Practices for Project-Level Analyses for Air Quality (2021)

Below is the uncorrected machine-read text of this chapter, intended to provide our own search engines and external engines with highly rich, chapter-representative searchable text of each book. Because it is UNCORRECTED material, please consider the following text as a useful but insufficient proxy for the authoritative book pages.

28 The case examples that follow highlight the wide variety in practice with regard to project-level air quality analyses that exists across the nation. They describe the current status of air quality procedures and issues across the DOTs and how this topic (transportation air quality) is being practiced. They cover DOTs from coast to coast. They also cover DOTs • With detailed and explicit air quality analysis procedures, and DOTs that rely more on institu- tional knowledge and experience, • That have unique methods for screening projects for air quality analysis needs, • That have dedicated air quality staff, as well as DOTs where staff are required to split their time between air quality and other duties (most commonly noise analysis), • Where air quality continues to be an important consideration at the project level, and DOTs where air quality is becoming less important as the state/district ends its transportation conformity requirements, and • That have interesting and unique institutional arrangements with their state/district air quality agency and/or involved MPOs. It was initially intended to include at least one attainment state in the case examples. However, of the attainment state DOTs responding to the survey, none had written air quality analysis procedures and otherwise did not have a particularly deep involvement with air quality matters. This reflected the air quality situation in the state as well as within their organization and capital program. Thus, all the case examples include DOTs with some transportation conformity require- ments that affect their air quality policies and practices. Colorado Colorado DOT has relatively new, detailed project-level air quality guidance (February 2019). It provides information on both NEPA and transportation conformity issues and compliance, and describes the interdependence and differences in analytic needs between the two (Colorado Department of Transportation, 2019). Colorado DOT also can go beyond meeting federal require- ments. It may require a project-level air quality analysis to ensure that the project complies with CDOT’s Environmental Stewardship Guide (Colorado Department of Transportation, 2017), which ensures that the statewide transportation system is “constructed and maintained in an envi- ronmentally responsible, sustainable, and compliant manner.” A feature of the guidance is the requirement for consultants that would like to contract with the agency to meet certain qualifications. The qualifications include specific experience in running MOVES and CAL3QHC, familiarity with appropriate federal- and state-related guidance, and experience in report preparation. Colorado DOT staff report that, although not many project-level air quality analyses are done, they have had to turn away some consultants for not meeting the qualifications. C H A P T E R 4 DOT Case Examples

DOT Case Examples 29   Colorado has a complex transportation conformity situation. It has a large ozone nonattain- ment area and several smaller CO and PM10 maintenance areas. The maintenance areas are typi- cally smaller than the county boundaries. The DOT’s guidance document lays out the process and requirements for meeting transportation conformity in the nonattainment and various maintenance areas, depending on the area, type of project and pollutant of concern. The guidance document does include a description of, and instructions for, use of FHWA’s “Updated Carbon Monoxide Categorical Hot-Spot Finding Memo,” but find that its parameters do not meet the project condi- tions for many of Colorado DOT’s projects. They employ a screening process for CO. The screen is based on present-day emission factors and future peak-hour traffic volumes. For PM analyses, interagency consultation is used to determine if a project is a potential POAQC and a modeling protocol is identified, if needed. Also, potential mitigation measures are identified. Colorado DOT’s guidance concerning MSATs is also very complete. It incorporates FHWA’s Interim Guidance and information from the “Frequently Asked Questions (FAQ) Conducting Quantitative MSAT Analysis for FHWA NEPA Documents” into a unified process to help evaluate Colorado DOT’s projects for potential MSAT analysis needs. The Guidance also includes infor- mation on GHG emission analysis. The treatment of GHGs will depend on the category of envi- ronmental document, with EAs having a qualitative discussion and EISs receiving a quantitative analysis. Colorado DOT has a schedule for consultation and review of their air quality analyses with their state air quality agency. DOT air quality staff reports that the consultation and review process is going well with the requested schedules for review being met. Colorado DOT’s air quality staff works closely with their counterparts in the interagency consultation group, describing and deciding issues that need resolution so that conformity deter- minations and other analyses can proceed in a timely manner. For example, there is consensus that exempt projects and projects of air quality concern need better definition and/or broadening. They encounter project types that may not be clearly identifiable as being in one of the categories. Delaware The Delaware transportation air quality story has features not that different from some other state DOTs. Delaware does not have written air quality analysis procedures or guidance. Instead, they rely on federal guidance and on institutional knowledge at the staff level. It is recognized within the agency that relying on institutional knowledge may have shortcomings, but since a project-level air quality analysis has not been needed in Delaware since the 2008/2009 time frame, other priorities have taken precedence. Nevertheless, it is realized that having written guidance is preferable and it is hoped that this could be accomplished soon. Delaware DOT does consider informal triggers for a project-level analysis based on federal guidance. The level of trucks in the design year or estimated time of completion would determine a need for a project-level hot-spot analysis, and Delaware DOT would use a travel demand model or a microsimulation traffic model to develop inputs for the air quality modeling process. Consul- tant services would be used to run the traffic models and perform the air quality analysis. They do have an on-call consultant contract for NEPA type analyses and would include a project-level air quality analysis should one become necessary. However, they do not expect any upcoming project to trigger a need for an air quality analysis. The air quality responsibilities at Delaware DOT are split along transportation conformity and project-level/NEPA lines in different functional units. Delaware DOT relies on the state air agency for air quality data and development of MOVES input files with updated vehicle registrations and

