METROPOLITAN WASHINGTON COUNCIL OF GOVERNMENTS
NATIONAL CAPITAL REGION TRANSPORTATION PLANNING BOARD
777 North Capitol Street, NE
Washington, DC 20002-4226
July 17, 2002
Honorable Jim Jeffords
Committee on Environment and Public Works
United States Senate
Washington, DC 20510-6175
Honorable Bob Smith
Committee on Environment and Public Works
United States Senate
Washington, DC 20510-6175
Dear Senator Jeffords and Senator Smith:
Thank you for your letter of July 3, 2002 requesting information about transportation and air quality planning efforts in the metropolitan Washington region. I appreciate the opportunity to contribute to the deliberations of the Senate Environment and Public Works Committee on this subject in the context of the TEA-21 reauthorization process.
Air quality planning for the metropolitan Washington non-attainment area is conducted by the Metropolitan Washington Air Quality Committee (MWAQC), which includes representatives of the local governments in the non-attainment area, the state air agencies, and the state transportation agencies. Air quality plans developed by MWAQC are incorporated into the State Implementation Plans (SIPs) submitted to the Environmental Protection Agency (EPA) by the District of Columbia, the State of Maryland, and the Commonwealth of Virginia. Transportation planning in the metropolitan Washington region is conducted by the National Capital Region Transportation Planning Board (TPB), the Metropolitan Planning Organization (MPO) for the area, which includes representatives of the local governments in the metropolitan area, the state transportation agencies, the Washington Metropolitan Area Transit Authority (WMATA), the Metropolitan Washington Airports Authority (MWAA), and federal agencies.
MWAQC and TPB are staffed respectively by the Department of Environmental Programs and the Department of Transportation Planning of the Metropolitan Washington Council of Governments (MWCOG), and several policy officials serve on both bodies. Close policy and staff coordination between MWAQC and TPB provided within the MWCOG structure has been critical in helping the Washington region to address linkages between air quality and transportation planning, and in particular to meet the transportation conformity requirements of the Clean Air Act. Despite this close coordination, however, we have experienced some significant challenges in carrying out our transportation and air quality planning activities, and we welcome the in-depth interest of the Senate Environment and Public Works Committee that is reflected in the questions you have posed. The responses I have provided to your questions have been coordinated with local government officials on MWAQC and TPB as well as with representatives of the state transportation and air agencies.
· Describe how the different schedules for the SIP, TIP, conformity, etc. and the impacts of data changes on out year emissions affect your ability to develop effective and timely transportation and air quality plans. Provide a time-line or narrative description of your various schedules.
· What impact have these schedules had on investments in highway and safety projects, construction costs, and air quality projects and activities.
· What has been your experience coordinating your SIP and conformity processes with SIP submittals or updates?
· State SIPs are developed to meet a current attainment year of 2005, the regional constrained long range transportation plan (CLRP) has a horizon year of 2025, and the current six-year TIP is for fiscal years 2003-2008. Mobile emissions budgets for VOC and NOx are set for 2005 as part of the attainment plan. Higher VOC and lower NOx budgets have been developed for 2015 and 2020 using VOC/NOx substitution procedures approved by EPA. The CLRP is updated every three years (1997, 2000, 2003, etc.), the six-year TIP is typically updated every year, and the SIPs are updated as needed to meet EPA and regional air quality requirements.
· Changes in input data on vehicle registration and vehicles miles of travel by vehicle type in the FY2002-2007 TIP update cycle caused projected mobile NOx emissions to increase by 8 tons per day in 2005. No updates were undertaken to
the state SIPs to reflect these changes in vehicle registration and vehicle miles of travel input data. Consequently, the entire 8 ton per day increase in NOx emissions had to be addressed within the transportation conformity process, using mobile emissions budgets which had been set in the SIPs using earlier input data. In order to provide time to address this difficult issue, proposed TIP updates had to be deferred for a year and were subsequently included in the FY2003-2008 TIP cycle. While there has not yet been a TIP lapse (since the approved FY2001-2006 TIP continues to be valid until January of 2003), there have been some delays in incorporating new projects into the CLRP and TIP.
· Synchronizing SIP updates with CLRP/TIP and conformity schedules requires extensive communication, coordination, and cooperation between MWAQC, TPB, EPA, and the Federal Highway Administration (FHWA) and the Federal Transit Administration (FTA). CLRP/TIP conformity and SIP update schedules as currently prescribed in federal regulations and as administered by FHWA, FTA, and EPA do not in themselves ensure synchronized processes. Regulatory changes are needed to improve coordination between these schedules; to place SIP planning and conformity on the same time frames (with out-years of, say, 10 years beyond the attainment date); and to require that key input data used in the SIP to establish mobile budgets continue to be used for conformity until the SIP is revised.
