Transportation/Air Quality Issues in Rural AreasBack to Search Page Federal Highway Administration Transportation/Air Quality Issues in Rural Areas Final Report April 2003 Prepared by Dye Management Group, Inc. 500 108th Avenue NE, Suite 1700 Bellevue, WA 98004

Federal Highway Administration Transportation/Air Quality Issues in Rural Areas Table of Contents

I. Introduction A. Background B. Approach C. Report Structure II. Summary of Findings III. Identification of Isolated Rural Areas IV. Survey Results A. Carbon Monoxide B. Ozone C. Particulate Matter-10 Appendix A: Survey A-1

Federal Highway Administration Transportation/Air Quality Issues in Rural Areas

I. Introduction Although air quality has been mainly an urban concern, it is beginning to become an issue that rural areas will also have to manage. Several rural counties have exceeded the national standard for one or more air pollutants. The purpose of this study is to increase understanding of how many rural areas are facing this problem and to identify the main causes for their exceeding air quality standards. The study also focuses on transportation's contribution to the air quality problems in rural areas and how these areas are meeting certain Clean Air Act requirements related to motor vehicle emission sources. In order to build this understanding, the research identified rural nonattainment and maintenance areas: how many are there, where are they, and are they isolated rural areas or donut areas? (These two different types of areas are defined in Section III.) Once the delineation of areas was accomplished, the study's in-depth evaluation of air quality and transportation conformity issues was restricted to only isolated rural areas. The research reported in this paper accomplished the following: Determined if transportation is generating the pollutants in each isolated rural area or if another source is primarily responsible for the pollutant. Identified what analysis rural areas have conducted to meet the Clean Air
Act requirements for transportation conformity and the control measures they have undertaken to address transportation-related sources of pollutants. Assessed the resources and planning capabilities of isolated rural areas to address the issue of conformity between transportation plans for their areas and State Implementation Plans (SIPs). Back to Table of Contents

A. Background The conformity provisions of the Clean Air Act are intended to integrate transportation and air quality planning in areas that are designated by the US Environmental Protection Agency (EPA) as nonattainment or maintenance.1 The transportation conformity process establishes a connection between transportation planning and the emissions levels for transportation sources that are established in the SIP. These emissions levels (or "budgets") in the SIP represent the maximum amount of emissions that can be generated from on-road transportation sources (e.g., cars, trucks, public transit) and still allow the area to attain or maintain the air quality standards. Under the CAA, nonattainment and maintenance areas must demonstrate through the conformity process that emissions projected from their transportation investments, strategies, and programs will be at or below the emissions budgets in the SIP. In order to comply with the National Ambient Air Quality Standards, federal, state, and local governments must take action. These actions, or controlmeasures, are typically identified in the SIP. Depending on the classification

and severity of the air quality problem, some areas may find that they need to reduce emissions from transportation sources. One option for reducing emissions for on-road mobile sources is to limit vehicle miles traveled (VMT). VMT is the sum of distances traveled by all motor vehicles in a specified region. In order to address VMT, some states have included Transportation Control Measures (TCMs) as strategies that are specifically identified and committed to in the SIP. TCMs are strategies that are listed in Section 108 of the Clean Air Act and include projects such as public transit and ride-share programs. Areas might also invest in other technology-based strategies that will reduce transportation-related emissions such as inspection and maintenance and fuels programs.

1 A nonattainment area is a region that does not meet (or that contributes to ambient air quality in a nearby area that does not meet) the national primary

or secondary ambient air quality standard for the pollutant. The area must take specified actions within a certain time frame to reduce emissions and attain the National Ambient Air Quality Standards (NAAQS). A maintenance area is a region previously designated as nonattainment, and subsequently redesignated to attainment. Back to Table of Contents

B. Approach To meet the objectives of this study, research was conducted to determine the classification of areas. A comprehensive survey was designed, administered, and analyzed. The entire process was overseen by officials from the FHWA and EPA Office of Transportation and Air Quality (OTAQ). Oversight Study oversight was provided by officials from the FHWA and EPA-OTAQ. The following officials were involved in the study oversight: Bob Gorman, FHWA Dee Spann, FHWA Cecilia Ho, FHWA Angela Spickard, EPA-OTAQ The oversight group provided input and validated the study at key points, including study inception, survey design, and presentation of findings. Research and Analysis August 2001 data on rural nonattainment and maintenance areas was compiled from the EPA Greenbook website (http://epa.gov/oar/oaqps/greenbk/). The EPA Greenbook data included information on all nonattainment and maintenance

