California Statewide Conformity Working Group 9/23/2009 Teleconference MEETING NOTES 10:00 AM Introductions; housekeeping; agenda review 10:10 AM Public Comment on matters not on the agenda 10:20 AM Federal Updates EPA Quantitative Analysis Guidance for PM Hot Spot Analysis This portion of the meeting involved EPA HQ/OTAQ discussion of PM quantitative analysis guidance and opportunity for stakeholder input. An EPA draft discussion paper was emailed to group members but was not, by EPA request, posted at the conformity working group web site due to its preliminary draft nature. Overview & issues: * The discussion paper is intended for staff discussion only. Do not cite/quote etc. Formal rulemaking will be done. Additional stakeholder input and webinar is possible and likely, at least as part of the rulemaking process. * PM hot spot analysis is required by the conformity rule. However, quantitative (dispersion modeling) analysis is not currently required because suitable models have not been available. * MOVES (the new EPA 49-state emission model) is coming out for rest of country soon. EMFAC 2007 is currently available for California use. Both have PM emission factors. Transition grace period for new model (MOVES) can be 3-24 months. EPA recognizes that the MOVES model is new, as will be the dispersion modeling process (so the longer end of the range is likely). * EPA is working with FHWA on model and transition details - needs to be accurate but also user- friendly. Quantitative modeling guidance for PM hot spots won't change existing rules - just specifies how to do analysis when required. Schedule * Continuing stakeholder discussions during September-October. Release target for draft guidance in October-November. Official release planned to happen along with MOVES by the end of the calendar year. * EPA will approve EMFAC 2007 for PM hot spot at the same time that MOVES and the hot spot modeling guidance are released. All action should have the same grace period. SIP and Conformity policy document for PM2.5 is expected to be out before the final release. * Grace period for project actions: finishing NEPA on based on current qualitative analysis process is fine for now. If developing NEPA analysis for approval a year or more out, consider using the new process. May be some flexibility for analyses started before the end of the grace period. * MPOs: have some responsibilities under this document, mainly related to consultation. MPOs usually are not project sponsors so direct application is limited - but other agencies will want to pay attention. No change to current POAQC decision and consultation process. Q: Consultation on models & data - how does it affect us? A: Similar to existing qualitative guidance. * Shouldn't be an issue in conformity SIPs. * Flowchart in guidance will include examples with MOVES for hwy & transit projects. * Road dust: for PM10 (and current PM2.5 in CA) - follows current guidance with a little more method detail. Use AP42 or EPA & consultation-approved local methods. * Transit/locomotives: locomotives especially - use 4/09 emission factors document. NEEDS INTERAGENCY CONSULTATION to develop specific approach & identify data. * Models: Use EPA models, NOT CALINE4. Main CALINE problem is ability to use a full year's meteorology and other data. o CAL3QHCR to be used for most road projects. If looking at rail expansion to substitute for trucks or other non-road project, will need to use AERMOD. EPA recognizes the relative lack of experience with AERMOD in the State DOT arena; will consider offering training. o Must use a full year of hourly meteorology data!! Consultation approval required every time if proposing to use CALINE4. o EPA meteorology expectations - similar to AERMOD: surface, high-altitude hourly for 24 hr and year. Must have matching (hourly etc.) background concentrations & feedback to traffic analysis from induced source activity. May want on-site or nearby monitoring data - not regional monitoring sites unless hot-spot oriented and nearby. Basic approach will be to calculate design values the way it's done for regular attainment monitoring and compare to annual and daily NAAQS. NOTE: question was not asked therefore not answered - does this require a full year's daily (or synthetic daily based on 6-day monitoring schedule) monitoring data at the project site? * Mitigation options offered will be similar to what's in the existing qualitative guidance. Not much detail about potential design changes. * Appendices will include various technical documents & project examples. FTA/FHWA helping to develop this. * Send comments to Meg, Dennis, Karina, etc. anytime - but sooner the better. Focus on challenges, data input/needs, training, etc. Comments * Steve McDonald/D6: MOVES wants 4 months of traffic data; traffic data now available focuses on school sessions - may not represent summer well. * Chris Dresser: there is an option to use peak hr & extrapolate to other hours - but may seriously overestimate traffic!!! * Average Speed: there is a big difference between average & peak hour speeds in San Joaquin Valley - need research project to look into better way to do this? * MOVES is very sensitive to temperature - so need good met. data for the whole year. * SPEEDS: concerns? o How to incorporate vehicle activity? HCM algorithms are for free flow - break down at v/c 1 - congested corridor speed prediction problems. o v/c >1 only for short time - include in average speed estimate. Average speed/hr used for EMFAC to generate HOURLY emission factors (not second by second as for MOVES). 11:00 ARB discussion of EMFAC guidance being prepared to incorporate into EPA PM guidance Dennis Wade: UCD working on it under Caltrans contract. Completing writeup now. EPA will incorporate the chapter into the PM Hot Spot Guidance when released for public review. * Intent: EMFAC and MOVES are very different models but some analogies apply - will point those out. * Discusses input parameters (vehicle mix, starts, temperatures, I&M handling, analysis years, speeds). * Looks at CO Protocol & data needs, how output will be formatted. 