California Statewide Conformity Working Group 3/11/2011 Teleconference Meeting Notes Times are from the agenda. Meeting moved faster than planned and ended shortly after 11:30. 9:00 AM Introductions; housekeeping; agenda review 9:05 AM Public Comment on matters not on the agenda No comments received. 9:10 AM Federal Updates * PM hot spot review process - discussion of modeling and consultation issues o EPA: reminder - documentation must support the decision being requested in the document. Keep in mind that PM hot spot documentation (POAQC forms, PM analysis, etc.) is a public document and needs to provide information so that the public can see what the decision is based upon. o Terminology: hot spot "analysis" or something else for the initial POAQC test? * SJV calls the initial review an "assessment" - if POAQC then it's "analysis" * No clear answer, but EPA Guidance calls only the detailed quantitative or emission analysis studies "analysis" though regulations talk about "analysis" in general. * SER boilerplate for public notice uses "analysis" for everything then qualifies based on the type of analysis. See http://www.dot.ca.gov/ser/forms.htm * New AP-42 for Paved Roads o EPA - New method announced 2/4; 2-year grace period for phase-in of revised method. "On February 4, 2011, we announced in the FR, a 2-year grace period for the 2011 AP-42 method for regional conformity emissions analysis. In January, OAQPS revised the equation used to predict PM emissions and now allows for the calculation of estimated emissions from the road surface excluding emissions from engine exhaust, tire wear and brake wear." o Use new method now for new SIPs in consultation w/ARB. o Discuss in each PM area for project use. If a different method is specified and approved for use in conformity, we can keep using it; otherwise, transition to new method over 2 years as decided per area. Note that the SJV MPOs use AP-42, so should transition to the new method. o SJV uses both EPA and CA procedures, not just the specific method in the PM10 SIP, so the new one can be used for PM10 when desired. * CO Standard Proposal o "On February 22, 1011, EPA proposed to retain the current CO standard and proposed to change the monitoring requirements and network design requirements for a minimum set of near road monitors located at a subset of the NO2 near roadway monitors for CBSA (core based statistical areas) areas with populations over 1,000,000 or more based on 2009 census." o Post meeting note - the proposal has now gone final, published on 8/31/11. EPA retained the existing CO standard, didn't finalize a secondary standard and updated the requirements to CO network design. o Discussion: * Is the 50m distance a potential safety issue? * Does a change to the "standard" affecting other issues but not the actual standard trigger conformity redetermination even though the numeric standard doesn't change? EPA to check & report back. * Conformity Restructuring Proposal: The proposed rule was published on August 13, 2010. Final expected this summer (August?) o Various versions in process - no Final version yet. o No immediate impact on areas - incorporate into conformity findings that start work after the Final is in effect. * PM2.5 Area (Non)Designation - North State o "Deferred" areas did not end up designated nonattainment - went unclassifiable o New & exceptional event data reviewed. EPA concurred that those areas area are clean so conformity doesn't apply. o See final rule published in Federal Register on February 3rd, 2011; Plumas and Shasta counties and their surrounding counties are designated ''unclassifiable/ attainment, effective March 7, 2011 for the 2006 24 hour PM2.5 standard. o Related: recently updated air quality maps at EPA Region 9 have links to KMZ, GIS files in addition to images and PDF. See: http://www.epa.gov/region09/air/maps/ * Status of Ozone Standard Reconsideration & Subpart 1 areas o "Former Subpart 1/Basic" areas: Final action soon * "Former Subpart 1/Basic" areas being reclassified because of court action requiring classification under Subpart 2. (Subpart 1 is generic nonattainment; Subpart 2 is the specific classification system for ozone.) * Areas should be Marginal or Moderate depending on design values & whether the met the required attainment date for that classification. * San Diego did not attain by the Moderate date so they will start as Serious. * Final action expected in