areas in the United States for six pollutants: ozone, carbon monoxide, nitrogen dioxide, sulfur dioxide, particulate matter, and lead. The data also distinguished between nonattainment and maintenance areas that are part of a Metropolitan Planning Organization (MPO) and those that are not. In this research, the three transportation-related pollutants examined were carbon monoxide, ozone, and particulate matter-10 (PM-10). Although nitrogen dioxide is also a pollutant emitted from transportation sources, there are no isolated rural areas violating the nitrogen dioxide air quality standard. A list of nonattainment and maintenance isolated rural areas was compiled. In order to differentiate between the isolated rural areas and the donut areas, many sources of information were used. (The two types of rural areas are defined in Section II.) The Association of Metropolitan Planning Organizations (AMPO) was consulted for determining which geographic areas MPOs covered. Organizational websites (where available) were used to determine the exact coverage area of the MPO; an organization without a website was contacted by phone. The MPO areas were mapped out, as were the nonattainment and maintenance areas, to determine if the area was a donut or an isolated rural area. The regional EPA offices were contacted by phone to verify the list of isolated rural nonattainment/maintenance areas and the donut areas. The Code of Federal Regulations was consulted to determine the current air quality classification of the area and to incorporate any updates since the Greenbook data was last updated in August 2001. The analysis and survey conducted was based on designations as of mid January 2002. Survey In conjunction with the EPA and the FHWA, a survey was developed to determine how isolated rural areas designated as nonattainment or maintenance for oneor more national ambient air quality standards are addressing air quality and

transportation conformity requirements. The survey specifically addresses Ozone, Carbon Monoxide, and PM-10 isolated rural areas. The main questions addressed in the survey are: Why are these isolated rural areas in nonattainment or maintenance (i.e., what are the main sources of their air quality problems)? How are these air quality problems being addressed by the different agencies involved? How are these areas meeting the transportation conformity requirements? The survey was e-mailed to the state department of transportation and state air quality agency for each area. In addition, regional FHWA and regional EPA offices were also e-mailed a survey. The consultant team answered survey respondents' questions and encouraged those who had not completed a survey
to do so. Interviews One jurisdiction from each pollutant nonattainment or maintenance area -- Presque Isle, Maine; Fairbanks, Alaska; and Greenbrier County, West Virginia -- was selected for a follow-up interview. These focused discussions were used to clarify how the area has used the conformity process and to identify the practical issues associated with different aspects of the process. The interviews confirmed the conclusions the study team reached from the survey data. Back to Table of Contents

C. Report Structure This report is organized into the following sections: II. Summary of Findings. This section presents the general findings from the surveys collected for all the isolated rural nonattainment and maintenance areas that responded.

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

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

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

II. Summary of Findings The following summarizes the major findings of a study that assessed the
process and techniques that isolated rural nonattainment and maintenance areas have used to address the requirements of the conformity process. More details and definitions can be found in the body of this report. There are few isolated rural nonattainment or maintenance areas compared to the total nonattainment or maintenance areas for each pollutant. Isolated rural nonattainment or maintenance areas represent a small percentage of the total nonattainment or maintenance areas, as shown in Exhibit II-1. Exhibit II-1: Number of Isolated Rural Nonattainment or Maintenance Areas Relative to Total Nonattainment or Maintenance Areas in 2001PollutantIsolated Rural AreasTotal areasPercent Isolated Rural Carbon Monoxide31212 Ozone314207 PM-103710635

The exhibit reinforces a predominant view that air quality is primarily an urban concern. However, the portion of PM-10 areas that are isolated rural areas is significant. In only two cases were more than 5 percent of the PM-10 emissions attributed to on-road mobile sources. Survey results indicated that in most of the isolated rural areas the PM-10 problem in an area are attributable to sources other than on-road mobile sources such as point source (e.g., factories or power plants). Consequently, transportation-related strategies did not really help these areas to attain the PM-10 standard. Experience with PM-10 problems in other areas, confirmed through the survey and telephone follow up with the isolated rural areas, indicates that more frequent street sweeping, changing deicing materials or other fugitive dust control measures can be effective in reducing PM-10 emissions. In the case of Presque Isle, Maine, (a PM-10 nonattainment isolated rural area) switching from a native sanding material to calcium chloride was very effective inreducing PM-10 emissions. However, the cost of using the chemical in place

