The Honorable Jim Jeffords
United States Senate
Chairman
Committee on Environment and Public Works
Washington, DC
20510-6175
Dear Chairman Jeffords:
This letter is in response to a request made by the Committee on Environment and Public Works of the United States Senate, dated July 3, 2002, regarding our experience with the Clean Air Act conformity program and transportation control measures, and the impact these have had on our transportation and air quality efforts. Attached you will find responses to the series of specific questions that were transmitted to us.
We appreciate the opportunity to provide input on the
reauthorization of the Transportation Equity Act for the 21st
Century process. If I can be of further
assistance on this subject matter, I can be reached at (817) 695-9240.
Sincerely,
Michael Morris, P.E.
Director of Transportation
CK:baw
Attachment
cc: Fred Abousleman,
National Association of Regional Councils
Delania Hardy,
Association of Metropolitan Planning Organizations
James Shrouds,
Federal Highway Administration
Chuck Mueller,
Texas Natural Resource Conservation Commission
Steve Simmons,
P.E., Texas Department of Transportation
2001-2002 UPWP
Element 3.02 Project File
Difference in Timing of Schedules
Describe
how the different schedules for the SIP, TIP, conformity, etc. and the impacts
of data changes on out year emissions affect your ability to develop effective
and timely transportation and air quality plans. Provide a time-line or narrative description of your various
schedules.
The differences of the schedules for the SIP, TIP, Metropolitan Transportation Plan (MTP), and Conformity are varied and can come without warning. For the Dallas-Fort Worth Metropolitan Planning Organization (MPO), the MTP is usually prepared every three years, consistent with federal rules. However, SIP or TIP influences could trigger a new MTP out of sequence. As a result, a new conformity analysis is required. As highlighted in Table 1, the MPO decided a MTP Update was required in 2001 (less than a year after receiving federal approval on a similar effort) to ensure a three-year MTP cycle due to a SIP schedule that would establish new motor vehicle emission budgets (MVEBs) and conformity.
A
new TIP is developed every year due to the number of transportation projects
being planned. This is above the
typical two-year cycle. As a result, a
new conformity analysis is required.
However, due to Tier II regulatory language contained in our applicable
SIP, the region is unable to perform a necessary conformity analysis on the TIP
in 2003, therefore our TIP schedule, and associative conformity analysis,
changed to make TIP modifications prior and after our freeze (see Table 1).
DALLAS-FORT WORTH
METROPOLITAN PLANNING ORGANIZATION TRANSPORTATION PLANNING DOCUMENT SCHEDULES |
||||
Current Schedules |
||||
Year |
SIP (as needed or attainment date) |
MTP (every three years) |
TIP (every two years) |
Conformity (used to measure SIP, TIP and MTP) |
1997 |
|
Ö |
Ö |
Ö |
1998 |
|
|
Ö |
Ö |
1999 |
Ö |
|
Ö |
Ö |
2000 |
|
Ö |
|
Ö |
2001 |
|
Ö* |
Ö |
Ö |
2002 |
|
|
Ö |
Ö |
2003 |
|
|
|
|
2004 |
Ö |
Ö |
Ö |
Ö |
2005 |
|
|
Ö |
Ö |
2006 |
|
|
|
|
2007 |
|
Ö |
Ö |
Ö |
*
MTP Update required to ensure three-year cycle maintained as result of new
SIP 2004 |
These conflicting
schedules hinder a region’s ability to appropriately implement policies,
programs, and projects in a Plan or TIP as planning documents continue to be
the focus. In addition, differences in
timing of schedules and premature adjustments to schedules impede development
of an out year strategic milestone calendar, sending confusion to our regional
partners and resource agencies as they try to incorporate their planning
activities to these federal obligations.
What impact have these schedules had on investments in highway and safety projects, construction costs, and air quality projects and activities?
The timely implementation of transportation projects and
programs are of high priority.
Therefore, to avoid impacts, schedules of the TIP and MTP are often
adjusted, within the limits allowed by regulations, to ensure that projects and
programs that are ready for implementation can proceed. However, SIP-related requirements are often
out of sync with the TIP and MTP and have the potential to cause TIP and MTP
modification freezes due to the inability to perform an air quality conformity
analysis. This could cause recommended
projects from being able to proceed because they may be inconsistent with TIP
or MTP. Unnecessary delays could cause
construction costs to increase and have a negative impact on air quality if
projects cannot be implemented as expected.
