· Describe how the different schedules for the SIP, TIP- conformity, etc., and the impacts of date changes on out year emissions affect your ability to develop effective and timely transportation and air quality plans.
Southern California is one of many areas in the nation that is facing a mismatch between air quality planning and transportation planning schedules. This mismatch is important because it could interrupt the flow of millions of federal transportation dollars to the region. The question posed has been answered in the following two parts; mismatch in the schedules and frequency of Regional Transportation Plan (RTP) and State Implementation Plan (SIP) updates; and mismatch between the RTP and SIP planning horizon requirements and its affect on out-year emissions.
Mismatch in the Schedule and Frequency of RTP and SIP Updates
In non-attainment and maintenance areas, the conformity of the RTPs must be re-determined at least every three years. However, there is no federal requirement for a regular or frequent SIP update. This has created a situation where RTPs are updated regularly while SIPs are updated on a discretionary basis inconsistent with the RTP process.
An RTP provides inputs (planning assumptions, i.e. socio-economic data and transportation activity data) to the SIP development process. While a SIP provides the set of constraints (e.g., emissions budgets and TCMs) for the RTP. The development of these two documents should be sequential and cumulative, not concurrent and independent.
Both the RTP and the SIP are required to use the Latest Planning Assumptions, as stipulated by the Federal agencies, whenever they are updated. The Latest Planning Assumptions include the most recent sociodemographic and vehicle activity data (e.g., population distributions, vehicle age and fleet mix). Since the SIPs are updated much less frequently than the RTPs, the planning assumptions in the SIPs tend to be much older than those in the RTPs.
In the SCAG region, there are 11 non-attainment areas, with 13 associated SIPs stipulating emissions budgets for transportation conformity. At the present time, there are only five applicable ozone SIPs and one applicable NOx SIP in place. However, all of them were developed and based on planning assumptions that are now seven to ten years old. As such, they are too obsolete for pertinent conformity analysis.
A related factor is the Federal requirement that any update of a SIP, with its associated new emissions budgets, triggers an 18-month clock within which all relevant RTPs must re-demonstrate conformity using these new emission budgets. This requirement, together with the mismatch in frequency of RTP and SIP updates discussed above, results in debilitating procedural inconsistencies.
Mismatch Between the RTP and SIP Planning Horizon Requirements and Impacts on Out Year Emissions
Federal regulations require at least a 20-year planning horizon for the development of any RTP. However, SIPs are only required to address the time period up to the attainment or maintenance date for the relevant area. Thus, SCAG’s 2001 RTP extends up to the year 2025, and the upcoming 2004 RTP will extend up to the year 2030. However, and as one example, the 1-hour Ozone SIP for the South Coast Air Basin (SCAB) in the SCAG region is only required to consider the period preceding its stipulated attainment year of 2010. As a consequence, there is always a gap of about 15 to 20 years between SIP and RTP planning horizons. The complex interplay of socio-demographic projections and emission budgets between the SIP and the RTP processes means that there is almost always the potential of a procedural conformity lapse.
Additionally, under the current conformity rule, all transportation agencies must demonstrate conformity up to the last year of the RTP. However, the applicable emissions budgets contained in the relevant SIP, and which are only required to extend up to the attainment year or last year of maintenance, establish a ceiling for conformity analysis. Thus, the RTP and Regional Transportation Improvement Program (RTIP) emission budgets for these future years—i.e., beyond the attainment year or the last maintenance year—can not exceed this SIP-established ceiling. As a result, demonstrating attainment for the out-years beyond the attainment year of the last year of maintenance becomes problematic for all MPOs.
This is particularly a problem for PM10 non-attainment or maintenance areas, as there is a direct relationship between population growth, increases in annual vehicle miles traveled (VMT), and annual PM10 (particulate matter) emissions. Generally, and because both of these metrics trend upward through time, both VMT and PM10 emissions tend to increase into these future years. For example, the current PM10 attainment year for the SCAB and for the Coachella Valley portion of the Salton Sea Air Basin (SSAB) is 2006. The gap between this PM10 attainment year and the stipulated planning horizon year ranges from 19 to 24 years (for the 2001 RTP and the 2004 RTP, respectively). In the absence of realistic PM10 emissions budgets for these future years, it is difficult, if not impossible, to demonstrate conformity beyond the attainment year of 2006.
