COMPILATION OF PUBLIC COMMENTS AND NEW 

HAMPSHIRE'S RESPONSE THERETO 

40 CFR Part 51, Appendix V, 2 .1(h) 

/40y AA, ,. 4 -t ThE STATE OF 1tiEW HAMPSHIRE 

DEPARTMENT OF TRANSPORTATION 

Dcpsvt-unt of Timeaportatioxi 

GEORGL' N. CAMPBELL, JR, 

COMMISSIONER 

JEFFBRILLHART, RE 

ASSISTi! NT COMMISSIONER 

September 14, 2011 

Representative Betsey L. Patten, Chair 

NH Joint Legislative Committee on Administrative Rules 

25 Capitol Street, Room 219 

Concord, NH 03301-6312 

RE: Revisions to Env-A 1500, Conformity of Transportation Plans and Federal Actions 

On behalf of the New Hampshire Department of Transportation (NHDOT), I would like to indicate our 

support for the proposed rule changes to Env-A 1500, that are being pursued by the NH Department of 

Environmental Services. 

NHDOT has actively participated in the development of the proposed Env-A 1500 with the New 

Hampshire Department of Environmental Services (NHDES) and other affected agencies. Through 

that development and consultation process, all of the concerns of the NHDOT were able to be 

discussed and adequately addressed by the proposed rules now being considered. 

Many portions of the proposed rules specify requirements for the NH Department of Transportation 

because the proposed rules are primarily derived from federal law that the NHDOT is already bound to 

and required to fulfill . Similarly, the requirements have remained largely unchanged between the 

proposed and existing Env-A 1500. As such, the inclusion of such requirements in the proposed rule is 

not an area of concern for Nl-IDOT. 

Please feel free to contact me should you have questions. 

Sincerely, 

William Watson 

Administrator, 

New Hampshire 

PE, 

eau of Planning and Community Assistance 

epartment of Transportation 

cc: Rebecca Ohler, Thomas Fargo, NH Department of Environmental Services 

Nicholas Alexander, NH Department of Transportation 

JOHN O. MORTON BUILDING " 7 HAZEN DRIVE " P.O . BOX 483 " CONCORD, NEW HAMPSHIRE 03302-0483 

TELEPHONE: 603-271-3734 " FAX: 603-271-3914 - TDD: RELAY NH 1-80D-735-2964 " INTERNET: WWW.NHDOT.COM 
J~~~EO srqT~s 

y2 

0? Q 

rq4 PROZEG 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

Region 1 

5 Post Office Square, Suite 100 

Boston, MA 02109-3912 

~'&VIED 

NEW i-IAM.P"W 

August 3, 2011 

Ms. Karla McManus 

New Hampshire Department of Environmental Services 

29 Hazen Drive 

P.O . Box 95 

Concord, NH 03302-0095 

Dear Ms McManus: 

AUG 0 8 2011 

AW M&0W101-M MIG6C?N 

New Hampshire is currently proposing revisions to its Env-A 1500 Conformity regulation. EPA 

staff have reviewed the proposal and you will find the Agency's comments in the Enclosure. 

EPA is pleased that the New Hampshire Conformity Rules being updated continue to reflect the 

State Implementation Plan (SIP) streamlining flexibility created by Safe, Accountable, Flexible, 

Efficient Transportation Equity Act: A Legacy for Users (SAFETEA-LU, August 10, 2005). 

The streamlined transportation conformity SIP needs to address three areas : criteria and 

procedures for consultation (40 CFR 93.105) ; enforcement (93 .125(c)); and enforceability 

(93 .122(a)(4)(ii)) . 

Once New Hampshire's revised Conformity Rule has been adopted, it should be submitted to 

EPA as a SIP revision to fulfill the SIP requirement established at 40 CFR 51 .390. 

If you have any questions regarding our enclosed comments, please contact Donald O. Cooke of 

my staff at (617) 918-1668 or cooke .donald(a~,epa.gov . 

Sincerely, 

C4 _AA-?~ IF 6~~j 

Anne E. Arnold, Manager 

Air Quality Planning Unit 

Enclosure 

cc : Thomas Fargo, NH DES 
Enclosure 

EPA Comments on the NH DES August 2011 proposed revisions to 

Env-A 1500 Conformity Rules 

General Comment 

1 . The New Hampshire Conformity Rule often uses the term "nonattainment area" 

to refer to areas subject to transportation conformity determinations. The 

Metropolitan Planning Organizations (MPOs) and the U.S . Department of 

Transportation, however, make transportation conformity determinations with 

respect to transportation plans, transportation improvement programs, and 

transportation projects in nonattainment areas and attaimnent areas with a current 

maintenance plan in place . In New Hampshire, pollutant nonattainment areas and 

attainment areas with a maintenance plan overlap. Specifically, there is the 1997 

8-hour ozone nonattainment area (Boston-Manchester-Portsmouth (SE), NH) and 

two carbon monoxide attainment areas with maintenance plans (Manchester and 

Nashua), triggering the requirement for multiple air quality conformity analyses, 

one for each pollutant/area . Therefore, the rule should be revised to clarify that it 

also applies in attainment areas with a current maintenance plan in place. 

St)ecific Comments 

2 . Env-A 1503 .06 - EPA would like to point out that the Statewide Transportation 

Improvement Program (STIP) is not subject to transportation conformity . 

Individual MPO transportation improvement programs (TIPs) in either 

nonattainment areas or attainment areas with a maintenance plan are subject to 

transportation conformity and those MPO TIPs are carried over in whole to the 

STIR For transportation projects located outside of MPO boundaries, and within 

a nonattainment area or attainment area with a current maintenance plan, the New 

Hampshire Department of Transportation would prepare the air quality 

conformity analysis in combination with any MPO(s) air quality analysis to 

collectively demonstrate transportation conformity for the area subject to 

transportation conformity . 

3 . Env-A 1503 .06(f) - Reference should be made to NHDOT's responsibility to 

assist in making transportation conformity determinations in nonattainment areas 

or attainment areas with a current maintenance plan located outside of the MPO 

boundaries . 

4. Env-A 1503 .06(g) - Reference should be made to NHDOT's responsibility to 

make project-level conformity determinations required by 40 CFR 93 .116. 