of the sand had prevented the local maintenance crews from switching for many
years. The isolated rural areas have limited staff resources to understand and address the implications of nonattainment status. In general the isolated rural areas do not have professional air quality and transportation planning staff. Local jurisdictions' responsibilities are typically addressed through their public works department or county engineer depending upon their organizational structure. They also rely on the expertise of State Department of Transportation staff in addressing conformity issues. There is typically limited local data and planning information to perform conformity analysis. The survey results indicate that in those few cases where analysis is performed, traffic data and growth estimates are derived from traffic counts and other traffic monitoring data reporting such as HPMS. Few areas indicated that they collected local data. Interagency consultation is helpful when needed, but most survey respondents have never held a meeting of all federal, state, and local agencies because they have not had transportation projects, and therefore, have not needed to determine conformity. Ten of the 18 survey respondents stated that there had never been a meeting among all agencies for the area, while two respondents explained that they have not needed consultation because the area has had no new projects. Three respondents did not provide any information about consultation for their isolated rural area. The three respondents that endorsed interagency consultation stated that the process has been helpful in facilitating cross-functionality training and resolving conformity issues. According to the Chief of EPA Region 4's Air Planning Branch, interagency consultation has been very effective in Edmonson County, Kentucky: Effective interagency consultation was the key to resolving this issue and could have been used as the means to prevent any delay from occurring. Because of this area's limited experience with conformity and the nature of how transportation conformity is implemented in isolated rural areas (i.e., until projects are seriously contemplated there is no need to do conformity analysis), planning parties may not have allowed time for any resolution
to potential issues, and may not have effectively consulted with parties who could work to resolve issues until there was no choice but for delay. In this case, it was not until the area ran the conformity analysis and was
not able to demonstrate conformity to a budget developed with the Mobile 4.1 emissions model that the area realized that it would be beneficial for them to have mobile emissions budgets developed with the new Mobile 5 emissions model. The efforts for developing new emissions budgets is not extremely burdensome but does require planning, review and approval on the part of various agencies that may not have been alerted to this situation until it was too late. The Kentucky Transportation Cabinet and air quality partners in the Edmonson County have gained a lot from their interagency coordination and communicate on at least a monthly basis on this area and other areas in Kentucky, even though the area has successfully demonstrated conformity. The partners are taking a more proactive approach and discuss any upcoming projects that
may be considered for Edmonson County. In fact, this interagency consultation discussion prevented KYTC (the Kentucky Transportation Cabinet) from performing conformity analysis unnecessarily for Edmonson County in the beginning of 2002. KYTC was under the impression that conformity determinations for isolated rural areas have a three year expiration just

as in metropolitan areas. When this topic was discussed on the monthly interagency consultation call, Kentucky transportation and air quality partners were able to discuss and resolve this issue prior to KYTC beginning work for this conformity determination. In this area, interagency consultation has been very beneficial. We all have a better understanding of the role of each consultation partner with regard to conformity. The air quality agencies are gaining more knowledge of the transportation planning process, and the transportation agencies are gainingmore knowledge of the air quality process.

Most areas reported no new Federal non-exempt transportation projects in the past five years. Consistent with their rural nature, 11 areas indicated no regionally significant projects. Only three survey respondents reported non-exempt transportation projects requiring conformity analysis over the past five years.2 Each of the three areas only had one such project. Two areas used an analysis period shorter than the required analysis period in their conformity determination. Although conformity analysis requires a 20-year analysis period, two areas reported a shorter timeframe. One area reported analysis 10 years into the future; another reported analysis 15 years into the future.

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

III. Identification of Isolated Rural Areas Federal regulations separate rural areas into two types: isolated rural areas and donut areas. For purposes of this survey, the distinction between an isolated rural area and a "donut" area is as follows. An isolated rural area is an area that is not part of the emissions analysis of any Metropolitan Planning Organization's (MPO) transportation plan or transportation improvement program (TIP). A "donut" area, on the other hand, is an area that is inside a non-attainment or maintenance area boundary, but is outside the metropolitan planning boundary (40CFR93.109(g)). The following tables show the rural areas currently (March 2003) in non-attainment status. Exhibit III-1: Carbon Monoxide Nonattainment or Maintenance Rural Areas (March 2003)StateEPA RegionIsolated Rural AreasDonut Areas Alaska10Fairbanks Oregon Grants Pass Klamath Falls

Exhibit III-2: Ozone Nonattainment or Maintenance Rural Areas (March 2003)StateEPA RegionIsolated Rural AreasDonut Areas Connecticut1Windam County (Greater Connecticut Area) Maine1Hancock & Waldo CountiesCumberland County (Greater Portland Area) Knox & Lincoln Counties New Hampshire1Cheshire County New York2Essex County Jefferson CountyMontgomery and Greene Counties (Albany-Schenectady-Troy Area) Maryland3Kent & Queen Anne's CountiesCalvert and Charles Counties (Washington, DC-MD-VA) Virginia3White Top Mountain (Smith County) Delaware3Sussex County Pennsylvania3Crawford County Franklin County Juanita County Lawrence County Northumberland County Schuylkill County Snyder County Susquehanna County Warren County Wayne County Virginia3White Top Mountain (Smith County) West Virginia 3Greenbrier County Georgia4 Coweta, Forsyth and Paulding Counties (Atlanta Area) Kentucky4Edmonson CountyPortion of Hancock County (Owensboro area) Paducah (Livingston and Marshall Counties)Scott County (Lexington Area) South Carolina4Cherokee County Tennessee4 Rutherford, Sumner, Williamson and Wilson Counties (Nashville area) Michigan5Allegan County Muskegon Ohio5Clinton CountyAshtabula and Portaqe Counties (Cleveland-Akron-Lorain area) Columbiana County Preble CountyDelaware and Licking Counties (Columbus area) Greene and Miami Counties (Dayton-Springfield area) Stark County (Canton area) Louisiana6Grant Parish Lafourche Parish St. James Parish St. Mary Parish

