October 1980
A Citizen's Guide
to Clean Air and
Transportation
Implications for Urban Revitalization

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Contents
i Foreword
1 Introduction
Hard Times for an Auto City
Transportation and Air Quality
Transportation Systems in Urban Society
3 Health and Economic Effects of Air Pollution
6 Congress and Clean Air
Early Air Pollution Legislation
Where We Stand Now
Controls on Auto Use
10 Urban Transportation Planning
The 3C Process
Air Quality and Urban Transportation Planning
18 The Clean Air Act Amendments of 1977
Current Clean Air Act Requirements
Federal air quality standards
Designation of air quality control regions
Assessing air quality
Reasonable further progress
Stationary source controls
Mobile source controls
Inspection! Maintenance
Transportation Control Measures
Basic Transportation Needs
Integration of Clean Air and Transportation Planning:
The Citizen’s Role
The Conformity Requirement
Section 175 Grants
Public Participation
Sanctions
30 Putting the Law to Work: Opportunities for Urban
Revitalization
The European Experience
Transportation Systems Management
Basic Transportation Needs
Transit User Panels
Joint Development
Developing a Shopping Mall Policy
Interstate Transfer
Bicycles
Appendices
47 A Acronyms and Abbreviations
48 B DOT! EPA Integration of Transportation
and Air Quality Planning (June 14, 1978)
50 C Community Conservation Guidance
52 D SIP Checklist
55 E Glossary
59 F Post-1982 Nonattainment States

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Foreword
This  is a guide, not a recipe. It
explains the process by which Congress
and public officials would like air
quality and transportation planning to
be conducted. But each city is its own
contraption, built upon generation after
generation of individual dreams, plans,
and physical effort, each in its unique
setting.  While this guide can list the
ingredients of the planning process, it is
up to you to find the recipe that works
in your city.
  The goals of the process described in
here are clean air, efficient use of federal
transportation assistance, and the
economic and cultural revitalization of
our cities. But the whole is greater than
the parts. If the process works—and it
can if you want it to—the result is one
of the most precious characteristics of a
working democracy: public
accountability. Participation in a process
you don't understand results in
frustration, and insulates our
government—federal, state and local—
from the consequences of public action.
But, armed with the  power that
knowledge of the process brings, you
can make a difference. That is the real
purpose of this guide.
  Before you begin note Appendix A—
a section on acronyms and
abbreviations.
  Good Luck.
This guide was prepared by David G.
Burwell and Christopher Meyer of The
National Wildlife Federation under a
contract with the U.S. Environmental
Protection Agency. The views and posi-
tions expressed here do not necessarily
represent those of EPA.
 Photos courtesy of the District of Columbia
 Department of Highways and Traffic,
 U.S. Department of Transportation, and the
 Highway Users Federation.

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I
.. . - I
I had the feeling over the weekend that
our civilization was winding down. The
mood of the city was reminiscent of “On
the Beach, “ that haunting movie in
which the world has been mortally
wounded in the nuclear Armageddon
and is dying with a whimper.
Jack Smith, L.A. Times*
‘Copyright 1979. Los Angeles Times. Reprinted by
permission.
E-5934Add’I Copy—EPA---- EPA277O—9/3/8O—9
(D}EPA (L)59344A