· Provide a time-line or narrative description of your various schedules.
A timeline, which incorporates both the air quality and transportation planning schedules for the SCAG region, is attached to the end of this document for your review. SCAG’s next RTIP comes due on October 6, 2002 and the next RTP comes due on June 8, 2004. In order to avoid an adverse impact on conformity, SCAG is working closely with the local, state and federal air agencies to ensure the timely approval of an adequate emissions budget.
· What impact have these schedules had on investments in highway and safety projects, construction costs, and air quality projects and activities?
As mentioned, a real potential exists for a conformity lapse due to the mismatch of air quality and transportation planning schedules, and the SCAG region will continue to face this constant threat. However, so far, the mismatch in schedules has not had an impact on investments in highway and safety projects, construction costs and air quality projects and activities. During a conformity lapse only certain projects can be implemented, such as: safety-related projects; those which are regional emission-neutral (known as exempt projects); and TCM projects. Generally, no capacity enhancement projects (such as all-purpose-lane highways) can be implemented during a conformity lapse. (The SCAG region experienced short-term, mild conformity lapses due to reasons beyond the mismatch of schedules during 1998 and 2001. These lapses are described in the last section of this document).
· What has been your experience coordinating your SIP and conformity processes with SIP submittals or updates?
A few months ago, in California, all MPOs and the State were facing a potential conformity lapse for all RTIPs and some RTPs. The transportation agencies were asked to use the most recent vehicle data to demonstrate conformity for the RTP and RTIPs. However, the Federal regulations also require that the RTPs and RTIPs conform to the applicable SIPs, which are currently based on old data.
The California situation has been temporarily resolved through inter-agency cooperation. The California Air Resources Board (CARB) and the local air agencies have committed to update all SIPs between late this year and late 2003, and, in return, the United States Environmental Protection Agency (USEPA) has agreed to process the emissions budgets based on this provisional schedule. In addition, the Federal Highway Administration (FHWA) has issued a letter permitting a limited use of the old version of the mobile source emissions inventory model, EMFAC7F and 7G, and its associated data through the end of the current calendar year of 2002. Therefore, the six-county SCAG region will be in what amounts to a conformity lockdown from January 1, 2003 until June 8, 2004, when the 2004 RTP should be in place as the region's federally approved and conforming RTP. This conformity lockdown means that no changes requiring conformity analysis and finding can be made to any transportation plans during this period. For a region as economically dynamic as Southern California, this is an unreasonable constraint.
To illustrate this SIP-related problem, the conformity lockdown situation described above will begin to have effects in the SCAB portion of the SCAG region as early as November 2002. With SCAG’s concurrence, the air agencies have had to re-submit their 1997 PM10 SIP in order to request a needed extension of the attainment year from 2001 to 2006. To extend the attainment date, USEPA will approve this PM10 SIP in mid-November, at which time the associated emission budget becomes the mandatory basis for all conformity analyses. However, this PM10 SIP is based on obsolete emission budgets that can not, realistically, be used for present-year conformity determinations.
In the SCAG region, the situation is further complicated by the fact that some air basins have been designated non-attainment for more than one criteria pollutant. For instance, the SCAB is non-attainment for four pollutants: ozone (O3), carbon monoxide (CO), nitrogen dioxide (NO2), and particulate matter less than 10 microns in aerodynamic diameter (PM10). Therefore, all pertinent SIPs for this air basin must be prepared on the same schedule, otherwise risking a conformity lapse.
The state of California utilizes its own mobile source emissions inventory model, known as EMFAC, rather than USEPA’s model, Mobile. CARB has long maintained a California specific model, which represents conditions unique to California. Therefore we have addressed the questions specifically to EMFAC. However, we do face a similar situation as the rest of the nation, as there is a projected emissions increase between model versions, as described below.
