REG ION 9
FHWA/EPA
AIR QUALITY GUIDELINES SUPPLEMENT
REGIONAL TRANSPORTATION PLAN
CONSISTENCY DETERMINATION
MAY 19 76
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REG ION 9
FHWA/EPA
AIR QUALITY GUIDELINES SUPPLEMENT
REGIONAL TRANSPORTATION PLA
CONS I STENCY DETERS I NAT I ON
MAY 1976
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TABLE OF CONTENTS
Preface Page 1
Background
The Law (23 U.S.C. 109(j))
The Regulations (FHPM 7-7-9)
The Region Nine Guidelines
Relationship to Overall Work Program
Part I: Development of the Consistency Determination Page 3
A. Guidelines for the formation of a "Continuing
Review Procedure"
B. Guidelines on the selection and use of an air
quality analysis
C. S.I.P. strategy coordination
D. Mitigation of air quality impacts
Part II: Contents and Format of an Annual Consistency Submittal Page 6
Part III: Review/Approval Process Page 8
Appendix A: Air Quality Guidelines (FHPM 7-7-9)
Appendix B: Guidelines for Analysis of Consistency Between
Transportation and Air Quality Plans and
Programs (April 1975)
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PREFACE
Section 109(j) was added to Title 23 (Highways) of the United States
Code by the 1970 Highway Act (Public Law 91-605, Section 136(b)).
In its entirety, Section 109(j) reads as follows:
"The Secretary (of transportation), after consultation with the
Administrator of the Environmental Protection Agency, shall develop
and promulgate guidelines to assure that highways constructed pursuant
to this title, are consistent with any approved plan for the implemen-
tation of any ambient air quality standard for any air quality control
region designated pursuant to the Clean Air Act, as amended."
The underlying intent of Section 109(j) was to prevent the expenditure
of Federal funds on the development of plans for the expansion of
transportation systems that are incompatible with plans for the improve-
ment of air quality.
On November 14, 1973, the Federal Highway Administration issued interim
guidelines referenced in the law. The new "Air Quality Guidelines"
were contained in Volume 7, Chapter 7, Section 9 of the Federal-aid
Highway Program Manual (FHPM 7-7-9). After an Environmental Impact
Statement covering the guidelines was circulated, the permanent
directive was issued on November 26, 1974, and became effective 30
days later (December 26, 1974). There were no significant changes in
the portions of the regulation that pertain specifically to transpor-
tation plans and programs.
The Air Quality Guidelines are reproduced in Appendix A: paragraph 7 of
the Air Quality Guidelines provides procedures for the project level
air quality analysis of highway improvements, and paragraph 8 requires
consistency between construction practices and the State Implementation
Plan. Paragraph 6 contains procedures for the systems level air quality
analysis and is the subject of these regional guidelines.
These guidelines are intended to serve as a supplement to the Air Quality
Guidelines and as an aid to those involved in the preparation and review
of air quality consistency determinations relating to transportation
plans and programs. These regional guidelines are not intended to take
the place of the Air Quality Guidelines (FHPM 7-7-9).
Figure 1 represents the process discussed in these guidelines. The
narrative that follows refers to the appropriate sections of Figure 1
as shown by the broken lines.
Work elements covering related activities should be included in the annual
Overall Work Program submitted to the Regional Intermodal Planning Group
(IPG) and appropriate funding should be budgeted. The work required to be
done by the Air Quality Guidelines is eligible for full funding by FHWA;
however, if the region has 208 or AQMA designation, the MPO may wish to
explore the possibility of using these programs as partial funding sources
should additional funding be necessary. The mechanism described in Part
I.A. of these guidelines should be shown in the "Activity Network"
required by the "Guidelines for Metropolitan Planning Organizations'
preparation of Overall Work Program."
1
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Figure 1
Highway
Agency
MPO
L
Air Pollution
Control Agency
J
Establish Continuing
Review Procedure
1
Part I A
Gather Data: Traffic,
Meteorology, Air
Quality, etc.
Does an Adequate Air
Quality Model Exist?
Analyze RTP
("Run" Model)
Develop .Model/
Validate ^Calibrate
Does RTP Contribute
to NAAQS Violations?
N'
\
Part I B
What Mitigation Measures
Can Be Taken?
\
Are all SIP/TCP
Measures Incorporated
into the RTP?
\
,\
Incorporate These Measures
into RTP - Determine Agencies
Responsible for Implementation,
Obtain Commitment
| No
\
f
Yes \
Modify RTP to
Extent Possible
j
N
/
\
Policy Board Makes
Consistency Determi
\
\
\
\
Part I C \ Part I D
/
Fn VMTIPI 1 >_^i AHnnt" PTP \ Fn v*uw v*H Nor'occav^w HOPI impni*?! 1" i nn
nation — Package Through Channels to FHWA
Parts II and III
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PART I: DEVELOPMENT OF THE
CONSISTENCY DETERMINATION
A. Guidelines for the formation of a "Continuing Review Procedure"
In order to achieve an adequate degree of coordination in the
regional comprehensive planning process between air quality
planning and transportation planning, it is desirable to establish
and maintain a mechanism that will insure that air quality
planning constraints are properly considered in the transportation
planning process and vice versa. Ideally, the mechanism will
involve input and coordination among all of the cognizant agencies
involved in either air quality planning or transportation planning,,
The Air Quality Guidelines refer to such a mechanism as a
"continuing review procedure."
Rather than list the ingredients that are required to achieve an
adequate review coordination mechanism, the following questions
can be used to guide the Metropolitan Planning Organizations (MPO's)
in their development of a continuing review procedure:
1. Which are the agencies responsible for air quality and
transportation planning for the region?
2. What are the functional responsibilities of those agencies?
3. How do these responsibilities interrelate?
4. Who are the appropriate staff level contact individuals for
each agency?
5. What has been the past interaction among the agencies?
6. What will be the future interaction among the agencies?
7. Which steps must be taken to bring about an adequate level of
interaction among the agencies?
8. How will this be accomplished (formal agreement? modification
of existing agreements? etc.)?
9. What timetable is proposed for accomplishment of this interaction?
10. How will this insure adequate integration of air quality
considerations into the transportation planning process?
Where other requirements for integration of transportation and air
quality planning exist, such as Air Quality Maintenance Planning
(AQMP), these must be recognized and coordinated with the Continuing
Review Procedure requirements.
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B. Guidelines on the selection and use of an air quality analysis
A second requirement of the Air Quality Guidelines is an annual
determination of consistency of the Regional Transportation Plan
(RTP) with the State Implementation Plan (SIP) for air quality by
the MPO policy board. In order to be meaningful, the consistency
determination must be based upon a suitable technical analysis,
which must be coordinated with all other air quality analyses of
the RTP being made for other planning efforts (i.e., AQMP and
EIR analyses). The following questions are presented in order to
quide the MPO's in their selection of that technical analysis method:
1. What basic analysis technique (including simulation modeling)
will be used?
2. How will the analysis technique be selected? (For example, the
selection of an analysis method could be made by concensus of the
agencies participating in the continuing review procedure.)
3. What are the assumptions upon which the analysis is made?
How valid are these assumptions for the region under consideration?
How sensitive is the analysis to the various assumptions?
4. What input data are required for the analysis?
5. Are these input data available? (If not, how will they be
obtained?)
6. Upon what assumptions are the input data based: How valid are
these assumptions for the region under consideration? How sensitive
is the analysis to these assumptions?
Further guidance on the selection of a level of analysis is found
in Appendix B. The regional offices of FHWA and EPA are available
to assist the MPO's in the selection of an analysis technique on an
individual basis.
C. SIP strategy coordination
RTP/SIP consistency implies, among other considerations, the
inclusion of SIP transportation control strategy measures into the
RTP. The MPO/HA/air quality agency's continuing review mechanism
should include the continuous assessment of both the SIP and the
RTP for the purpose of determining the degree of progress being
made toward that end.
1. What SIP measures come under the planning responsibilities of
the MPO/HA?
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2. What progress is being made toward incorporating these measures
into the RTP?
3. What steps remain to be taken in order to fully incorporate
all relevant SIP requirements into the RTP?
4. How will this be accomplished? What is the anticipated time
schedule?
D. Mitigation of Air Quality Impacts
In the event that the air quality analysis uncovers any potential
air quality problems that will result from implementation of the RTP,
steps will need to be taken to insure that they are mitigated to the
extent possible. As the Regional Transportation Plan evolves,
additional mitigation measures may need to be included to offset
any adverse impacts likely to result from implementation of the RTP.
1. What air quality problems have been identified in the air
quality analysis (if any)?
2. What mitigation measures are proposed?
3. What evidence exists to indicate that these measures will be
adequate?
4. How will these mitigation measures be incorporated into the RTP?
5. Should these mitigation measures be incorporated into other
plans (i.e., the AQMP and/or the SIP)? If so, how will this be
accomplished?
6. What progress has been made toward including in the current RTP
those mitigation measures that have been proposed in previous years?
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PART II: CONTENTS AND FORMAT OF AN ANNUAL
CONSISTENCY DETERMINATION SUBMITTAL
The Air Quality Guidelines require the MPO and highway agencies to:
1. Establish a continuing review procedure with the air pollution
control agency.