30 Practices for Project-Level Analyses for Air Quality other inputs that are copied and used for plan and TIP horizon years with vehicle populations and speed bin VMTs created for each future year for each county, as appropriate based on conformity triggers. Related to transportation conformity, the state has three counties; two are nonattainment for ozone and one is in attainment for ozone, but in a complex conformity situation. The attain- ment county was one of the more than 80 counties for which conformity was reinstated due to the South Coast Air Quality District court decision of early 2018. Delaware DOT had to complete a conformity determination for the “attainment county” (against the 2009 latest-available budgets for VOCs and NOx). Each county has an MPO which 1. Manages “regional significance” determinations, 2. Maintains the “project list” of investments by type and horizon year, 3. Conducts public involvement, 4. Provides or conducts inter-agency consultation, and 5. Prepares and submits the relevant conformity documents. However, each county’s conformity experiences are quite different, as suggested by the following details: 1. New Castle County (WILMAPCO MPO) is the northernmost and largest county, on average doing a new conformity analysis 4 out of 5 years. It is ozone nonattainment and PM 2.5 maintenance. 2. Kent County (Dover/Kent MPO) is the county that is in ozone attainment but has to do confor- mity because they are one of the “orphan” South Coast-decision counties. 3. Sussex County (Salisbury/Wicomico MPO), the southernmost county, is ozone nonattainment, but the MPO boundary extends from Maryland and covers only about 10% of the county. The conformity analyses cover the entire county (donut area), not just the MPO. It tends to have few regional project triggers and thus needs conformity on the 4-year “maximum” determination frequency. In all three cases, Delaware DOT conducts (25% in house, 75% consultant) travel demand modeling, MOVES runs, and report preparation in support of the MPOs. One of the MPOs in the state (WILMAPCO) acts as an informal chair of the interagency consultation process. Two of the state’s three MPOs also include counties in Maryland. District of Columbia The District of Columbia DOT (DDOT) has a relatively extensive set of guidance documents related to project-level air quality analysis. This includes the following: 1. Chapter 14 of the DDOT Environmental Manual (2nd Edition), which covers the applicable laws and regulations, the NEPA process and the connection to project-level air quality studies, pollutants of interest, transportation conformity, and the format and content of documentation. 2. A “Hot-Spot Analysis Guide” that includes specific details for performing a hot-spot analysis, whether for transportation conformity or NEPA purposes. It covers data sources, modeling needs, and mitigation measures, among other analysis parameters. 3. An update (2016) to the District’s maintenance status for CO (“Carbon Monoxide Hotspot Analysis Requirement for the Metropolitan Washington Air Quality Region”), explaining that the maintenance period had concluded, and that project-level transportation conformity determinations were no longer necessary. DDOT has worked extensively with the MPO (Metropolitan Washington Council of Govern- ments), which has assisted them with data and analytical tools and has been the main point of

