California Transportation Conformity Working Group 
Wednesday, November 3, 2004 
ARB’s 13th and T Street Conference Room 

NOTES 

10:30 Welcome; introductions; housekeeping; agenda review 

10:40 FHWA Updates 

• Update on Status of TEA-21 Reauthorization – Steve Luxenberg 
At this point TEA-21 has an 8-month extension; we really don’t know when congress will 
revisit the proposal. 
• Transportation Conformity Checklists – Steve Luxenberg 
New checklists being done to simplify the checklists. The old ones will be removed from the 
website. We will substitute the new checklists when ready in the RTP guidelines 
• Statewide FSTIP – Jean Mazur 
o Finding : Wade Hobbs (FHWA) / and Abhjit Badge (Caltrans) 
FHWA approved the FSTIP on October 4th, with several conditions & exclusions. 
No amendments can now be developed until the exclusions are resolved. Excluded 
from the finding were Sacramento and Tahoe, Santa Barbara’s Interim TIP was only 
included. The conditions: SHOPP, STIP, and HBRR projects are held for 6 months 
pending added documentation of financial constraint. FTA 5311 funds were 
excluded in 8 areas. The SHOPP conditions have now been satisfied. Abhjit 
responded that the SHOPP projects in the FSTIP can now move forward. Revised 
STIP documentation should be submitted within 1 week. STIPs – MPOs that are 
programmed based on the August, 2004 STIP can be amended as needed to match. 
Caltrans is revising the bridge list and hopes to get it to MPOs by November 23rd. 
We’ll need to make amendments by February 15th. 5311 – overprogramming – 
requesting amendment to reduce to apportionment. 
Questions: Cari Anderson: Will FTA issue a letter regarding the 5311 lifting 
restrictions? Response: Abhjit: We can ask for a letter like the FHWA SHOPP 
project letter. Cari: Will the letter cover all projects or be a partial coverage? 
Response: Abhjit: We will try to get a partial letter from FTA . Question: 
SANDAG: What about pending amendments – how will they be handled? Response: 
Abhjit: Caltrans is holding amendments until we receive a letter from FHWA that we 
can move forward with amendments. Question: Leann: Will changes in financial 
constraint for amendments affect conformity? Response: Wade: It is possible if the 
changes affect projects in the conformity analysis to make financial constraint work. 
Jean: We’d rather areas not to move on conformity analysis until the need for 
amendment is verified – including 8-hr ozone. Wade: Because a significant number 
of planned HBRR supported projects provide for the reconstruction of bridges with 
no additional travel lanes, which are generally exempt projects under the conformity 
regulations, the modification to HBRR supported projects in the FTIPs/FSTIP is less 
likely to result in AQ conformity issues than are, for example, modifications to STIP 
supported projects listed the FTIPs/FSTIP. However, because HBRR program 
eligibility is not restricted to bridge reconstruction projects, each MPO will need to 
consider the FTIP conformity implications of the updated HBRR project list 
currently being developed by Caltrans. 
o Improvements for Next Round: Jean Mazur 
FHWA would like earlier Interagency Consultation to include reviewing conformity 
analysis BEFORE it goes out for public comment. Examples: TX uses a “Preconsensus” 
determination to formally accept assumptions, etc. This might be hard to 
do here due to time constraints but we do have some local examples that are getting 
closer. In the last TIP round for the SJV – a boilerplate document was circulated 
Site. Karina: it was good to have the opportunity to give early comments. Also, 
SCAG, in their last Conformity working group meeting covered their proposed 
method for covering 8-hr standard in a memo and presentation. That handout will be 
posted to the statewide web site. Lastly, MTC sent out a planning assumptions memo 
(will also be posted). FHWA would like to see a list of financially constrained 
projects earlier in the process and more clearly documented in the RTP. 