2. Assess the consistency of the transportation plans and programs with
the approved SIP.
3. Annually solicit comments from the air pollution control agency
prior to transportation plan approval by the policy board.
4. Identify and attempt to resolve differences with the air pollution
control agency.
Further, the MPO policy board is required to make a formal annual
determination of consistency between the current RTP and the approved
SIP.
The Air Quality Guidelines also charge the Regional Administrators of
the Federal Highway Administration and the Environmental Protection
Agency with annually: (1) assessing the degree of coordination, and
(2) reviewing the determination of consistency. With this in mind,
following is a list of minimum items to be contained in the annual
air quality submittal:
A. Contents
1. A description of the continuing review procedure: As a minimum,
this should consist of a discussion of all the points in Part I.A. of
these guidelines. It is likely that a flow chart (with a time line)
will be of great value in demonstrating how the various agencies will
interact and how the review procedure will be integrated into the
transportation planning process. The inclusion of such a flow chart
into the air quality submittal is strongly encouraged.
2. Technical analysis: This portion shall consist of a discussion of
the rationale and a summary of the analysis used to support the deter-
mination of consistency. Included in the discussion of the rationale
will be, as a minimum: the points discussed in Part I.B. of these
guidelines, the results of the technical analysis to determine what
the future impact of the RTP on air quality will be, and the points
outlined in Part I, Sections C and D, of these guidelines.
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3. Written comments received from the air pollution control agency:
This should contain only those comments pertinent to the RTP/SIP
Consistency Determination. Unless there is complete agreement
between the MPO and the APCA, this section should contain a thorough
discussion of the disposition of the air pollution control agency's
comments by the MPO policy board. For example, if the MPO policy
board makes a positive determination of consistency in spite of a
negative determination by the air pollution control agency, a detailed
explanation is obviously warranted.
4. A record of consistency determination by the policy board: Any
reasonable documentation, such as: a copy of a resolution passed
by the policy board (desirable); a copy of the policy board meeting
minutes; or a statement that the consistency determination was made
by the policy board in the MPO's transmittal letter will be acceptable.
(However, if the policy board's consistency determination contains
qualifying clauses, then these qualifying statements should be
pointed out and fully explained in the transmittal.)
5. A report on accomplishments addressing previously cited
deficiencies relating to the Air Quality Consistency Determination.
6. The Transportation Plan and Program, or suitable summary.
B. Format
To the extent possible, all of the pertinent information related to
the Air Quality Consistency Determination shall be consolidated
into a separate statement which should be self-contained to the
extent practicable. In the case where an Environmental Impact
Report is prepared on the plan, it may be necessary to repeat
information contained in the EIR to eliminate excessive references
to it.
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PART III: REVIEW/APPROVAL PROCESS
Figure 2 is a flow chart combining the steps required by the Air
Quality Guidelines (FHPM 7-7-9) and the steps that will be
followed by this region in reviewing the air quality submittals.
Note particularly that three copies of the submittal will be needed.
It is advisable that the highway agency and the MPO keep FHWA apprised
of significant accomplishments throughout the development of the
annual consistency determination. This should be done as informally
as possible.
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Figure 2
t MPO/HA Assess Consistency of TPP with SfF
MPO/HA Solicit Comments from APCA Including
Its Assessment of Consistency of TPP with SIP
.MPO/HA Identify and Attempt to Resolve Differences with
APCA
HA Requests MPO Policy Board to Determine
Consistency of TPP with SIP (by Resolution)
MPO Policy Board Determines Consistency
MPO Policy Board Adopts TPP
HA Transmits (3 copies): 1) Description of the "Continuing Review Procedure";
2) Rationale and Analysis Used; 3) Comments by APCA and Disposition of
Comments by MPO Policy Board; 4) Record of Determination; 5) Report on
Accomplishments; and 6) TPP to FHWA Division Office
Upon Receipt, FHWA Division Office
Transmits (2 copies) to FHWA Region Office
•«/
FHWA Division Office Reviews and
Transmits Comments and Recommendations
to FHWA Region
1 r
i v •£ ,
I FHWA Region Office Reviews |
Upon Receipt, FHWA Region Office
Transmits (1 copy) to EPA Region
Office
i i
•4'
EPA Region Office Reviews |
FHWA/EPA Resolve Differences, Assess Degree
of Coordination (Between MPO/HA and APCA),
and Review Determination of Consistency
No Deficiencies Found
f
Minor Deficiencies Found
Major Deficiencies Found
Process May Be Either "Certified" or
"Certified with Deficiencies" Depending
Also on Other Planning Certification
Considerations by FHWA and UMTA
Certification Withheld
(Certification May Also
Be Withheld for Other
Reasons)
LEGEND:
HA Highway Agency
MPO Metropolitan Planning Organization (3C Planning Agency)
APCA Air Pollution Control Agency (State and/or Local)
TPP Transportation Plan and Program
SIP State Implementation Plan (as approved or promulgated by EPA, latest revision)
FHWA Federal Highway Administration
EPA Environmental Protection Agency
UMTA Urban Mass Transportation Administration
^Reference FHPM, Volume VII, Chapter 7, Section 9, paragraph 6
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U- s- DEPARTMENT OF TRANSPORTATION
FEDERAL HIGHWAY ADMINISTRATION
FEDERAL-AID HIGHWAY PROGRAM MANUAL
VOLUME
RIGHT-OF-WAY AND ENVIRONMENT
CHAPTER
ENVIRONMENT
SECTION
AIR QUALITY GUIDELINES
Transmittal 105
November 26, 1974
HEV-10
Par. 1. Purpose
2. Authority
3. Definitions
4. Policy
5. Application
6. Urban Transportation Plans and Programs
7. Highway Sections
8. Construction of Highways
1. PURPOSE
* To issue policy and procedures covering air quality
guidelines for use in planning- location and construction
of highway improvements pursuant to 23 U.S.C.
2. AUTHORITY
a. 23 U.S.C., Sections 109(h) and 109(j).
b. 42 U.S.C., Section 4332.
3. DEFINITIONS
a. Action. The construction or reconstruction, including
associated activities, of a highway section.
b. Air Quality Control Region. An interstate or intra-
state area designated by the Administrator of the
Environmental Protection Agency (EPA) pursuant to U.S.C,
185? (Section 108 of the Clean Air Act of 1970).
*Regulatory material is italicized
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Federal-Aid Highway Program Manual Vol. 7, Ch, 7
Transmittal 105, November 26, 1974 Sec. 9
o. Air Pollution Control Agency^. The State, local or
multistate agency as defined by 42 U.S. C. 1.857
(Section 302(b) of the Clean Air Act of 1970).
d. Environmental Impact Statement (EIS). A detailed
statement prepared in response to 42 U.S.C. 4332
(Section 102(2)(C) of the National Environmental
Policy Act of 2969).
e. Highway Agency. The agency with the primary responsi-
bility for initiating and carrying forward the action.
For highway sections financed with Federal-aid highway
funds, the highway agency will normally be the appro-
priate State, county or city highway agency. For
highways financed with other funds, such as forest
highways, park roads, etc., the highway agency will
be the appropriate Federal or State agency with the
primary responsibility for initiating and carrying
forward the action.
f. Highway Section. A highway development proposal
between logical termini (population centers, major
traffic generators, major crossroads, etc.) as normally-
included in a location study or multiyear highway
improvement program.
g. Indirect Source Review Agency. The agency designated
in an applicable State implementation plan to meet
the requirements of 40 CFE 51.18 (38 Federal Register
15834, June 18, 1973).
h. National Ambient Air Quality Standards. The National
Ambient Air Quality Standards established pursuant to
42 U.S.C. 1857 (Section 109 of the Clean Air Act of 1970)
i. negative Declaration. A document supporting a deter-
mination that a proposed,, major action, will not have a
significant impact upon the quality of the human
environment of a magnitude to require the processing
of an EIS.
3 - Policy Board (Policy Committee,,, Coordinating Committee,,
etc.). That group of local officials, individuals or
representatives of agencies or organizations which have
been designated by the State to provide policy guidance
and direction in the conduct of the urban transportation
planning process in an urbanized area.
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m.
Federal-Aid Highway Program Manual Vol. 7, Ch. 7
Transmittal 105, November 26, 1974 Sec. 9
Urban Transportation Planning Process (3C Planning
Process). The continuing, comprehensive and cooperative
planning process established pursuant to 23 U.S.C. 134.
State Implementation Plan (SIP). The plan required by
42 U.S.C. 1857 (Section 110 of the Clean Air Act of
1970) to attain and maintain a national ambient air
quality standard. For the purpose of this directive,
an approved SIP is the implementation plan, or most
recent revision thereof, which has been approved or
promulgated by the Environmental Protection Agency
under Section 110 of the Clean Air Act.
Urban Transportation Plans and Programs. Proposed
areawide plans and proposed capital improvement programs
developed through the urban transportation planning
process.
4. POLICY
It is the policy of the Federal Highway Administration (FHWA)
that highway agencies responsible for the planning, location
and construction of highways pursuant to 23 U.S.C. consult
with the local, State and Federal air pollution control
agencies, as appropriate, and assure that decisions on
highways are consistent with approved State implementation
plans and that adequate consideration is given to preser-
vation and enhancement of air quality .