Generally, more time is spent on replanning already approved plans than
working on the implementation of specific projects. Greater focus on mobility and air quality project delivery is
necessary.
What
has been your experience coordinating your SIP and conformity processes with
SIP submittals or updates?
Keeping in mind the
varying schedules with SIPs and conformity associated to a MTP and TIP,
experiences in coordinating among these elements have been a challenging
process in the Dallas-Fort Worth Metropolitan Area. This can be attributed to coordinating a MTP that has a
three-year update cycle, a TIP that has a two-year update cycle, and a SIP
submittal process influenced by real-time observed air quality data.
As experienced in the
DFW area, a SIP submittal can introduce regulatory language that would require
changing air quality conformity schedules of a MTP and TIP. An example is the Environmental Protection
Agency’s (EPA) position with regards to use of Tier II automobile standards in
the MOBILE5 emission factor model. This
situation required the region to take a step back in its implementation of
policies, programs, and projects and reissue multiple planning activities.
MOBILE6 Versus MOBILE5 Projections
Compare
and contrast your MOBILE5 and MOBILE6 emission projections.
In the fall of 2001, the EPA sponsored a study to evaluate the differences of MOBILE5 and MOBILE6 using local data from the Dallas-Fort Worth region. Although a final report has not yet been published, draft reports indicate an increase in MOBILE6 projected Volatile Organic Compounds (VOC) and Nitrogen Oxides (NOx) of up to 50 percent over MOBILE5. After approximately 2008, projected emissions are similar between MOBILE6 and MOBILE5. This
significant trend continues to occur into the future where we see MOBILE6 emissions well below those of MOBILE5 emissions. These trends are consistent with national research performed on MOBILE6 versus MOBILE5.
How does
the increase in near term emissions (through 2010) from MOBILE6 affect your
conformity status?
Due to the significant differences in near term emissions between the two emission factor models, it would be extremely difficult for a region to pass a conformity analysis using MOBILE6 against SIP motor vehicle emissions budgets previously developed with MOBILE5. Since this is an obvious analysis mismatch, the Dallas-Fort Worth nonattainment area has planned its schedules accordingly to avoid such an evaluation (as noted in the Differences in Timing of Schedules responses above). The proper method, which is included in our mid-course review, is to recalibrate the air chemistry model with the new MOBILE6 emission software and reforecast the emissions permitted in a demonstration of attainment (i.e., higher emission do not necessarily mean a SIP or conformity analysis would not be successful.)
How will
your air quality planning process take the new MOBILE6 into account, and will
the SIP be updated before or after the new MOBILE6 projections?
As part of the Dallas-Fort Worth SIP submittal in April 2000, a mid-course SIP review is committed to EPA by May 2004. Within this process, MOBILE6 emission projections will be incorporated into an air chemistry model through new on-road mobile source emission inventories. This modeling process will establish MOBILE6 derived motor vehicle emissions budgets for the nonattainment area for use in an air quality conformity analysis scheduled in 2004.
Will the
new 8-hour NAAQS likely lead to an increase or decrease in your vehicle
emissions budget?
As an example, if more on-road mobile emission reductions are necessary to ultimately meet the 8-hour standard, then it could be assumed the resulting motor vehicle emissions budgets will decrease. More information will be available through a comprehensive emissions analysis following final rules. A different mix of controls may be necessary to meet an 8-hour standard, which are not well understood today (e.g. role of VOC emissions.)
What additional existing controls could be implemented in your
area to significantly reduce vehicle emissions, e.g., inspection and
maintenance, reformulated fuels, diesel retrofit, TCMs?
Having
just completed a comprehensive and technical review of on-road mobile control
strategies for the Dallas-Fort Worth SIP, there is no other existing control
strategy to significantly reduce vehicle emissions that could be
feasibly implemented in the region. As
we continue to seek or develop additional controls, we keep in mind the main
elements of on-road mobile emissions; cold starts, pre 10 a.m. emissions, hard
acceleration, excessive idling, high emitting vehicles, diesel engines, low
speeds, excessive speeds. Another
approach to reduce vehicular emissions is to advance already existing federal
gasoline, diesel, and engine standards earlier than required. One has to remember that Dallas-Fort Worth
is already implementing an aggressive high-emitting vehicle program, freeway
management curriculum for fire and police, vehicle speed reduction with
enforcement, and sustainable development projects.
Would these
controls be sufficient to address the potential increase in emissions projected
under MOBILE6?