May starts 12 month SIP clock for Moderate or Serious-area RACT & NSR, Conformity, etc. * SIP will need to do emission budgets for SD * Moderate/Marginal areas will have Clean Data findings so possibly no MVEBs. However, before EPA makes a clean data finding, ARB can request development of a MVEB based on the latest year of clean data. * EPA notes that the option exists to set a budget even if not required. * For E. Kern: classification should be the same as proposed in 2009. Eastern Kern will be either marginal or moderate. o Reconsideration of ozone standard * The 2008 standard is not yet fully implemented while reconsideration is underway, so no nonattainment area designations yet. * Some deadlines will be missed; have been sued. Reconsideration has been pushed back a couple of times; now July 29. * Standard will have to change - Administrator has said that the 2008 standard is not health-protective. Primary & secondary standards coming. Area Designation schedule will be set when the standard is changed, too - not clear how or if it will be accelerated. * Implementation Rule will be proposed for the reconsidered standard & probably will revoke the 1997 standard as part of transition. * Question/comment: ozone has an effect on CMAQ funds. Going from Basic to Moderate would change apportionment factor but the new standard will spread the money more thinly because of many more nonattainment areas. Programming will have to determine how it will work. * Note - on September 2, 2011,President Obama requested that Administrator Jackson withdraw the draft Ozone National Ambient Air Quality Standards and mentioned that Work is already underway to update a 2006 review of the science that will result in the reconsideration of the ozone standard in 2013. * NAAQS Review Schedule Update (handout) o WHAT'S NEW? * SO2: added note about 6/13 due date for unclassifiable area "110a1" maintenance SIPs (everybody except designated nonattainment areas - no nonattainment areas in CA). Due date is based on standard procedures. Does not set MVEBs or otherwise affect conformity. * Dates for ozone reconsideration updated. Attainment/RFP SIP due dates for the new ozone standard must be proposed before implementation continues - will happen along with reconsideration final action. * Significant Litigation & Other Matters o Too many cases going on! * NOIs filed for Ozone, PM. Lawsuits could affect a lot of SIPs. * Clean Data vs. Non-submittal. Do areas have to submit SIPs even if clean? If EPA has made a clean data finding, the applicable SIP requirements that can be suspended will be outlined in the associated Federal Register Notice. * Deadline lawsuits filed for PM2.5 in South Coast, for 8h ozone in SJV& South Coast. * AIR (Association of Irritated Residents) suit: EPA looking at the case to decide what to do; decision to be made @HQ (interpretation of VMT requirements & TCMs re. 1-hr ozone (South Coast)) * Have traditionally looked at emissions for TCMs. Clean Air Act Section 182(d)(1)(A), as interpreted by court, requires VMT reduction too. * SCAG question: if State provides info that is OK, what's the process from now? EPA: Working with ARB re. SIP revision - if completed by 4/28 at ARB EPA would repropose in May-June. * Looming conformity freeze. * Federal Highways & Other Updates o CA Division Reorganization * Management decided it would be beneficial to have more presence in LA. Will include Admin, ITS, Planner (Michael Morris), Sr. TE (Tay Dam), & 6 new positions: Associate Division Administrator, engineers, border specialist, financial. Targeting implementation this Spring but some uncertainty due to funding/continuing resolution. * Jermaine Hannon new Planning/AQ team leader. Cecelia Crenshaw now Professional Development Coordinator. o Reauthorization - draft bills * SAFETEALU expired. Under continuing resolution until 9/30/11. * EPA: would proposed merging of funding categories in reauthorization end CMAQ? FHWA: budget proposal takes 55 programs down to 5 areas; old programs don't necessarily end & CMAQ may consolidate into the "Livability" program. EPA: Would "Livability" apply to all areas or still just nonattainment as for CMAQ? FHWA: remember it's still all proposals in the budget, including a reauthorization bill for $500+B. * CT: would the changes add CMAQ money and/or pollutants? FHWA: Volpe studying funding levels. Expanding to other pollutants not likely. 