Currently in the state of New Hampshire, only carbon monoxide (CO) hot-spot 

analyses are required within the Nashua CO attainment area with a maintenance 

plan, and within the Manchester CO attainment area with a maintenance plan. 
Projects in the STIP outside of the two carbon monoxide attainment areas with a 

maintenance plan would not currently be subject to project-level transportation 

conformity. Note a project should satisfy all transportation conformity 

requirements (at the transportation plan, transportation improvement program, and 

project level) before added to the STIP. 

5 . Env-A 1503 .06(k) and Env-A 1503 .07(f) - EPA recommends that these sections 

also include coordinating and consulting with EPA on data inputs into air quality 

models . 

6 . Env-A 1503 .07(j) - The MPO has the responsibility of notifying NHDOT and the 

department of any amendments to the MPO's metropolitan transportation plan or 

TIPs that add or delete exempt projects. Please consider adding EPA as well as 

FHWA and FTA to the notification . Notifying the interested parties of adding 

and/or deleting exempt projects allows the opportunity for consultation on 

whether the "exempt" project truly fits the exempt definition or should be treated 

as a non-exempt project. See Env-A 1503 .14(a)(2) . On the other hand, adding or 

deleting a non-exempt project, located in an area subject to transportation 

conformity, triggers the need for a new conformity determination that may be 

satisfied by the existing air quality conformity analysis or may require a new air 

quality conformity analysis. EPA would like to see the MPO's responsibility 

include notifying the department, other MPOs, RPCs, FHWA, FTA, and EPA of 

amendments which add or delete non-exempt projects which trigger new air 

quality conformity determinations . 

Therefore, EPA recommends that Env-A 1503 .07(j) be revised to read as follows : 

"Notify NHDOT, FHWA, FTA, EPA, other MPOs, RPCs, and the 

department of any amendments to the MPO's metropolitan transportation 

plan or TIPs that add or delete exempt and non-exempt projects" 

Similarly, Env-A 1503 .06(n) should be revised to include non-exempt projects . 

7. Env-A 1503 .08(d) - EPA recommends that this section be expanded to include 

minor revisions to a TIP, and any TIP amendment as events to initiate interagency 

consultation . 

8. Env-A 1503 .09(a)(6) - NH DES may wish to expand this section to refer to 

"STIP amendments in nonattainment areas or attainment areas with a maintenance 

plan outside MPO areas" for potential future nonattainment areas outside of the 

MPO boundaries being redesignated to attainment and having a maintenance plan, 

hence subject to transportation conformity . 

9. Env-A 1503 .09(d) - EPA recommends that NH DES expand subsections (d)(1) 

and (d)(2) to also include providing access to the referenced materials to EPA. 
10 . Env-A 1503 .13(b)(3) - EPA recommends that NH DES consider modifying this 

section to require all MPO's, not just those in nonattainment areas, to maintain 

regional transportation models . 

11 . Env-A 1503 .14(a)(1) - Projects to be reviewed should not be restricted to those in 

nonattainment areas, nor to those in the STIP and TIP. All projects partially or 

wholly located in an area subject to transportation conformity (nonattainment 

areas and attainment areas with a maintenance plan) and identified within the 

Metropolitan Transportation Plan, Statewide Transportation Plan, TIP or listed on 

the Statewide Transportation Improvement Program, should be reviewed to 

determine whether the project is exempt under 40 CFR 93 .126 and 93 .127 . The 

air quality conformity analysis is based on existing network and future projects 

identified in the area's long range transportation plan and transportation 

improvement programs. 

12. Env-A 1503 .16(a) and (b) - These sections address an amendment which adds or 

deletes an exempt project. As discussed above, . notification of amendments that 

add and/or delete exempt projects allows the opportunity for consultation on 

whether the "exempt" project truly fits the exempt definition or should be treated 

as a non-exempt project. On the other hand, adding or deleting a non-exempt 

project, located in an area subject to transportation conformity, triggers the need 

for a new conformity determination that may be satisfied by the existing air 

quality conformity analysis or may require a new air quality conformity analysis. 

Therefore, EPA recommends that Env-A 1503 .16 be revised to address 

notification of amendments which add or delete non-exempt projects which 

trigger new air quality conformity determinations . 

13 . Env-A 503 .17(a) - This section states that "NHDOT shall determine conformity 

of STIPs." As noted above, there is no "conformity determination" made on 

STIPs. However, all projects located within an area subject to transportation 

conformity (nonattainment areas and attainment areas with a maintenance plan) 

must be included in all appropriate long range transportation plans, multi-year 

transportation improvement programs for that area, and must be reflected 

appropriately in the air quality conformity analysis. 

Typographical Errors 

14. Env-A 1503 .01 - Reference in section (c) should be to "The mitigation measures 

required by 40 CFR §93 .125(c)." Please replace the capital letter S ("S") in this 

section with the section symbol. 

15 . Env-A 1503 .04 - Reference in section (h) to "Env-A 1501 .18" which does not 

exist, should be revised to reference "Env-A 1503 .18 Resolving Conflicts ." 

16. Env-A 15003 .21 - It appears there is an extra zero and the number should be 

1503 .21 . 
The State of New Hampshire 

DEPARTMENT OF ENVIRONMENTAL SERVICES 

Thomas S. Burack, Commissioner 

August 18, 2011 

Anne Arnold, Manager 

Air Quality Planning Unit 

US EPA, Region I 

5 Post Office Square, Ste 100 

Boston, MA 02109-3912 

RE: NH DES Proposed Chapter Env-A 1500 Conformity Rules 

Dear Ms . Arnold : 

Thank you for taking the time to comment on the readoption with amendment of Env-A 

1500, Conformity. We have reviewed your suggestions and have complied with all of your 

sixteen requests by revising the appropriate language in the rule (copy enclosed). EPA's 

comments and our responses are summarized in the enclosed chart. 

Once the Env-A 1500 rule has been adopted, we will submit it to EPA as a SIP revision 

to fulfill the SIP requirement established at 40 CFR 51 .390. 

If you have any questions, please call me at 603-271-6854. 

