS 28 65 15 108

Two Pollutants/NAAQS 33 90 20 143

Table 15: State and Local Annual Cost

Each Project-level Conformity Determination

Regional Emissions Analysis 

For Isolated Rural Areas – Population Less than 50,000

Demonstrating Conformity For

Burden 

Hours 

No. of 

Areas

Frequency 

of Action

Total 

Annual 

Burden 

Hours

Cost 

Per 

Hour

Total 

Annual Cost

One Pollutant/NAAQS 108 47 5 1,015 $59.40 $60,291

Two Pollutants/NAAQS 143 4 5 114 $59.40 $6,772

Total for All Actions: 1,129 hours/year x $59.40/hour = $67,063/year 

Table 15 reflects a frequency of project-level conformity determinations being done 

once every five years in each isolated rural area, which is less than MPOs in the previous 

burden calculations. MPOs are required by regulation to determine conformity once every four 

years. Our experience from previous ICRs and existing research (see Appendix A) is that 

isolated rural areas determine conformity less than once every four years.

In general, conformity determinations for projects in isolated rural areas are more 

involved than for projects in metropolitan areas, because a regional emissions analysis is also 

performed when a regionally significant project “not from a conforming transportation plan and 

TIP” is to receive federal funding or approval.33

EPA notes that this ICR may overestimate burden associated with determining 

conformity for projects in isolated rural areas, since conformity determinations for nonregionally significant projects may not require that a new regional emissions analysis be 

completed every time. 

 

33Isolated rural areas are not required by federal law to develop metropolitan transportation plans or TIPs.
28

Consultation between state and local agencies would also occur for each project 

requiring a hot-spot analysis.34 Like metropolitan projects, EPA is also assuming that 

conformity-related topics would be one of many issues discussed through consultation meetings 

as a project proceeds through the NEPA process. 

Localized analyses are assumed to be used to meet both transportation conformity and 

NEPA requirements. Therefore, EPA is assuming that the estimated burden associated with 

consultation and preparation of these hot-spot analyses would be divided equally between 

transportation conformity and NEPA. Accordingly, the burden estimates in Table 16 reflect 

only the share of the burden attributable to fulfilling transportation conformity requirements for 

hot-spot analyses (i.e., half of the burden hours associated with the analyses). 

. 

Table 16: State and Local Burden Hours For

Each Project-Level Conformity Determination 

Hot-Spot Analysis

Isolated Rural Nonattainment and Maintenance Areas 

Pollutant

Type of Hotspot Analysis ConsultationHot-spot 

Analysis

Total Burden 

Hours

CO Quantitative 6 14 20

CO Qualitative 3 2 5

Table 17 shows state and local burden hours estimated for performing project-level 

conformity determinations in CO isolated rural areas. EPA did not include PM quantitative 

analysis for isolated rural areas in this ICR, reflecting our experience to date.

To calculate the total burden hours for state and local agencies in isolated rural areas, 

EPA assumed that a conformity determination occurs once every five years, as in the previous 

ICR. Also, the transportation conformity regulation requires a hot-spot analysis for every nonexempt project in a CO nonattainment or maintenance area. Because there are two isolated 

rural areas that are nonattainment or maintenance for CO, we assumed there would be two CO 

hot-spot analyses in isolated rural areas over a five-year period.

 

34EPA estimates that four state and local agencies would participate in one consultation meeting on each 

transportation project.
29

Table 17: State and Local Annual Cost

Project-Level Conformity Determinations 

Hot-Spot Analysis

Isolated Rural Nonattainment and Maintenance Areas

Metropolitan 

Area

Burden

Hours per 

Action No. of Areas

Frequency of 

Action

Total

Annual 

Burden 

Hours

Cost Per 

Hour

Total 

Annual 

Cost

CO -

Quantitative 

Hot-spot 

Analyses

20 2 5 years 8 $59.40 $475

CO –

Qualitative HotSpot Analyses5 2 5 years 2 $59.40 $119

Total State and Local Respondent Burden for Project Level Conformity Determinations: 10hours/year x 

$59.40/hour = $594

6(b) Estimating	State	and	Local	Respondent	Costs

The following paragraphs describe the assumptions used for estimating state and local 

respondent costs illustrated in Section 6(a):

(i) Estimating Labor Costs

EPA assumed that each state and local burden hour associated with conformity

determinations is completed by an experienced technical staff person at a state or local agency

or contractor. In addition to salary costs, EPA is also including overhead costs associated with 

employing an experienced technical staff person, such as paid leave, health insurance, 

retirement savings, office space, computers, and other business expenses.

