California Transportation Conformity Working Group Thursday, June 15, 2006 10:30 am - 3:30 pm San Diego Association of Governments (SANDAG) 401 B Street, Suite 800, San Diego, CA 92101 Meeting Notes 10:30 Welcome; introductions; housekeeping; agenda review - Extra handout – SCAG PM2.5 form (http://www.scag.ca.gov/tcwg/docs/PM-HotSpot-Form.doc) 10:40 Public Comment on matters not otherwise on the agenda - None 10:50 FHWA Updates - SAFETEA-LU Implementation Update o July 2007 deadline issues o FHWA prefers not to make any SAFETEA-LU compliance determinations before final regulations and Guidance are issued. * If a compliance approval does occur before regulations are final FHWA will not take it back if final process is different. - Planning NPRM available for comment; comments due 9/7. o FHWA especially wants comment on July 1 transition issues. o CT requests email comments to Garth Hopkins by 8/11. - CMAQ update o Rulemaking schedule * Still draft. Will not be out soon; hopefully by the end of summer. o Off-road/construction equipment * Provisions different in current drafts. KEEP USING ARB GUIDANCE pending updates. o Question: How does Interoperating Emergency Communication Equipment eligibility fit into the CMAQ process? No specific guidance right now. o FHWA: EPA diesel retrofit guidance is relevant to CMAQ – discuss later in meeting. o Question: When will Conformity SIP guidance be out? EPA: Do not know – need to check. - PM Hot Spot Analysis (with EPA & CT) o Summary of 3/10/06 Rule, 3/29/06 Guidance, and 5/9/06 FAQ - handout o Update on PM hot spot analysis procedures * EPA: national conference call held – chaotic in some areas. Lots of projects in a short time. PA working on statewide standardized process. EPA wants consistency nationwide. * San Joaquin Valley: Local procedures working OK in SJV. Memoranda circulate for review that detail why a project is not POAQC; concurrence by email with conference call if needed. Still need to document procedures. * Question: If PM10 analysis is already done, does it need to be re-done along with PM2.5? FHWA: just do PM2.5; do not change prior PM10 analysis. * SCAG: 20 projects so far used SCAG review form – SCAG compiles forms & places on conformity working group web page for review. Intent is for people to look at forms before meeting & only discuss questionable projects. Resource issue: need consolidators – County commissions. RTIP # used as project identifier. * Question: Need to review exempt projects for PM2.5 to confirm exemption? No. Do not need review if it's exempt. * Question: What supporting data are needed? Use MPO model for ADT, etc? Send request to IAC members to review all NEPA projects or leave to sponsors? NEPA-stage process (if different) not decided yet in SCAG. SJV working on separate process for NEPA-stage consultation. * Need a website with an ongoing list of what's reviewed/approved identified; SCAG does it on their regular CWG website. However it's done, FHWA/EPA consensus that there needs to be a way to quickly see what was reviewed and disposition. * CRITERIA for HOT SPOT ANALYSIS: location in SIP as violation site for comparison approach to studies – air agencies need to ID that in SIPs? Need some samples or guidance for how EPA and FHWA want it handled in the SIP. o Do we need contingency plans? Environmental groups filed a petition for review of the 3/10/06 hotspot conformity rule. * EPA: Suit filed on 5/9 – no stay of rule implementation requested, so implementation continues. Challenged issues include: PM Hot Spot criteria meet "contribute to reduction" standard; criteria & procedures; categorical conformity. No need for short-term contingency plans. - Project Listing Criteria Table – handout o FHWA has issues w/NEPA documents – hard to tell for sure whether a project is in the TIP, and what the TIP description really contains. FHWA focus on financial management makes it a bigger issue. Every E76 has to be in the TIP to avoid project approval glitches. o Sample table can be used as template – not required at this time. 11:20 US EPA Updates - Recent EPA SIP Actions (emission budget adequacy, approvals, sanctions clocks, etc.) o On 2/23/06 EPA sent a letter to CARB notifying them of the adequacy finding on the Sacramento 8 hour Rate of Project Plan. The FR notice was published on March 14, 2006, effective on March 29th. - Particulate Matter Standards proposal next steps o Web site for information: http://www.epa.gov/air/particulatepollution/actions.html * Comments closed on standards and monitoring issues (April 17th) – proposed rule was published on 1/17/06 * Comments open on transition rule until July 10th – ANPR was published on 2/9/2006, exceptional events. * EPA must finalize standards and revocation of existing standards by September due to court settlement. o Where old standards are revoked, conformity will no longer apply for the revoked standard; however, boundaries for areas retaining standards will not change until designations occur for the new standards – several years out. So no immediate changes will occur to the conformity process due to the new standards. o For a new PM-coarse (10-2.5) standard, states need to establish a monitoring network and develop data first – so that would take 6-7 years before nonattainment designations could be made. - SAFETEA-LU Implementation Rulemaking update o OTAQ is currently working on the revisions to the conformity rule – but do not expect finalization until close to the two year deadline. Issue – the rule changes may trigger changes to section 93.105- consultation activities (e.g. horizon year changes) – would this create a problem for areas updating their conformity SIP? o Rulemaking would