DOT Case Examples 31   contact with the air quality agency. The MPO obtains air quality data and appropriate inputs and shares them with DDOT, as needed, for a project-level analysis. The majority of DDOT’s projects are classified as categorical exclusions (∼99%). Air quality concerns, therefore, are not generally an issue. When an analysis is done, it is typically completed through the use of consultant services and documented in the appropriate NEPA document. Typically, CO analyses are quantitative, while analyses for other pollutants, including GHGs, are qualitative. When doing a project-level analysis, traffic data is provided by different methodologies, depending on the project and the project’s traffic analysis. It is generally assumed that indirect and cumulative effects of projects are included in the traffic analysis. Illinois Illinois, being a larger state, has a number of districts/regions designated to carry out the mission of the agency. This also applies to project-level air quality analysis. The Central Office provides guidance, policy, and direction on project-level air quality analysis, and the Districts are in charge of having an air quality analysis done when one is needed. The Districts determine the scope of work for the analysis and keep track of progress and the results of the analysis. Illinois’ situation is further complicated by the Chicago metropolitan area in which the Chicago Metropolitan Agency for Planning (the MPO) has the responsibility for many transportation issues (including project-level air quality) within that area. The air quality responsibilities at Illinois DOT are split between the planning function, which is responsible for the interagency consultation process and participates in the conformity meet- ings and conference calls, and the highway implementation function, which is responsible for the project-level air quality issues and has developed the work described below. Illinois DOT’s written project-level air quality analysis procedures are geared toward a hot-spot analysis to satisfy a project-level conformity determination. Although in attainment for PM10 and PM2.5, the procedures explain the steps for a hot-spot conformity determination for these pollutants should the attainment situation change. For CO, Illinois DOT uses a tool called COSIM (Carbon Monoxide Screen for Intersection Modeling). Currently version 4.0, COSIM is a Windows-based screening model used for determining worst-case CO concentrations at signalized intersections. The model is the product of research sponsored by the Illinois Transportation Research Center and the University of Illinois Urbana campus. In addition, Illinois DOT has entered into an agreement with their state air quality agency (Illinois Department of Transportation and Illinois Environ- mental Protection Agency Agreement on Microscale Air Quality Assessment for Illinois Depart- ment of Transportation-Sponsored Transportation Projects) on the need for, and method of, CO hot-spot analyses. The agreement recognizes COSIM, which has both a screening component and analysis component. COSIM screens out projects that have traffic volumes below a certain volume on the busiest leg of an intersection or the total average daily traffic for the intersection. This bi-agency agreement is still in place as of the writing of this synthesis report. As indicated above, in the Chicago area, the MPO has its own hot-spot analysis procedure. Regarding MSATs, Illinois DOT follows FHWA guidance for determining a need for an analysis and uses federal guidance in the explanation of the issue and relationship of the project to ambient concentrations. For example, their guidance includes sample language: “The addi- tional travel lanes contemplated as part of the project alternatives will have the effect of moving some traffic closer to nearby homes, schools and businesses; therefore, under each Build Alterna- tive carried forward there may be localized areas where ambient concentrations of MSAT could be higher under certain Build Alternatives than the No Build Alternative. The localized increases in

32 Practices for Project-Level Analyses for Air Quality MSAT concentrations would likely be most pronounced along the expanded roadway sections that would be built at [specify location], under Alternatives [specify], and along [specify route] under Alternatives [specify alternatives].” Illinois staff reports that this type of specific language has not raised concerns with environmental groups or the public. It is not anticipated that the hot-spot analyses procedures, whether for CO or the PM species, will be needed in attainment areas. While recognizing the requirements of NEPA, based on expe- rience and current progress in meeting air quality standards in nonattainment and maintenance areas, air quality concerns are not expected to occur at the project level in attainment areas. Nevada Nevada is in a situation not uncommon in Western states, where in addition to a state air quality agency, there are also regional air quality agencies. Thus, on transportation conformity matters, the state DOT has additional members in the interagency consultation process. Nevada DOT’s project-level air quality guidance is currently being revised, as is the inter- agency conformity process in Nevada. The Nevada DOT air quality staff currently ensures that all Nevada DOT projects meet federal requirements for air quality and documents this within the appropriate environment documents. They also ensure that DOT’s projects are correctly listed in TIPs and the state transportation improvement program (STIP) for conformity purposes and are included in the regional travel demand modeling. In general, Nevada DOT’s approach is to consider a quantitative approach to CO analysis, focusing on the “worst-case” intersection. For PM10 and PM2.5, a qualitative approach is taken, especially since Nevada is in attainment for PM2.5. FHWA guidance is followed for MSATs. Climate change is no longer addressed in environmental documents since the rescission by CEQ of its GHG requirements for projects. The focus within Nevada DOT’s air quality practices is on meeting transportation conformity requirements. It is recognized that an air quality analysis for NEPA purposes is conceivable, but an analysis for NEPA needs is not anticipated. An air quality analysis for NEPA would likely have to be initiated externally, for instance by FHWA, an air agency, or the public. Any analysis that would be undertaken would likely be done by consultant services. At the DOT air quality staff level, the modeling skill set is not in place, training is very difficult to obtain, and other duties (noise analysis) factor into this situation. Air quality staff would use past projects’ levels-of-effort and a project’s scope and anticipated intensity of work to estimate workload for consultant services to perform a project-level air quality analysis. Internal DOT guidance and procedures are used to generally oversee and provide QA of consultant work. Oregon Oregon DOT has developed an updated project-level air quality manual that is complete and has features that appear to be unique to Oregon. The manual covers the common transportation- related air quality pollutants, distinguishes between NEPA and transportation conformity issues, breaks down the conformity status by Oregon DOT’s regions, and includes GHG emissions. The manual also specifies consultant qualifications and contains requirements for an Oregon Indirect Source Construction Permit. Oregon DOT also has an air quality webpage. It includes links to regulations, sample air quality reports, the air quality status of the ODOT STIP, standard state- ments of work, QA/QC guidance, and maps of nonattainment and maintenance areas, among other information.