MOBILE 6 Versus MOBILE5 Projections
· Compare and contrast your MOBILE5 and MOBILE6 emission projections.
· How does the increase in near term emissions (though 2010) from MOBILE6 affect your conformity status?
· How will your air quality planning process take the new MOBILE6 into account, and will the SIP be updated before or after the new MOBILE6 projections?
· Will the new 8 hour NAAQS likely lead to an increase or decrease in your vehicle emissions budget?
· The Washington metropolitan area has been working on preparing inputs for the Mobile6 model, but has not yet developed emissions projections using the model. Consequently, we are unable to provide any comparisons to Mobile 5 projections.
· We do not yet know how emissions projections from Mobile 6 will affect our conformity status.
· We are planning to update our regional air quality plan and our state SIPs to reflect Mobile6 emissions projections.
· We do not yet know what the effect of the new 8 hour NAAQS will be on our vehicle emissions budgets.
· What additional existing controls could be implemented in your area to significantly reduce vehicle emissions, e.g., inspection and maintenance, reformulated fuels, diesel retrofit, TCMs?
· Would these controls be sufficient to address the potential increase in emissions projected under MOBILE6?
· In seeking measures to mitigate projected excess NOx emissions from mobile sources in 2005, the TPB has developed and analyzed an extensive list of Transportation Emission Reduction Measures (TERMs) which could provide additional reductions in mobile emissions. These measures and associated analyses of potential costs and effectiveness in terms of emissions reductions are documented in a report entitled “Transportation Emissions Reduction Measures (TERMs) Under Consideration for Conformity of the 2002 Constrained Long Range Plan (CLRP) and FY2003-2008 Transportation Improvement Program (TIP),” June 28, 2002. In terms of cost-effectiveness, the most promising additional measures for NOx reductions appear to be diesel fuel additives, diesel engine replacements, and other potential diesel retrofit measures. These measures appear to be in the range of $2,000 to $10,000 per ton in cost-effectiveness, and have the added advantage of providing substantial reductions in particulates. Since it will be several years before the EPA heavy-duty diesel regulations will result in significant changes in the diesel fleet, measures aimed at reducing emissions from existing diesel engines appear to be very promising in the short time-frames addressed in air quality attainment plans. Measures aimed at promoting more telecommuting and more effective enforcement of speed limits on freeways and other high speed facilities might also have significant short-term benefits.
· As noted earlier, the metropolitan Washington region is still developing inputs for the Mobile 6 model, and we do not yet know how Mobile 6 will affect our emissions projections.
· What role do TCMs play in helping to meet attainment? Please list the TCMs and CMAQ projects in your plan, and the associated “off” or “on” model emission reduction credits for each.
· What percentage of total emission reductions do they represent?
· Are there CMAQ projects in your plan for which you have not applied any on or off model emissions reductions?
· Transportation Control Measures (TCMs) play a very small role in the regional air quality attainment plan, accounting for only 0.2 tons per day of VOC reductions and 0.4 tons per day of NOx reductions in 2005. As you know, once TCMs are included in SIPs they can be changed only through a lengthy SIP amendment process. Because of this lack of flexibility, the only TCMs included in the Washington area SIPs are TCMs associated with capital projects that have already been completed. Such measures include park-and-ride lots, bus and rail transit vehicle replacements, and bicycle facilities. By comparison, emissions reductions of around 4.5 tons per day of VOC and 7.7 tons per day of NOx are being achieved through Transportation Emission Reductions Measures (TERMs) which are incorporated into the CLRP and annual TIP updates as they are needed to meet conformity requirements. These latter measures include employer outreach programs to promote increased carpooling and van pooling, transit use and telecommuting, CNG buses, and bicycle facilities. Should any of these “TERMs” not meet anticipated emissions reductions goals, new or revised TERMs can be developed and implemented through the CLRP and TIP update process, without requiring amendments to the SIPs.
· TCMs and TERMS collectively provide 4.7 tons per day of VOC reductions and 8.1 tons per day of NOx reductions in 2005. Of these totals, TCMs account for 4.3 percent of the VOC reductions and 4.9 percent of the NOx reductions.
· Emissions reductions credits are taken for all CMAQ projects included in the CLRP and TIP as part of meeting conformity requirements.
Impacts of Conformity Lapse
· If your area has experienced a conformity lapse, describe the effect this has had on transportation and air quality planning, funding process, preconstruction, and construction.
· When projects were reactivated, after USDOT approved your conformity determination, what impact did this have on funding, project completion dates, personnel, renegotiation of contracts, updating old information, etc.