Sincerely, 

~" ~~ `l~v 

Karla S. McManus 

Planning and Rules Manager 

NH DES Air Division 

ec: Donald Cooke, EPA 

Enclosures 

DES Web site: www.des .nh.gov 

P.O. Box 95,29 Hazen Drive, Concord, New Hampshire 03302-0095 

Telephone: (603) 271-1370 " Fax: (603) 271-1381 " TDD Access : Relay NH 1-800-735-2964 
Added text in bold italics FP 2011-80 Annotated 08-17-11 1 

Deleted text °tFu^k *hi-^u^h 

C1-IAPTER Env-A 1500 CONFORMITY 

Statutory Authority: RSA 125-C :4, 1(a) 

Change the heading of PART Env-A 1501 to read as follows : 

PART Env-A 1501 PURPOSE AND APPLICABILITY 

Readopt with amendment Env-A 1501 . 01(a), eff. 10-14-03 (doc. #7971), to read as follows : 

Env-A 1501 .01 Purpose. The purpose of this chapter is to implement § 1"l6 of the Clean Air Act (the 

Act), as amended, and 40 CFR 93, wi&relative to conformity determinations for transportation plans, 

programs, and projects and federal actions, to ensure that the purpose and intent of the state implementation 

plan (SIP) are being met. 

Adopt Env-A 1501 .02 to read as follows: 

Env-A 1501 .02 Applicability. This chapter shall apply as specified in Env-A 1503 .02 and Env-A 

1504.02 . 

Insert a heading for PART Env A 1502 to read as follows: 

PART Env-A 1502 REFERENCES AND DEFINITIONS 

Readopt with amendment Env-A 1501. 03, eff. 10-14-03 (doc. #7971), as amended eff. 6-22-05 (doc. #8382), 

and renumber as Env-A 1502.01 and Env-A 1502.02, to read as follows: 

Env-A 1502.01 References. 

(a) . For the purpose of this chapter, unless otherwise specified all references to 23 CFR 450 shall be 

to the April 1, 2011 edition . 

(b) For the purpose of this chapter, unless otherwise specified all references to 40 CFR 93, including 

any subpart thereof, shall be to the July 1, 2011 edition . 

Env-A 1502.02 Federal Definitions Incorporated . Except as specified in Env-A 1502 .03 or pail--Env-A 

1504 .03, the definitions contained in and referred to in 40 CFR §93 .101 shall apply to the terms used in this 

chapter . 

Readopt with amendment Env-A 1501.04 and Env-A 1502.04(a) and (c), eff. 10-14-03 (doc. #7971), and 

renumber as Env-A 1502.03, to read as follows: 

Env-A 1502.03 Definitions . 

(a) "Interagency consultation" means a meeting or other formal consultation process convened or 

initiated pursuant to Env-A 1503 .08. 

(b) "Large scale development" means a development that is expected to generate 10,000 or more 

vehicle trip ends on any typical summer day. 

(c) "Long-range statewide transportation plan" means "long-range statewide transportation plan" as 

defined in 23 CFR §450 .104, namely "the official, statewide, multimodal, transportation plan covering a 

period of no less than 20 years developed through the statewide transportation planning process ." 

(d) "Maintenance area" means any geographic region of New Hampshire previously designated as a 

nonattainment area pursuant to the Act, and subsequently redesignated to attainment subject to the 

requirement to develop a maintenance plan that is subject to transportation conformity measures under 

§ 175A of the Act. 
Added text in bold italics FP 2011-80 Annotated 08-17-11 2 

Deleted text t " ^'" t'"'^""'' 

(e) "Metropolitan planning organization (MPO)" means "metropolitan planning organization" as 

defined in 23 CFR §450 .104, namely "the policy board of an organization created and designated to carry 

out the metropolitan transportation planning process." 

(f) "Nonattainment area" means any geographic region in New Hampshire designated as a 

nonattainment area by EPA under § 107 of the Act for any pollutant for which a NAAQS exists . 

(g) "Provide access to" means: 

(1) For any document(s) for which access is being provided to a specific entity (recipient 

entity), to do one or more of the following : 

a. Send a paper or electronic copy of each document to each recipient entity ; 

b. Post a copy of each document on a web site that is accessible by each recipient entity and 

notify the recipient entity(ies) of the document's URL; or 

c. Make a paper or electronic copy of each document available for inspection at the 

providing entity's office and notify each recipient entity of the availability of the document 

~ for inspection; or 

(2) For documents for which access is being provided to the public, to comply with the 

requirements of RSA 91-A:4 . 

(h) "Regional planning commission (RPC)" means any specific planning region as delineated by the 

office of state energy and planning or otherwise established as specified in RSA 36 :45 through RSA 36 :58 . 

For the purposes of this chapter, the reference to RPCs includes only those RPCs with municipalities located 

'in a nonattainment or maintenance area. 

(i) "Significant comments" means, for purposes of conformity findings, comments relating to any 

issue or data that have the potential to change the outcome of a conformity determination, including but not 

limited to the following: 

(1) Incorrect project design concept and scope that could affect emissions analysis ; 

(2) Improper or missing analysis years; 

(3) Regionally significant projects improperly reflected in the emissions analysis ; 

(4) Incorrect emission factors ; 

(5) Missing pollutant analyses ; 

(6) Projects improperly placed in a baseline scenario ; 

(7) Incorrect comparison with SIP emissions budgets ; and 

(8) Failure to list not exempt projects as specified in Env-A 1503 .14 in the emissions analysis. 

(j) "Statewide transportation improvement program (STIP)" means "a statewide transportation 

improvement program (STIP)" as defined in 23 CFR §450.104, namely "a statewide prioritized listing/ 

program of transportation projects covering a period of four years that is consistent with the long-range 

statewide transportation plan, metropolitan transportation plans, and TIPs, and required for projects to be 

eligible for funding under title 23 U.S.C . and title 49 U.S .C. Chapter 53." 