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Introduction
Hard Times for an Auto City
Nineteen Seventy-Nine was a rough year
for Los Angeles air. The Great Gasoline
Crunch hit early in May and continued
through August. forcing cars to idle in
long gas lines. In late August the city’s
bus operators went on strike, driving
Los Angeles commuters, with no rail
transit alternative, into their cars in even
greater numbers than usual. In early
September, nearby Mt. Wilson caught
fire, billowing heavy smoke into the air
basin. To top it off, a high pressure
system stagnated over the city
throughout September, trapping auto
exhaust and fire fumes in the basin.
Temperatures over 100 degrees and high
humidity turned the air into muggy
soup.
The regional air quality agency
warned citizens that breathing the air
was “hazardous” in certain places and
advised people to stay indoors and avoid
physical activity. Golf courses and tennis
courts emptied, but hospitals filled up
with patients suffering from emphysema,
bronchitis, and asthma. Schools
cancelled recess. A California Institute
of Technology study coined a new name
for the brown cloud over the city, “acid
smog.” Earlier, rain samples taken in
Pasadena showed levels of acidity only
slightly milder than vinegar.
The primary cause of air pollution in
Los Angeles, unsurprisingly, is
automobile exhaust. The city has been
fighting air pollution since the 1950’s.
Since 1970, when the Clean Air Act was
amended to set a national goal of 90
percent reduction in pollution from auto
exhausts and attainment of uniform
National Ambient Air Quality Standards
(NAAQS) by 1975, these efforts have
intensified. The multi-billion dollar
effort has included sophisticated
monitoring of air quality trends, controls
on auto exhausts, controls on vapor loss
from stationary sources such as gas
stations, and even controversial controls
on auto use. Still, gasoline consumption
hit an all-time high in 1978 and daily
maximum ozone readings during the
June-to-September smog season
increased from less than 20 parts per
million (ppm) in 1972 to over 23 ppm in
1978 (the national standard is 12 ppm).
While perhaps not Armageddon, Los
Angeles is clearly losing the fight for
clean air.
The lesson learned from Los Angeles
is also being learned in Phoenix,
Denver, Dallas and Houston—other
U.S. cities reporting little or no progress
in reducing air pollution over the last
five years. It is this: there is no quick,
technological fix to air pollution.
Emission controls, inspection and
maintenance of automobiles, and
stationary controls reduce pollution, but
are not enough. Clean air will only be
achieved through a basic rethinking
about urban development and how
urban residents want that development
to proceed.
It won’t be easy. The greater Los
Angeles Metropolitan Area, including
Orange, Riverside, San Bernardino and
Ventura Counties, contains over ten
million people sprawled over 34,000
square miles—one third the size of West
Germany. Yet the average density of the
area is about 300 people per square mile,
compared to 637 per square mile in
West Germany (with urban agglomera-
tions of about 6,000 per square mile).’
This means long commutes for Los
Angeles area residents—and more air
pollution. Such an urban development
pattern compounds air quality problems
by making public transit uneconomical
and, therefore, unavailable. At the
height of the gas crunch of 1979, driving
decreased 15 percent in the Los Angeles
basin, but air pollution increased. The
reason—people sitting in gas lines with
their car motors running. They simply
had no choice.
Can that choice be provided? Above
all else, Americans are pragmatic. We
also have a long history of citizen
activism. Our political institutions are
decentralized, with extensive power
residing in municipal, local, and even
neighborhood groups. Traditionally, this
has been particularly true with respect to
land use. It has no: been true with
respect to transportation, but
‘Compare this with ancient Greece where Athens, at
the time of Pericles, jammed a population of over
200,000 into just over two square miles.
transportation decisions are now
becoming more decentralized as regional
and local officials recognize the
importance of joint land use and
transportation decisionmaking to
promote rational urban development. As
transportation and land use decision-
making converge, a bigger “piece of the
action” becomes available to citizens
concerned about dirty air, gas lines,
neighborhood destruction, and urban
economic stagnation.
1

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Transportation and
Air Quality
Transportation systems can be used to
promote a variety of social goals. In this
booklet, we have selected one social
goal—clean air—and will explain how
urban transportation systems and
transportation system planning can be
exploited to promote that goal. The
handles are there, both in our
transportation laws and our clean air
laws, not because transportation systems
improve air quality, but because they
contribute significantly to air pollution.
We will not achieve national clean air
goals without vast improvement in our
urban transportation systems; making
them efficient and non-polluting while
recognizing the importance of accessible
and low cost transportation to urban
vitality.
This last point bears emphasis. Heavy-
handed or inappropriate clean air
strategies could strangle the vitality of
cities rather than save them. Banning
private automobiles from the central
business district in Denver, for example,
without an adequate public
transportation system to move people to
work and shopping, would have a
devastating effect on the city economy.
On the other hand, in cities where
adequate public transit exists, such as
Portland, Oregon, selected auto-free
zones could stimulate the economy.
Great sensitivity is required in
understanding the purposes served by
transportation systems generally, and
then in shaping clean air solutions that
also promote those purposes. A tall
order.
Transportation Systems in
Urban Society
Before tackling transportation issues, it
is worth reflecting on why we spend
public funds on transportation. First and
foremost, transportation systems move
goods and people. A good
transportation system is necessary to
facilitate the marketing of goods and
services, and to broaden the choice of
social and business activities available to
all citizens. These benefits alone have
justified public funding and regulation of
virtually all modes of transportation.
Second, any transportation system
helps to create commerce by opening up
previously inaccessible lands for
development. It brings the market to the
goods (the land), as well as the goods to
market. Witness the development that
springs up around interstate highway
interchanges, or subway stations, or the
strip developments that characterize
major unlimited access nignways. Ana,
besides development, transportation
systems open up land for recreational
use.
Third, transportation provides
employment. About 16 percent of the
people employed in the United States
are directly or indirectly involved with
transportation. In most countries these
people are public employees since the
companies involved in transportation
development are owned in whole or in
large part by the government. This
applies to everything from the motor
vehicle manufacturers that make the
cars, buses, trolleys, and trains that use
the system to the energy companies that
feed the system. In the United States,
transportation operates in a mixed
economy. This creates a lot of pulling
and tugging between federal, state, and
Action Tip
There are many non-transportation
strategies for keeping cities compact
thereby reducing transportation needs,
improving air quality, and promoting
energy efficiency. A good summary is
Compact Cities: Energy Saving
Strategies for the SOs, Subcommittee on
the City, House Committee on Banking,
Finance and Urban Affairs, Committee
Print 96-15 (July 1980).
• +i
rmI
- I ,z
ir?i’ : -
2