EPA is assuming that state and local burden hours would be completed by an 

experienced technical staff person being paid at a GS-13, Step 3 federal government employee 

salary of $77,217/year.35 EPA then divided the annual 2014 GS-13, Step 3 salary rate by 2080 

(the number of hours in a work year) and multiplied this number by the standard government 

overhead factor of 1.6. This calculation results in a state and local cost of $59.40/burden hour. 

(ii) Estimating Capital/Start-up and Operations and Maintenance (O&M) Costs

In general, EPA is not expecting that additional computers, software, or other capital 

 

35 January 2014 U.S. Office of Personal Management, Salary Table 2014-GS, 2014 General Schedule, 

http://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2014/GS.pdf
30

investments are needed to do conformity analyses. Planners should be able to adapt existing 

equipment and systems for conformity use.

The transportation conformity regulation does not contain any continuing recordkeeping or reporting requirements that require additional capital or O&M costs for individual 

state or local respondent actions. Thus, no capital or O&M costs are included for recordkeeping and reporting actions.

(iii) Annualizing Capital Costs

EPA has assumed the following in annualizing estimates:

 Estimates for transportation plan and TIP conformity determinations are annualized over 

a four-year period, to correspond with Clean Air Act requirements that transportation 

plans and TIPs conform with a new conformity determination and regional emissions 

analysis every four years. EPA included the cost associated with meeting the minimum 

requirements, and therefore assumed that only one transportation plan or TIP conformity 

determination will be done for each MPO every four years in metropolitan nonattainment 

and maintenance areas, with one exception. For MPOs designated nonattainment or 

maintenance for 3 or more NAAQS, the frequency is assumed to be once every 3 years. 

For the purposes of this ICR, EPA is not considering additional burden from MPOs 

updating or revising transportation plans and TIPs voluntarily, or as required by state 

regulations, on a more frequent basis.

6(c) Estimating	Agency	Burden	and	Costs		

This section of the ICR shows federal agency burden and costs associated with carrying 

out transportation conformity regulations. 

(i) Estimating Federal Labor Costs

EPA estimates that each DOT and EPA federal burden hour associated with conformity

determinations and adequacy findings is completed by an experienced technical staff person. 

EPA is also including overhead costs associated with employing an experienced technical staff 

person, such as paid leave, health insurance, retirement savings, office space, computers, and 

other business expenses.

EPA assumed that federal burden hours would be completed by an experienced technical 

staff person being paid at a GS-13, Step 3 federal government employee salary of 

$77,217/year.36 EPA then divided the annual 2014 GS-13, Step 3 salary rate by 2080 (the 

number of hours in a work year) and multiplied this number by the standard government 

overhead factor of 1.6. This calculation resulted in a federal cost of $59.40/burden hour. 

 

36 January 2014 U.S. Office of Personal Management, Salary Table 2014-GS, 2014 General Schedule, 

http://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2014/GS.pdf
31

Transportation Plan and TIP Conformity Determinations in Metropolitan 

Nonattainment/Maintenance Areas – Federal Burden Hours and Cost

 

Tables 18 through 20 show estimated federal burden hours and cost associated with 

making conformity determinations for transportation plans and TIPs in metropolitan 

nonattainment and maintenance areas. EPA assumes that federal burden in these areas is 

associated only with conformity-related work prior to an MPO’s determination and for 

reviewing transportation plan and TIP conformity determinations and that MPOs have 

established interagency consultation procedures with regularly scheduled meetings for 

discussing conformity issues. Because MPOs serving smaller metropolitan areas (populations 

between 50,000-200,000) typically do conformity determinations for transportation plans and 

TIPs at the same time since they are typically on the same four-year update cycle, EPA also 

assumes that federal burden associated with consulting on and reviewing transportation plan and 

TIP conformity determinations for these MPOs is done at the same time as well. Therefore, 

federal burden associated with transportation conformity requirements in smaller metropolitan 

areas (50,000-200,000) is half the burden associated with transportation plan and TIP 

conformity determinations in large metropolitan areas.

EPA calculated estimated federal burden hours based upon survey responses from EPA 

Regional Offices and DOT offices that are responsible for work associated with making 

conformity determinations for transportation plans and TIPs. 