DOT Case Examples 33   In general, CO analyses are quantitative and qualitative, based on LOS and project descrip- tion, while PM10/PM2.5 are qualitative because most of the maintenance/nonattainment areas have low traffic volumes as well as a low number of projects. Interagency consultation is required in PM10/PM2.5 areas. CO and PM10/PM2.5 analyses are done to satisfy transportation conformity requirements while MSAT and GHG analyses are done to meet NEPA and/or Oregon environ- mental requirements. Oregon DOT is also responsible for conformity determinations in rural nonattainment or maintenance areas but has not had to do one since 2005. Although there is no formal programmatic agreement or screening process in place, close coordination occurs with the state air quality agency, U.S. EPA, FHWA, FTA and relevant MPOs on project analyses. This coordination focuses on MOVES inputs to ensure that the latest model inputs are used in the analysis and for projects located in PM10/PM2.5 areas. Traffic data for a project-level air quality analysis depends on the methodology used for the overall project traffic analysis. On occasion, the traffic data provided for an air quality analysis is only that requested by the analyst (rather than the complete traffic analysis). In the CO analyses, for background concentration data one value is used for the Eugene/Springfield area and a slightly higher value for everywhere else in the state. To meet qualifications, consultants working on project-level air quality analyses must have had MOVES training and have used the model in a previous analysis. Oregon DOT air quality staff report that there have been no issues with this policy, and it seems to be working well. Oregon’s transportation conformity situation is complex, but the interagency consultation process seems to be working well. Oregon has a number of nonattainment and maintenance areas for CO, PM10 and PM2.5. It also has a limited maintenance plans in several areas for CO and PM10. To keep current and provide up-to-date information, Oregon DOT air quality staff strives to update the standard statement of work that the consultants use and the air quality webpage annually. Oregon DOT leads the annual statewide conformity meeting with all involved federal, state, and local agencies and MPOs to address conformity concerns. Oregon has an Indirect Source Construction Permit that is overseen by the state’s air quality agency. An indirect source permit requirement was not reported by any other DOT. The require- ment applies within the boundaries of a CO nonattainment or maintenance area within a city containing a population of 50,000 or more. In addition, a local air quality agency, the Lane Regional Air Protection Agency, which includes Eugene, Oregon, has a separate, more stringent, indirect source permit requirement. In practice, these permits most commonly apply to larger parking facilities. Oregon DOT air quality staff report that this is not an issue for their projects, but they must periodically report to the respective agencies, although the CO maintenance period has long ended. The manual also discusses an emissions burden analysis (also called a mesoscale analysis in some states). This type of analysis has been done for large transportation projects that meet regional transportation needs. This type of analysis is not required but could be considered as an option on a project-by-project basis. Oregon DOT air quality staff report that while this type of analysis is discussed in an appendix in the manual, one has not been performed for a long time. Finally, the manual has an extensive set of examples of air quality report sections, boilerplate language, references, and other information that can be used to provide documentation of an air quality study. All pollutants that may be analyzed have examples provided as well as the break- down for the various nonattainment and maintenance situations in Oregon.