11:00 Shingle Springs Litigation – Statewide Implications – Janet Brennan 

The case is El Dorado County v. Caltrans, District 3, heard in the Sacramento Superior Court. It 
has been appealed and it has statewide implications. The decision is concerned with demonstrating 
no cause/ or contribution to the State ozone standards. The EIR for the project indicated that the 
measures in SIP are identical to those in the El Dorado state plan (CAP), and found that the project 
would not impede attainment of the state standard. The Court Findings included: 1) while control 
measures are the same, no calculations were included in the CAP for meeting the state standard – 
so there is no way to determine if the standard is being impeded; also, Federal conformity does not 
show that State standard will be met. 2) It is not infeasible or impractical to do an analysis for the 
State. Caltrans responded that it is infeasible to do the calculations because the state standards do 
not have attainment dates, therefore quantification of reductions to meet standards can not be done 
and without that information, it is not possible to develop state conformity budgets. In the 
September ruling – such limitation of CEQA by a regulatory program improperly constricts 
CEQA full disclosure. Caltrans’ statements don’t explain why no methodology was done to show 
impacts on the State standard. Only if methodological issues fully explored can we determine 
whether analysis is reasonable feasible and fully discloses all impacts. On its face, this isn’t that 
difficult a case. Monterey has always required consistency with the State Plan. The plan, however, 
has no attainment date, and no budgets. The case brings up an enormous issue, since will make it 
nearly impossible to say that there is no impact on State O3 standard which is being made more 
stringent. The issue needs attention. How do we address the issue? Legislation? 
A copy of decision electronic will be posted on the Caltran’s statewide web site. . 
Questions: Arnie Sherwood: Any significant project under CEQA will have a significant impact 
even if area will attain Federal standard. We need to describe significant thresholds & mitigation. 
The Federal plan has 20 year conformity window. How does State law address this? Response: 
(Janet) The districts make a good faith effort. ARB or anybody can do an analysis of future State 
attainment status. Monterey’s view of transportation projects is that we can’t look at project 
independent of system as whole – so the APCD has not asked for calculations of individual 
projects and assess if we have accommodated the emissions in State plan. Typically the RTP 
needs to be the place to address the issue, perhaps in the RTP CEQA document. After that it gets 
difficult with out a plan showing when State standard is attained to show project-level consistency. 
El Dorado’s State plan is old and meeting the Federal requirements was more stringent. We need 
more attention to consistency with the State Plan. 
ARB Response: (Dennis) It would be difficult to make a showing. MarcChytillo: the problem is 
because ARB hasn’t required it. But the CCAA has requirements for reducing transportation 
emissions – ARB has tried, but hasn’t reached the point of doing conformity yet. The State plan 
should be good enough to address the court. Response: (Janet): The CCAA required a 5 percent 
reduction over 3yrs – nobody did that – so do all feasible control measures are required but there is 
no requirement for attainment by a date. Budgets were required for transportation planning, early 
on, but that has gone by wayside over the years. (Marc): The CCAA does have attainment dates; 
the 5 percent requirement does not supplant the CCAA dates. All feasible measures are for those 
who can’t meet the dates. 
Doug Eisenger suggested that the Statewide group put together whitepaper on the issues and how 
to deal with it technically. Janet, Dennis and Mike Brady all agreed that the paper can’t be done to 
and develop an approach. We don’t want to have to make a Statement of Overriding 
Considerations for every project. 