(k) "Transportation improvement program (TIP)" means "a transportation improvement program 

(TIP)" as defined in 23 CFR §450.104, namely "a prioritized listing/ program of transportation projects 

covering a period of four years that is developed and formally adopted by an MPO as part of the 
Added text in bold italics FP 2011-80 Annotated 08-17-11 3 

Deleted text stFUalrtlff$aigh 

metropolitan transportation planning process, consistent with the metropolitan transportation plan, and 

required for projects to be eligible for funding under 23 title U.S.C. and 49 title U.S.C. Chapter 53 ." 

Insert a heading for PART Env-A 1503 to read as follows: 

PART Env-A 1503 TRANSPORTATION CONFORMITY 

Readopt with amendment Env-A 1501. 01(b), eff. 10-14-03 (doc. #7971), and renumber as Env-A 1503.01, to 

read as follows: 

Env-A 1503 .01 Purpose. The purpose of this part is to implement the following provisions relating to 

transportation conformity: 

(a) The consultation procedures required by 40 CFR §93 .105 ; 

(b) The control measures required by 40 CFR §93 .122(a)(4)(ii) ; and 

(c) The mitigation measures required by 40 CFR S-§93 .125(c) . 

Readopt with amendment Env-A 1501.02 and Env-A 1501 .05 through Env-A 1501.21, eff. 10-14-03 (doc. 

#7971), and renumber as Env A 1503.02 through Env-A 1503.19, to read as follows: 

Env-A 1503 .02 Applicability. This part shall apply as specified in 40 CFR §93 .102 . 

Env-A 1503 .03 Conformity to State and Federal Implementation Plans . 

(a) All transportation plans, programs, and projects developed, funded, or approved by the state of 

New Hampshire shall conform to the SIP or federal implementation plan (FIP) developed pursuant to § 110 

and § § 171 through 193 of the Act. 

(b) Conformity determinations shall be made in accordance with § 176 of the Act and 40 CFR 93, 

Subpart A. 

Env-A 1503 .04 Metropolitan Planning Organizations (MPOs). 

(a) When used in this chapter, the term "metropolitan planning organizations (MPOs)" shall include 

the Southern New Hampshire MPO, the Nashua MPO, the Strafford MPO, and the Rockingham MPO . 

(b) Each MPO shall serve as a forum for cooperative transportation decision-making . 

Env-A 1503 .05 Roles and Responsibilities of the Department. The department shall : 

(a) Develop and implement the SIP and its revisions ; 

(b) Monitor progress in achieving the NAAQS; 

(c) Consult with representatives of the NH department of transportation (NHDOT), MPOs, RPCs, 

EPA, Federal Highway Administration (FHWA), and Federal Transit Administration (FTA) at the initiation 

of and during the development of SIP revisions pertaining to mobile sources, including those relating to 

inventories, budgets, forecasts, and strategies for reduction of emissions, transportation control measures 

(TCMs), transportation conformity, general conformity, area classifications, and redesignations ; 

(d) Coordinate with EPA on issues related to the SIP and transportation; 

(e) Coordinate with NHDOT, MPOs, RPCs, and EPA to determine inputs for air quality analysis 

emissions modeling on MPO transportation improvement programs (TIPs), transportation plans, and 

projects; 
Added text in bold italics FP 2011-80 Annotated 08-17-11 4 

Deleted text stfuelE through 

(f) Provide assistance to NHDOT, RPCs, and MPOs during transportation planning processes 

relating to air quality, including but not limited to emissions modeling, emissions budget comparisons, 

exempt/not exempt project lists, and regionally significant projects; 

(g) Review and provide comments on the conformity determinations for metropolitan transportation 

plans, TIPs, and NHDOT regional emissions analyses of transportation projects outside MPO areas or in 

areas covered by more than one MPO; and 

(h) Forward unresolved disputes regarding conformity determinations to the governor of New 

Hampshire for resolution in accordance with Env-A 4-541-1503 .18. 

Env-A 1503.06 Roles and Responsibility of NHDOT. In implementing 23 CFR 450, NHDOT shall: 

(a) Act as the lead agency responsible for coordinating and planning multi-regional and statewide 

transportation systems; 

(b) Develop a long-range statewide transportation plan and a statewide transportation improvement 

program (STIP) as specified in RSA 228 :99; 

(c) Obtain required FHWA and FTA approvals for the STIP; 

(d) Develop, in coordination with MPOs and the department, current estimates of vehicle miles 

traveled (VMT) for each nonattainment or maintenance area and forecasts of VMT necessary for input to 

the SIP; 

(e) Provide assistance to MPOs in performing analysis leading to transportation conformity 

determinations in their regions; 

(f) Conduct analyses and Mmake transportation conformity determinations in-reg~ens-for all 

projects outside 4-MP0 boundaries, but within nonattainment or maintenance areas; 

(g) Make project-level conformity determinations as required by 40 CFR 93.116, including hot-spot 

analyses in carbon monoxide (CO) nonattainment or maintenance areas, for all projects in the STIP; 

(h) Coordinate interagency consultation with MPOs, the department, RPCs, EPA, FHWA, and FTA 

at the initiation of and during the transportation confarmity determinations and transportation planning 

processes relating to air quality issues such as VMT and speed estimates, exempt/not exempt project lists, 

emissions modeling, emissions budget comparisons, and regionally significant projects ; 

(i) Coordinate conformity determinations in nonattainment or maintenance areas consisting of more 

than one MPO area; 

(j) Evaluate, select, maintain, and update a statewide transportation model capable of emissions 

analysis in non-attainment areas outside MPO boundaries, in consultation with the department; 

(k) Coordinate and consult with the department and EPA to determine appropriate data inputs into air 

quality models used for emissions analysis in conformity determinations to ensure consistency with the SIP; 

(1) Consult with MPOs, RPCs, and the department in the selection and development of TCMs if 

determined to be necessary or desirable to attain the NAAQS and in the preparation of the SIP with respect 

to these measures ; 

(m) Provide assistance and comments to the department on SIP revisions dealing with mobile source 

issues ; 
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Deleted text s'm°'- t"Fou^k 

(n) Noti~y the department, IMIPOs, RPCs, Fii WA, PTA, and EPA of STIP amendments which add or 

delete exempt and non-exempt projects; 

(o) Document timely implementation of TCMs which are in the SIP and transportation projects in the 

STIP which have positive air quality impacts ; and 

(p) In cooperation with MPOs, develop a list of regionally significant public or private transportation 

projects in accordance with Env-A 1501 .14(c). 