Exhibit III-3: PM-10 Nonattainment or Maintenance Rural Areas (2003)StateEPA RegionIsolated Rural AreasDonut Areas Maine1Presque Isle (Aroostook County) Illinois5Oglesby (La Salle County) Indiana5Vermillion County New Mexico6 Anthony (Dona Ana County) Colorado8Telluride (San Miquel County) Pagosa Springs (Archuleta County) Canon City (Fremont County) Aspen (Pitkin County) Lamar (Prowers County) Steamboat Springs (Routt County) Montana8Columbia Falls (Flathead County) Whitefish and vicinity (Flathead County) Kalispell (Flathead County) Polson (Lake County) Libby (Lincoln County) Lame Deer (Rosebud County) Thompson Falls and vicinity (Sanders County) Ronan area (Lake County) Butte (Silver Bow County)Ronan Wyoming8Sheridan County Arizona9Douglas (Coachise County) Paul Spur (Coachise County) Hayden/Miami (Gila and Pinal Counties) Payson (Gila County) Mohave County Nogales (Santa Crus County) California9Mammoth Lake (Mono County) Owens Valley (Inyo County) Mono Basin (Mono County) Alaska10Juneau Idaho10Sandpoint (Bonner County) Shoshone County (excluding Pinehurst)

Pinehurst (Shoshone County) Oregon10Lake County Grants Pass (Josephine County) LaGrande (Union County) Klamath County (Klamath Falls area) Washington10Wallula (Walla Walla County)

The study team surveyed a sample of the isolated rural areas identified in the exhibit. IV. Survey Results The survey was administered to a sample of the carbon monoxide, ozone, or PM-10 nonattainment or maintenance isolated rural areas. The survey was sent to 41 isolated rural areas: 2 carbon monoxide nonattainment or maintenance areas, 6 ozone nonattainment or maintenance areas, and 34 PM-10 nonattainment areas. (Grant's Pass, Oregon is both a carbon monoxide maintenance area and a particulate matter nonattainment area.) For each area, the survey was sent to the corresponding: State department of transportation (DOT). State and/or local air quality agency. FHWA Division and EPA Regional offices. A total of 18 surveys were completed, for an overall response rate of 43 percent. However, response rates differed according to pollutant: 100 percent for ozone; 50 percent for carbon monoxide; and 32 percent for particulate matter-10. Below are general conclusions from all surveys, as well as conclusions drawn for each of the pollutants. Back to Table of Contents

A. Carbon Monoxide Only one of the two carbon monoxide maintenance or nonattainment areas responded to the survey, as shown in Exhibit IV-1. Exhibit IV-1: Carbon Monoxide Nonattainment and Maintenance Isolated Rural AreasStateCountyArea NameStatusClassEPA RegionCompleted Survey AlaskaFairbanks EdFairbanksNonattainmentSerious10No OregonJosephineGrants PassMaintenanceN/A10YesOver 50 percent of Grants Pass's carbon monoxide emissions is caused by

on-road mobile sources. VMT is projected to grow 0.8 percent per year between 1993 and 2015, as determined by a model developed in collaboration between the Rogue Valley Council of Governments and the Oregon Department of Transportation. Grants Pass has a maintenance SIP, which contains one transportation control measure: wintertime oxygenated fuel. The survey respondents also indicated that the one federal action that has helped the area maintain air quality standards is improved vehicle emissions standards on new cars. Grants Pass used the less than 1990 test and the build/no-build test in its last conformity determination. For years beyond the timeframe of the SIP, Grants Pass uses the budget test and demonstration using air quality modeling. It is not clear from the survey responses why Grants Pass appears to have used both the budget test and an air quality modeling demonstration for conformity in years past the SIP. Grants Pass, like all Oregon local jurisdictions, is required to develop a transportation system plan (TSP) and receives financial support to do so. This requirement has likely led to an improved capacity to handle planning efforts such as the conformity process. While the sample size for carbon monoxide nonattainment and maintenance areas is small, there may be opportunity for Fairbanks to learn from Grants Pass. Since both areas are in EPA Region 10, EPA officials could coordinate a meeting between officials in both areas. Comments on the Process A survey respondent from the FHWA Division office made the following
comment: The FHWA Division must rely heavily on the Oregon DEQ and USEPA for information on how and when areas are designated as non-attainment or maintenance areas and how conformity needs to be addressed in each. If new guidance were developed, the most useful would be something that could make it easier to track the status of each specific area. Often when changes in requirements are published in the Federal Register, it can be difficult and time consuming to determine which areas are impacted and the actions that may be needed. Back to Table of Contents