· Compare and contrast your EMFAC7F/7G and EMFAC2000/2001 emission projections.
EMFAC2001 (Version 2.08) will soon be the working version of the motor vehicle emissions inventory model. USEPA intends to approve this model for new SIP development purposes on a statewide basis in the near future. This new EMFAC version replaces the previous model versions: EMFAC2000 (which was approved on a limited basis for SIP development in the San Francisco Bay area only) and EMFAC7F and 7G. In California, most of the current SIPs and their associated emission budgets are based on EMFAC7F or 7G, which use seven to 10 year old data. As previously mentioned, Federal agencies require that conformity determinations be based on the Latest Planning Assumptions, which includes the most recent socio-demographic and vehicle activity data (e.g., population distributions, vehicle age, and fleet mix). Effective January 1, 2003, all RTPs and RTIPs in the State of California will be required to be based on the most recent EMFAC2001 model, which incorporates these Latest Planning Assumptions.
EMFAC2000 was under development for five years and represented a complete rewrite of computer code and algorithms. EMFAC2000 represents a significant change to the existing on-road motor vehicle emissions inventory as compared to EMFAC7F and 7G. Emission inventories based on EMFAC2000 increase substantially for nearly every category of motor vehicle fleet and for all pollutants, with NOx being somewhat less impacted than reactive organic gases (ROG) and CO. NOx emissions from heavy-duty diesel vehicles have doubled for this vehicle class in year 2000. For light-duty cars and trucks, the calendar year 2000 ROG inventory has increased by 192%, the CO inventory has increased by 204%, while the NOx inventory has increased by a modest 3%. Much of the light-duty vehicle ROG increase is related to the way EMFAC2000 handles evaporative emissions, which increase three-fold when compared to EMFAC7G.
EMFAC2001 (Version 2.08) is one of a series of minor updates planned for the on-road model, and reflects clean-up items and incorporation of the impacts of new emission standards (e.g., federal Tier 2 standards) and new data (e.g., travel activity data); there are no major changes to algorithms or structure. It is unclear how the proposed changes will impact overall inventory estimates, but it appears that EMFAC2001 will have lower emissions when compared to EMFAC2000, especially for calendar years 2010 and beyond. However, EMFAC2001 will certainly have higher emissions than the current EMFAC7F and 7G models
· How does the increase in near term emissions (through 2010) from EMFAC2001 affect your conformity status?
It is unclear how the increase in near term emissions from EMFAC2001 will affect the conformity status of the SCAG region. There have been considerable delays in the development of the SIPs for the SCAG region, and hence there are no emission budgets established at this time.
· How will your air quality planning process take the new EMFAC2001 into account, and will the SIP be updated before or after the new EMFAC2001 projections?
The 2003 SIPs for the SCAG region will be updated subsequent to the finalization of EMFAC2001. As mentioned previously, USEPA intends to approve EMFAC2001 for SIP development purposes on a statewide basis in the near future. The emission budgets of the SIPs for the SCAG region will be based on EMFAC2001, which are scheduled to be approved by EPA in mid-2003. Subsequently, SCAG’s 2004 Regional Transportation Plan (RTP), which comes due June 8, 2004, will be based on budgets generated from EMFAC2001. SCAG is working with the respective air agencies to maintain consistency between the SIP and 2004 RTP schedules.
· Will the new 8 hour NAAQS likely lead to an increase or decrease in your vehicle emissions budget?
It is unclear if the new 8 hour NAAQS standards will increase or decrease SCAG’s vehicle emissions budget. Implications of the new 8-hour Ozone NAAQS are currently being assessed by the CARB. USEPA plans to implement the new 8-hour ozone standard and the new PM2.5 standard over the next few years. Implementation of the 8-hour ozone standard will occur in the early part of the TEA-21 reauthorization period, while that of the PM2.5 standard may occur somewhat later. The impacts will probably include conformity requirements for the existing RTPs and RTIPs, and some new areas will need adequate time to prepare to meet these new requirements.