Env-A 1503 .07 Roles and Responsibilities of MPOs . In implementing 23 CFR 450, each MPO shall : 

(a) Develop a metropolitan transportation plan; 

(b) Develop TIPs ; 

(c) Assist the department and NHDOT in determining current estimates of VMT and forecasts of 

VMT necessary for input to the SIP development process ; 

(d) Implement public involvement procedures in the development of its metropolitan transportation 

plan and TIPs including conformity determinations ; 

(e) Make conformity determinations for its metropolitan transportation plan and TIPs, with 

assistance from NHDOT and the department; 

(f) Coordinate and consult with NHDOT, EPA, and the department to determine appropriate data 

inputs into emissions analysis models used for emissions analysis in conformity determinations to ensure 

consistency with the SIP; 

(g) Consult with the department and NHDOT in the selection and development of TCMs for the 

MPO area, if the department determines that TCMs are necessary or desirable to attain the NAAQS, and 

assist in the analysis of these measures for inclusion in the SIP; 

(h) Provide assistance and comments to the department on SIP revisions dealing with mobile source 

issues in the MPO area; 

(i) Consult with the department, NHDOT, EPA, FHWA, RPCs, and PTA in transportation 

conformity determinations and transportation planning processes relating to air quality issues including but 

not limited to VMT, speed estimates, emissions modeling, and emissions budget comparisons, exempt/not 

exempt project lists, and regionally significant projects; 

(j) Notify NHDOT, FHWA, FTA, EPA, other MPOs, RPCs, and the department of any amendments 

to the MPO's metropolitan transportation plan or TIPs that add or delete exempt and non-exempt projects ; 

(k) Evaluate, select, maintain, and update regional transportation models in nonattainment or 

maintenance areas in cooperation with NHDOT, RPCs, and the department; 

(1) Document implementation of TCMs which are in the SIP and transportation projects in the 

MPO's metropolitan transportation plan and TIPs which have positive air quality impacts ; 

(m) Through interagency consultation, develop a list of regionally significant projects in the MPO's 

area and provide the list to NHDOT and the department; and 

(n) Provide preliminary conformity findings to the department. 
Added text in bold italics FP 2011-80 Annotated 08-17-11 6 

Deleted text Ara& through 

Env-A 1503 .08 Interagency Consultation . 

(a) To facilitate the consultation required by 40 CFR §93 .105, NHDOT shall schedule and convene 

consultation meetings relating to the transportation conformity process as follows: 

(1) Regular meeting shall be held no less frequently than semi-annually ; and 

(2) Additional meetings may be held as needed to facilitate interagency communications . 

(b) NHDOT shall invite the department, MPOs, RPCs, EPA, FHWA, and FTA to participate in each 

meeting convened pursuant to (a), above, provided however that a meeting shall qualify as a regular meeting 

under (a)(1), above, only if representatives of NHDOT, the department, and MPOs are present . One or more 

representatives may participate by electronic means provided the individual can hear and be heard 

simultaneously by all other attendees . 

(c) Any invitee listed in (b), above, may request NHDOT to schedule an interagency consultation 

meeting at any time. 

(d) The purpose of regular interagency consultation meetings shall be to discuss topics relevant to 

transportation conformity requirements, including but not limited to any-er-aIkhe following: 

(1) Development of a SIP or SIP revisions, including but not limited to those involving 

transportation-related issues and mobile sources; w 

(2) Development of a metropolitan transportation plan or TIP, minor revisions to a TIP, or any 

amendment(s) to a TIP, and any determination of conformity for such plans; 

(3) Emissions budgets; 

(4) TCMs and mitigation measures pursuant to 40 CFR 93 .125(c) and 93 .122(a)(4)(ii), 

respectively, that are in the SIP or are being considered for inclusion in the SIP; 

(5) Evaluation and determination of events that will trigger new conformity determinations ; and 

(6) Coordination of emissions analyses for transportation activities that cross the borders of 

MPOs or nonattainment or maintenance areas or include areas outside of MPO boundaries. 

Env-A 1503 .09 Access to Materials. 

(a) NI-DOT or each MPO, as appropriate, shall provide access to the following materials to the 

department no later than at the start of the public comment period for the metropolitan transportation plan, 

TIP, or regional emissions analyses performed by NHDOT outside MPO areas : 

(1) Lists of exempt/not exempt projects and regionally significant projects, regardless of 

funding source; 

(2) Metropolitan transportation plans, TIPs, and corresponding air quality analyses and 

conformity determinations and g' ' ^s analyses of all projects 

outside MPO boundaries, but within the nonattainment or maintenance area; 

(3) Amendments to the metropolitan transportation plans and TIPs and significant changes in 

project design and scope since the previous conformity determination ; 

(4) Notices of public hearings and public comment periods for the metropolitan transportation 

plans, TIPs, or regional emissions analyses performed by NHDOT; 
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Deleted text °tr^^' " thF^^gh 

(5) All correspondence received from EPA, FHWA, FTA, or MPOs regarding conformity 

determinations and/or transportation planning processes relating to air quality issues; and 

(6) STIP amendments in nonattainment or maintenance areas outside MPO areas. 

(b) The department shall provide access to the following materials to NHDOT, EPA, FHWA, FTA, 

MPOs, and RPCs for comment during the SIP development process and conformity determination process : 

(1) SIP revisions pertaining to mobile sources including inventories, budgets, forecasts, and 

strategies for reduction of emissions, TCMs, transportation conformity, general conformity, area 

classifications, and redesignations ; 

(2) Proposed and final inputs to emissions analyses models necessary for SIP development and 

conformity determinations ; 

(3) Comments and guidance from EPA to the department regarding SIP development issues 

relating to mobile sources and transportation ; and 

(4) Notices of public hearings and public comment periods on SIP revisions regarding mobile 

sources or emissions budgets. 

(c) Each MPO shall provide access to its metropolitan transportation plan and TIPs that have 

received a final conformity determination by the MPO to NHDOT and to the department. 