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Health and Economic
Effects of Air
Pollution
local governments, manufacturers and
suppliers, financial interests and users as
each group tries to get the most it can
from the system at the lowest cost.
Therefore, when studying any
transportation system—urban or rural—
it is wise to keep in mind two questions:
Who pays? Who benefits?
Fourth, there is the purely social
purpose of transportation systems.
Scenic highways are as much “recrea-
tional facilities” as are ski lifts and
public parks, and are constructed for
that specific purpose. An “evening spin”
or a “Sunday drive” are forms of
recreation. As energy supplies get tight,
gas prices increase, and costs of
construction skyrocket, it is likely that
the purely social purposes of
transportation systems will decrease
sharply.
Mobility, development opportunity,
commerce, recreation: these are the
primary social and economic benefits of
a healthy transportation system in an
urban society. But transportation has
costs, and one of the most severe is air
pollution. Transportation is a major
contributor of five pollutants—hydro-
carbons, carbon monoxide, nitrogen
oxides, lead, and total suspended par-
ticulates. Another cost is energy waste.
The average American consumes 3.7
times as much energy on transportation
as does a citizen of West Germany, a
country equally industrialized as the
United States. Moreover, a city whose
citizens “export” their dollars out of the
urban area to pay for fuel has that much
less money to invest in urban
redevelopment.
Urban vitality, therefore, depends to a
significant extent on the ability of public
officials, planners, neighborhood groups,
and citizens to develop transportation
programs that meet the mobility needs
of their communities while keeping faith
with other broad social goals such as
clean air and energy efficiency. This
manual is designed to help you promote
these twin goals and, in the process,
make your city a nicer place to live.
Clean air certainly makes a city a nicer
place to live. There’s a real pleasure in
opening your front door for the morning
paper, taking a deep breath, and
smelling fresh air rather than toxic
fumes from the traffic. But the pleasure
of breathing clean air was not the
driving force behind enactment of the
Clean Air Act. The real reason was
health.
We are a Nation 220 million strong—
until we take a closer look. Six million
of us suffer from chronic bronchitis and
6 million more from asthma; 50,000 die
each year from lung cancer and another
20,000 from chronic obstructive
pulmonary diseases. Add to this an
increased incidence of heart attacks,
brain damage to fetuses, more colds, eye
and skin irritations, coupled with
reduced exercise performance among
healthy adults, and you have a snapshot
of a not-too-healthy nation. While air
pollution alone does not generate these
statistics, best present estimates are that
air pollution does result in about 15,000
excess deaths,* 7 million sick days, and
15 million days of restricted activity per
year. The total affected population—
about 40 million—represents about one
out of every five Americans.
In a country accustomed to the
spectacular statistic, the insidious effects
of air pollution on health remain largely
hidden. Only the most alarming events
reach the attention of the general public:
Donora, Pennsylvania, where about half
the population of 13,000 got sick, and 20
died, in an air inversion in 1948;
New York City, where 200 people died
from high levels of sulfur dioxide in
1953.
However, the most serious effects of air
pollution result from chronic exposure
to mildly unhealthy air. We must
understand precisely what happens to
*Remarks by Senator Edmund Muskie, Congres-
sional Record, S. 9162 (June 8, 1977).
our bodies as a result of such exposures
to fully appreciate the problem. While
all physiological effects have not been
documented, here are some identified
consequences of breathing the types of
pollution produced by our
transportation system:
Ozone, Nitrogen Oxides
and Hydrocarbons
Ozone is formed in bright sunlight (or
ultra-violet light) from nitrogen dioxide
and volatile hydrocarbons and is
commonly referred to as smog. When
introduced into the lower respiratory
tract, ozone damages small airways,
causing increased resistance to airflow.
This, in turn, prevents the transfer of
oxygen from the lungs into the blood-
stream. Ozone also damages the alveoli,
the millions of small hollow sacs in our
lungs where this oxygen transfer occurs,
and can ultimately result in these sacs
being filled with fluid, a condition called
pulmonary edema. The result: increased
breathing effort, more strain on the
heart and aggravation of symptoms of
emphysema. Nitrogen dioxide is
suspected of reducing resistance to
respiratory tract infections and certain
hydrocarbons, the other major ozone
precursor, are suspected carcinogens.
Carbon Monoxide
Carbon monoxide attaches to
hemoglobin (the oxygen-carrying matter
of red blood corpuscles) 245 times more
easily than oxygen, thereby reducing the
oxygen-carrying capacity of red blood
cells for up to 24 hours. Carbon
monoxide also enhances clotting and
inhibits the release of oxygen from
hemoglobin to the tissues. Effects
include anemia (less oxygen-carrying
capacity in blood), heart disease
(impaired circulation of oxygenated
blood), and lung disease (impaired
oxygen intake and expulsion of carbon
monoxide and carbon dioxide). Short-
term effects of relatively low-level
exposure (30 ppm) include headaches,
3