5. APPLICATION
Land use, air quality and transportation planning are
interdependent. It is, therefore, essential that planning
activities be closely coordinated in the conceptual stages
and throughout the highway development process. The highway
agency shall follow the appropriate procedures outlined in
paragraphs 6 through 8 in order to assure that the planning,
location, and construction of highways are consistent with
the approved State implementation plan for attainment and
maintenance of air quality standards.
a,
The continuing review procedure described in paragraph 6
shall be a requirement for each transportation planning
process established pursuant to 23 U.S.C. 134.
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Federal-Aid Highway Program Manual Vol. 7, Ch. 7
Transmittal 105, November 26, 1974 Sec. 9
b. The procedures for consideration of air quality described
in paragraph 7 shall apply to the processing of Federal-
aid highway proposals.
a. The procedures described in paragraph 8 shall apply to
the consideration of construction specifications as
related to air quality.
6. URBAN TRANSPORTATION PLANS AND PROGRAMS
a. To assure that land use and transportation planning
conducted pursuant to 23 V.S.C. 134 and air quality
planning conducted pursuant to 42 U.S.C. 1857 and the
transportation plans resulting therefrom are coordinated,
the responsible highway agency in cooperation with each
SC planning agency shall establish a continuing review
procedure with the air pollution control agency to:
(1) assess the consistency of the transportation plan
and program with the approved State implementation
plan,
(2) solicit comments annually from the air pollution
control agency including its assessment of the
consistency of the transportation plan and program
with the approved State implementation plan prior
to transportation plan approval by the policy board,
and
(3) identify and attempt to resolve differences with
the air pollution control agency.
b. The highway agency shall request the policy board to
annually determine the consistency of the current
transportation plan and program with the approved State
implementation plan. The highway agency shall furnish
FHWA a record of this determination along with any
written comments received from the air pollution control
agency and the policy board's disposition of these comments,
c. The Regional Federal Highway Administrator, in consultation
with the Regional Administrator of the Environmental
Protection Agency, shall annually:
(1) assess the degree of coordination in the planning
process between planning for transportation and air
quality planning, and
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Federal-Aid Highway Program Manual Vol. 7, Ch. 7
Transmittal 105, November 26, 1974 Sec. 9
(2) review the determination on consistency between
the transportation plan and program and the
approved State implementation plan.
d. Any deficiencies shall be cited to the highway agency.
Significant deficiencies (including major instances of
inconsistency) shall be considered by the Regional
Federal Highway Administrator as grounds for withholding
planning certification.
HIGHWAY SECTIONS
a. The following procedures shall apply to highway
sections for which both the draft and the final
environmental impact statement are submitted to
FHWA or for which a negative declaration is
considered by FHWA after the effective date of
this directive:
(1) The studies and coordination activities related
to the construction or reconstruction of a
highway section shall include an appropriate
consideration of air quality. The level of this
consideration and/or the air quality analysis
is to be determined on the basis of the nature
and location of the highway section, anticipated
traffic volume, existing air quality problems,
sensitivity of nearby receptors to air pollution,
and meteorological conditions. It is anticipated
that lower volume facilities in areas without
critical air quality problems can be satisfac-
torily analyzed using simplified analysis techniques
and that onsite measurements will not be required.
High volume facilities in areas with critical air
quality problems will usually require onsite data
gathering and a high level of analysis.
(2) For highway sections where a negative declaration
rather than an EIS is to be prepared, the negative
declaration shall briefly outline the air quality
considerations involved in the development of the
highway proposal. For highway sections subject to
the requirements of 40 CFR 51.18 (see Attachment 1) ,
"Review of New Sources and Modifications," the
negative declaration shall also include a record
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Federal-Aid Highway Program Manual Vol. 7, Ch. 7
Transmittal 105, November 26, 1974 Sec. 9
of required coordination with the indirect source
review agency. The FHWA Division Engineer shall
review the air quality information in the negative
declaration for adequacy. FHWA adoption of the
negative declaration shall constitute the FHWA
determination that the highway is considered to be
consistent with the approved State implementation
plan.
(3) For highway sections on which a draft EIS is
prepared, the draft shall contain:
(a) an -identification of the air quality impact of
the highway section,
(b) an identification of the analysis methodology
utilized,
(a) a brief summary of the early consultation
with the air pollution control agency and,
where applicable, a brief summary of consul-
tation with the indirect source review agency,
(d) any comments received from the air pollution,
control agency and, where applicable, any
comments received from the indirect source
review agency, and
(e) the highway agency 's determination on the
consistency of each alternative under consid-
eration with the approved State. implementation
plan.
(4) Where required by 40 CFR 51.18 (see Attachment 1),
the preferred alternative shall be submitted to
the indirect source review agency for review. The
proposed final EIS shall not be submitted to the
FHWA Regional Administrator for adoption if the.
indirect source review agency has found as a part
of the procedures established pursuant to 40 CFR 51.18
that the highway section will result in a violation
of applicable portions of the control strategy or
will interfere with the attainment or maintenance of
the National Ambient Air Quality Standards.
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Federal-Aid Highway Program Manual Vol. 7, Ch. 7
Transmittal 105, November 26, 1974 Sec. 9
(5) The final EIS may be adopted by the FHWA only
after FHWA has determined that the proposed
highway section is consistent with the approved
State implementation plan. The determination
on consistency shall be made by the Regional
Federal Highway Administrator.
(6) In making his determination, the Regional Federal
Highway Administrator shall consider the following:
(a) the adequacy and the conclusions of the air
quality analysis,
(b) the comments received from the air pollution
control agency resulting from the require-
ments of paragraphs 6a(2) and 7a(3) (Where
issues raised by the air pollution control
agency have not been resolved by the highway
agency or the FHWA Division Engineer prior to
submission of the proposed final EIS to the
FHWA, the Regional Administrator shall not
make a positive determination on consistency
without first consulting with the EPA Regional
Administrator), and
(c) comments received from other agencies as part
of the EIS procedure and the disposition of
these comments.
(7) The Regional Federal Highway Administrator shall
furnish the results of any consultation with the
EPA Regional Administrator on the final EIS and
the FHWA determination on consistency in the
transmitted information for those final environ-
mental impact statements which require review by
FHWA Headquarters.
The following procedures shall apply to highway sections
for which the draft environmental impact statement was
submitted to the FHWA prior to the effective date of
this directive and for which the final environmental
impact statement is submitted to FHWA after the effec-
tive date of this directive:
(1) Prior to the processing of the final EIS, the
highway agency, in consultation with the FHWA
Division Engineer, shall review available material
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Federal-Aid Highway Program Manual Vol. 7, Ch. 7
Transmittal 105, November 26, 1974 Sec. 9
on the development of the highway section, including
the draft EIS, and shall make a written determination
on the adequacy of the consideration of air quality
for the highway section.
(2) If the determination concludes that the consideration
of air quality is adequate, the final EIS may be
processed following established EIS processing
procedures.
(S) If the determination concludes that additional
information and/or analysis are necessary, a
revised draft or supplement shall then be furnished
to appropriate local, State and Federal agencies
with expertise in air quality. At least 45 days
shall be allowed for comment by interested agencies.
(4) Comments received shall be incorporated and addressed
in the final EIS as required in Volume 7, Chapter 7,
Section 2 of the Federal-Aid Highway Program Manual,
"Environmental Impact and Related Statements."
(5) Where required by 40 CFR 51.18 (see Attachment 1),
the preferred alternative shall be submitted to the
indirect source review agency for review. The
proposed final EIS shall not be submitted to the
FHWA Regional Administrator for adoption if the
indirect source review agency has found as a part
of the procedures established pursuant to 40 CFR 51.18
that the highway section will result in a violation
of applicable portions of the control strategy or
will interfere with the attainment or maintenance
of the National Ambient Air Quality Standards.
(6) Where issues raised by the air pollution control
agency have not been resolved by the highway agency
or the FHWA Division Engineer prior to submission
of the proposed final EIS to the FHWA, the FHWA
Regional Administrator shall not make a positive
determination on consistency without first consulting
with the EPA Regional Administrator.
(7) Adoption of the final EIS by the FHWA shall constitute
the FHWA determination that the highway section is
considered to be consistent with the approved State
implementation plan.
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Federal-Aid Highway Program Manual Vol. 7, Ch. 7
Transmittal 105, November 26,, 1974 Sec, 9
o. The following procedures shall apply to highway
sect-ions for which the final environmental impact
statement is submitted to FHWA not later than the
effective date of this directive, for which a
substantial amount of the grade and drain work
remains to be advertised for bids, and for which a
decision on the consistency of the highway section
with the approved State implementation plan has not
been made by the Regional Federal Highway Administrator;
(1) The highway agency shall review the information
available on the development of the highway
section, including the final EIS, and shall
prepare a report for the FHWA on the consistency
of the proposed action with the approved State
implementation plan.
(a) If the highway agency or the FHWA Division
Engineer concludes that additional infor-
mation and/or analysis are necessary to make
a determination on consistency., the highway
agency shall develop such information or
perform such analysis before making the
report.