(d) NHDOT shall provide access to the following materials as noted: 

(1) The metropolitan transportation plans and TIPs to FHWA, EPA, and FTA for conformity 

findings ; and 

(2) Any final regional emissions analysis for 

non-attainment or maintenance areas 

outside MPO afeas-boundaries to the department, each MPO, aPA-the affected RPC, EPA, 

FHWA, and FTA. 

(e) Access to all materials specified in (b) through (d), above, also shall be provided to the public for 

review and comment. 

Env-A 1503 .10 Responding to Comments . 

(a) After reviewing comments received on conformity determinations performed for STPs,-TIPs, 

metropolitan transportation plans, and any non-attainment or 

maintenance areas outside the MPO areas, NHDOT shall: 

(1) Document and respond to significant comments; and 

(2) Include a compilation of written comments and responses in any final conformity 

determinations. 

(b) After reviewing comments received on draft conformity determinations for the metropolitan 

transportation plan and TIP, each MPO shall: 

(1) Document and respond to significant comments; and 

(2) Include a compilation of written comments and responses in the final metropolitan 

transportation plan and TIP conformity determination . 
Added text in bold italics FP 2011-80 Annotated 08-17-11 8 

Deleted text rtru^'" *hr^u^" 

(c) If any significant comment requires additional analysis, NHDOT, the department, and the 

appropriate MPO(s) shall establish the appropriate course of action pursuant to 40 CFR 93, Subpart A. 

Env-A 1503 .11 TransDortation Control Measures. 

(a) If, after consultation as described in Env-A 1503 .05(c), the department determines the need for 

TCMs in the SIP, the following actions shall occur: 

(1) The department shall request NHDOT to coordinate an interagency consultation to identify 

the quantity of emissions reductions necessary; 

(2) The department, NHDOT, affected MPO(s), and RPCs shall each prepare a list of 

appropriate TCM(s) which potentially achieve the emissions reductions required, quantify the 

emissions benefits from their proposed projects, and review funding availability, scheduling, and 

permitting issues for the proposed TCM(s); 

(3) NHDOT shall coordinate an interagency consultation to discuss the list of TCM(s) and 

corresponding emissions benefits to be incorporated into the SIP; 

(4) The TCM(s) selected shall be incorporated into the affected metropolitan transportation 

plan(s), affected TIP(s), and the STIP, if necessary, and go through the applicable public 

participation process(es) necessary to amend the STIP, TIP(s), and/or metropolitan transportation 

plan(s) ; 

(5) The TCM(s) shall include a written commitment to implement the measure from the 

responsible entity per 40 CFR 93.122(a)(4)(ii) ; and 

(5) The department shall develop a SIP revision in accordance with §110 of the Act which 

incorporates the selected TCM(s) according to the implementation time frame agreed to by the 

affected MPO(s), NHDOT, and the department. 

(b) If TCMs are incorporated into the SIP, NHDOT shall : 

(1) Track the implementation of the TCM project and provide periodic updates no less than 

annually on implementation to the department, the affected MPO(s), and RPCs; 

(2) Prepare an update on TCM(s), if any, identified in the SIP prior to conformity 

determinations and provide the update to the department, affected MPO(s) and RPCs; and 

(3) Coordinate an interagency consultation if TCM(s) are not on schedule or if funding for the 

project is in jeopardy. 

Env-A 1503 .12 Regionally Sianifi cant Proilects . 

(a) Projects that are considered regionally significant for purposes of regional emissions analysis 

shall include any transportation project that: 

(1) Is not otherwise required to be included in the metropolitan transportation plan, TIPs, or 

STIP; 

(2) Is not considered exempt according to the federal transportation conformity rule, 40 CFR 

§93 .126 and 40 CFR §93 .127 ; and 

(3) Is expected to have a significant impact on travel patterns, consistent with the definition of 

regionally significant in 40 CFR §93 .101 and as determined through interagency consultation . 
Added text in bold italics FP 2011-80 Annotated 08-17-11 9 

Deleted text tu^k r"r^ugk 

(b) Each MPO shall: 

(1) Maintain a list of regionally significant projects for inclusion in the conformity 

determinations in its area based on information requested from communities in the MPO through 

established committees including technical advisory committees and other public participation ; 

and 

(2) Provide access to the list of regionally significant projects to NHDOT and the department. 

(c) Pursuant to 23 CFR 450, NHDOT shall : 

(1) Develop a list of regionally significant projects in nonattainment or maintenance areas 

outside an MPO area based on information regarding state funded or permitted projects and on 

information gathered from RPCs in the nonattainment or maintenance areas; 

(2) In cooperation with the MPOs and RPCs, combine the list described in (1), above, with the 

list of regionally significant projects, described in (b)(1), above, from the MPOs and RPCs ; 

(3) Provide access to the combined list described in (2), above, .to the department, the MPOs, 

RPCs, EPA, FHWA, and FTA as part of conformity determinations of the metropolitan 

transportation plan, TIP or regional emissions analyses of projects outside MPO areas; and 

(4) Provide information on regionally significant projects within MPO and RPC areas to the 

affected MPO(s) and RPCs. 

(d) When an application is received from a major traffic generator for access to a state-maintained 

highway, NHDOT shall: 

(1) Notify the affected MPO and RPC to make the MPO and RPC aware of potential traffic 

impacts from major traffic generators; and 

(2) If the application results in a transportation project which meets the criteria of a regionally 

significant project, include that project on its list of regionally significant projects circulated as 

specified in (c), above. 

Env-A 1503.13 Emissions and Transportation Modeling. Pursuant to 23 CFR 450: 

(a) NHDOT shall coordinate an interagency consultation for the evaluation and selection of both 

microscale and mesoscale emissions models used in the conformity determination process for metropolitan 

transportation plans, TIPs, and projects. 

(b) MPOs shall : 

(1) Evaluate and select the appropriate travel demand models for their area with input from 

NHDOT; 

(2) At the time of initial model selection or at the time when an MPO has decided to change to a 

new model, notify EPA, FHWA, FTA, and the department; and 

(3) If MPOs are located in nonattainment or maintenance areas, maintain regional 

transportation models. 