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slowed muscle and nerve reaction time,
constriction of visual field, and general
sluggishness. Long-term effects include
increased mortality following heart
attacks, mental confusion, impaired
eyesight, and reduced birth weights of
children born of smoking mothers. In
addition, studies indicate that high
carbon monoxide concentrations,
together with a high cholesterol diet, will
rapidly produce hardening of the arteries
(atherosclerosis).’
Sulfur Dioxide,
Particulates and Lead
Sulfur dioxide and particulates—from
both stationary sources (i.e. power
plants) and mobile sources (i.e. cars)—
may absorb and hold active agents in
contact with respiratory tissues, thereby
‘Mitchell, Roger S., et a!, “Health Effects of Urban
Air Pollution,” 242 Journal of the American
Medical Association. pp. 1163, 1166 (September
14, 1979).
increasing the likelihood of respiratory
disease. Lead—an important source of
which is the burning of leaded
gasoline—is a dangerous and insidious
poison that can cause infertility, brain
damage, and impaired growth and
development. However, no studies to
date have shown evidence of long-term
lead poisoning resulting solely from
airborne sources.
Effects of air pollution are not evenly
distributed among the exposed or “at
risk” population. Pre-existing health is
the most significant variable and, in fact,
scientists have not yet been able to
establish a threshold of air pollution
below which no health effects are
detected. Climate, nutrition, location,
age, and smoking habits also influence
Figure 1 Distribution of Health Effects
Death
Exacerbation of
Chronic Bronchitis
Acute Upper
Respiratory Illness
Nose Irritation
distribution of health effects (see Figure
I). While it is extremely difficult to
isolate the precise incremental effect of
ambient air pollution on human health,
there is no disagreement on the bottom
line—it’s significant, it’s unhealthy, and
it’s hard to cure.
This description is grim, but the
situation gets even worse in higher
altitudes where oxygen is less available
and the effects of ozone and carbon
monoxide are felt at lower
concentrations. For this reason,
California has set a more stringent eight-
hour CO standard of 6 ppm for areas
above 1500 meters, compared to a 9
ppm eight-hour standard at sea level.
The problem is compounded by the fact
that at higher altitudes, fuel combustion
Environmental Stressors
Intensity of Insult —4W
Source: National Commission on Air Quality (Washington, DC, 1980)
4

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is impaired due to lack of oxygen,
resulting in higher emissions. It is this
combination of higher emissions and a
lower threshold for health-related effects
that makes air pollution such a severe
health issue in high altitude cities such
as Denver, Colorado.
From 1940 to 1970 controllable
particulate emissions in this country
increased 15 percent, sulfur dioxide
increased 50 percent, carbon monoxide
and hydrocarbon emissions more than
doubled, and nitrogen dioxide emissions
quadrupled. 2 Understandably, as
pollution levels rose, people became
increasingly concerned. After 1970,
pollution control measures began to
have a significant effect. Particulate
emissions are down about 8 percent,
sulfur dioxide is down about 17 percent,
and carbon monoxide is being reduced
at a rate of about 7 percent a year.
Hydrocarbon and nitrogen dioxide
emissions, while not showing measurable
improvement on a national level, have at
least not continued their alarming rate
of increase (see Where We Stand Now,
p. 7).
Increased rates of sickness and death
obviously increase human suffering
among the victims of air pollution and
their families. These costs are invisible,
but real. Some costs, however, are
quantifiable and EPA has made an
effort to identify them. 3
Conservative estimates of benefits gained
from a 60 percent reduction in air
pollution place savings at about $25
billion in annual labor productivity
(1970 labor base, 1978 dollars) for urban
areas, and $36.4 billion for the Nation as
a whole. These figures are substantiated
by a three-year study conducted at the
Universities of Wyoming, Southern
2 Remarks by Senator Edmund Muskie, Congres-
sional Record, S. 9162 (June 8, 1977).
3 Merhods Development for Assessing Air Pollution
Control Benefits (February 1979), Office of Health
and Ecological Effects, US EPA, Washington, DC
20460.
California, and New Mexico which place
annual benefits,in terms of increased
labor productivity and increased
property values, at about $41 billion. 4
That is the positive side of a successful
air pollution control effort. But what
about the cost? A recent study
conducted for EPA estimates that the
Gross National Product (GNP) is
marginally higher as a result of air and
water pollution control programs. 5
However, as investments in
environmental control equipment force
industries to forego other investments,
GNP will suffer a slight decline of about
1 percent in 1986 as compared to what it
would have been in the absence of
federal pollution control requirements.
Pollution control has increased
employment in the industries established
to provide the necessary technology, but
some jobs have also been lost because of
lower demand for products that cost
more due to pollution control expenses.
On balance, however, a net increase of
about 200,000 jobs is estimated by 1986,
which should reduce the unemployment
rate about .2 percent. Higher product
prices to help cover environmental costs
would add slightly to inflation. Finally,
total corporate profits are projected to
4 BNA, Current Developments, March 2, 1979 at
2031.
5 &onopnics and Clean Air, Data Resources, Inc.
(February, 1979). This report is available from the
Office of Program Analysis, US EPA,
Washington, DC 20460.
be down about 0.9 percent in 1986 as a
result of pollution control, paralleling
the effect on total GNP.
Is pollution control worth the cost?
That is a decision each of us must make
individually. The macroeconomic effects
outlined above do not appear to make
the case for or against pollution control
efforts. However, when the strongly
positive health and economic effects of
air pollution control programs
themselves are added to the balance, the
case for aggressive pursuit of national
clean air goals becomes compelling. And
even these figures don’t reflect the
very real, albeit unquantifiable, benefit
of satisfying the universal need for a
breath of fresh air.
5