Table 18: Federal Burden Hours 

Each Transportation Plan or TIP Conformity Determination 

Metropolitan Nonattainment and Maintenance Areas

Population of 200,000 or More

Metropolitan

Planning Organization Activity FHWA FTA EPA Total

Per Conformity 

Determination

(Includes all areas with 

populations of 200,000+)

Attending Consultation Meetings 12 12 12 36

Conformity-Related Work Prior to 

MPO Submission 12 1 3 16

Reviewing Plan Conformity 

Determination 13 2 7 22

Federal Hours Burden Hours for Each Plan or TIP Conformity Determination: 74
32

Table 19: Federal Burden Hours

Each Transportation Plan/TIP Conformity Determination

Metropolitan Nonattainment and Maintenance Areas

Population of 50,000-200,000

Metropolitan

Planning Organization Activity FHWA FTA EPA Total

Per Conformity 

Determination

(Includes all areas with 

populations of 50,000-

200,000)

Attending Consultation Meetings 12 12 12 36

Conformity-Related Work Prior to 

MPO Determination 12 1 3 16

Reviewing Plan Conformity 

Determination 13 2 7 22

Federal Hours Burden For Each Plan/ TIP Conformity Determination: 74

Table 20: Federal Annual Cost for MPOs

Transportation Plan and TIP Conformity Determinations

Metropolitan Nonattainment and Maintenance Areas

Action

Metropolitan 

Nonattainment Area

Burden 

Hours 

Per 

Action

No. of 

MPO’s

Frequency 

of Action

Total 

Annual 

Burden 

Hours

Cost 

Per 

Hour

Total 

Annual 

Cost

Plan

Per Conformity 

Determination

(Pop. 200,000+)

74 87 4 years 1,609 $59.40 $95,575

TIP

Per Conformity 

Determination

(Pop. 200,000+)

74 87 4 years 1,609 $59.40 $95,575

Plan/

TIP

Per Conformity 

Determination (pop. 

50,000-200,000)

74 39 4 years 721 $59.40 $42,827

Total Federal Burden for Plan and TIP Actions: 3,939 hours/year x $59.40/hour = $233,977
33

Project-Level Conformity Determinations in Metropolitan Nonattainment and Maintenance 

Areas – Federal Burden Hours and Cost

Tables 21 and 22 estimate the burden hours and cost that federal agencies incur 

associated with conformity determinations for projects in metropolitan nonattainment and 

maintenance areas. These tables are intended to illustrate burden associated with a typical 

project-level conformity determination. 

To calculate burden for federal agencies associated with consultation and reviewing 

project-level conformity determinations for metropolitan nonattainment and maintenance areas, 

EPA polled its regional offices and DOT. The following tables show federal burden associated 

with consultation and reviewing project-level conformity determinations prepared by state and 

local respondents. State and local respondents burden hours and cost associated with 

consultation, hot-spot analysis and regional emissions analysis may be found in Tables 10 and 

11.

Table 21: Federal Burden Hours 

Each Project-level Conformity Determination Metropolitan Nonattainment and 

Maintenance Areas

Pollutant

Type of Hotspot Analysis Consultation

Reviewing Projectlevel conformity 

determinations

Total

Burden 

Hours

Ozone, NO2, PM2.5 and PM10 None 0.5 0.5 1

PM2.5 and PM10 Quantitative 5 11 16

CO Quantitative 1 2 3

CO Qualitative 0.25 1.25 1.5
34

Table 22: Federal Annual Cost 

Project-level Conformity Determinations 

Metropolitan Nonattainment and Maintenance Areas

Type of Analysis

Burden 

Hours Per 

Action

Average

No. of 

Actions/

Year

No. of 

MPOs

Total 

Annual 

Burden 

Hours

Cost 

Per 

Hour

Total 

Annual

Cost

Project level 

conformity 

determination 

- No Hot-spot 

Analysis

Pop. 

200,000+ 1 65 87 5,656 $59.40 $335,966

Pop. 

50,000-

200,000

1 15 39 585 $59.40 $34,749

PM2.5 Hot-spot Analyses 16 0.1 79 126 $59.40 $7,484

PM10 Hot-spot Analyses 16 0.1 48 77 $59.40 $4,574

CO Quantitative Hot-spot 

Analyses 3 5 50 750 $59.40 $44,550

CO Qualitative Hot-Spot 

Analyses

1.5 0.5 50 37 $59.40 $2,198

Total for All Project-level Actions: 7,231hours/year x $59.40/hour= $429,521/year 

Project-Level Conformity Determinations in Isolated Rural Nonattainment and Maintenance 

Areas – Federal Burden Hours and Cost

Table 23 shows federal burden associated with conformity determinations for a typical 

regionally significant project in an isolated rural nonattainment or maintenance area. Table 24 

shows federal burden associated with interagency consultation and review of hot-spot analyses 

in isolated rural CO, PM2.5 and PM10 nonattainment and maintenance areas. Table 25 shows 

federal annual cost associated with conformity determinations for project-level conformity 

determinations in isolated rural nonattainment and maintenance areas.