(b) If the information on the development of
the highway section or the air quality
analysis indicates that implementation of
the proposed action will result in a signi-
ficant air quality impact, the highway agency
shall solicit comments from and consult with
the air pollution control agency. In such
cases, the report shall set forth the
anticipated air quality effects of the
proposal, a brief summary of coordination
with the air pollution control agency,
including comments received, and a discussion
of substantial unresolved air quality issues^
if any.
(2) The FHWA Division Engineer may concur in such
reports, except those which include an inconsistency
finding by the air pollution control agency. Concur
rence in the report by the FHWA Division Engineer
shall constitute the FHWA determination that the
highway section is considered to be consistent with
the approved State implementation plan.
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Federal-Aid Highway Program Manual Vol. 7, Ch. 7
Transmittal 105, November 26, 1974 Sec. 9
(S) Reports containing an inconsistency finding shall
be forwarded to the FHWA Regional Administrator.
Before concurring in proposed highway section
approvals, the FHWA Regional Administrator shall
consult with the EPA Regional Administrator for
the purpose of reviewing the air quality informa-
tion and consistency determination presented in
the report.
(4) Concurrence in_ proposed highway section approvals
by the FHWA Regional Administrator shall constitute
the FHWA determination that the highway section is
considered to be consistent with the approved State
implementation plan.
(5) The FHWA Regional Administrator may request prepara-
tion and processing of a revised or supplemental
EIS for the highway section where, in his judgement,
the air quality issues raised are of such magnitude
as to make the processing in this form necessary.
The revised or supplemental EIS shall be processed
in accordance with procedures contained in Volume 7,
Chapter 7, Section 2 of the Federal-Aid Highway
Program Manual, "Environmental Impact and Related
Statements."
d. Advancement of highway sections may continue under the
provisions of 23 U.S.C. where the Regional Federal
Highway Administrator has made a consistency determination
in accordance with the interim regulations (23 CFR 770,
38 FR 31677) or where a substantial amount of the grade
and drain work has been authorized prior to the effective
date of this directive.
8. CONSTRUCTION OF HIGHWAYS
a. The highway agency shall take steps to assure that its
current specifications, and any revisions thereof, and
the use of specific equipment and/or materials associated
with construction are consistent with the approved State
implementation plan. This shall be accomplished in
coordination with the air pollution control agency.
b. The highway agency shall establish procedures in order
that any changes in the State implementation plan will
be reviewed to determine if revisions to the construction
specifications will be necessary.
10
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Federal-Aid Highway Program Manual Vol. 7, Ch. 7
Transmittal 105, November 26, 1974 Sec. 9
G. Revisions to the construction specifications resulting
from the above requirements shall be made in consulta-
tion with FHWA.
11
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Federal-Aid Highway Program Manual Vol. 7, Ch. 7
Transmittal 105, November 26, 1974 Sec. 9, Attach. 1
REVIEW OF NEW SOURCES AND MODIFICATIONS
(40 CFR 51.18)
"Indirect Source Regulations"
As a result of a court order by the U.S. Court of Appeals for
the District of Columbia, Code of Federal Regulations Title 40,
Chapter I, Part 51, Section 18 (40 CFR 51.18), "Review of New
Sources and Modifications," was promulgated June 18, 1973,
requiring the States to submit revisions to the State imple-
mentation plans in order to include a consideration of the
air quality impact not only of pollutants emitted directly
from the stationary sources, but also of pollution arising
from mobile source activity associated with such buildings
or facilities (termed indirect sources). Indirect sources
were defined to include, but were not limited to, highways
and roads, shopping centers, commercial or industrial develop-
ments, recreation centers, parking lots and garages, sports
stadiums and airports.
In order to comply with the indirect source regulations, the
States were to submit revisions to their State implementation
plans by August 15, 1973; where States submitted inadequate
plan revisions or where no submission was made, the Environ-
mental Protection Agency (EPA) was required to promulgate
plan revisions which would meet the air quality maintenance
requirements.
By August 15, 1973, only a very few States had submitted
acceptable revisions to their State implementation plans.
Consequently, EPA promulgated regulations for review of
indirect sources for those States not submitting acceptable
revisions. The promulgated regulations (40 CFR 52.22) were
published in final form on February 25, 1974 (39 FR 7270), and
revised on July 9, 1974 (39 FR 25292).
These regulations assign the responsibility for review of
indirect sources to the Administrator of EPA. The revised
regulation (40 CFR 52.22) requires that those highways in
Standard Metropolitan Statistical Areas (SMSA) meeting the
following criteria be subject to indirect source review:
1. any new highway project with an anticipated average
annual daily traffic volume of 20,000 or more vehicles
per day within 10 years of construction, or
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Federal-Aid Highway Program Manual Vol. 7, Ch. 7
Transmittal 105, November 26, 1974 Sec. 9, Attach. 1
2. any modified highway project which will increase
average annual daily traffic volume by 10,000 or
more vehicles per day within 10 years after modifi-
cation.
For new highway projects with anticipated traffic volume greater
than 20,000 but less than 50,000 vehicles per day, an evaluation
of the carbon monoxide concentration at reasonable receptor
locations is required.
For new highway projects with an anticipated average daily
traffic volume of 50,000 or more vehicles within 10 years of
construction (or modified highway projects resulting in an
increase of the average daily traffic volume by 25,000 or more
vehicles within 10 years after modifications) an area-wide
analysis of expected concentrations of photochemical oxidants
and nitrogen dioxide is required in addition to the evaluation
of carbon monoxide concentrations.
The regulations provide that the construction or modification
of an indirect source shall not commence after December 31, 1974,
without approval from EPA. The phrase "to commence construction"
has been defined in the regulation as follows: "To engage in a
continuous program of onsite construction including site clearance,
grading, dredging, or land filling specifically designed for an
indirect source in preparation for the fabrication, erection, or
installation of the building components of the indirect source."
The regulations establish a process with specific time frames
identified for each element of the review process. Within 30
days of receipt of an indirect source application, EPA is
required to make a preliminary determination of approval or
disapproval and to notify the public of the proposal and of its
preliminary determination. EPA is also required to allow an
additional 30 days for public comment. No later than 10 days
after the 30-day comment period, the applicant may submit a
written response to any comments submitted by the public. EPA
must take final action on the application within 30 days after
the close of the public comment period (or within 90 days of the
application date).
The Administrator of EPA has continued to encourage States to
develop and submit their own indirect source review procedures
with the understanding that EPA will revoke its promulgated plan
upon finding a State's procedures to be acceptable.*
*As of September 1, 1974, the States of Alabama, Florida, Kentucky,
and North Carolina had submitted acceptable revisions to their
State implementation plans to provide for the review of indirect
sources.
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GUIDELINES FOR ANALYSIS OF CONSISTENCY
BETWEEN TRANSPORTATION AND AIR QUALITY PLANS AND PROGRAMS
PREPARED JOINTLY BY
THE FEDERAL HIGHWAY ADMINISTRATION
and
THE ENVIRONMENTAL PROTECTION AGENCY
April 1975
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Form FHWA 121 (Rev. 5-73)
JNITED STATES GOVERNMENT
(um
DEPARTMENT OF TRANSPORTATION
FEDERAL HIGHWAY ADMINISTRATION
DATE:
SUBJECT, "Guidelines for Analysis of Consistency Between
Transportation and Air Quality Plans and Programs"
FROM s Associate Administrator for Planning
Washington, B.C. 20590
HHP-23
TO
Regional Federal -Highway Administrators
Regions 1 through 10
The attached "Guidelines for Analysis of Consistency Between
Transportation and Air Quality Plans and Programs" were
developed jointly by the Federal Highway Administration (FHWA)
and the Environmental Protection Agency (EPA). The guidelines
represent agreement between the FHWA and the EPA, at the national
level, on the methods of analysis appropriate for determining
whether metropolitan planning organization transportation plans
and programs are consistent with State plans for implementing
national ambient air quality standards. A primary objective in
developing the guidelines was to identify levels of analysis
commensurate with the severity of the air pollution problem in
a specific geographic area.
The guidelines for analysis are being distributed to assist in
implementing the procedures described in the FHWA "Air Quality
Guidelines," Volume 7, Chapter 7, Section 9, of the Federal-Aid
Highway Program Manual. As noted in the introduction to the
guidelines for analysis, the guidelines should not be
interpreted as a limitation on the types of air quality assessment
methods that may be used. The purpose of the analysis guidelines
is to provide assistance to all the agencies preparing and
reviewing consistency determinations in reaching agreement on
what constitutes an adequate air quality analysis.
The joint FHWA-EPA working group that prepared the analysis guidelines
will refine and supplement the guidelines, as necessary, based on the
experience gained during the consistency determination reviews. Any
comments you,may have concerning the analysis guidelines will be
appreciated.
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The EPA concurs in the recommendations of air quality analysis
procedures contained in "Guidelines for Analysis of Consistency
Between Transportation and Air Quality Plans and Programs."