· What impact did the March 1999 U.S. Court of Appeals decision to eliminate the EPA “grandfather” provision from the conformity regulations have on your transportation investments?
· The metropolitan Washington area has not experienced a conformity lapse, and consequently has not had to address any of the three issues raised above.
· How has conformity analysis helped improve the quality of estimates of motor vehicle emissions for SIPs to better protect public health?
· How accurate and consistent have estimates of regional motor vehicle emissions been when compared with each other over time and with actual experience?
· How have official estimates of motor vehicle emissions in your metropolitan region changed over the past 10-20 years and how well have they tracked actual emissions in years past?
· Conformity analysis requirements have focused attention on key transportation and land use variables that can significantly affect the levels of motor vehicle emissions, and provided a better understanding of the relative importance of these variables for policy-makers and the general public. In particular, the increase of 8 tons per day of NOx emissions resulting from changes in input data on vehicle registrations and vehicle miles of travel by vehicle type in metropolitan Washington has highlighted the importance of obtaining accurate data on these vehicle inputs, and on how these inputs may be changing through time.
Substantially increased planning resources need to be devoted to improving data collection procedures for these vehicle fleet variables, and to analyzing measures
such as diesel fuel additives that can produce significant reductions in emissions from high-emitting vehicle classes.
· The greatest challenges in maintaining consistency in estimates of motor vehicle emissions over time have been related to the vehicle fleet mix inputs discussed
above. While land use and transportation system inputs generally change relatively slowly over time and are relatively easy to track, changes in fleet mix have been occurring rather rapidly and have been difficult to track accurately with current data collection procedures. Changes in these data collection procedures have resulted in significant changes to fleet mix estimates and to regional emissions estimates, creating challenges in demonstrating conformity to mobile emissions budgets developed using earlier procedures and data. Forecasting changes in vehicle fleet mix and vehicle miles of travel into the future is an additional challenge for planners and policy-makers. With ever-changing vehicle technologies, emissions and fuel economy standards, and consumer preferences, estimating motor vehicle emissions even a few years into the future is subject to considerable uncertainty. This uncertainty compounds as the out-years stretch to 2015, 2020, and 2020.
· Official estimates of motor vehicle emissions have shown steady declines in overall emissions over the past 10-20 years, despite steady growth in vehicle travel in the Washington region. Improvements in emission control and fuel technologies have been largely responsible for these declines. Further substantial reductions in mobile emissions are projected to result from EPA’s TIER II/low sulfur rule and heavy-duty diesel standards over the next 10 to 15 years. While current conformity procedures do not permit anticipation of new technology in emissions calculations, further technological advances such as hydrogen fuel cells are likely to produce additional mobile emissions reductions over the longer term.
· Has conformity analysis been supported by adequate regional transportation analysis models that accurately reflect how changes in highway capacity affect total travel and air pollution emissions?
· How well have your region’s travel models tracked actual experience with growth in vehicle miles of travel (VMT)?
· Please include an indication of how sensitive your/these models are to effects of induced traffic.
· Conformity analysis requirements have placed new demands on regional transportation analysis tools, and prompted us to invest a significant portion of our MPO planning funds into upgrading these models to address emerging conformity issues. The Washington region is currently introducing a new
“Version 2” set of travel models which will significantly enhance our current “Version 1” model capabilities. Continuing development and upgrading of these models is anticipated over the coming years, placing continuing demands on our planning resources. We believe that we have been keeping pace with the “state-of-the-practice” in regional travel modeling, and we are continuing to introduce “state-of-the-art” improvements as they are developed and validated. The models have been used to assess the impacts on travel and air emissions of changes in highway, transit, telecommuting and other transportation programs, and have produced results that policy-makers find useful and credible.
· We regularly compare vehicle miles of travel (VMT) estimates produced by our regional travel models with observed VMT collected through FHWA’s Highway Performance Monitoring System (HPMS), and provide reports to EPA on these comparisons. My most recent letter to EPA, dated April 23, 2002, transmitted regional comparisons of estimated versus observed data for 1997, 1998, 1999 and partial data for 2000. These comparisons showed that the results of the regional travel modeling process track quite well with observed VMT data.
· In response to a request by the TPB, we recently conducted an extensive study of the concept of induced travel and how it is addressed by our regional travel models. The study, which is available on our web site at www.mwcog.org, concluded that all of the significant aspects of induced travel are captured in our modeling process, although induced travel is not generally broken out from other changes in travel behavior (such as travel that is diverted from one route to another by a highway improvement.)
I hope these responses will be helpful to the Committee as it continues its deliberations on these important issues. I would be pleased to provide any additional information you may require. I can be reached at 202-962-3310 or by e-mail at email@example.com.
Ronald F. Kirby
Director, Department of