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Congress and
Clean Air
Early Air Pollution Legislation’
Congress first tackled air pollution
problems in 1955 by establishing a
program to provide federal technical
assistance, while leaving to each State
the task of assessing existing air quality,
setting state air quality goals and
developing strategies to meet those
goals.
It didn’t work. First, this approach
failed to recognize the “federal” nature
of the problem. Because pollution in one
State may drift to neighboring States, no
single State was able to clean up air
pollution on its own. Furthermore, no
State was willing to adopt strict
standards for sources within its
boundaries for fear of placing itself at a
competitive disadvantage in attracting
new industry. Second, early laws weren’t
backed up with strong sanctions, but
instead relied entirely on voluntary state
cooperation. And third, federal law
instructed each State to impose its own
controls, rather than placing uniform
federal requirements directly on the
polluters. Consequently, if a State was
lax in imposing controls, citizens could
take no action against the polluters.
‘The first federal air quality legislation was the Air
Pollution Control Act of 1955 which confined the
federal role primarily to research. Pub. L. No. 84-
145, 69 Stat. 322. The Clean Air Act of 1963
provided the first federal regulatory foothold, but
was limited to cases in which a pollution source
endangered health or welfare in another state. Pub.
L. No. 88-206, 77 Stat. 392. The first
comprehensive regulatory scheme was the Air
Quality Act of 1967. Pub. L. No. 90-148, 81 Stat.
485. The 1967 Act provided a framework of state
air quality standards and implementation plans
which was similar to the 1970 Act, except for its
orientation toward state rather than federal
regulation.
Passage of the Clean Air Act
Amendments of 19702 ufarked the
beginning of the first serious national
effort to control air pollution. The 1970
Act left behind the voluntary, state-
initiative approach and adopted instead
a firm federal program which:
• set uniform national ambient air
quality standards (NAAQS—”ambient
standards” measure the overall quality of
the air we breathe without reference to
the source of the pollution, while
“emission standards” set limits on the
pollution which may be emitted from
particular sources),
• established an attainment deadline
(January 1, 1975) for meeting those air
quality standards,
• required federal approval of “state
implementation plans” (SIPs) to achieve
NAAQS, with sanctions for non-
compliance,
• established technology-based
standards for controls on emissions
which applied directly to industrial
sources,
• established separate standards for the
emissions from motor vehicles (90
percent reduction in carbon monoxide
and hydrocarbon emissions by 1975 and
similar reductions for nitrogen oxide
levels by 1976), and
• brought the public into the picture by
outlining broad citizen participation
requirements and by permitting citizens
to sue States, the federal government or
individual sources in order to insure
enforcement. 3
2 Pub. L. No. 91-604, 84 Stat. 1676 (1970), cod fled
at 42 U.S.C. 4740l, et seq.
3 1n the year after the first major “energy crisis” in
1973, the Act underwent minor changes designed
to insure that air quality improvement would not
come at the expense of energy efficiency. Pub. L.
No. 93-319, 88 Stat. 246 (1974). These amendments
provided certain exceptions to industrial pollution
control requirements and empowered the President
to override other requirements of the Act in order
to meet an energy emergency.
Many of the innovations of the 1970 Act
are preserved in present clean air laws.
However, by the mid-1970’s it became
apparent that even the aggressive new
federal approach to air pollution control
wasn’t accomplishing the goals Congress
had established. Most States failed to
submit effective implementation plans.
Attempts by the federal government to
force States to promulgate adequate
plans were ineffective. Tampering, poor
maintenance, and “fuel-switching”
(putting cheaper, leaded gasoline in
“unleaded only” cars) caused the
emission control systems in new
automobiles to fall far short of the
hoped-for 90 percent reduction in auto
emissions. Moreover, total vehicle miles
traveled (VMT) continued to climb,
tending to offset gains achieved in
reduced emissions per mile traveled.
6

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Where We Stand Now
For the reasons described above,
progress towards cleanup of air
pollution can only be described as
mixed. Controls of mobile sources of
pollution (cars, trucks, etc.) has been
particularly difficult. Mobile sources
contribute substantially to five of the
seven pollutants for which standards
have been established (see Figure 2).
Figure 2 Percentage of Pollutants
from Mobile Sources
These statistics are national averages; in
urbanized areas the contribution of
mobile sources to the key
transportation-related pollutants may be
much greater. For example, in Miami,
Florida, automobiles contribute 95
percent, 85 percent and 70 percent of the
area’s carbon monoxide, hydrocarbons
and nitrogen dioxide pollution,
respectively.
Progress over the last two decades in
reducing the levels of these pollutants
has been slow. Carbon monoxide levels
are generally down, while hydrocarbon,
nitrogen oxide and ozone levels are
increased slightly. Here are the specifics:
Carbon Monoxide: Carbon monoxide
levels in urban areas have shown a
steady decline over the last decade.
Between 1972 and 1978, carbon
monoxide levels in central cities fell 35
percent, or 7 percent a year. This
improvement is explained by the fact
that transportation corridors in
downtown areas were already saturated
with traffic in 1972. As emission control
devices were applied to these constant
levels of traffic, carbon monoxide levels
went down. However, in rural and
suburban areas, where highway corridors
were not saturated, increases in
vehicle miles traveled cancelled out
gains obtained through emission
controls. Consequently, growth areas
showed increase in carbon monoxide
emissions. Indeed, overall emissions of
carbon monoxide remained constant
between 1970 and 1978.
Ozone and Hydrocarbons: Levels of ozone
and hydrocarbons (an ozone precursor)
rose slightly between 1974 and 1978.
Although emissions of hydrocarbons per
vehicle mile traveled were reduced, this
gain was more than offset by a 20
percent increase in vehicle miles traveled.
The net effect has been a 3 percent
increase in hydrocarbon emissions, a
trend which parallels the national ozone
trend (see Figure 3).
74 75 76 77
percent from
highway
vehicles
pollutant nationally
ozone NM
lead 85%
carbon monoxide 70%
nitrogen dioxide 35%
hydrocarbons 33%
total suspended particulates 6%
sulfur dioxide 2%
Note: No statistic is available for ozone
because it is not emitted directly into the air
from pollution sources. It is, however,
considered to be a major transportation-
related pollutant, because it is formed from
the reaction of hydrocarbons, nitrogen dioxide
and sunlight.
Figure 3 National Ozone and Hydrocarbon Trends
(excerpt from figure 3-6 Trends (1977))
Source: How to Prepare the Transportation
Portion of Your State Air Quality Implementa-
tion Plan, Technical Guidance of the U.S.
Department of Transportation, Federal Highway
Administration, with the cooperation of the
U.S. Environmental Protection Agency,
November 1978, pages P2-I, P2-12.
x .
nO
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- a,
00
0
E ’ 4 2
ou; .
a
C
—o
O .
>E
0
0
160
California
140
National
120 —
Non-California
100
30
VOC
20 1 I
72 73
Year
Source: National Air Quality, Monitoring, and Emissions Trends Report, 1977 (EPA, 1978, p. 3-8)
7