Attachment
Concurrence by:
Date:
Roger Strelow
Assistant Administrator for Air and
Waste Management
Environmental Protection Agency
£5 1975
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I. INTRODUCTION j_
II. DETERMINATION OF LEVEL OF ANALYSIS 2
A. Analysis Area Air Quality 3
1. AQCR Priority Classification
2. TCP Adoption Or Promulgation
3. AQMA Designation
B. Years of Analysis 5
1. Initial Air Quality Analysis Years
2. Long-Range Plan Year
3. Interim Analysis Years
a. Attainment Year
b. Short-Range Transportation Improvement Program
(TIP) Year
c. AQMP Year
C. Analysis Input Data Requirements 8
1. Development of Levels A and B Data
2. Determination of Appropriate Data Level
D. Methods of Analysis 12
1. Total Pollutant Burden
2. Rollback Modeling
3. Air Quality Simulation Modeling
M-. Selection of Analysis Method
III. INTERAGENCY COORDINATION ^
IV. DETERMINATION OF CONSISTENCY 16
V. APPENDICES
A. Prioritv Classification Criteria
B. Priority I AQCRS
C. Priority III AQCRS With Violations on the NAAQS
D. AQCR With TCPS
E. AQMA's for Transportation Related Pollutants
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GUIDELINES FOR ANALYSIS OF PLAN AND PROGRAM CONSISTENCY
I. INTRODUCTION
The 1970 Federal-Aid Highway Act added Section 109 (j) to Title 23
U.S.C. and directed the Department of Transportation to develop and
promulgate guidelines to assure that highways constructed with Federal
funds are consistent with any approved plan for implementation of any
ambient air quality standard. On November 26, 1974, the Federal Highway
Administration (FHWA) published final regulations setting forth the
procedures for establishing such consistency with approved State air
quality implementation plans. The regulations require annual determin-
ations by the policy board of Metropolitan Planning Organizations (MPO's)
that the transportation plans and programs of the agencies are consistent
with the State implementation plans. The regulations also require
continuing coordination between the transportation planning process and
the relevant air pollution control agencies.
Under the FHWA regulations, the Environmental Protection Agency
(EPA) has certain responsibilities in the implementation of section 109 (j) .
The FHWA regional administrator must consult annually with the regional
administrator of the EPA to (1) assess the degree of coordination in
the planning process between planning for transportation and air quality
planning, and (2) review the determination on consistency between the
transportation plan and program and the approved State implementation
plan. The primary purpose of these guidelines, developed jointly by
the EPA and FHWA, is to assist State and local agencies in identifying
the appropriate levels of analyses for determining the effect of MPO's
transporation plans and programs on air quality and to provide EPA
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and FHWA regional offices with guidance in reaching agreement in
their review of air quality assessments upon which the policy board's
consistency determinations are made.
The EPA and the FHWA recognize that, in many instances, these
guidelines will not be available in sufficient time to be used by
State and local agencies in making the consistency determinations
required for the 1975 fiscal year. These guidelines should not be
interpreted as a limitation on the types of air quality assessment
methods that may be used. The guidelines are not meant to require
additional study or analysis if the agencies preparing the air quality
assessments to be used as a basis for the consistency determinations
have reached agreement with reviewing agencies on the appropriate
methods of analysis. The guidelines are also not meant to restrict the
scope of already agreed upon studies. If agreement is not reached
on what constitutes an adequate analysis on which to base a consistency
determination, these guidelines should be used as a means of reaching
agreement. Although some minor changes in the guidelines may occur
as a result of the increased experience gained during the 1975
consistency determinations, no major modifications are anticipated,
II, DETERMINATION OF THE LEVEL OF ANALYSIS
The scope and detail of the air quality analysis on which the
policy board's consistency determinations are based should be commen-
surate with existing and possible future air quality problems in the
MPO planning areas.
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3
The air quality analysis procedures can be separated into four
components. By using variations of each of these components, levels
of analysis can be developed which are appropriate for specific air
quality problems, existing or potential, in the MPO planning areas.
The four components are:
A. Analysis Area Air Quality
B. Analysis Years
C. Analysis Input Data Requirements
D. Analysis Methods
A. Analysis Area Air Quality
The level of air quality analysis and the years for which the
analysis is carried out should be based on the nature and severity
of the existing and forecasted air quality problems in the MPO' s planning
area. Three criteria are used to determine the nature and severity of
transportation-related air quality problems:
1. Air quality control region (AQCR) priority classifications
for carbon monoxide (CD) , photochemical oxidants (Ox) and nitrogen
dioxide (N02) .
2. Transportation control plan (TCP) adoption or
promuIgation.
3. Air quality maintenance area (AQM&) designation for
CD, Ox or N02.
1. AQCR priority classification
In 1972 AQCR's were classified priority I or priority III
for CD, Ox, and MO2, the transportation-related pollutants. The
priority classifications were based either on existing air quality
measurements or, if no air quality measurements had been made, on the
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4
size of the urban population in the AQCR. The purpose of the classifi-
cations was to establish the levels of analysis necessary in preparing
State plans to implement the National Ambient Air Quality Standards
(NAAQS). AQCR's were classified priority I where pollutant concentrations
at certain levels above the NAAQS were measured. In the absence of
measured data AQCR's were also classified priority I, with respect
to CD, QX and NC>2, if they contained an area whose 1970 "urban place"
population exceeded 200,000. All other AQCR's were classified priority
III. The CD, Ox, and N02 concentrations used as criteria for making
AQCR priority classifications are listed in Appendix A. AQCR's which
have been classified priority I for any of these three pollutants are
listed in Appendix B. The counties and urban areas in each AQCR are
listed in the EPA publication "Federal Air Quality Control Regions. "•='
Some areas, where there were no air quality measurements and
where the 1970 populations were under 200,000, were erroneously
designated priority III. Recent air quality monitoring data have
revealed that some of these areas now experience pollutant concentra-
tions in excess of the levels used as criteria for priority I
classification. In addition, other areas having measured pollutant
concentrations less than priority I level at the time of AQCR
classification now have levels sufficiently high to be reclassifiad
priority I. Attachment C lists those priority III AQCR's in need of
reclassification. Because the EPA intends to change the priority I
criteria from the levels listed in Appendix A to levels coinciding
with NAAQS, Appendix C lists all priority III areas with measured con-
centrations above NAAQS, The MPO Policy Board should be aware of the
impending classification changes and should begin making preparation
for appropriate AQCR air quality analysis.
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5
2. TCP adoption or promulgation
In 31 metropolitan areas, the emission reductions
resulting from implementation of relatively stringent stationary
source controls and of Federal emission standards for new motor
vehicles will be insufficient to attain national ambient air quality
standards by the attainment dates required by the Clear Air Act. In
these areas measures were adopted by the States or promulgated by the
EPA to reduce emissions from individual vehicles or to reduce vehicle
travel. The areas in which TCP's are required as parts of the State
plans to implement NAAQS are listed in Appendix D.
3. AQMA designation
The States and the EPA have made preliminary
identifications of geographical areas where the potential exists for
violation of NAAQS in the years following the attainment of these
standards through 1985. For these areas, States must include within
their air quality implementation plans additional measures to assure
the maintenance of the NAAQS, once attained. These additional measures
comprise and are referred to as the "air quality maintenance plan"
(AQMP) for the period 1975-1985. Areas which have been tentatively
designated AQMA.' s for transportation-related pollutants are listed
in Appendix E.
B. Years of Analysis
Again, the years for which analyses of the MPO transportation
plans and programs should be carried out as part of the determination
of consistency with State air quality implementation plans should be
determined by the nature and severity of the air pollution problem
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6
in the planning area and by v/hether violations of NAAQS are existing
or potential. The analyses should be completed for an initial air
quality analysis year, for the year of the long-range plan, and for
one or more interim years. The interim years may include the year
for NAAQS attainment, and the year projects in the short-range
transportation improvement program (TIP) are expected to be completed,
or the year of the AQMP-
1. Initial air quality analysis year
Analysis of some past year is necessary to
establish relationships between air pollutant emissions and concen-
trations which can then be used in forecasting the future year emissions
allowable if NAAQS are to be attained and maintained. The selection
of the initial air quality analysis year is determined primarily by
the availability of air quality concentration measurements. In sane
instances, air pollutant concentrations will not have been monitored
during the most recent year for which the MPO has collected and
analyzed transportation and land use information. In these cases, a
proportional type adjustment in the emissions estimated from base
year transportation and land use data will be necessary to have
measured air quality concentrations and emissions data for a common
year.
2. Long-range plan year
The long-range plan year will vary from area to
area depending, in part, on the year the transportation planning process
was initiated or on the year of the most recent plan update. In
general, the target year of the long-range plan will be about 20 to 25
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7
years f ran the year of plan development or the most recent update
and will include evaluation of alternative transportation systems for
one or more land use forecasts. One alternative normally evaluated
is a "no-build" case where future transportation demands are
accommodated on the existing transportation system. In general, the
analysis of the effect of the long-range plan on air quality should
include an assessment of the no-build alternative as well as of the
selected plan alternative.