11:10 US EPA Updates 

• Recent EPA Actions (Adequacy, plan approvals) – Karina O’Connor 
o Imperial Valley: EPA signed two rules on August 3, 2004: First, prompted by a 
recent Ninth Circuit Court Order, EPA signed a final rule to reclassify the Imperial 
Valley from a moderate to a "serious" PM-10 nonattainment area. Second, EPA 
signed a proposed rule that would find that the Imperial County failed to attain the 
national PM-10 standard for serious nonattainment areas by December 31, 2001. 
These two rules were published in the FR on August 11, 2004, the classification was 
effective 9/10/04. Comments were due on the failure to attain by 9/10/04. 
• .Amendments to Conformity Rule & Litigation – Karina O’Connor 
o PM10/PM2.5 proposal: Focus in the proposal will be on hotspot modeling 
requirements. Schedule: probably won't come out until December with a 30 day 
comment period. Final notice probably won't be drafted until February. 
o Litigation issues on 2004 rule: (ED, Sierra Club, NRDC and TRANSDEF), 
OTAQ has now received the petition for review, focusing in on (1) failure to finalize 
rules for PM2.5 hotspot analyses, (2) provision which allows 8 hour ozone areas to 
use the interim tests instead of budgets, (3) provision that allows conformity 
determination to rely on a previous emissions analysis (minor updates, etc), (4) 
change to latest planning assumptions requirement (changed timing of when the 
latest planning requirements are locked in). There could be additional issues in the 
brief. DOJ has indicated that the certified index was due on October 26th. 
o Guidance: EPA will soon post a summary of July rule by section, Analysis years for 
areas using the budget test for the 8 hour standard (attainment date) 
• 8-hour Implementation Rule / PM2.5 designations – John Kelly 
o 8 hour rule: The 8 hour implementation rule was split into 2 phases: Phase 1 
covered designations and antibacksliding (e.g. how to do classifications /attainment 
dates); Phase 2 is everything else (e.g. NSR, RACT). Phase 2 is now expected to be 
published in the Nov-Dec 04 timeframe. Some litigation on Phase 1 and designations 
has been filed regarding the classificaiton system; antibacksliding, and NSR 
o PM designations / Implementation rule: Expected for release in mid-December, 
likely effective January or February 2005. Only 3 areas in R9 are included, (all in 
CA): San Joaquin Valley, South Coast, and San Diego. The Implementation Rule 
will probably come out during the same time as designations, it will be a proposal; 
the effective date is unknown – sometime later in 05. 
• Conformity SIPs (Guidance) – Karina / John Kelly 
o Upcoming OTAQ guidance: Covers areas with approved Conformity SIPs (Bay 
Area), goes through the 2004 rule section by section since some sections will not 
apply to areas with approved SIPs – only those ones directly related to the court 
proposal or the new standards apply. Some of the rule clarifications and 
streamlining actions (removal of triggers) do not apply. 
o EPA review - John Kelly:We’d like to get you comments before any SIP changes 
are made in response to new rule. We need to first address what has changed since 
the SIPs were submitted and if there are any approvability issues. A new conformity 
SIP clock will be started once the PM proposals are finalized. 
Questions: (1) Cari Anderson: If we know of major changes, should we withdraw the 
SIP submittal? Response: You could withdraw it but you could also resubmit the 
revised sections – which would keep the submittal at EPA. 
(2) Eyvonne Sells: We’ve had a pending item at our board meeting for SIP revisions 
for the last couple of years – should we hold it longer? Response: You should 
probably hold off on board action since you’ll need to revise the rule portion again 
o Saftea proposal – At least one of the proposals may remove the need for the rule 
portion of the conformity SIP – requiring only the consultation portion. 