11:15 EPA discussion of other SIP and conformity matters Ozone standard reconsideration (handout - PDF file) * 2008 revision to 0.075 ppm was outside the range recommended by CASAC. PM2.5 was done similarly in 2006 - EPA lost a lawsuit on it - expect similar action on ozone. o Asked court for stay pending possible reconsideration - so reconsidering - filed notice w/court on last day. o Proposal & final 12/09 & 8/10. Pending court approval. * DOES NOT AFFECT FULL REVIEW OF OZONE STANDARD CURRENTLY IN PROGRESS focused on 2013. * Reviewing 2008 standard based on same studies used in 08 - that's how it's expedited. * May delay implementation of 08 standard: holding off on current round of area designations then will expedite after reconsideration including faster SIP schedules. o So emission budgets would happen in 2013. Conformity would be due in 2012 based on 2011 area designations. o Expect new standard in 60-70 ppb range, with new seasonal secondary standard based on the W126 method as proposed previously. * Expedite is only for primary standard not secondary. Need recommendations from State for secondary. Some California counties may be nonattainment for secondary that are OK for primary. PM2.5 Designations * Nothing to talk about regarding PM2.5 designations at this time. Subpart 1 Areas * San Diego: When will final action happen on Subpart 1>2 redesignations? o EPA: Draft Final Federal Register notice is done but not yet published. Subpart 1 areas would become Subpart 2 as Moderate or higher. * Question: since the final ozone season for Moderate is this year and Marginal deadline is long past, if an area would be Marginal what happens - extension, bumpup? Need to make them all Moderate? * Question: what's blocking action? Subpart 1 SIP deadlines on hold - Marginal areas that attained have no issue, but others should get new due dates (12 mo.). NAAQS table (handout - PDF file) * EPA: THIS IS AN INTERNAL DRAFT - has been revised - no updates available on paper. Don't share too widely - some speculative info. "Infrastructure SIP" * Has nothing to do w/designation status - keys off NAAQS change * Covers authority & resources to administer & enforce NAAQS. Transportation Conformity Rule restructuring NPRM * Amendment restructures especially 93.109 o Organized by pollutants o More consistency & easier to understand/revise when standards change o Not really related to isolated rural; some touch of clean data policy * Proposal coming before next Statewide Conformity Working Group meeting, Previously planned to come out with ozone reconsideration but now separated from it. PM Standard Amendments Final Rule and related process * Finalizing May proposal for 2008 transition to new standard. o Use existing budgets if available otherwise interim procedures o Includes transition to using both 24hr AND annual standards * COURT VACATED ANNUAL PM2.5 Std (2006) EQUAL TO 15 ug/m3. o CASAC wanted LESS THAN. Same issue as for ozone. * PM NAAQS REVIEW underway is for both PM10 and PM2.5. 11:30-12:00: Other Federal issues FHWA: * Senate passed transportation bill with continuing appropriation. In conference committee. $1B difference between House/Senate. Expecting fix by end of month. * Working on a 3-mo SAFETEALU extension with no changes to programs. 12:00 Lunch 1:00 PM Project-Level Conformity CO Protocol * No updates planned this Fiscal Year. [CO Protocol] PM hot spot screening procedure * Further discussion of local implications of EPA changes. * Will need to identify any projects "in the middle" of the process. * Isolated Rural PM Analysis: regional and project-level analysis issues noted for E.Sierra/Great Basin PM10 areas. 1:30 PM Status of Air Quality and Transportation Planning in California MPO & Air District Status Reports and Discussion Air Districts: * Butte Co.: waiting for PM2.5 action * Sacramento: now have 8 hr ozone budgets. Attained 1-hr standard but in limbo re SIP. * San Joaquin Valley: partial disapproval Kern Co. for ozone. Fix Status Table: no lapse occurred.. Waiting regarding new PM2.5 standard. EPA won re PM10 Plan! * MTC: Status Chart: fix conformity determination date - 5/26/09. Waiting on PM2.5 - getting ready to set up hot spot consultation process. * Nevada Co.: still waiting on reclassification for ozone. PM2.5 - Plumas very close; much documentation for wildfire events; if accepted Plumas will just get by. RACT etc being developed in preparation for reclassification. * Other Mountain Counties: ARB will assist with SIPs. Can they get "105" money? (no answer) MPOs: * SANDAG: Starting on 2050 RTP (July 11). TIP amendment to be done in January needs conformity. S.D. APCD: SD expects to be Moderate for ozone with SIP to be submitted 1 yr after designation. If bumpup requested may not need attainment demo then but with a new date - need to do RFP with budgets? May not need SIP and budget if clean data, but bumpup holds off details to a later attainment demo. * SCAG: working on PM10 redesignation to attainment w/AQMD - public comment period next month. Working on Amend#2/RTP with new conformity analysis for December council approval. Starting 2012 RTP process with an SB 375/SCS focus. * SJV: RTPs scheduled for 7/2010. Amendment in process now for Kern due in September. * MTC: just adopted 2035 in April - next in 2013. * SACOG: new RTP just done last year; start again next year. RTP amendment in process now: new traffic, EMFAC07, budgets targeting November completion. Curious things with happening with EMFAC for Sac and Solano. ARB: resolved for now. * Butte - just finished last RTP in January. * (Handout - Caltrans Status Chart) 2:45 PM General Information Sharing * Next meeting - suggest March 2010, by teleconference. Agreed: March 24. 3:00 PM Adjourn