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Nitrogen Dioxide: Ambient levels of
nitrogen dioxide have shown only a
slight increase since 1972, although
emissions of this pollutant increased 16
percent between 1970 and 1978 (see
Figure 4 for a breakdown of nitrogen
dioxide trends by EPA regions).
These trends reveal the intractable
nature of the air pollution problem.
Nationally, emission controls are barely
keeping pace with iflcreases in total
travel. The most positive observation
that can be made is that in the densely
populated areas, such as the Northeast
megalopolis where transportatioi%
corridors had very nearly reached
saturation levels in 1972, the percentage
of the total population exposed to
pollution levels above the standards has
been reduced. Increases in pollution are
concentrated in less densely populated
growth areas. Since the decreases in
pollution levels are concentrated in the
densely populated areas and the
increases in the less densely populated
areas, the total percentage of the
national population exposed to levels of
pollution above air quality standards has
declined in the last seven years.
Small comfort. The 1970 Clean Air
Act mandated that all areas of the
country meet the standards by July 1,
1977, at the latest. The 1977
Amendments set the deadline back to
December 31, 1982, with an extension
until 1987 in those areas that can show
that the 1982 deadline cannot be met for
transportation related pollutants.
Virtually all urbanized areas over
200,000 will need the benefit of the
extension, at least for ozone. 4
4 For a list of the areas which have received an
extension of the attainment deadline to 1987, see
Appendix F.
What has gone wrong? To avoid
repeating mistakes under the new
planning requirements, it is important to
understand why previous clean air
strategies failed. A review of the last ten
years leads to two explanations:
unfulfilled expectations for vehicle
emission controls and a failure to win the
support of local elected officials and the
public for effective controls on
transportation use.
Figure 4 Nitrogen Dioxide Trends in the Annual Mean, 1972-1977
Trend
Direction
EPA Regions
1
2
3
4
5
6
7
8
9
10
Total
CA
Other
Down
No
Change
Up
16
17
17
38
50
3
12
4
15
2
2
176
1
—
0
—
7
26
5
119
9
86
1
7
2
27
0
6
4
26
0
2
1
2
30
312
9
2
Total of
26
19
50
162
145
11
41
10
45
4
5
518
Source: National Air Quality, Monitoring, and Emissions Trends Report. 1977 (EPA, 1978, p. 3- 10)
8

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Controls on Auto Use
Our attachment to the automobile is
strong. The recent history of travel
behavior in the United States is
characterized by
• more automobile trips per person per
• longer trips per person,
• a continued decline in the average
number of occupants per vehicle (i.e.,
there are more single occupant trips),
and
• a sustained increase in the percentage
of all trips that are made by automobile.
Figure 5 shows the predominant mode
of travel is automobile, although air
travel has been making substantial gains
in recent years.
Figure 5 Modal Distribution of
Total Intercity Travel
[ J Air [ ]Rail Highway
1940
1950 J
1960
1970
1975
LI
F
L
I