In general, conformity determinations for projects in isolated rural areas are more 

involved than for metropolitan areas, since isolated rural areas also need to perform a regional 

emissions analysis when a regionally significant project is to receive federal funding or 

approval. 

To account for additional burden hours spent by state and local agencies for 

consultation, the consultation for Federal agencies has also been increased to support additional 

meetings and activities.
35

Table 23: Federal Burden Hours 

Each Project-Level Conformity Determination 

Isolated Rural Nonattainment and Maintenance Areas

Regional Emissions Analysis Component

Type of Project Activity FHWA FTA EPA Total

Projects in Isolated 

Rural Area

Attending Consultation Meetings 6 1 1 8

Conformity-Related Work on Draft 

Determination 6 1 2 9

Reviewing Project Conformity 

Determination 10 1 5 16

Total for Each Isolated Rural Area Project Determination: 33 

Table 24: Federal Burden Hours Each Project-Level Conformity Determination Isolated 

Rural Nonattainment and Maintenance Areas

Hot-spot Analysis Component

Pollutant

Type of Hotspot Analysis Consultation

Reviewing Projectlevel conformity 

determinations

Total

Burden 

Hours

CO Quantitative 1 2 3

CO Qualitative 0.25 1.25 1.5
36

Table 25: Federal Agency Burden Cost For

Project-Level Conformity Determinations 

Isolated Rural Nonattainment and Maintenance Areas

Type of Project

Burden

Hours per 

Action

No. of 

Isolated 

Rural Areas

Frequency of 

Action

Total

Annual 

burden hours

Cost Per 

Hour

Total 

Annual 

Cost

Projects in 

Isolated Rural 

Areas – Regional 

Analysis

33 51 5 years 337 $59.40 $20,018

CO –Quantitative 

Hot-spot Analyses 3 2 5 years 1 $59.40 $59

CO –Qualitative 

Hot-spot Analyses 1.5 2 5 years 1 $59.40 $59

Total Federal Agency Burden for Project Level Conformity Determinations: 339 hours/year x $59.40/hour = 

$20,136/year

Adequacy Findings for SIP Motor Vehicle Emissions Budgets – Federal Burden Hours

One component of the federal burden associated with transportation conformity is EPA’s 

role in making adequacy findings for SIPs with new motor vehicle emissions budgets. The 

conformity regulation requires the motor vehicle emissions budget(s) from a submitted SIP to be 

used as the measure of conformity once EPA finds such a budget(s) adequate (40 CFR 93.118(e) 

and (f)).37 The total burden of the adequacy review process is completed by EPA. No other 

federal agencies are involved in the adequacy review process. This ICR also does not account 

for any state or local work associated with developing the SIP because SIPs are developed to 

meet other non-conformity requirements. 

EPA based burden hours associated with each adequacy review on the average amount of 

EPA staff time needed per adequacy determination, EPA staff time includes the time needed to 

notify the public that a SIP has been submitted and is under adequacy review, the adequacy

review of the SIP’s budget(s), responding to any public comments, and publishing a Federal 

Register notice with EPA’s finding. 

Table 26 illustrates EPA’s burden hours for each adequacy finding. These estimates were 

 

37 Per 40 CFR 93.118(e)(4), EPA will find a budget adequate if the following minimum criteria is met: 

(i)The submitted SIP is endorsed by the Governor or his/her designee and has been subject to a state public hearing; 

(ii) Interagency consultation took place and any EPA stated concerns have been addressed; (iii) The budget is clearly 

identified and precisely quantified; (iv) The budget, when considered with all other emissions sources, is consistent 

with applicable SIP requirements; (v) The budget is consistent with and is clearly related to the emissions inventory 

and submitted SIP control measures; and, (vi) Revisions to a previously submitted SIP explain and document any 

changes to the previous budget and control measures, impacts on point and source emissions, and any changes to 

established safety margins and reasons for those changes
37

drawn from a recent survey of EPA Regional Offices, as well as an estimate of the time spent at 

headquarters. 