B. Ozone All six isolated rural areas in nonattainment or maintenance for ozone, in the survey sample, completed the survey. The areas are listed in Exhibit IV-2. Exhibit IV-2: 2002 Ozone Nonattainment and Maintenance Isolated Rural Areas StateCountyArea NameStatusClassEPA RegionCompleted Survey DelawareSussexSussex CountyNonattainmentMarginal3Yes KentuckyEdmonsonEdmonson CountyMaintenanceN/A4Yes Livingston and MarshallPaducahMaintenanceN/A4Yes New YorkEssexEssex CountyNonattainmentMarginal2Yes VirginiaSmythWhite Top MountainNonattainmentMarginal3Yes West VirginiaGreenbrierGreenbrier CountyNonattainmentN/A3Yes

Four ozone nonattainment or maintenance areas have SIPs; two areas (White Top Mountain and Sussex County) do not. For emissions dealing with ozone, areas list precursors: nitrogen oxides (NOx) and/or hydrocarbons (VOC). On-road mobile sources of NOx ranged from 0 percent for White Top Mountain to 87 percent for Greenbrier County. On-road mobile sources of VOC ranged from 0 percent for White Top Mountain to 53 percent for Greenbrier County. Exhibit IV-3 shows the full results of the survey. Exhibit IV-3: Percentage of Emissions from On-road Mobile SourcesArea NameNOx VOC Sussex County 21%22% Edmonson County63%36% Paducah, Kentucky33%3% Essex CountyN/AN/A White Top Mountain0%0% Greenbrier County87%53% Notes:N/A = not reported

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

Using historical data from the federal Highway Performance Monitoring System (HPMS), VMT growth in Edmonson County is determined to be 2.28 percent annually from 2000 to 2020. HPMS data was also used to determine the annual increase of VMT in Paducah, which is 2.05 percent for Marshall County and 2.11 percent for Livingston County. None of the other areas reported VMT information, and noneof

the four areas with a SIP employ transportation control measures. However, several areas listed federal actions that have helped the area attain or maintain the air quality standards. Exhibit IV?4 lists those effective federal measures cited by the areas. Exhibit IV-4: Effective Federal Measures for Attaining or Maintaining Air Quality StandardsArea NameMeasures Cited Sussex CountyNone. Edmonson CountyAll measures, including federal vehicle emission controls and fleet turnover. PaducahFleet turnover, non-road rules, the national low emission vehicle program (NLEV), and heavy duty diesel program. Essex CountySection 126 rule for NOx transport. White Top MountainNone. Greenbrier CountyFederal Motor Vehicle Control.Program (FMVCP), Heavy Duty Diesel Rule, and small spark ignition gasoline engines.

For those areas with SIPs, Exhibit IV-5 lists conformity tests used both in their conformity determination and in the years beyond the timeframe of the SIP. (Only two areas provided information.) Exhibit IV-5: Conformity TestsAreaLast DeterminationDeterminations in Years Beyond Timeframe of SIP Budget testLess than 1990 testBuild/no build testNo-greater-than 1990 testBudget testLess than 1990 testBuild/no build testNo-greater-than 1990 testDemonstration using air quality modeling Edmonson CountyX X PaducahX X Total Number2 2

Both Edmonson County and Paducah reported having non-exempt transportation projects in the past five years. Edmonson determined conformity for its project in 1999. Paducah failed in 1998 to determine conformity due to an increase in VMT, but eventually the area was able to make a conformity determination in Spring 2002 after revising its SIP to incorporate new data. Comments on the Process A state transportation engineer commented on the survey: "A recent ruling that an isolated rural area need only do conformity when adding a new project will help." The same engineer noted that "It doesn't seem appropriate to be spending so many resources and creating local headaches over adding a minor amount of VMT when the mobile contribution to pollution in the area is so small anyway. For most isolated rural areas, the primary contribution is likely coming from outside the area, so why not focus attention and