One cannot
conclusively state that the above-mentioned measures would counter all the
potential increases in emissions projected in MOBILE6, since the model is yet
to be tested under Dallas-Fort Worth specific conditions and the appropriate
methodology is to recalibrate the air chemistry models to determine needed
emission budgets.
What role do TCM’s plan in helping to meet
attainment? Please list the TCMs and
CMAQ projects in your plan, and the associated "off" or
"on" model emission reduction credits for each.
Conformity could not be certified without CMAQ funds and Transportation Control Measures (TCMs). TCMs, along with other pollution reduction strategies, have assisted the Dallas-Fort Worth region in working towards attainment by continually reducing the number of ozone exceedance days recorded in the region from 15 in 1995 to 2 in 2001. Currently, the Dallas-Fort Worth region is under a conforming MTP that includes Intersection Improvements, Rail Projects, Bicycle and Pedestrian Facilities, High Occupancy Vehicle Lanes, Vanpools, Park and Ride Lots, and Grade Separations. Table 2 outlines the emission reduction estimates associated with each TCM category. Most TCMs in the plan are funded through the CMAQ Program. Although not classified as TCMs, additional strategies utilizing CMAQ funds and included in the region’s SIP include clean vehicles, Intelligent Transportation Systems, vehicle retirement, sustainable development, and traffic signal improvements.
Table 2
Transportation
Control Measures |
Commitments |
Emission
Reduction Estimates (lbs/day) |
||||||||
Volatile
Organic Compounds |
Nitrogen
Oxides |
|||||||||
2007 |
2015 |
2025 |
2007 |
2015 |
2025 |
|||||
|
|
|
|
|
|
|
|
|
|
|
Intersection Improvements |
|
775 |
|
Locations |
2,306 |
1,450 |
1,293 |
4,635 |
2,420 |
2,150 |
Grade Separations (1) |
|
15 |
|
Locations |
-- |
-- |
-- |
-- |
-- |
-- |
HOV
Lanes (1) |
|
76 |
|
Miles |
-- |
-- |
-- |
-- |
-- |
-- |
Park-n-Ride Lots (2) |
|
8,236 |
|
Spaces |
94 |
60 |
54 |
190 |
100 |
87 |
Pedestrian/Bicycle Facilities |
|
710 |
|
Miles |
1,140 |
727 |
649 |
2,290 |
1,202 |
1,046 |
Rail (1) |
|
96.9 |
|
Miles |
-- |
-- |
-- |
-- |
-- |
-- |
Vanpool |
|
547 |
|
Vanpools |
341 |
217 |
194 |
685 |
360 |
313 |
TOTAL
(lbs/day) |
|
|
|
|
3,881 |
2,454 |
2,190 |
7,800 |
4,082 |
3,596 |
TOTAL
(tons/day) |
|
|
|
|
1.94 |
1.23 |
1.10 |
3.90 |
2.04 |
1.80 |
(1) Emission reduction benefits have been included
directly in the Dallas/Fort Worth Regional Travel Model (DFWRTM). |
|
|
||||||||
(2) Emission reduction benefits are both post-processed
and included directly in the DFWRTM. |
|
|
|
What percentage of
total emission reductions do they represent?
TCMs amount to approximately five percent of on-road NOx emission reductions in 2007 and four percent of on-road VOC emission reductions. Without CMAQ funding, conformity could not have been certified.
Are there CMAQ
projects in your plan for which you have not applied any on or off model
emissions reductions?
No. All CMAQ projects have identified emission reduction credits as requested by the Texas Department of Transportation for a CMAQ Annual Report. It should be noted that the CMAQ program has encouraged a great deal of planning and funding creativity due to different regulations impacting CMAQ and the Surface Transportation Program. This creativity has shaped air quality policies, programs, and projects for the benefit of reaching attainment and better quality of life for each citizen. Without innovative programming, a less aggressive air quality program would have resulted.
If your area has experienced a conformity lapse, describe the effect this
has had on transportation and air quality planning, funding process,
preconstruction, and construction.
The Dallas-Fort Worth
region has not experienced a conformity lapse.
When projects were
reactivated, after U.S. DOT approved your conformity determination, what impact
did this have on funding, project completion dates, personnel, renegotiation of
contracts, updating old information, etc.
This question does
not apply to the Dallas-Fort Worth region.