Table 26: Federal Burden Hours Adequacy Findings of

SIP Motor Vehicle Emissions Budgets

Activity Hours to perform

Per Adequacy Finding

Adequacy Review 17

Federal Register Notice Preparation and 

Publication 19

Preparation for and Website Posting 3

Burden hours per Adequacy Finding: 39

Adequacy Findings – Federal Costs

Table 27A shows the total federal annualized cost associated with making adequacy

determinations for SIP motor vehicle emissions budgets. EPA based the number of adequacy

reviews need each year based on the historical average number of SIPs that EPA has processed 

for adequacy over the past seven years, and responses from EPA regions regarding the 

anticipated number of SIPs expected to process for adequacy in fiscal year 2015.

Table 27B show costs associated with Federal Register notices of adequacy findings. A

Federal Register notice of EPA’s adequacy determination is always required, but often such 

notice is given with a proposed or final rulemaking action to approve the submitted SIP which is 

required due to other non-conformity requirements. Therefore, EPA included in the above table 

only the cost associated with Federal Register notices that were published separate from a 

proposed or final rulemaking action to approve the submitted SIP. 

Table 27A: Federal Annual Cost of Adequacy Findings 

Action

Average

Number of 

Actions per 

Region

No. of 

Regions

Burden 

Hours per 

Action

Total 

Annual 

Burden 

Hours

Cost Per 

Hour

Total 

Annual 

Burden 

Cost

Adequacy Finding 3 10 39 1,170 $59.40 $69,498
38

Table 27B: Federal Annual Cost of Federal Register Notices 

Action

Average

Number of 

Actions

No. of 

Regions 

Total Federal Register 

Notice Publications

Average 

cost per 

Publication

Total 

Annual 

Burden 

Cost 

Federal Register Notice 

– Publication Costs 3 10 30 $413 $12,390

Total Burden for Adequacy Findings: 1,170 hours/year x $59.40/hour =$69,498+ $12,390 = $81,888

6(d) Estimating	the	Respondent	Universe	and	Total	Burden	and	Costs

EPA estimates that 126 MPOs will be subject to conformity requirements during the 

period covered by this ICR and that EPA Regional Offices, the FHWA and FTA will be 

involved in interagency consultation, and review of any transportation-related conformity 

determinations performed by MPOs during this process. EPA also estimates that similar 

consultation will occur for projects in isolated rural areas. 

6(e) Bottom	Line	Burden	Hours	and	Cost	Tables

The bottom line annual burden for all state and local respondents is 50,558 hours with a 

cost of $3,003,146. 

The bottom line annual burden for federal agency respondents is 12,679 hours with a 

cost of $765,522.

38

Finally, the bottom line burden to all federal, state, and local agency respondents over 

the 3-year period covered by this ICR is estimated at 189,711 hours with a cost of 

approximately $11,306,004. 

(i) State and Local Agency Tally

The bottom-line annual burden for all State and local agencies in performing 

transportation conformity determinations for transportation plans and TIPs in nonattainment and 

maintenance areas and isolated rural areas is 33,079 hours/year with a cost of $1,964,893/year. 

 

38 To obtain bottom-line annual Federal agency cost associated with conformity determinations, EPA 

multiplied the bottom-line Federal agency annual burden hours by estimated hourly labor costs of $59.40 and then 

added $12,390 in Federal Register notice publication costs from Table 27A and B to reach the bottom line Federal 

agency annual estimated cost of $734,038.
39

The bottom-line annual burden for all State and local agencies in performing project 

level conformity determinations and, where applicable, hot-spot analyses in metropolitan areas, 

and isolated rural areas is 17,479 hours/year at a cost of $1,038,253/year. 

(ii) Federal Agency Tally

The bottom-line annual burden for Agencies associated with transportation conformity

determinations for transportation plans and TIPs in nonattainment areas and isolated rural areas 

is 3,939 hours/year at a cost of $233,977/year.

The bottom-line annual burden for Agencies associated with project level conformity

determinations (including, where applicable, hot-spot analysis) in metropolitan areas and isolated 

rural areas is 7,520 hours/year at a cost of $449,657/year.

The bottom-line annual burden for EPA burden associated with adequacy determinations 

for motor vehicle emission budgets associated with SIPs is 1,170 hours/year at a cost of 

$81,888/year.

39

Tables 28 and 29 show the total annual estimated burden hours and cost associated with 

transportation conformity determinations requirements incurred by state, local and federal 

respondents.