11:40 Lunch Break 

1:00 ARB General Updates 

• CO Maintenance Plan – Dennis Wade 
The plan will be submitted to EPA shortly. We waited until after October TIP approvals so to 
proceed. Questions: Cari: Will adequacy be determined within 6 months? What about the 
FHWA conditions, could there be impacts related to new budgets? Response: Dennis: The 
original intent was to work with the October 4th date, we need to review potential impacts on 
the next conformity determinations. (Update: the CO plan has now been submitted to EPA, an 
adequacy finding is expected in late March). 
• 8 Hour ROP / Attainment Plans / Coordination- Kurt Karperos 
ARB is developing similar schedules for the northern half of the state (N of Tehachapis) and 
the southern half of the state. Working backwards from the SIP due date, ARB needs to act 
by spring of 2007 for submittal by June 2007 to EPA. Therefore the Air Districts must 
approve the SIPs by early Jan/Feb 2007. So expect to see draft plans developed by fall of 
2006; with emission targets developed by mid-2006. The emission inventory (finalize/grid 
version) needs to be started by mid-2005 and the inventory inputs frozen in mid-2005. 
EMFAC revisions need to finalized by mid-2005; working versions by spring 2006. There is 
an obvious disconnect between the modeling inventories and the final planning inventories if 
new and significantly different activity data occurs in 2006 or 2007, when the SIPs are due. 
So we have inserted a placeholder for critical activity updates around 9/06 we will insert any 
updates available at that time to use in budget. Can’t roll into EMFAC VMT (except via 
WIS), then but could use for budget development. No full solution for disconnect. 
Questions: L Seitz: What form of activity data will be requested & what will be done with the 
information? Will the data will be input into ITN/photochemical model or just BURDEN? 
Response: Doug Thompson: We need VMT by speed group & time of day, for the planning 
inventories which will come from EMFAC but should be consistent with ITN data. Dennis 
Wade: ITN data will usually be the same as in EMFAC. In December timeframe the data 
should certainly be same data. Question: Cari Anderson: Has the letter requesting the data 
gone out yet? Response: Doug Thompson: not yet. Timing – late summer 2006 will be the 
last chance to fold new activity data into budgets before SIP goes out. 
Questions: Will ROP be a part of 2007 submittal? Response: (EPA) Yes. Question: Can ROP 
plans be done earlier? Response (EPA):Yes. Question: Why aren’t they due in 2 years? 
Response: (John Kelly): The details will be in the Phase 2 implementation rules. We had 
originally proposed that the ROP plans be due in June of 2006 but received many negative 
comments so have moved the deadline to 2007 when the attainment plans are due. 
Question: Sara Siwek – Has there been a final decision whether or not to have ROP plans? 
Response: John Kelly: They are not due previous to the attainment demonstrations; all will be 
due in 2007. Question: Sara Siwek: I had thought that Headquarters folks had indicated that 
no decision had been finalized. Response: John Kelly: This will be finalized in the Phase 2 
rule. Question: Eyvonne Sells: Will ARB post the schedule online? 
• Applicable Budgets Spreadsheet – Doug Ito 
Since we have now finished the last round of updating SIPs, we now need to update the 
spreadsheet of budgets online. We’d like to add the links to FR actions. I will send the draft 
spreadsheet for Conformity web site and eventually also post on the ARB site. 
• Statewide Conformity Rule –Dennis Wade 
There has been a few requests for ARB to adopt the verbatim portions of the conformity SIP 
However, there is not currently a push to complete this until the Conformity Rule updates are 
completed and SAFETEA moves further forward. 
Questions: Eyvonne: what is the timeframe for the statewide rule? Response: Dennis Wade: 
We are in holding pending SAFETEA and other rule amends. Do not expect anything before 
mid2005. Question: What is the status of the old submittals? Response: Karina: We are 
currently reviewing the submittals for changes since they have been sent in. If you have 
changed, your SIP, please contact EPA (John Kelly). Question: Eyvonne: SoCo submitted 
it’s SIP awhile ago, what is the status? Response: Karina: It is in our SIP backlog; we need to 
first check to see if you’ve incorporated out previous comments, made any changes, etc. If the 
consultation portion has changed, please contact EPA. 
• CMAQ Methods (PM) - Dennis Wade 
In previous statewide conformity meetings, ARB has been requested to re-examine the ARB 
CMAQ guidance on analysis procedures for PM. Clarification from Cari Anderson: SJV 
would like ARB to develop methods for current CMAQ that are specific to reentrained road 
dust/PM projects which were included in the area’s PM10 plan. The current methods only 
apply to PM from exhaust, however, the SJV effort is focused on fugitive dust. Dennis Wade: 