3. Interim analysis years
To assure attainment and maintenance of
NAAQS in AQCR's where violations of the standards now exist or
are forecasted, one or more years between the base year and the year
of the long-range plan should be analyzed as part of the consistency
determination. If a major highway or airport requiring an indirect
source permit from EPA or a State, or local agency is being proposed,
this may also influence the interim year or years selected for analysis.
a. Attainment year. The 1970 amendments to the
Clean Air Act require that NAAQS must be attained by 1975 or no later
than 1977, if an extension for attainment has been granted by the
Administrator of the EPA. To assure that the air quality standards are
attained within the applicable time frame, those areas where trans-
portation control plans have been adopted by States or promulgated by
the EPA should be analyzed for the attainment year.
b. Short-range Transportatiom Improvement Program
(TIP) Year. The short-range TIP identifies
proposed transportation system improvements proposed for implementation
in the planning area in the near term. These programs represent the
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8
MPO's projection of projects proposed for implementation and, as such,
provide an indication of what the transportation system will include
in some future year prior to the long-range plan target year. By
estimating the emissions from the existing transportation system and
including the short-range program improvements, it is possible to
provide a general indication of the air quality of the area in the
year the short-range program is fully implemented and open to traffic.
This year will be approximately 10 years from the current year and may
coincide with the AQMp year.
c. AQMP year. Additional provisions are being
added to State plans to implement NAAQS to assure that the plans provide
for maintenance of the standards once attained. States are required
by EPA regulations to develop air quality maintenance plans for 1985
for those geographical areas where a potential exists for future vio-
lations of standards. For these areas, some form of analysis should
be conducted for 1985 to assure that the transportation plan is con-
sistent with the AQMP when AQMP's are required for the transportation-
related pollutants (00, Ox and NC^)«
C. Analysis InputData Requirements
Two general levels of transportation and land use data, A
and B, itiay be used as input in estimating the emissions and air quality
information necessary to assess whether the plans and programs developed
by the MPO's are consistent with State plans to attain and maintain NAAQS
The basic difference between levels A and B is the manner in which motor
vehicle travel and land use data, which provide the basis for estimating
mobile and stationary source emissions, are determined. The level of
data input appropriate for use in the analyses on which the consistency
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9
determinations are based is once again dependent on the severity of
the air pollution problem.
!• Development of levels A and B data
Level A analysis data is that information
which results from the land use and transportation modeling and survey
procedures typically used in transportation planning. In assessing the
air quality associated with MPO transportation plans and programs using
level A data, the results of these procedures are used directly. For
example, motor vehicle emissions for past years are determined using
information such as vehicle miles of travel (VMT) , average speeds, and
travel mode distributions available from the network assignments. Similarly
emissions from stationary sources are calculated using information from
land use inventories. Emissions for the year of the long-range plan are
forecasted using the results of travel models for estimating motor vehicle
emissions and the results of an activity allocation process for estimating
stationary source emissions.
Level B analysis data is that data which does not result directly
from land use and transportation modeling and survey procedures, but is
determined by interpolation between information available for the years
for which level A analysis data has been developed. Level B analysis
data is used primarily to estimate emissions for intermediate years when
the air quality problems in a given area appear minor and do not justify
development of level A analysis data. For example, if an urbanized area
is part of a priority I AQCR, but has not been designated as an AQMA and
has no TCP requirements, then B level data would be appropriate for the
intermediate year analysis. The travel data needed to estimate mobile
source emissions for years between a past year and the year of the long-
range plan can be interpolated from the past year travel data developed
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10
through network assigment CA level) and the plan year travel data forecasted
by travel models (A level). Similarly., land use data needed to determine
intermediate year stationary source emissions can be determined by inter-
polation between past year land use inventories and projected land use developed
through a land use allocation process.'
2. Determination of appropriate data level
The development of level A data requires a substantial
amount of time and resources. Only a limited number of MPO's develop such
data for any years between the year of the long-range plan preparation or update
and the target year for the long-range plan. Because of the time and resources
required, level A data should be developed for only areas where a serious
transportation related air quality problem has been forecasted (see Table I) .
Also, because of the time and resources required, level A data shall be developed
only when the MPO undertakes a level 2 major review of the long-range plan, as
described in the FHWA instructional memorandum 50-4-68. The IM prescribes that
transportation plans should undergo major reviews every five years. Until a
level 2 review is carried out, level B data may be used in the consistency
determination.
An additional consideration in determining the interim analysis years for
which to develop level A data is the EPA requirement for preconstruction review
of major new highways and highway modifications. For proposed new highways
having anticipated daily traffic volumes of 50,000 or more vehicles within 10
»»
years of construction or highway modifications which will increase average daily
volumes by 25,000 vehicles, an areawide Ox and NC>2 assessment, similar to that
necessary for consistency determination, will be required by the EPA. The
EPA is now developing indirect source review procedures that will allow the system
air quality analyses for consistency determination to be used to satisfy the
indirect source requirements for assessments of the effects of new highways or
highway modifications on Ox and N02 concentrations provided:
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TABLE I RECOMMENDED METHODS OF ANALYSIS FOR ASSESSING
THE AIR QUALITY EFFECTS OF MPO PLANS AND PROGRAMS
ANALYSIS YEARS
AQCR CATEGORY
Priority III AQCR for CO,
Ox, or N02
and
with no AQMA designation
for CO, Ox, or N02
Priority 1 AQCR for CO,
Ox, N02 with no TCP
and no AQMA designa-
tion for CO, Ov, or NO,,
x 2
TCP area, but no AQMA
designation for CO,
0 , or N00
x' 2
AQMA designation for CO,
Ox , or NOj , but no TCP
TCP area and AQMA
designation for CO,
Ox, or N02
INITIAL AIR QUALITY
ANALYSIS YEAR
No annual analysis
required; analysis
only required at
time of level 2
major reviews*
A level transpor-
tation and land
use data used to
estimate emissions;
emissions -- air
quality relationship
established
NAAQS ATTAINMENT YEAR
No analysis required
No analysis required
B level transportation
and land use data used
to estimate emissions;
air quality estimated
using proportional model
No analysis required
B level transportation
and land use data used
to estimate emissions;
air quality estimated
using proportional model
SHORT-RANGE TIP/AQMP
YEAR
No analysis required
B level transpor-
tation and land use
data used to estimate
emissions; air quality
estimated using propor-
tional model
B level transportation
and land use data used
to estimate emissions
until level 2 major
review; level A data
used for year of level 2
review; air quality esti-
mated using proportional
model
LONG-RANGE PLAN YEAR
No annual analysis
required; analysis
only required at time
of level 2 major reviews
A level transportation and
land use data used to
estimate emissions; air
quality estimated using
proportional model
'•''Analysis at the time of a level 2 major review should be the same as the analysis required for a priority I AQCR with no TCP and
no AQMA designation.
" ' Once an air quality analysis has been satisfactorily performed, a reanalysis should be performed only when either the transportation
plan is revised or updated or when there are changes in air quality requirements, or when other changes occur that r.imif icantlv affect pollution.
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12
(1) tiie transportation systems analyzed include the proposed facility and
(2) the analysis is based on A level data.
The indirect source analysis is reouired for th^ 10 years after the new
highway modification is completed.
D. Methods of Analysis
There are three general methods that can be used to assess
the effects of the MPO transportation plans and programs on air quality:
1. Total pollutant burden
2. proportional or "rollback" modeling
3. Air quality simulation modeling
The method selected for use should reflect the nature and severity of
the air pollution problem in the MPO transportation planning area. The con-
ditions under which each method of analysis is generally appropriate are
identified in Table I. Additional characteristics of the methods are sutrmarized
in the EPA publication, "Guidelines for Air Quality Maintenance Planning and
Analysis, Volume 12: Applying Atmospheric Simulation Models to Air Quality
Maintenance Areas •" _V
1. Total pollutant burden
The total pollutant burden approach involves estimating only motor
vehicle and stationary sources pollutant emissions associated with a par-
ticular transportation plan or program and does not include relating the
resultant emissions to pollutant concentrations and forecasting air quality*
The approach is thus appropriate for making relative comparisons between
transportation system alternatives or between systems for different years r
but cannot be used to demonstrate attairment or maintenance of NAAQS.
The pollutant burden approach is generally most appropriate for
urbanized areas where no transportation control strategies
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13
are required and no violations of NAAQS for CO, Ox or N02 have been
forecasted.
2. Rollback modeling
The basic assumption on which rollback modeling is
based is that pollutant concentrations are proportional to pollutant
emissions; any increase or decrease in pollutant emissions will be
reflected by an accompanying increase or decrease in pollutant concen-
trations. Both linear and nonlinear models have been developed. In
general, the linear models are appropriate for estimating concentrations
of the relatively inert pollutants such as carbon monoxide, while the
nonlinear models are appropriate for estimating photochemical oxidant
concentrations.
3. Air quality simulation modeling
Air quality simulation models are numerical models
for estimating the spatial and temporal distribution of pollutant con-
centrations in an urban area under various meteorological conditions.
Models have been developed to determine the concentrations of both the
relatively inert .and the reactive pollutants. The models for the
reactive pollutants are the least developed of the two types and have
been applied to only a limited number of urban areas. Because air
quality simulation modeling for reactive pollutants is still in
essentially a research stage at this time, such modeling should not be
a required "method of analysis for the section 109 (j) consistency
determinations. Modeling for reactive pollutants is an analysis
method that is being encouraged to advance the present state-of-the-art
in estimating Ox concentrations; it" is not recommended for evaluating
air quality as part of the MPO consistency determination.