—
This trend in travel behavior is not hard
to understand. Single passenger auto
travel can be private, comfortable,
convenient, flexible, and fast. However,
it can also be polluting, land-intensive,
energy-consumptive, disruptive of
communities, and increasingly costly.
As increases in total travel have
outstripped gains in emissions, the
importance of finding ways to control
demand for auto travel has become
apparent. The marketplace has already
had a significant effect through price
increases at the gas pump. Demand for
gasoline fell over 7 percent in 1979 and
the federal government hopes for
another 5.5 percent reduction in demand
in 1980. A less costly approach is to
reduce demand through controls on land
use. Simply put, the idea is to move the
land uses that generate vehicle trips
closer to the land uses that attract the
trips. By encouraging mixed land uses
and dense or “cluster” developmçnts,
while controlling access to high-
way improvements, fewer and shorter
auto trips will be needed to meet
the mobility needs of urban areas. This
means fewer emissions, less energy waste
and more open space as urban growth is
directed toward city centers rather than
away from them. It does not, in any
sense, mean “doing without”
transportation.
Changing the flow of traditional
urban growth patterns is a tall order.
Urban expansion will continue.
However, there is room for vast
improvement in present trends, which
can best be described as accelerated
sprawl. And the potential for economic
resurgence in our central cities through
controls on sprawl makes the battle
worth joining. This, however, requires a
knowledge of one of the driving forces
behind urban growth—the planning and
placement of transportation
improvements—and it is to this urban
transportation planning process that we
now turn.
LI
F
E
I
I
I
day,
Source: Transportation Facts & Trends, Trans-
portation Association of America
(1979) P. 18.
9

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Urban Transportation
Planning
The 3C Process
Until recently, the major focus of urban
transportation planning could be
summarized in two words: trip time, that
is, how long it took to get where people
wanted to go. That, transportation
planners realized, is the overwhelmingly
determinative factor in h w often people
drove and where they went. With the
real price of gasoline declining, cost was
not a factor. The major cost of
transportation was the initial investment
to buy a car. Once that investment was
made, it simply did not make sense not
to use it.
Reducing distance means controlling
land use to bring land uses closer
together. Controlling land use, however,
is very difficult and, to date, has been
considered to be the exclusive
prerogative of regional and local
governments. On the other hand,
transportation planning is conducted
primarily at the state level, in state
highway and public works departments.
Excluded from affecting the “distance”
side of trip time, state transportation
planners concentrated on the factor they
could influence: speed. The goal was to
increase it, both by increasing the safety
of high speed travel by designing safe
highways (wide lanes, broad shoulders,
banked curves, etc.) and reducing
congestion (keeping highway capacity
ahead of the demand for that capacity).
Transportation planners were
extraordinarily successful in achieving
safe, high-speed travel. By the early
1970’s, most new highways had a
“minimum design speed” (the maximum
speed for safe travel) of 70 miles per
hour. Rights of way were broad. The
acreage required to build one mile of
highway was extensive; see Figure 6.
Figure 6 Land Use Required for
Each Mile of Roadway
Source: Estimated data from Department of
Interior, National Park Service, Office of Park
Planning and Environmental Quality, October
24, 1978 memorandum.
Credit: Environmental Siatfuics 1978, Council
on Environmental Quality, Figure 4-5, p. 87.
Figure 6, however, reveals a major
problem with concentrating on reducing
trip time; it is land intensive and,
therefore, very disruptive in the
communities where highways are
located. The U.S. Congress recognized
this problem and, in the late 1960’s,
commissioned a study which found that
between 1956, the start of the interstate
program, and 1967 more urban housing
units were destroyed by highways
(approximately 330,000) than were
constructed by our entire national public
housing program (239,374).’ Even more
alarming, over two-thirds of this lost
housing was in low to moderate-income
‘Figures from Report on the National Commission
on Urban Problems to the Congress and President
of the United States, Building the American City,
91st Cong., 1st Sess, HR. Doc. No. 91-34, at 81,
130 (1969).
units. 2 Complaints poured in, not only
from the people whose homes were
taken but from people who lived next to
these new roads and didn’t like the
noise; members of neighborhood groups
who didn’t like their communities split
in two; mayors who didn’t like land
taken off the tax rolls for highways; and
other transportation interests (bus,
transit) that lost customers to new
highways. 3
Congress acted. First, it required that
local elected officials get together with
the various state transportation planning
agencies to establish a “continuing,
cooperative, comprehensive” planning
process (the 3C process). 4 Next it
required that certain areas, such as
urban parks and recreation areas, be
given special protection from highway
construction. 5 Then, concurrent with the
passage of the Clean Air Act of 1970, it
required transportation planners to
coordinate with air quality planners and
EPA to assure that highway
construction was “consistent” with plans
to clean up the air (see discussion of
consistency at p. 16).6 Finally, Congress
required that States develop a plan
(called an Action Plan) that would
assure that final decisions on
2 Low income in 1971 was considered $60 per
month or less (rental) or less than $6,000 valuation
(house), moderate income $60-SIlO per month
(rental) or between 56,000-515,000 (house).
Secretary of the Department of Transportation,
1972 Annual Report on Highway Relocation
Assistance (1972), cited in P.W. Sly, In the Path of
Progress: Federal Highway Relocation Assistance,
82 Yale L.J. 373, n. 27 (1972).
3 lronically, improvements have not resulted in
reduced trip time. Studies of commuter behavior
have shown that the average commuter trip time
has remained stable at about 20 minutes. What has
changed is the distance covered by the trip. The
average trip distance is now about nine miles.
Therefore, the very success of transportation
planners in improving speed has resulted in more
sprawl development, with obvious detrimental
effects on air quality and energy use.
‘23 U.S.C. *134(a) (1970).
349 U.S.C. *1653(f).
‘23 U.S.C. * 109 (J) (1970).
Number
Roadway Type of Acres
Major Highway 35
Interstate-Urban Segment (1) 38
Interstate-Urban Segment (2) 33.5
4-Lane Highway (3) 18.2
2-Lane Highway (4) 14.6
Urban Street (5) 7.3
Data based on the following assumed
right-of-way widths:
1) 250 feet (30.34 acres + 25% for
interchange)
2) 250 feet (30.34 acres + 10% for
interchange)
3)150 feet
4)120 feet
5) 60 feet
10