ARB is willing to do this effort but the timing is indeterminate. 
• Activity Development Updates for SIPs: Doug Thompson 
ARB is currently in an effort to collect the best available activity data. Mark Carlock would 
like the data by 12/1/04, we can not guarantee that the data will be processed for modeling 
and EMFAC2005 if received later but will try. The letter requesting the VMT data will be out 
soon. MPOs and districts should expect to receive the letter the week of November 15th. ARB 
has new internal review procedures that involve both planning and inventory branches. We 
will follow up on activity submittals with questions about these forecasts to assist SIP 
documentation. The APCDs will be partners & discuss the results with the COGs as needed. 
Because many MPOs may wish us to process activity updates prior to SIP adoption, we’ll 
need to develop a more efficient change process (a new batch process/spreadsheet input for 
EMFAC). ARB will propose a different VMT distribution for HDT in EMFAC2005 based on 
Caltrans’ MVSTAFF model. We are looking for input especially from agencies that do their 
own HDT projections. 
Questions: Cari Anderson: What is the final date that you need QA’s data? Response: Doug 
Thompson: The final date will go out with letter. Question: LSeitz: What happening in ITN? 
The ITN/EMFAC data should be consistent. Response: Doug Thompson: For planning, the 
inventory need more years than in ITN. Question: LSeitz: ITN will be used to develop the 
gridded inventories for photochemical modeling correct? Will it also be used for 
development of the budgets? Response: Doug Thompson: We will need DTIM or equiv to 
distribute VMT spatially. Question: LSeitz: Will photochemical modeling be used for SIP? 
Response: Doug Thompson: We have not contemplated that the Airshed model or ITN would 
directly generate emission budgets; we will use summary info from EMFAC/Burden for that. 
Photochemical will be completed, but the budgets will be based on the amount of emission 
reductions needed. Question: LSeitz: What is needed for the new submittal in Dec04? 
Response: DT: New ITN traffic data to drive photochemical modeling and summary activity 
data (VMT by speed group by time period) for next summer’s EMFAC2005 inventory. 
Question: SBCAG: We will submit activity data then ARB will spatially distribute? We 
understand that we will supply loaded network to ITN and Burden. Response: Doug 
Thompson: That is correct. 
Question: Arnie Sherwood: Due to the changes in the truck VMT, it would seem that some 
areas may require changes to their PM SIPs and budgets as well. How is that change being 
coordinated? Response: DT: The need is very possible. South Coast will revisit their PM SIP 
along with development of the 8hr Ozone SIP. Kurt K: SJV must also update their PM SIP in 
2006 – that SIP should incorporate the truck VMT changes. We will be talking with the 
District about these issues. 
1:30 ARB EMFAC Updates 
• EMFAC Workshop & Timing– Dennis Wade 
The slides presented are all highlights from the EMFAC workshop presentation, which is on 
the ARB web site. The schedules for activity updates and EMFAC updates should result in an 
EMFAC05 submission to EPA in early 2007. 
Questions: FACILITY-TYPE EMISSION FACTORS – What are the before/after impacts of 
changes? Response: Dennis Wade: We can’t identify that yet – since the work is still in 
progress. We will hold more workshops early ‘05 with some updates. Question: Jim D.(SB): 
Will the same method be used as in 2002 regarding vehicle registration data vs unregistered 
vehicles? Response: Dennis Wade: We don’t know; Mark Carlock did not discuss this at the 
previous EMFAC workshop. Question: L Seitz: Will trip end information be brought into 
BURDEN? Response: Dennis Wade: We are probably not changing the model in that respect, 
but we can work w/regions to incorporate if needed. Question: Jean Mazur, FHWA: Do the 
PM2.5 precursors include: NOx VOC SOx? How will ammonia be calculated? Response: 
Dennis Wade: probably no ammonia in EMFAC05, but we may be able to develop a separate 
method for that. Doug Thompson: The ammonia test program was not completed since 
ammonia sticks to the testing equipment, we don’t have sufficient data to incorporate it into 
EMFAC yet. Alt method? NH3 existing inventory methods could be adapted. Question: 
Doug Eisinger: Are there any air toxics projections in EMFAC05? Response: Doug 
Thompson: Diesel particulate is part of EMFAC. We have methods for speciating VOCs. But 
no plans to incorporate in EMFAC yet. Question: Cari Anderson: Is the CRC study that you 
mentioned available for review or has it already been finalized? Response: it’s been finalized. 
Question: Cari Anderson: What about the NAFTA model/data for review? Response: Yes, 
but we’re not certain how to do it. Dennis Wade: The information is based on both 
MVSTAFF and ARB GIS work to estimate paths. Use in ITN too? No. SCAG region truck 
model will be used. Timing may not jibe. 