Table 28: Total Annual Burden Hours

Transportation Conformity Determinations

Type of Conformity 

Determination

Total Annual

State and Local

Burden Hours

Total Annual

Federal

Burden Hours

Total Annual 

Conformity Burden 

Hours

Transportation Plan/ TIP 

Conformity Determination 33,079 3,939 37,018

Project Conformity 

Determination 17,479 7,570 25,049

Adequacy Finding N/A 1,170 1,170

Total 50,558 12,679 63,237

BOTTOM LINE ANNUAL BURDEN HOURS: 63,237/ year 

 

39 To obtain bottom-line annual cost associated with adequacy determinations for motor vehicle emission 

budgets, EPA multiplied the total burden hours in Table 27A and B by estimated hourly labor costs of $59.40 and 

then added $12,390 in Federal Register notice publication costs to reach the bottom line annual cost of $81,888.
40

Table 29: Total Annual Costs 

Transportation Conformity Determinations 

Type of Action Total Annual State and 

Local Cost

Total Annual Federal 

Cost

Total Annual 

Conformity Costs

Transportation Plan/ TIP 

Conformity Determination $1,964,893 $233,977 $2,198,870

Project Conformity 

Determination $1,038,253 $449,657 $1,487,910

Adequacy Finding

Determinations

N/A $81,888 $81,888

Total $3,003,146 $765,522 $3,768,668

 BOTTOM LINE ANNUAL COST: $3,768,668/year 40 

(iii) Variations in the Annual Bottom Line

EPA does not anticipate significant variations in the annual respondent reporting burden 

or cost over the course of the clearance period. 

6(f) Reasons	for	Change	in	Burden

Decrease in state and local respondent burden hours since the previous ICR was 

approved is approximately 45,400 hours/year:

(i) Adjustment for decreased burden associated with decreased transportation 

conformity analysis for PM10, CO, and 1997 Ozone NAAQS

A decrease in burden was projected due to the requirement for transportation conformity

ending in PM10 and CO areas that have reached the end of the 20-year maintenance period. A 

decrease in burden was also projected due to fewer transportation conformity determinations for 

areas previously designated nonattainment or maintenance for 1997 ozone NAAQS that is 

anticipated to be revoked in early 2015, which is early in the period covered by this ICR.

(ii) Adjustment for decreased burden associated with the transition from MOVES2010 

to MOVES2014

 

40 To obtain bottom-line costs associated with conformity determinations (Table 29), EPA multiplied the 

bottom-line burden hours in Table 28 by estimated hourly labor costs of $59.40 and then added $12,390 in Federal 

Register notice publication costs from Table 27A and B to reach the bottom line annual cost of $3,992,708.
41

A decrease in burden was projected over the previous ICR for model transitions. During 

the period covered by the previous ICR, the transition between MOBILE6.2 to MOVES2010 

occurred, which was more resource-intensive than the transition from MOVES2010 to 

MOVES2014. The amount of training hours was reduced however, the burden hours for 

consultation remained the same. The transition from MOVES2010 to MOVES2014 occurs in 

the period covered by this ICR.

(iii) Adjustment for decreased burden associated with project-level conformity

A decrease in burden was projected over the previous ICR for project-level conformity

as fewer areas are performing PM2.5 and PM10 quantitative project-level hot-spot analysis.

6(g) Burden Statement

Burden means the total time, effort, or financial resources expended by persons to 

generate, maintain, retain, or disclose or provide information to or for a federal agency. This 

includes the time needed to review instructions; develop, acquire, install, and utilize technology

and systems for the purposes of collecting, validating, and verifying information, processing 

and maintaining information, and disclosing and providing information; adjust the existing ways 

to comply with any previously applicable instructions and requirements; train personnel to be 

able to respond to a collection of information; search data sources; complete and review the 

collection of information; and transmit or otherwise disclose the information. An agency may

not conduct or sponsor, and a person is not required to respond to, a collection of information 

unless it displays a currently valid OMB control number. The OMB control numbers for EPA's 

regulations are listed in 40 CFR part 9 and 48 CFR chapter 15. 
42

Appendix	A:	Conformity-Related	Research	Considered	for	This	ICR

The following is the conformity research studies that were considered for this ICR. EPA has 

cited in the ICR when these studies were utilized as appropriate. 

 April 2003, “Transportation/Air Quality Issues in Rural Areas,” FHWA and Dye 

Management Group.

 October 2003, “Rural Conformity: A Survey of Practice,” NCHRP and ICF Consulting.