What
impact did the March 1999 U.S. Court of Appeals decision to eliminate the EPA
"grandfather" provision from the conformity regulations have on your
transportation investments?
The March 1999 U.S. Court of Appeals decision did not have any noticeable impact on transportation investments in the Dallas-Fort Worth region.
ROLE OF MOTOR VEHICLE
EMISSION ESTIMATES AND MODELS
How has
conformity analysis helped improve the quality of estimates of motor vehicle
emissions for SIPs to better protect public health?
The procedure for estimating on-road mobile emissions is consistent for both the SIP and the Air Quality Conformity Analysis. However, conducting a conformity analysis on a more frequent time scale allows for the use of latest planning assumptions and tools to better quantify vehicle emissions. Many parameters involved in the quantification of emissions change over time such as roadway and transit networks, vehicle mix, and demographic data. As a result, new emission estimates are actually created with each conformity analysis. In addition, the effectiveness of control strategies, including TCMs are evaluated based upon implementation schedule and before/after studies. The regular study of a region’s dynamics and the consequential effect on emissions better prepare an agency when it is time to develop a new SIP. Better knowledge of vehicle emission estimates ultimately leads to better protection of public health. This replanning effect is offset by less time actually implementing aggressive air quality strategies.
How
accurate and consistent have estimates of regional motor vehicle emissions been
when compared with each other over time and with actual experience?
Regional on-road motor vehicle emissions estimates in the Dallas-Fort Worth nonattainment area have been consistently following a decreasing trend due to the region implementing many control strategies over the past 10 years. Specifically, significant emissions reductions are attributed to inspection and maintenance, reformulated fuels, transportation control measures, continual advances in vehicle technology, and associated vehicle fleet turnover. Table 3 lists the official on-road mobile emission estimates for the Dallas-Fort Worth ozone nonattainment area.
TABLE 3
Dallas-Fort Worth Ozone Nonattainment
Area Motor Vehicle Emission Estimates |
||
YEAR |
VOC (tpd) |
NOx (tpd) |
1990 |
306.60 |
293.03 |
1996 |
235.00 |
NOx Waiver |
1999 |
125.25 |
NOx Waiver |
2007 |
75.34 |
149.72 |
How have
official estimates of motor vehicle emissions in your metropolitan region
changed over the past 10-20 years and how well have they tracked actual
emissions in years past?
The
overall decrease in modeled motor vehicle estimates compare well with monitor
data from 1990 to 2001. During this
time period, the extents to which the monitors violate the one-hour ozone standard
have steadily decreased indicating a concurrent decrease in precursor
pollutants released into the atmosphere.
In comparison to observed monitored data, the highest number of
exceedances recorded at any given monitor over a three-year averaging period
has decreased from 12 exceedances in the 1994 to 1996 timeframe to 3
exceedances in the 1999 to 2001 timeframe.
Has conformity analysis been supported by adequate regional
transportation analysis models that accurately reflect how changes in highway
capacity affect total travel and air pollution emissions?
Yes
and no. Transportation analysis models
in use today were originally developed for macro-scale level planning, not
micro-scale level planning required in air chemistry modeling. Issues include time-of-day, speeds,
functional classification, vehicle miles of travel, etc. For more information on concerns regarding
existing transportation analysis models and recommendations for future models,
please refer to a report published by the National Research Council; Modeling
Mobile Source Emissions, 2000, National Academy of Science. However, transportation models are more
accurate than emission models (e.g., MOBILE5 vs. MOBILE6) and air chemistry
models (e.g., for 20 years urban areas were told to reduce VOC emissions
instead of NOx emissions.)
How well have your region’s travel models tracked actual experience
with growth in vehicle miles of travel (VMT)?
The Dallas-Fort Worth Regional Travel Demand Model tracks vehicle miles of travel very well. The roadway travel model calibration and validation process are major steps prior to the forecasting process to ensure the travel model replicates observed human travel behavior in the region adequately. In the Dallas-Fort Worth region, models project 20 years backward before they are asked to project 20 years forward.
Please include an indication of how sensitive your/these models are to
effects of induced traffic.
The
travel model is sensitive to the effects of induced traffic. It depends on your definition of induced
travel. Induced travel includes
population and employment relocation, and trip length increases with freeway
investments. This travel model does
this. Route choice and time of day
travel is not classified as induced travel although most models successfully
address this. The better question is
how well does EPA forecast emissions and air quality models forecast ambient
ozone levels accurately. A review of
the previously cited NAS document is suggested.