resources on the real problem?" Back to Table of Contents

C. Particulate Matter-10 Only 11 of the 34 PM-10 nonattainment and maintenance areas, in the survey sample, completed the survey, as shown in Exhibit IV-6. Exhibit IV-6: 2002 PM-10 Isolated Rural Nonattainment and Maintenance AreasStateCountyArea NameStatusClassEPA RegionCompleted Survey MaineAroostookPresque IsleMaintenanceN/A1Yes ColoradoSan MiguelTellurideMaintenanceN/A8No ArchuletaPagosa SpringsMaintenanceN/A8No FremontCanon CityMaintenanceN/A8No PitkinAspenNonattainmentModerate8No ProwersLamarNonattainmentModerate8No RouttSteamboat SpringsNonattainmentModerate8No MontanaFlatheadColumbia FallsNonattainmentModerate8No FlatheadFlathead County; Whitefish and vicinityNonattainmentModerate8No FlatheadKalispellNonattainmentModerate8No LakePolsonNonattainmentModerate8No LincolnLibbyNonattainmentModerate8No RosebudLame DeerNonattainmentModerate8No SandersSanders County (part); Thompson Falls and vicinityNonattainmentModerate8No Silver BowButteNonattainmentModerate8No WyomingSheridanSheridanNonattainmentModerate8Yes ArizonaCochiseDouglasNonattainmentModerate9No CochisePaul SpurNonattainmentModerate9No GilaHayden/MiamiNonattainmentModerate9No GilaPaysonNonattainmentModerate9No MohaveMohave CountyNonattainmentModerate9No PinalHayden/MiamiNonattainmentModerate9No Santa CruzNogalesNonattainmentModerate9No CaliforniaMonoMammoth LakeMaintenanceN/A9Yes InyoOwens ValleyNonattainmentSerious9YesInyoSearless ValleyNonattainmentModerate9Yes MonoMono BasinNonattainmentModerate9Yes AlaskaJuneau EdJuneauNonattainmentModerate10No IdahoBonnerSandpointNonattainmentModerate10Yes ShoshonePinehurstNonattainmentModerate10Yes OregonLakeLake CountyNonattainmentModerate10Yes JosephineGrants PassNonattainmentModerate10Yes UnionLaGrandeNonattainmentModerate10Yes WashingtonWalla WallaWallulaNonattainmentSerious10No

All 11 PM-10 nonattainment or maintenance areas reported having a SIP. The contribution of emissions from on-road mobile sources to the areas' air quality problem varied and was difficult to determine in some areas. For Presque Isle, Maine, on-road mobile-sources, including road dust, was estimated to be 61% of the area's total PM inventory in 1994; more recent estimates show that the percentage of direct emissions only is estimated at 7.3 percent. For Mammoth Lakes, direct emissions from transportation sources has been determined to be less than 1%, however, emissions from resuspended road dirt and cinders is estimated to be 56.1% of the areas' emissions inventory. Unfortunately, survey information did not indicate what percentage of the resuspended road dirt was from roads versus what percentage is from cinders. Exhibit IV-7 illustrates the percentage of on-road mobile emissions by area. Exhibit IV-7: Percentage of Emissions from On-road Mobile SourcesArea NameYear of InventoryPM-10 Presque Isle (Maine)199461* Sheridan (Wyoming)1988N/A Mammoth Lake (California)1988Less than 1 Owens Valley (California)1995Less than 1 Searless Valley (California)N/ALess than 1 Mono Basin (California)N/ALess than 1 Sandpoint (Idaho)19943 Pinehurst (Idaho)19882 Lake County (Oregon)N/AN/A Grants Pass (Oregon)198610 LaGrande (Oregon)19865 Notes:N/A = not available

An interview with Presque Isle revealed problems with the 1994 measurement, which included road sand with on-road mobile sources. The percentage of direct emissions from on-road mobile sources is 7.3 percent. However, several areas listed TCMs, shown in Exhibit IV-8. Exhibit IV-8: Transportation Control MeasuresArea NameTCM Cited Presque Isle (Maine)Removing de-icing and anti-icing materials as soon

as possible from roads. Sheridan (Wyoming)Limiting sand and gravel usage and removing them as

soon as possible from a road after snow. Mammoth Lake (California)Restricting parking, increasing transit ridership, and reducing vehicle traffic. Owens Valley (California)None. Searless Valley (California)None. Mono Basin (California)None. Sandpoint (Idaho)Aggressive street sweeping program and anti skid material
specs. Pinehurst (Idaho)None. Lake County (Oregon)Paving gravel roads. Grants Pass (Oregon)None. LaGrande (Oregon)Controlling fugitive dust (winter road sanding, paving gravel streets, etc.).