(c) NHDOT, FHWA, and FTA shall have an opportunity to comment on the development and 

maintenance efforts of these models through approval of the unified planning work program. 
Added text in bold italics FP 2011-80 Annotated 08-17-11 10 

Deleted text t "" ^' " th'^"^'' 

(d) In areas where transportation models exist currently or are required in the future, MPOs shall 

update, at least every 2 years, land use assumptions in the model to reflect any large scale developments 

approved subsequent to the date of the last update. 

Env-A 1503 .14 Exempt/Not Exempt Project Lists. Pursuant to 23 CFR 450: 

(a) Prior to making any conformity determinations, MPOs and NHDOT shall : 

(1) Review all projects within nonattainment or maintenance areas that are on the STIP and 

TIPs, to determine whether the projects are exempt under 40 CFR §§93.126 and 93 .127; and 

(2) Determine if any exempt projects shall be classified as not exempt because of potential 

emissions impacts . 

(b) NHDOT and MPOs shall provide access to the department, RPCs, EPA, FHWA, and FTA for 

review and comment a list of projects and their exempt/non-exempt status as part of conformity 

determinations of metropolitan transportation plans, TIN, and regional emissions analyses performed 

outside the MPO areas. 

Env-A 1503 .15 Proiects in PM, -S and Nonattainment or Maintenance Areas. - RESERVED 

Env-A 1503 .16 Notification of Metropolitan Transportation Plan TIP or STIP Proposed 

Amendments of Exempt Proiects . Pursuant to 23 CFR 450: 

(a) NHDOT shall notify the appropriate MPO(s), the department, affected RPCs, EPA, FHWA,. and 

FTA of any proposed STIP amendment which adds or deletes an exempt or non-exempt project as listed in 

40 CFR §§93.126 and §93 .127. 

(b) MPOs shall notify NHDOT, the department, EPA, FHWA, and FTA of any proposed amendment 

to a metropolitan transportation plan or TIP that adds or deletes an exempt or non-exempt project as listed 

in 40 CFR §*93 .126 and §93 .127 . 

Env-A 1503 .17 Conformity in Nonattainment or Maintenance Areas Outside MPO Areas or 

Containinv, More Than One MPO Area. Pursuant to 23 CFR 450: 

(a) In portions of nonattainment or maintenance areas that are not included in an MPO area or that 

contain more than one MPO area, NHDOT shall determine conformity of S-T~s-,-TIPs, ?=na range stM°" "ia° 

metropolitan transportation plans, and plans for any nonattainment or 

maintenance areas outside the MPO boundaries, incorporating the most recent emissions analysis from the 

currently conforming metropolitan transportation plan and TIP for all MPOs which are within the 

nonattainment or maintenance area. 

(b) In nonattainment or maintenance areas which contain more than one MPO, each MPO shall 

consider the most recent emissions analysis from the other currently conforming metropolitan transportation 

plans and TIPs within the region. 

(c) NHDOT shall coordinate conformity determinations in nonattainment or maintenance areas with 

more than one MPO. 

Env-A 1503 .18 Resolving Conflicts . 

(a) During the public comment period on conformity determinations of metropolitan transportation 

plans, TIPs, and NHDOT regional emissions analyses of transportation projects, the department shall: 
Added text in bold italics FP 2011-80 Annotated 08-17-11 11 

Deleted text struek thr-eugi-i 

(1) Review the conformity determination of such metropolitan transportation plans, TIPs, and 

NHDOT regional emissions analyses; 

(2) Submit written comments on the conformity determinations to the appropriate MPO and to 

NHDOT as soon as possible but no later than the close of the public comment period ; and 

(3) Include in the comments specified in (2), above, a clear finding of concurrence or 

nonconcurrence on the conformity determinations and a list of issues to be addressed, if any. 

(b) If the department does not concur with the conformity determination, NHDOT or the appropriate 

MPO, as applicable, shall submit a written response(s) to the department within 14 calendar days of the 

receipt of the department comments, which clearly addresses each of the stated issues either by revising the 

determination or by explaining why the determination was not revised. 

(c) if the issues cannot be resolved, the provisions of 40 CFR 93 .105(d) relative to resolving conflicts 

shall apply. 

(d) Pursuant to 23 CFR 450, if a conflict arises among MPOs with respect to conformity 

determinations, NHDOT shall: 

(1) Act as the arbitrator; and 

(2) Invite the department to any meetings held to resolve the conflict . 

Env-A 1503 .19 Public Consultation . 

(a) Pursuant to 23 CFR 450, NHDOT, the department, and MPOs, RPCs, EPA, FHWA, and FTA 

shall implement all applicable federal and state required public notification and public participation 

processes throughout the interagency consultation process . 

(b) MPOs shall provide a minimum of 10 days for receipt of public comment prior to taking a 

formal action on conformity determinations of MPO transportation plans and MPO TIPs. 

(c) NHDOT shall provide a minimum of IO days for receipt of public comment prior to taking 

formal action on conformity determinations of NHDOT regional emissions analysis in areas outside 

MPO areas or in areas covered by more than one MPO. 

Adopt Env A 1503.20 and Env f1 1503.21 to read as follows: 

Env-A 1503 .20 Commitments for Regional Emissions Analysis . In accordance with 40 CFR 

93 .122(a)(4)(ii), an MPO shall not include emissions reduction credits from control measures that are not 

included in its metropolitan transportation plan or TIP and that do not require a regulatory action in the 

regional emissions analysis used in the conformity determination unless the MPO, er-FHWA, or FTA 

obtains written commitments, as defined in 40 CFR 93 .101, from the appropriate entities to implement those 

control measures. 

Env-A 15093 .21 Commitments for Project-Level Mitigation and Control Measures. 

(a) In accordance with 40 CFR 93 .125(c), prior to making a project-level conformity determination 

for a transportation project, the FHWA or FTA shall obtain from the project sponsor or operator a written 

commitment, as defined in 40 CFR 93 .101, to implement any project-level mitigation or control measure in 

the construction or operation of the project identified as a condition for NEPA process completion. 