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14
4. Selection of analysis method
Table I combines the four components of analysis and
provides general guidance as to the methods which are appropriate
for determining the effects of a transportation plan or program on
air quality. The recommendations of appropriate methods are based
on the nature and severity of the air quality problem and on the
quality of the information available. For example, the decision
whether to use rollback modeling or total pollutant burden estimation
would depend on the availability of air quality concentration measure-
ments at some time relatively close to the base year or update year of
the transportation plan.
III. INTERAGENCY COORDINATION
The discussion thus far has focused on the appropriate approaches
to be used in completing the analyses necessary for a determination
of consistency by the MPO policy board and has not dealt with the
possible ways the analyses could be carried out. In many cases,
certain expertise and information necessary to complete the analyses
will not be readily available to the MPO or to the State transportation
agency, but may rather be found in the State or local air pollution
control agency. This is particularly true of expertise and information
relating to stationary sources of air pollution and their control and
to air quality monitoring. Because the results of the air quality
analyses for consistency determinations should be useful to both
transportation and air pollution control agencies, the FHWA and the
EPA strongly encourage that the analyses be a coordinated effort
involving both types of agencies. As indicated earlier, the FHWA air
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15
quality guidelines do require interagency coordination; assessments
of the coordination are made annually by the regional administrators
of the FHWA and the EPA. The AQMP requirements which EPA will be
publishing shortly also require interagency coordination.
The variations in State and local governmental organizations
and responsibilities and in the expertise and information available
within agencies precludes any description of a division of agency
responsibilities which will have general applicability. Table II
provides one possible way in which agency responsibilities could be
divided in a coordinated analysis for consistency determination.
TABLE II. DIVISION OF AGENCY RESPONSIBILITIES IN CONSISTENCY
DETERMINATION ANALYSES
Transportation/Land Use
Agency Responsibilities
Air Pollution Control Agency
Responsibilities
Develop or acquire trans-
portation and land use
data for all analysis
years.
Estimate transportation-
related emissions for all
analysis years
Determine, if necessary,
changes in MPO transportation
plans or programs to reduce
transportation-related
emissions
Estimate stationary source
emissions based on land use data
supplied by transportation
agencies, on technology forecasts,
and on existing and future regulations.
Analyze air quality data and
determine allowable transportation-
related and stationary emissions of
CO, Hydrocarbons, and NO2
Determine/if necessary, regulatory
or other changes to reduce stationary
source emissions
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16
IV. DETERMINATION OF CONSISTENCY
For MPO transportation plans and programs to be consistent
with State plans to ijnplement NAAQS, the plans and programs, when
iinpmemented, should meet five basic criteria.
1. The MPO transportation plans and programs must not exacerbate
any existing violations of NAAQS. This does not mean that
new highways or highway modifications cannot be completed
until NAAQS are attained, only that proposed facilities
should not increase pollutant concentrations beyond the levels
that already exist.
2. The MPO transportation plans and programs must not contribute
to a violation of NAAQS for a pollutant for which no concen-
trations in violation of standards have been measured.
3. The MPO transportation plans and programs must not delay the
attainment of NAAQS. The attainment deadline for NAAQS, as
now specified in the Clear Air Act, is 1975 unless an extension
has been granted by the Administrator of the EPA. Extensions
may be granted through 1977. The EPA has requested from Congress
authority to grant further extensions in meeting deadlines, if
all reasonable control measures have been implemented and NAAQS
still cannot be attained.
4. The MPO transportation plans and programs must not interfere
with maintenance of NAAQS, once the standards are attained.
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17
5. The MPO transportation plans and programs must include all
appropriate portions of State plans to implement NAAQS,
including the transportation control measures either adopted
by a State or promulgated by the EPA to reduce VMT, such as
exclusive buslanes, carpcol matching programs, etc. Other
transportation control measures to reduce pollutant emissions
from individual vehicles should not be included in MPO
transportation plans and programs, but should be reflected
in the estimation of emissions as part of the air quality
analyses. For example, measures such as mandatory inspection
and maintenance of vehicles will reduce hydrocarbon and carbon
monoxide emissions from individual vehicles. This reduction
should be taken into account in forecasting such emissions
for future years.
The MPO policy board should consider these five criteria, and
other appropriate criteria determined jointly with State and local
air pollution control agencies, in determining the consistency of
the MPO transportation plans and programs. The regional administrators
of the FHWA and the EPA will then review board's determination.
-------
REFERENCES
1. U.S. Department of Transportation, Federal Highway Administration,
"Air Quality Guidelines," Vol, 7, Chapt. 7, Section 9
Federal-Aid Highway Program Manual, November 26, 1974. The
regulations are also published in the December 24, 1974, Federal
Register (39 FR 44441).
2. U.S. Environmental Protection Agency, Federal Air Quality Control
Regions, AP-102, January 1972.
3. U.S. Environmental Protection Agency, Applying Atmospheric
Simulation Models to Air Quality Maintenance Areas, Vol. 12,
Guidelines for Air Quality Maintenance Planning and Analysis,
EPA-450/4-7-013, September 1974.
4. U.S. Department of Transportation, Federal Highway Administration,
"Operations Plans for Continuing Urban Transportation Planning,"
Instructional Memorandum 50-4-68, May 3, 1968.
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APPENDIX A
CRITERIA FOR PRIORITY I CLASSIFICATION
FOR CO, Ox, AND N02*
POLLUTANT AMBIENT CONCENTRATION LIMITS
Equal to or above 55 milligrams per
cubic meter (48 p. p.m.), 1-hour
maximum; or 14 milligrams per cubic
meter (12 p. p.m.), 8-hour maximum
Equal to or above 110 micrograms per
cubic meter (0.06 p. p.m.) annual
maximum
Equal to or above 195 micrograms per
cubic meter (0.10 p. p.m.), 1-hour
maximum
*Published in the August 14, 1971 Federal Register at page 15488.
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STATE
APPENDIX B
PRIORITY I AQCR'S FOR CO, Ox, OR NO
AQCR
CO Ox N02
Alabama
Alaska
Arizona
Arkansas
Cal i form' a
Colorado
Connecticut
Delaware
District of
Columbia
Florida
Georgia
Idaho
Metropolitan Birmingham Intrastate
Mobile-Pensacola-Panama City-
Southern Mississippi Inter-
state
Northern Alaska Intrastate
Clark-Mohave Interstate
Phoenix-Tucson Intrastate
Metropolitan Memphis Interstate
San Francisco Bay Area Intrastate
North Central Coast Intrastate
Metropolitan Los Angeles Intrastate
Sacramento Valley Intrastate
San Joaquin Valley Intrastate
Southeast Desert Intrastate
San Diego Intrastate
Metropolitan Denver Intrastate
New Jersey-New York-Connecticut
Interstate
Hartford-New Haven-Springfield
Interstate
Metropolitan Philadelphia Interstate
National Capital Interstate
Mobile-Pensacola-Panama City-
Southern Mississippi Inter-
state
Jacksonville-Brunswick Interstate
Jacksonville-Brunswick Interstate
Eastern Washington-Northern Idaho
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X X
X
X
X
X
X
X X
X
X
X
X
X
X
Interstate
-------
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Nevada
New Jersey
Metropolitan Chicago Interstate
Metropolitan Dubuque Interstate
Metropolitan St. Louis Interstate
Louisville Interstate
Metropolitan Chicago Interstate
Metropolitan Cincinnati Inter-
state
Metropolitan Indianapolis
Intrastate
South Central Iowa Intrastate
Metropolitan Kansas City Interstate
South Central Kansas Intrastate
Louisville Interstate
Metropolitan Cincinnati Interstate
Southern Louisiana-Southeast Texas
Interstate
Metropolitan Baltimore Intrastate
National Capital Interstate
Metropolitan Boston Intrastate
Hartford-New Haven-Springfield
Interstate
Metropolitan Toledo Interstate
Minneapolis-St. Paul Intrastate
Mobil e-Pensacola-Panama City-
Southern Mississippi Interstate
Metropolitan Memphis Interstate
Metropolitan Kansas City Interstate
Metropolitan St. Louis Interstate
Clark-Mohave Interstate
New Jersey-New York-Connecticut
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Interstate
Metropolitan Philadelphia Interstate x
New Jersey Intrastate x
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3.
STATE
New Mexico
AQCR
Albuquerque-Mid Rio Grande
Intrastate
El Paso-Las Cruces-Alamogordo
Interstate
CO Ox N02
x
X X
New York
North Carolina
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
Tennessee
Texas
Niagara Frontier Intrastate
Central New York Intrastate
Genesee-Finger Lakes Intrastate
New Jersey-New York-Connecticut
Interstate
Metropolitan Charlotte Interstate
Greater Metropolitan Cleveland
Intrastate
Metropolitan Cincinnati Interstate
Metropolitan Columbus Intrastate
Dayton Intrastate
Metropolitan Toledo Interstate
Central Oklahoma Intrastate
Northeastern Oklahoma Intrastate
Portland Interstate
Metropolitan Philadelphia
Interstate
Southwest Pennsylvania Intrastate
Metropolitan Providence Interstate
Metropolitan Charlotte Interstate
Middle Tennessee Intrastate
Metropolitan Memphis Interstate
Austin-Waco Intrastate
Corpus Christi-Victoria Intrastate
Metropolitan Houston-Galveston
Intrastate
Metropolitan Dallas-Fort Worth
Intrastate
Metropolitan San Antonio Intrastate
Southern Louisiana-Southeast
Texas Interstate
El Paso-Las Cruces-Alamogordo
Interstate
x
x
x
x
x
x x
x
x
x
x
x
x
x
x
X
X
X
X
X
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4.