2:15 Status of Transportation and Air Quality Planning in California 

a) Near Term Air Quality Plans (Bay Area (1 hr), Sacramento (8 hr), SJV (1 hr)) – Area 
Representatives 
Bay Area: Combining w/other planning documents. Expect to have full air quality plan out in Dec 
for review. The plan will be finalized in April. 
Sacramento: 8hr ozone ROP plan to Board in the summer 2005. The schedule will depend on 
potential impacts from EPA’s Phase 2 rule. 
SJV: The extreme plan is done and to ARB, to EPA on November 15th. We expect the new 
budgets to be adequate by February 2005; the 8hr schedule is drafted but may change. The PM10 
plan update is due in 2006. 
b) RTP and TIP updates for the 8 Hour standard (Approach and Schedule): Jean Mazur 
& Karina O’Connor, Area Representatives 
8hr Ozone Conformity Approach Questions. (see last page). 
Schedules for 8h findings: Depends on Phase 2 etc and FSTIP issues being resolved, but here are 
the plans for completion of the 8 hour conformity analyses as envisioned: 
San Diego: Late April 2005 
SCAG; not sure, hoping for February 2005 
MTC (Bay Area): planning to amend the 2005TIP+2030 Plan and submit in March 2005 using old 
1 hour budget (since the new plan won’t be completed at that time) 
Sacramento: We’ll do the analysis as soon as the 8hr ROP plan is done 
San Joaquin Valley: Our response depends on when the FSTIP issues are resolved, but we were 
hoping for February 2005 using the older 1 hour budgets. 
c) Conformity SIP or TCM Substitution Rule Updates (Any submissions in next year?) 
– Area Representatives 
Conformity SIPs: None. 
TCM Substitution Rules: The Bay Area will update their conformity SIP with the next ozone 
plan submittal. The South Coast has not reevaluated their TCM rule with the newer EPA 
guidance. Eyvonne- we’re hoping for feedback from EPA. Must this be a SIP revision? Response 
(EPA): yes. Sacramento is considering a TCM substitution rule with the 8 hour ozone 2007 
attainment SIP. 

3:15 Information Sharing 

• ARB Solid Waste Collection Vehicle Rule – Sara Siwek 
Sara recommended that areas consider this rule and consider the need for additional NOx 
reductions for PM2.5 plans and recommended using CMAQ money to supplement reductions 
to get excess reductions 
• Staff Changes, Chair for 2005 – Karina, Dennis 
CARB: Dennis Wade is now the conformity lead for ARB conformity. He’s still in the 
process of coming back up to speed. 
EPA: Karina: I will be on maternity leave in mid-December thru February; John Kelly will be 
able to respond to questions and focus on the 8hr implementation rule, 8 hour conformity 
analysis or the Conformity SIPs; contact information for conformity staff: 
o Becky Rosen (415) 947-4152, Rosen.Rebecca@epa.gov 
o Toby Tiktinsky (415) 947-4223 (who will be working with Sacramento), 
Tiktinsky.Toby@epa.gov 
o John J Kelly (415) 947-4151 (lead for conformity SIPs and 8 hour implementation), 
Kelly.JohnJ@epa.gov 
o Ginger Vagenas (415) 972-3964 (lead for Bay Area), vagenas.ginger@epa.gov 
The chair of the working group for next year will be Mike Brady from Caltrans, keep 
your eye on the web site: 
http://www.dot.ca.gov/hq/env/air/State_CWG/CWGindex.htm for upcoming meeting 
agendas and handouts. 
• The Next Meeting will be on January 27th in San Diego. 