(b) Prior to making a conformity determination for a metropolitan transportation plan or TIP, the 

MPO shall ensure that any project-level mitigation or control measures for which a written commitment has 
Added text in bold italics FP 2011-80 Annotated 08-17-11 12 

Deleted text s+r^^'r }hr^u^h 

been made are included in the project design concept and scope and are appropriately identified in the 

regional emissions analysis used in the conformity analysis . 

(c) Written commitments shall be obtained before such mitigation or control measures are used in a 

project-level hot-spot conformity analysis for a project-level determination . 

Renumber the heading of PART Env A 1502 to be PART Env-A 1504, as follows: 

PART Env-A 1504 CONFORMITY OF GENERAL FEDERAL ACTIONS 

Readopt with amendment Env-A 1502. 01 and Env .4 1502. 02, eff. 10-14-03 (doe . #7971), and renumber as 

Env-A 1504.01 and Env-A 1504.02, to read as follows: 

Env-A 1504 .01 Purpose. The purpose of this part is to implement §176(c)(4) of the Clean Air Act (the 

Act), as amended, and 40 CFR 93, Subpart B, with respect to the conformity of federal actions to the SIP, to 

ensure that the purpose and intent of the SIP are met. 

Env-A 1504.02 Applicability . 

(a) Pursuant to § 176(c)(1) of the Act, this part shall apply to any federal department, agency, or 

instrumentality which meets the applicability criteria as specified in 40 CFR §93 .153 . 

(b) This part shall not apply to any entity subject to a conformity determination for a federal action 

related to a transportation plan, program, or project developed, funded, or approved under 23 USC §§101 et 

seq. or the Federal Transit Act, as amended, 49 USC §§ 1601 et seq. 

Readopt with amendment Env-A 1502.03(a), eff. 10-14-03 (doe. #7971), as amended eff. 6-22-OS (doe. 

#8382), and renumber as Env-A 1504.03, to read as follows: 

Env-A 1504.03 References . For the purpose of this part, unless otherwise specified all references to 

40 CFR 93, Subpart B, shall be to the July 1, 2011 edition. 

Readopt with amendment Env 14 1502.03(b), eff. 10-14-03 (doe. #7971), as amended eff. 6-22-05 (doe. 

#8382), and Env f1 1502.04 and Env-A 1502. 05, eff. 10-14-03 (doe. #7971), and renumber as Env-A 1504.04 

and Env-A 1504.05, to read as follows: 

Env-A 1504 .04 Federal Definitions Incornorated. 

(a) The definitions contained in and referred to in 40 CFR §93 .152 shall apply to the terms used in 

this part. 

Env-A 1504.05 Conformity to State and Federal Implementation Plans. 

(a) Pursuant to § 176(c)(I) of the Act, no applicable federal entity shall engage in, support in any way 

or provide financial assistance for, license or permit, or approve any activity which does not conform to the 

SIP or FIP developed pursuant to § 110 and §§ 171 through 185 of the Act. 

(b) Such determination that a federal activity conforms to the SIP or FIP shall be made in accordance 

with § 176 of the Act and 40 CFR 93, Subpart B. ' 
Added text in hold italics FP 2011-80 Annotated 08-17-11 13 

Deleted text s4uek through 

APPENDIX 

Rule Section/Paragraph State Statute Implemented Federal Statutes or Regulations Implemented 

Env-A 1501 .01 - 

Env-A 1502 .02 RSA 125-C:4, 1(a) 42 U.S .C. §7506 ; 40 CFR 93, Subpart A 

Env-A 1502 .01(a) RSA 125-C:4, I(a) 42 U.S .C. §7506 ; 23 CFR §450 

Env-A 1502 .01(b) RSA 125-C:4, I(a) 42 U.S.C. §7506; 40 CFR §93 

Env-A 1502 .02 RSA 125-C:4, I(a) 42 U.S .C. §7506 ; 40 CFR §93 .101 

Env-A 1502 .03 RSA 125-C:4, 1(a) ; 

RSA 36:45 - 58 

42 U.S.C. §7506; 40 CFR §93 .101 

Env-A 1502 .03(d) & (f) RSA 125-C:4, 1(a) 42 U.S .C. §7506; 42 U.S .C . §7407; 40 CFR §51 .852 

Env-A 1503 .01 RSA 125-C:4, 1(a) 42 U.S.C. §7506; 40 CFR §93 .105 ; 40 CFR 

§93 .122(a)(4)(ii) ; 40 CFR §93 .125(c) 

Env-A 1503 .02 RSA 125-C:4, I(a) 42 U.S .C. §7506; 40 CFR §93 .102 

Env-A 1503 .03 RSA 125-C :4, I(a) 42 U.S.C. §7506; 42 U.S .C. §7511 ; 42 U.S.C. §§ 7501- 

7515 ; 40 CFR 93, Subpart A 

Env-A 1503 .04 RSA 125-C:4, 1(a) 42 U.S .C. §7506; 42 U.S .C . §7407 

Env-A 1503 .05 RSA 125-C:4, I(a) 42 U.S.C. §7506; 40 CFR 51, Subpart T; 40 CFR 93, 

Subpart A 

Env-A 1503 .06 RSA 125-C:4, 1(a) 42 U.S.C . §7506; 23 CFR 450, Subpart B 

Env-A 1503 .07 RSA 125-C:4, 1(a) 42 U.S .C . §7506; 23 CFR 450, Subpart C 

Env-A 1503 .08-1503 .21 RSA 125-C:4, I(a) 42 U.S .C. §7506; 23 CFR 450; 40 CFR 93, Subpart A 

Env-A 1504.01 RSA 125-C:4, I(a) 42 U.S .C . §7506 ; 40 CFR 51, Subpart W 

Env-A 1504.02 RSA 125-C:4,1(a) 42 U.S .C. §7506 ; 40 CFR 51 .853 

Env-A 1504.03 RSA 125-C:4, 1(a) 42 U.S .C. §7506; 40 CFR 51 

Env-A 1504 .04 RSA 125-C:4, I(a) 42 U.S.C. §7506; 40 CFR 51 .852 

Env-A 1504.05 RSA 125-C:4, I(a) 42 U.S .C. §7506; 42 U.S .C. §7511 ; 42 U.S.C. §§ 7501 I 

through 7515; 40 CFR 51, Subpart W 
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