Congress provided a one-year grace period for new areas to demonstrate conformity after the new 8-hour ozone or PM2.5 non-attainment designations are made. One year is not sufficient for transportation agencies to address conformity issues.
· 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?
SCAG has no regulatory authority, and, therefore, does not formulate or administer rules and regulations pertaining to vehicular emission controls. However, a number of additional vehicle emission control measures and related actions which promise air quality benefits are being considered or implemented by regulatory agencies within the region. These include the following measures.
- Improved implementation of Air Quality Investment Program, under the South Coast Air Quality Management District’s (SCAQMD’s) Ridesharing Rule 2202
- Improved implementation of SCAQMD’s Fleet Rules 1186.1/1191-96 – These fleet rules require new garbage trucks, sweepers, buses and airport vehicles to switch to alternative fuels such as natural gas.
- Incentivize use of reformulated fuels (such as biodiesel)
- Controls on truck-idling at goods movement centers (such as the Ports of Los Angeles and Long Beach)
- Urban forestry for heat island mitigation (tree plantation in open-to-sky parking lots and thoroughfares—reduction in evaporative emissions and indirect benefits of evapo-transpiration)
- Use of innovative technologies (e.g., fuel cells, personal transportation devices, photocatalytic VOC- and NOx-reducing chemical coatings such as titanium dioxide, which can be applied to wall surfaces in semi-enclosed areas which see high volumes of vehicular emissions such as parking garages)
· Would these controls be sufficient to address the potential increase in emissions projected under EMFAC2001?
As mentioned previously, emission budgets based on EMFAC2001 have not been established at this time. Therefore, it is unclear if the control measures described above are adequate to offset a potential increase projected under EMFAC2001.
Role of Transportation Control Measures
· 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.
There are 11 non-attainment areas in SCAG’s six-county region, with 13 SIPs associated with them. Only two of the six applicable SIPs contain Transportation Control Measures (TCMs)—the South Coast Air Basin's 1997 Ozone SIP, and the Ventura County portion of the South Central Coast Air Basin's 1994 Ozone SIP.
TCMs in the South Coast 1997 Ozone SIP/AQMP (as amended in 1999):
1. High Occupancy Vehicle (HOV) Improvements
HOV projects and related pricing alternatives and park and ride lots/intermodal facilities.
2. Transit/System Management
The following system management measures improve congestion and reduce emissions:
- Bus, rail, and shuttle transit improvements.
- Bicycle and pedestrian facilities.
- Urban freeway system management improvements.
- Smart Corridors system management programs.
- Railroad consolidation programs (e.g., Alameda Corridor).
- Congestion Management Plan-based demand management strategies.
- County/corridor-wide vanpool programs.
- Telecommunication facilities/satellite work centers.
- Seed money for transportation management associations.
- Transportation Demand Management (TDM) demonstration programs/projects eligible for programming in the RTIP.
3. Information Services
By targeting individuals who travel to and from employment sites and other activity centers (e.g., airports, schools, shopping centers, and special event centers) and providing them with information specifically tailored to facilitate use of alternative travel modes, vehicle travel and the associated emissions can be significantly reduced. Providing information services offers an innovative way of reducing vehicle emissions when combined with facility improvements, service enhancements, product development, extensive education, marketing, and promotion.
Potential actions to reduce congestion and emissions through individual efforts include:
- Promoting multi-modal strategies to maximize all options available to commuters.
- Targeting peak period trips for reduction.
- Marketing and promoting the use of HOV lanes to the general public.
- Marketing and promoting rail lines to the general public.
- Educating the public regarding cost, locations, accessibility, and services available at park and ride lots.
- Promoting and marketing vanpool formation, incentive programs promoting ride-matching through the Internet, and other means of making alternative travel option information more accessible to the general public.