3:30 Adjournment 

8-HOUR CONFORMITY DETERMINATIONS 
General Questions 
Q1: Does the conformity determination for the 8-hour ozone standard restart the 3-year 
planning clock? 
A1: The three-year planning clock would only be re-set if the MPO performed an update to 
the RTP in conjunction with the conformity determination. 
Q2: If an area is nonattainment for multiple pollutants, does the conformity determination for 
the 8-hour ozone standard have to include the other pollutants? 
A2: If the conformity determination is based on a new regional emissions analysis it must 
include all pollutants for which the area is designated nonattainment or maintenance. If 
none of the planning assumptions or project information is changing, then an MPO can 
“rely on a previous regional emissions analysis” for the other pollutants. Requirements 
for relying on a previous regional emissions analysis are found in section 93.122(g) of the 
transportation conformity rule. Please note that relying on a previous regional emissions 
analysis does not re-set either the 3-year planning clock or the 3-year conformity clock. 
Q3: If there is no associated RTP/TIP update or amendment, what documentation should be 
circulated for the 8-hour conformity determinations (do MPOs have to re-circulate the 
whole RTP/TIP again)? 
A3: Only the conformity documentation needs to be re-circulated. However, the project 
listing with the revised analysis year dates needs to be included in the conformity 
documentation. Additionally, the conformity documentation should at least provide a 
reference to the RTP and TIP. A website location would also be helpful. 
Q4: Does the timely implementation of TCMs have to be addressed in the new conformity 
determinations? 
A4: Yes, timely implementation of TCMs has to be addressed. You should recheck the TCM 
project schedules. 
Q5: Does financial constraint need to be addressed in the conformity documentation? 
A5: Yes, but the level of effort regarding the financial constraint demonstration will probably 
depend on what the MPO is doing in conjunction with the conformity analysis. If there is 
an associated RTP/FTIP amendment, the MPO should coordinate the level of financial 
documentation with the FHWA transportation planner. If the MPO is only performing a 
conformity determination to satisfy 8-hour ozone standard requirements then the MPO 
should, at a minimum, reaffirm that the financial constraint information as included in the 
RTP and FTIP is still valid and note that the conformity determination is based on the list 
of financially-constrained projects in the RTP and FTIP. 
Q6: What type of public involvement has to be performed for the conformity determination? 
A6: Public involvement should be conducted in accordance with the locally adopted public 
involvement procedures. If there is no associated RTP/TIP update or amendment and 
the individual MPO public involvement procedures do not include procedures for stand 
alone conformity determinations, then a minimum 30-day public comment period should 
be used. 
Q7: What year should be used for analysis of the attainment year? 
A7: Note that this only applies to areas using their 1 hour SIP budgets to show conformity for 
the 8 hour standard. Before an 8-hour ozone SIP is adequate or approved, these areas 
may perform a regional emissions analysis and demonstrate consistency for either the 
moderate nonattainment area using a 1-hour conformity budget to show conformity for 
the 8-hour standard is required to include the 8-hour attainment year as an analysis year. 
The area could pick either 2010, which is its statutory maximum attainment date, or 2009 
which is the last possible year for the area to implement controls that are needed as part 
of its attainment demonstration. 
Q8: Does the 8-hour conformity determination have to be made for both the RTP and TIP? 
A8: Yes, the conformity requirements pertain to both the RTP and TIP. 
Q9: When do 8-hour ozone conformity determinations have to be complete? 
A9: In order to avoid a conformity lapse, the USDOT conformity determination has to be 
complete by June 15, 2005. 
Q11: When does FHWA/FTA need the final conformity documentation in order to make a 
conformity determination on the RTPs and FTIPs by June 15, 2004? 
A11: The answer depends on if the RTP/FTIP has changed or if it’s just a simple submittal of 
the conformity analysis. 
Area Specific Questions 
Q: SCAG - Do the portions of the 1-hour ozone mobile source emissions budgets that are 
applied to the 8-hour ozone standard need a new adequacy finding prior to using them 
for a conformity determination? 
A: No, they do not need a new adequacy finding. They were reviewed as part of the area’s 
previous adequacy finding. 
Q: SANDAG - What emissions test should be used for an analysis year that is earlier than 
the year that the current one-hour budgets are set for? 
A: Interagency consultation should be used to determine the most appropriate test. In 
general, however, if there are no budgets for the 8-hour attainment year that are currently 
being used for conformity purposes, then the appropriate interim emissions test (or both 
tests for moderate and above 8-hour ozone areas) should be used for that analysis year 
and the 1-hour budgets should be used for all analysis years subsequent to the year the 
budget was set for. There is an example of this scenario in the presentations from the 
workshops. 
Q: SJV - In nonattainment areas with multiple MPOs, what should the documentation 
include given the current policy that all MPOs must have a conforming RTP and TIP in 
order for any of the MPOs to make a conformity determination. 
A: The documentation should include a statement that all the MPOs in the nonattainment 
area have currently conforming RTPs and TIPs. It should be noted that FHWA will not 
make an initial 8-hour conformity determination until it has received all of the 
determinations from the individual MPOs. (See the July 2004 Multi-jurisdiction Guidance