Interestingly, the most frequently listed TCMs do not fit the commonly used definition of TCM, which includes actions to adjust traffic patterns or reduce vehicle use. Only three of the 11 areas that responded to the survey noted effective federal measures relating to VMT and tailpipe emissions, as reflected in Exhibit IV-9. Exhibit IV-9: Effective Federal Measures for Attaining or Maintaining Air Quality StandardsArea NameMeasures Cited Presque Isle (Maine)None. Sheridan (Wyoming)None. Mammoth Lake (California)VMT cap, phase out of non-certified wood stoves and fireplaces, mandatory wood burning curtailment. Owens Valley (California)N/A Searless Valley (California)N/A Mono Basin (California)N/A Sandpoint (Idaho)Tier II, CAFE standards, OBD etc. -- improving fuel economy and emission rates. Pinehurst (Idaho)Tier II, CAFE standards, OBD etc. -- improving fueleconomy and emission rates. Lake County (Oregon)CMAQ funds used to pave gravel roads (to reduce transportation-related fugitive dust). Grants Pass (Oregon)N/A LaGrande (Oregon)Reducing transportation-related fugitive dust by paving gravel roads. Notes:N/A = not available

Only three PM-10 nonattainment areas reported having ever made a conformity determination, and only one of these areas has done so within the last five years. All three cited the build/no build test in their latest determination, and two of the three noted the build/no build test in years beyond the timeframe of their SIP. Exhibit IV-10 summarizes the responses. Exhibit IV-10: Conformity TestsAreaLast DeterminationConformity in YearsBeyond Timeframe of SIP Budget testLess than 1990 testBuild/no build testNo-greater-than 1990 testBudget testLess than 1990 testBuild/no build testNo-greater-than 1990 testDemonstration using air quality modeling Sandpoint (Idaho) X X Pinehurst (Idaho) X X Grants Pass (Oregon) XX X Total Number 13 2 1

Only Sandpoint reported having a non-exempt transportation project in the past five years. It determined conformity for its project in 2000. Comments on the Process According to a Division FHWA Transportation Engineer who completed the
survey: Rural areas by their very nature (small, sparsely populated, relatively low traffic volumes and densities, and infrequent capacity expansion projects) should have minimal transportation related air quality problems. To the extent that the above generalization is accurate, it begs the question of why a regional level analysis is currently expected for such areas. Perhaps consideration should be given to evaluating, and as necessary, analyzing such areas at the project level, only. Since there is no PM-10 modeling process, this would effectively limit the analysis to CO. According to a state environmental agency transportation specialist who completed the survey: One of the biggest holes in modeling transportation emissions for conformity purposes is VMT and speeds. Transportation and Air Quality agencies often must rely on minimal or spotty data to base speed and VMT assumptions. As

an example, the statewide transportation emissions inventory is based on VMT extrapolated from Federal Highways Statistics. The conformity process and the quality of associated air quality analysis would be vastly improved with consistent and reliable VMT and speed data. Rural areas would greatly benefit if FHWA could expand the monitoring done for the Federal Highways Statistics. Back to Table of Contents

Appendix A: Survey

This appendix contains a copy of the survey used to collect the data for this report. FHWA Transportation/Air Quality Issues in Rural Areas Background FHWA is interested in assessing how isolated rural areas that have been designated non-attainment or maintenance for one or more air quality standards are addressing their transportation conformity related issues. FHWA has assigned Dye Management Group, Inc. the task of identifying and describing current practices. FHWA and EPA are considering developing additional guidance on how
to conduct conformity determinations in these areas, so your responses are important to us. As part of this effort, we are seeking your collaboration to participate in a survey. The three main questions we hope to answer through this survey are: Why are these isolated rural areas in non-attainment or maintenance (i.e., what are the main sources contributing to their air quality problems)? Who is involved in the transportation planning and conformity processes for these isolated rural areas and what are each agency's roles? How are these air quality problems being addressed by the different agencies involved? The attached questionnaire, a product of the substantial collaboration from theFederal Highway Administration (FHWA) and Environmental Protection Agency

(EPA), was designed to gather information on the identified issues of interest. For each isolated rural area a questionnaire will be sent to the corresponding
state department of transportation (DOT), the state and/or local air agency, the Division FHWA and Regional EPA offices, and any other applicable state or local
agency. Rural Areas Defined By definition, an isolated rural non-attainment or maintenance area is not part of, or contiguous to, a metropolitan area having a population of 50,000 or

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

FHWA Transportation/Air Quality in Rural Areas Questionnaire Name: _______________________________________________________________ Position: _____________________________________________________________ Organization: _________________________________________________________ Telephone: __________________ E-mail:___________________________________ General [Area Name] has been designated as a [nonattainment area or maintenance area] for [ozone, carbon monoxide, or particulate matter-10]. Please verify that the designation(s) and pollutant(s) listed above for this area is/are correct. If not accurate please correct as appropriate.