STATE
Utah
Virginia
Washington
AQCR
Wasatch Front Intrastate
State Capitol Intrastate
Hampton Roads Intrastate
National Capital Interstate
Eastern Washington^Northern Idaho
Interstate
Portland Interstate
Puget Sound Intrastate
CO
X
X
X
X
X
°x
X
X
X
X
X
X
N02
X
Wisconsin Southeastern Wisconsin Intrastate
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STATE
APPENDIX C
PRIORITY III AQCR'S WITH VIOLATIONS OF NAAQS*
AQCR
Maine
Maryland
Michigan
Minnesota
Nebraska
Androscoggin Valley Interstate
Cumberland-Keyser Interstate
Merrimack Valley-Southern New Hampshire
Interstate
Metropolitan Detroit-Port Huron
Intrastate
Minneapolis-St. Paul Intrastate
Metropolitan Omaha-Council Bluffs
Interstate
CO 0N
California
Florida
Georgia
Hawaii
Illinois
Indiana
Iowa
Kansas
Kentucky
South Central Coast Intrastate
Southeast Desert Intrastate
Southeast Florida Intrastate
Southwest Florida Intrastate
Metropolitan Atlanta Intrastate
Hawaii
Paducah-Cairo Interstate
Evansvi 1 1 e-Owensboro-Henderson Interstate
Louisville Interstate
Metropolitan Omaha-Council Bluffs
Interstate
South Central Iowa Intrastate
Northeast Kansas Intrastate
South Central Kansas Intrastate
Evansvi 1 1 e-Owensboro-Henderson Interstate
Hun ting ton-Ash! and -Portsmouth- I ronton
Interstate
Louisville Interstate
Paducah-Cairo Interstate
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
x
x
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2.
STATE
AQCR
CO 0.
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
Ohio
Oklahoma
Pennsylvania
South Carolina
Vermont
Virginia
West Virginia
Northwest Nevada Intrastate x
Androscoggin Valley Interstate
Merrimack Valley-Southern New Hampshire x
Interstate
Northeast Pennsylvania-Upper Delaware x
Valley Interstate
Albuquerque-Mid Rio Grande Intrastate x
Champlain Valley Interstate
Genesee-Finger Lakes Intrastate x
Hudson Valley Intrastate x
Niagara Frontier Intrastate x
Metropolitan Charlotte Interstate x
Western Mountain Intrastate
Dayton Intrastate x
Greater Metropolitan Cleveland Intrastate x
Huntington-Ashland-Portsmouth-Ironton x
Interstate
Northwest Pennsylvania-Youngstown
Interstate
Central Oklahoma Intrastate x
Northeastern Oklahoma Intrastate x
Northeast Pennsylvania-Upper Delaware x
Valley Interstate
Northwest Pennsylvania-Youngstown
Interstate
Metropolitan Charlotte Interstate x
Champlain Valley Interstate
Hampton Roads Intrastate x
State Capitol Intrastate x
Cumber!and-Keyser Interstate x
Huntington-Ashland-Portsmouth-Ironton x
Interstate
x
x
*Based on "Monitoring and Air Quality Trends Report, 1973," EPA-450/1-74-007?
published in October 1974 by the Environmental Protection Agency.
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STATE
APPENDIX D
AQCR'S WITH TCP'S FOR CO OR 0)
AQCR
CO 0,
Alaska
Arizona
Cal ifornia
Colorado
District of
Columbia
Illinois
Indiana
Maryland
Massachusetts
Minnesota
New Jersey
New York
Ohio
Oregon
Pennsylvania
Northern Alaska Intrastate
Phoenix-Tucson Intrastate
San Francisco Bay Area Intrastate
Metropolitan Los Angeles Intrastate
Sacramento Valley Intrastate
San Joaquin Valley Intrastate
Southeast Desert Intrastate
San Diego Intrastate
Metropolitan Denver Intrastate
National Capital Interstate
Metropolitan Chicago Interstate
Metropolitan Indianapolis Intrastate
Metropolitan Baltimore Intrastate
National Capital Interstate
Metropolitan Boston Intrastate
Hartford-New Haven-Springfield Interstate
Minneapol is-St. Paul Intrastate
New Jersey-New York-Connecticut
Interstate
Metropolitan Philadelphia Interstate
Genesee-Finger Lakes Intrastate
New Jersey-New York-Connecticut
Interstate
Metropolitan Cincinnati Interstate
Portland Interstate
Metropolitan Philadelphia Interstate
Southwest Pennsylvania Intrastate
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
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2.
STATE AQCR CO 0
Texas Austin-Waco Intrastate x
Corpus Christi-Victoria Intrastate x
Metropolitan Houston-Galveston Intrastate x
Metropolitan Dallas-Fort Worth Intrastate x
Metropolitan San Antonio Intrastate x
El Paso-Las Cruces-Alamogordo Interstate x
Utah Wasatch Front Intrastate x
Virginia National Capital Interstate x x
Washington Eastern Washington-Northern Idaho Inter- x
state
Puget Sound Intrastate x
x
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APPENDIX E
AQCR'S CONTAINING ALL OR PART OF PROPOSED AQMA'S FOR CO, Ox, OR N02*
STATE
Connecticut
District of
Columbia
Florida
Illinois
Indiana
Iowa
Kentucky
AQCR
New Jersey-New York-Connecticut
Interstate
Hartford-New Haven-Springfield
Interstate
National Capital Interstate
West Central Florida Intrastate
Metropolitan Chicago Interstate
Metropolitan St. Louis Interstate
Metropolitan Chicago Interstate
Metropolitan Cincinnati Interstate
Metropolitan Indianapolis Intrastate
South Central Iowa Intrastate
Metropolitan Cincinnati Interstate
CO 0,
x
x
X
X
X
X
X
X
X
NO'
Arizona
Cal i form' a
Colorado
Clark-Mohave Interstate
Four Corners Interstate
Phoenix-Tucson Intrastate
North Central Coast Intrastate
Sacramento Valley Intrastate
San Diego Intrastate
San Francisco Bay Area Intrastate
San Joaquin Valley Intrastate
Metropolitan Los Angeles Intrastate
Southeast Desert Intrastate
South Central Coast Intrastate
Four Corners Interstate
Pawnee Intrastate
Metropolitan Denver Intrastate
San Isabel Intrastate
Yampa Intrastate
Grand Mesa Intrastate
x
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
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2.
STATE
Louisiana
Maryland
Massachusetts
Missouri
Montana
Nevada
New Jersey
New Mexico
New York
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
AQCR
Southern Louisiana-Southeast Texas
Interstate
Metropolitan Baltimore Intrastate
National Capital Interstate
Metropolitan Boston Intrastate
Metropolitan Providence Interstate
Merrimack Valley-Southern New Hampshire
Interstate
Hartford-New Haven-Springfield Interstate
Metropolitan St. Louis Interstate
Billings Intrastate
Great Falls Intrastate
Missoula Intrastate
Clark-Mohave Interstate
New Jersey-New York-Connecticut Interstate
Metropolitan Philadelphia Interstate
Albuquerque-Mid Rio Grande Intrastate
Four Corners Interstate
El Paso-Las Cruces-Alamogordo Interstate
Pecos-Permian Basin Intrastate
Upper Rio Grande Valley Intrastate
New Jersey-New York-Connecticut
Interstate
North Dakota Intrastate
Metropolitan Cincinnati Interstate
Central Oklahoma Intrastate
Northeastern Oklahoma Intrastate
Portland Interstate
Southwest Pennsylvania Intrastate
Metropolitan Philadelphia Interstate
CO
X
X
X
X
X
X
X
X
X
X
X
X
X
Ox
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
N02
X
X
X
X
X
Rhode Island
Metropolitan Providence Interstate
-------
3.
ACQR CO Ox N02
Texas Southern Louisiana-Southeast Texas x
Interstate
Corpus Christi-Victoria Intrastate x
Metropolitan Dallas-Fort Worth Intrastate x
Metropolitan Houston-Galveston Intrastate x
El Paso-Las Cruces-Alamogordo Interstate x x
Metropolitan San Antonio Intrastate x
Austin-Waco Intrastate x
Utah Four Corners Interstate x
Wasatch Front Intrastate x
Virginia National Capital Interstate x x
Washington Portland Interstate x x
Wisconsin Southeastern Wisconsin Intrastate x
•Proposed AQMA's are published in the July 10, 1974 Federal Register
at pages 25330-25351 and in the August 12, 1974 Federal Register
at pages 28906-28910.
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