10:00 AM ARB Updates * EMFAC Update Status o EMFAC is nearing completion but no release date yet. * Fleet or real model change? ARB: Latest Planning Assumptions is the minimum; not willing to talk about other features. * CT: converting to MOVES? ARB: unlikely especially this round. * VCAPCD: timeline after release for implementation? ARB: need to get through release, submittal to EPA for conformity/SIP approval; EPA approval. Should start using with c2012 SIPs; a grace period should allow options. * SCAG: existing Planning Assumptions are 2007 - will be 5yr+ soon; so will there be any grace period? EPA: ARB/EPA does the model; DOT does Planning Assumptions. ARB: difference this time is that Planning Assumptions aren't quite as old. EPA: EPA definitely does consult w/DOT when setting grace period. * VCAPCD: Early Progress Plan budgets continue until when? Transition issues again? * OFFROAD Update to match EMFAC? No news. * State Attainment Designations: No news. * ANNOUNCEMENT: Jason Crow is the New Dennis Wade - ARB conformity contact. Dennis moving to SB375 group. * SJV: is ARB looking @MOVES? ARB: ARB trying to understand how it works. Data-hungry; not suitable for use in CA off-the-shelf. Could be made to work but Todd Sax & modeling group would need to look at it more closely for possible future EMFAC versions. SCAG is looking @MOVES for off-model scenario analysis work. 10:30 AM Break 10:45 AM Caltrans Updates * CALINE4 can do NO2 if desired (no interface at this time) o Command Line only. Not required for conformity at this time. * How can CT support the conformity process better? o Just asking. Send comments/suggestions. * DTIM: o CT (Leonard Seitz) is rehabbing DTIM, which should make impact calculations easier. Older DTIM couldn't do evaporative emissions well & nobody was available to fix it when EMFAC changed. o DTIM is tied to trip-ends so some parking emissions are lost, but if you can figure out where parking happens you could figure it. o SCAQMD: still uses DTIM for gridding & temp correcting. SCAG: has agreed for some time that DTIM should be updated for EMFAC changes. o ARB: uses only as surrogate tool for gridding - can't use absolute values because they don't match EMFAC. CT: would try to address differences in update. 11:00 AM Status of Air Quality and Transportation Planning in California -- MPO & Air District Status Reports and Discussion * (3/2011 Caltrans Conformity Status Chart - not available) * MPO & Air District Status Discussion o SANDAG: draft RTP due out late April w/conformity and SB375 analyses. RTP conformity timeframe shortened to 2040 with info for 2050 overall RTP horizon year. o SDAPCD: working on SIP submittal for Ozone Serious designation. o SCAG: will start working on 2012 RTP draft in 11/11; final in 4/12. Got Fed approval for 2011 FTIP & Amendment 4 to 2008 RTP. o SCAQMD: SIP submittal re partial disapproval PM2.5 done last Friday - to CARB for April approval then EPA. Shows that stationary source plan meets 96% of commitment. Emission budgets depend on ARB truck rule etc. o SJV/EKern: Processing several Regionally Significant amendments. Waiting to see about PM2.5 SIP disapproval - probably around May. o SJVAPCD: working on midcourse review for this month/next; also rules addressing limited disapproval triggering sanctions clocks. Midcourse out for review this week. o MTC: working on new RTP; due 2013 so some time left compared to others. 2011 TIP & 2009 RTP reconformed in December. o SACOG: adopted last conformity determination in February - starting one for June. Main MTP for 4/12 to be released in November. o SacAQMD: finishing 3rd yr of clean PM2.5 data - may not need a PM2.5 SIP. Ozone - Board didn't like the concept for indirect source & construction rules - produced minimal emission reductions so will ask removal from current SIP - but might go back into new ozone SIP. o Northern Sierra AQMD: Mountain Counties looking for clean data finding any day now (1997 ozone standard) which avoids RFP SIP & modeling. Should have infrastructure SIP done for 1997 standard soon. o Ventura: APCD still working on RFP issue - needs credit for emission reductions outside the area. 2007 8-hr ozone SIP done but approval held due to out-of-area emissions issue. Might have to re-do. 11:45 AM Information Sharing * Next meeting - September 2011 teleconference * EPA PM hot spot training coming - late summer. 2 sessions in California using EMFAC. 12:00 Noon Adjournment