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______ State Implementation Plan and Air Quality Does this area have a SIP? ______Yes ______ No If this area has a SIP, what control measures in the SIP help the area show attainment?

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

Year of Inventory = ___________ Units of Inventory = ___________ Sector:Inventory: On-road mobile sources_______________________________Others? Please list._______________________________

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

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

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

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______ How is VMT information determined for this isolated rural area?

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______ Is speed information determined? If so, how?

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

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______ Have the difficulties in demonstrating conformity ever resulted in the

area not being able to implement/approve a new transportation project? ___________ Yes ___________No If yes, for how long was this project delayed? (If a project has been delayed on more than one occasion, please specify how long for each delayed project.)

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______ Transportation Planning and Conformity Is this isolated rural area implementing any transportation control

measures included in the SIP to address its air quality problem? Yes________ No ________ If so, what is/are the specific transportation control measures that this area is implementing?

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______ Given that before a new Federal non-exempt project can be approved or funded in an isolated rural area, a conformity determination is required. How
many non-exempt transportation projects for this isolated rural area in the past 5 years required FHWA/FTA approval? 2001 ________________________________________ 2000 ________________________________________ 1999 ________________________________________ 1998 ________________________________________ 1997 ________________________________________ Did you determine conformity in any of these years: 1997 Yes_____________No, _______ if no, why not?

___________________________________ 1998 Yes_____________No, _______ if no, why not?___________________________________

1999 Yes_____________No, _______ if no, why not?

___________________________________ 2000 Yes_____________No, _______ if no, why not?

___________________________________ 2001 Yes_____________No, _______ if no, why not?

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

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

_______ This area does not have a SIP

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

_______ Attainment SIP.

What are the budget years, if budgets exist:

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_______ 15 percent SIP.

What are the budget years, if budgets exist:

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_______ 9 percent rate of progress SIP.

What are the budget years, if budgets exist:

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_______ Maintenance Plan.

What are the budget years, if budgets exist:

__________________________ Which of the following conformity test(s) did the isolated rural area use in its last conformity determination? Please mark all that apply. _______ Budget test. _______ Less than 1990 test. _______ Build/no-build test. _______ No-greater-than 1990 test. Which method below is being used to determine conformity in the years beyond the timeframe of the SIP? _______ Budget test. _______ Build/no-build test. _______ Less than 1990 test. _______ No-greater-than 1990 test. _______ Demonstration using air quality modeling (same modeling used in the SIP). What agency runs the emissions analysis for this isolated rural area? What agency prepares the travel estimates (e.g., estimating VMT)?

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

_________________________________________ Dates on which these conformity determinations were made:

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

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______ Has this isolated rural area ever had difficulty demonstrating conformity (i.e., they cold not pass their conformity test as listed above)? If

answer to this question is No, please skip to question 3-l below. ______ Yes _______ No For what analysis years did this area have difficulty demonstrating conformity?

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______ What was the nature of this area's conformity difficulties? Please check all that apply. ________ Population grew faster than anticipated. ________ New data/information on fleet resulted in higher emissions. ________ Control measures ended because of a sunset date. If yes, which measures?

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

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______ Other? Please explain briefly:

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______ Why was this area not able to meet the SIP budget(s)? Please check all that apply. ________ SIP was based on an earlier version of emissions factor model. ________ SIP was based on older data that was updated for the conformity determination. ________ Area was experiencing unanticipated growth. ________ A control measure not being implemented; which measure?

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______ Other? Please explain.

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______ If this area has experienced conformity difficulties, have the difficulties been successfully addressed and resolved? ______ Yes ______ No. If yes, what factors contributed to this outcome? (Choose all that apply from the two categories below: Revision to SIP and Revisions Transportation Projects.) Revision to SIP _________ Identifying a safety margin and applying some or all of it to the budget. _________ Adding transportation control measures in the SIP. Which measures?

_________ Adding emission reduction control measures. Which measures?

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______ _________ Updating the budget with new data (e.g., population, employment, etc.). _________ Updating the budget with a new emissions factor model. _________ Other? Please briefly explain:

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______ Revision to Transportation Projects _________ Eliminating, changing scope of or delaying transportation projects. _________ Adding transportation control strategies (but will not be included in the SIP). Which strategies?

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_______________ Adding other emissions reduction measures (not already in the

SIP). Which measures?

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

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______ _________ Other? Please briefly explain:

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

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______ Interagency Consultation Who actually does the modeling and/or approves the conformity determination for the isolated rural areas?

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

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

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

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

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

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

_______ Other? Please explain other consultation procedures applicable to this

area.

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______ Has the consultation process helped resolve difficulties related to demonstrating conformity for a new project? _____ Yes _____ No Why or why not? Please briefly explain:

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______ Other Comments on the Process

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