TCM strategies in the Ventura County portion of the South Central Coast Air Basin's 1994 Ozone SIP:
1. Clean Fuel Bus Fleets & Support Facilities
2. Improved Public Transit
3. Bicycle & Pedestrian Facilities
4. Traffic Flow Improvements
SCAG’s Regional Transportation Model generates the vehicle miles traveled (VMT) based on all projects in the system. The regional emissions estimates are the product of the collective action of all strategies (HOV lanes, transit, mixed flow, etc), not just an aggregation of the individual projects and programs, including the TCM projects. It is not possible to allocate specific emission credits for individual TCMs.
All CMAQ program funds are allocated to a variety of projects that meet the CMAQ eligibility criteria (such as HOV lanes, purchase on the alternative fuel buses, signal synchronization, rideshare program, etc.). Some of these projects are regionally significant, e.g., HOV lanes, while some are not, e.g., bicycle parking racks.
All regionally significant projects and programs were included in SCAG’s Regional Transportation Model (RTM) and their regional emissions were calculated directly through the model. No off-model emission reduction credits were claimed.
· What percentage of total emission reductions do they represent?
TCMS for the South Coast 1997 Ozone SIP/AQMP (as amended in 1999)
Emission reductions resulted from the major TCM categories and were calculated for the year 2010 for the SCAB area. They are reflected in the applicable SIP as follows.
No emission reduction benefits were claimed for any of the TCM strategies in the Ventura County portion of the South Central Coast Air Basin's 1994 Ozone SIP:
· Are there CMAQ projects in your plan for which you have not applied any on- or off-model emissions reductions?
Yes. There are two types of CMAQ projects for which no emission reduction credits were applied: 1) small projects, which are not regionally significant and which are not included in SCAG’s RTM (e.g. bike racks), and 2) some technology-based projects, such as alternative fuel infrastructure and the replacement of old buses with new, clean fuel ones. No off-model emission reduction credits were taken for any type of project.
· 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.
Since the publication of the Transportation Conformity Rule in November 1993, SCAG has experienced a conformity lapse three times. However, because none of these lapses in conformity extended for more than two months, in no case was SCAG required to prepare an Interim RTP/RTIP. Each conformity lapse is described below.
- The first conformity lapse occurred in 1998, because SCAG did not complete its 1998 RTP on time. Due to the size and complexity of the federal non-attainment areas contained within the SCAG region, preparation of the RTP—including the required conformity analysis—sometimes took more time than other MPOs. Presently, the completion of one RTP marks the beginning of the next one. It takes more than two years, from the beginning to the federal approval, to complete an RTP in the SCAG region. However, from the Draft RTP stage—i.e., once most of the RTP’s projects, programs, and policies are set—the associated regional emissions analysis, publication of the Draft, public review and comment, public hearing, through SCAG’s submission for federal approval takes at least nine months.
- The next conformity lapse was caused by a non-transportation related development. The U.S. Court of Appeals' March 2, 1999, ruling invalidated the use of submitted emission budgets in conformity findings. SCAG revisited the 1998 RTP and 1998 RTIP in the PM10 non-attainment areas in the region and re-affirmed their original conformity finding by using the build/no-build method for conformity determination.
- The most recent conformity lapse was caused by the USEPA's interpretation of the PM10 construction-related emission analysis. This occurred during the 2001 RTP process; only two PM10 non-attainment areas were affected and the lapse lasted for less than two months.
Due to the short duration of each lapse, SCAG did not survey the transportation project sponsors to determine which projects were halted. However, all constituents were informed of the lapse and its resolution.
· 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.
SCAG’s RTIP has a six-year planning horizon, in compliance with California requirements, and is valued at about $22-24 billion. However, only the first and second fiscal years of each TIP are used in estimating the cost of a conformity lapse. Therefore, between $0.5 and $2 billion of all transportation projects were subject to postponement during the 1998 and the 2001 conformity lapses, respectively. All projects were fully implemented, once the conformity status was reinstated.
· 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?
Due to the fact that, in each instance of conformity lapse, the SCAG region was out of conformity for less than two months, and, hence, no interim RTP was required, the implications of the above decision were not evaluated.