trigger another 1 year clock for Conformity SIP updates. – EPA planning on issuing this in July. o MPOs encouraged to wait on conformity consultation SIP until guidance is released. * May withdraw rule portion of existing Conformity SIP submittals if so desire. * Only area with approved Conformity SIP is MTC/Bay Area. Most work concentrated on that area for now. - Other information/guidance o PM conformity rule changes lawsuit: see above. o EPA Diesel Retrofit Guidance should be used for upcoming SIPs and conformity credit. o Confirmed CA approach for reentrained road dust in SJV SIP was approved. o TCM substitution delegation to Region Administrator? Still in EPA HQ. 11:45 Lunch Break 1:15 ARB Updates - EMFAC update o ARB: Still planning on November release for EMFAC 2007. o Question: will another activity data letter go out? ARB: there will be no letter; if MPO has new data feel free to submit – ARB wants it. ARB decided to do final activity updates informally by area rather than with a form request letter – GET THEM IN AS SOON AS POSSIBLE! o FHWA: as soon as EMFAC is released FHWA starts 6 month transition period to new model. Issue: 02 budgets vs 07 model. START ANALYSIS BEFORE MAY if you want to use 02. If 07 used can't submit to FHWA until EPA approves 07 for conformity use. o MTC question: any more EMFAC workshops? ARB: no new workshops planned at this time. Exercise when released & comment by early 07. o San Diego question: did FHWA respond to the ARB letter to FHWA with the EMFAC 2007 approach? EPA & FHWA: letter is drafted and in the office, not (yet) sent. o EMFAC now goes to 2040 – will the next version go further out in to the future? ARB- will need to wait till next version. Schedule for updates is in the letter to EPA/FHWA. o Any impacts on DTIM? – just new vehicle classes. - 8 hr ozone & PM2.5 SIP progress o No update. o Sacto ROP was local & existing strategies only – stopgap. . - Conformity SIP strategy – deadlines and process o See above – WAIT. 1:45 Caltrans Updates - CO Protocol update o No update o Need for Caline4 upgrade to handle more than 20 links? Not at this time. - PM10/2.5 Hot Spot Analysis o Update of 2005 guidance still pending task order - RTP Guidelines/Handbook update o Still planning on release in the Fall, but may postpone until after FHWA releases planning rules. - California Transportation Planning Conference (5/30-6/1/06) report o No update - AASHTO SCOP/SCOE (6/11-15) meeting report o Major meeting focus on NEPA/Planning coordination. 2:15 Status of Transportation and Air Quality Planning in California - Near Term Air Quality Plans – Area Representatives o South Coast: Recent AQ summit – hoping for new ideas and strategies. Currently updating inventory with ARB. October 2006 is target date for draft plan. RACT to board in July. o San Diego: Subpart 1 area, close to attainment. How soon they can demonstrate attainment is their issue. The dates for different requirements are different depending upon what date they attain. Waiting for data from ARB to determine when they can attain. o Ventura: Workshopped the RACT SIP in July, emission inventory being developed. December 2006 to get the draft plan out. RACM process for TCMs – communicating with SCAG, Ventura wants to piggyback on that. o San Joaquin Valley: RACT SIP has been prepared, public comment done. Waiting for planning inventory from ARB – expecting NOx to increase 40- 60%. Workshop planned for August 10. Will start RACM process after completion of this round of conformity. Clean data submittal on PM10 sent to EPA. - RTP and TIP Updates and Amendments – Area Representatives o SJV: draft 2006 TIP Conformity analysis all out for public review. First hearing was yesterday – to end of month. Multi-juridictional guidance – nonattainment finding for entire valley in each document. All adoptions next month. This needs to be done until the subarea PM2.5 budgets are developed. Did demonstrate regional conformity for PM2.5. RTP: Directors accelerating schedule to try for approval by 6/30/07 – modeling starting Nov/Dec – need to coordinate all 8 MPOs. Next month – decide on horizon year – all 8 need the same. o SCAG: 2006 RTIP release next week. Regional Emission Analysis shows conformity. RTP – shooting for 12/07 based on possible gap analysis. o SANDAG: 2006 RTIP released May – to Transportation Committee Friday – if OK will adopt 6/23. RTP – June 2007 target – will start analysis w/old EMFAC. o MTC: public hearing on draft TIP yesterday. Public comment period ends on June 30th. Hope to have approval from commission on July 26. Draft interagency consultation procedures – public hearing on June 9th – no comments. 30 day public review period ended June 12th . TCM substitution procedures also included. o SACOG: 2006 TIP to be done in 30-45 days. RTP: Blueprint plan/report due next spring – basis for next RTP. Have adopted a variety of growth projections but won't allocate until transportation network done then will adjust. Question: do they intend to get General Plan changes to implement the Blueprint? FHWA requires that changes by local jurisdictions be approved before RTP adoption. Answer: growth forecasts based on Blueprint outside of holdouts – in them it's business as usual. FHWA wants actual General Plan changes only if Blueprint/Local plans not compatible. EPA: for both SIP & Conformity – need something enforceable and monitored (see Bay Area) – have talked w/SACOG already. 3:00 Information sharing - STAPPA/ALAPCO PM2.5 Options document (Mark Brucker) – handout (no notes) - PM2.5 webinar: Mainly emphasized PM2.5 hot spot EPA guidance and Q&As. Meeting materials (PDF files) are on conformity working group web site. 3:30 Adjournment