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transportation projects would be made
“in the best overall public interest.” 7
Subsequent statements and regulations
have elaborated on these requirements in
an attempt to fully integrate
transportation planning into
comprehensive plans for urban
development and air quality plans. With
the signing of an agreement between
EPA and the U.S. Department of
Transportation (DOT) in June 1978 to
encourage joint air quality/transporta-
tion planning in nonattainment areas (see
Appendix B), the process has moved even
further away from a sole focus on “trip
time” towards effective implementati on of
the Congressional directive that trans-
portation decisions be made “in the best
overall public interest.” For simplicity,
this evolving planning process has all
fallen under the rubric of the “3C
process.”
The fundamental improvement of 3C
planning over traditional transportation
planning is that it gives planners and
public officials on the regional and local
levels, who have a mandate to serve
broad community needs, a limited
degree of control over the initiation and
implementation of transportation
projects.
The 3C process presents a
potentially powerful access point for
citizens. 8 It requires that each urban area
establish a Metropolitan Planning
Organization (MPO), comprised in part
of “principal elected officials of general
purposelocal government,” 9 to do
comprehensive transportation planning.
This includes the setting of goals and
objectives through the adoption of a
long-range (15-20 year) transportation
23 U.S.C. §109(h) (1970).
The federal regulations implementing the 3C
process are found at 23 C.F.R. Part 450 (1979).
23 C.F.R. §450.106(d) (1979). Other regulatory
language refers to cooperation with “appropriate
local officials,” raising the question of whether
cooperating merely with local highway officials
rather than local elected officials is sufficient. See,
e.g., 23 U.S.C. §103(cX2). However, the
regulations covering planning for the entire federal
system indicate that “appropriate local officials”
means elected officials, not just highway officials.
23 C.F.R. §470.2 (bX8) (1979).
approve the projects within its urban
area that are forwarded to the State for
inclusion in the annual Program of
Projects. No MPO approval means no
federal funding. It is this power over the
purse strings that gives MPOs a
potentially key role in implementing
the transportation goals laid out in their
long-range Transportation Plan.
The public must be involved in MPO
planning. Citizens are often members of
MPOs, either in a voting or advisory
capacity. As indicated in Figure 7, 22
percent of all MPOs include at least one
citizen representative on their policy
board.
Figure 7 Summary of Representation on Section 134 Policy Boards
Credit: Urban System Study, Report of the Secretary of Transportation to the United States
Congress (1977), p. 47.
plan. What makes the MPO unique is its
supervision of implementation of that
plan through annual approval of (1) the
process through which highway and
transit projects are developed (found in
two documents called the Unified Work
Program and the Prospectus), and (2)
the transportation construction priorities
that result from that process (contained
in the Transportation Improvement
Plan). In exercising its review function
the MPO can both initiate projects for
implementation from the long-range
plan, and review projects and planning
activities initiated by highway and
transit agencies. An MPO must annually
Percent
100—
80
60
40
20
0
11

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The MPO reviews a tremendous amount
of information concerning costs,
revenues, priorities, and scheduling of
federal-aid projects. This information
can be extremely useful to citizens
concerned about urban transportation
air quality planning.
Initiation of projects taken from the
long-range plan for implementation is
shared among MPOs, transit and
highway officials, and local elected
officials. However, it is the MPO
exclusively which reviews and approves
the program documents required by
federal regulations. Following is a brief
description of these documents and how
they can be used.
Unified Planning Work Program
(UPWP):10
This document describes all the planning
activity that will take place over the next
one to two years. One element may
explain how the long-range
1023 C.F.R. §450.I 14(c) (1979).
transportation plan will be broken down
into specific projects and implemented.
Another element may study proposed
changes in the long-range plan. Still
another may plan for more effective
citizen participation. Whatever the MPO
planning staff is doing should be
reflected in this document.
Commitments to study and evaluate
transportation control measures to
determine if they are “reasonably
available” and needed to attain air
quality standards must be included in
this plan.
Prospectus:”
This document describes how the
Unified Planning Work Program will be
implemented. It describes the MPO, its
structure, the responsibilities of its
various departments, and its agreements
1123 C.F.R. §450.114(b) (1979).
with other state transportation agencies
(such as the highway department, the
State Secretary of Transportation, the
regional transit authorities) regarding
planning. It outlines major
transportation issues facing the region,
and describes how the MPO intends to
fulfill its duties, under federal
regulations, to (1) consider social,
economic, and environmental effects, (2)
coordinate air quality planning, (3)
involve the public, (4) comply with anti-
discrimination statutes, (5) provide
public transportation for the elderly and
handicapped, (6) conserve energy, (7)
consider private transportation services,
and (8) bring technical expertise to bear
on transportation problems.’ 2 The
prospectus tells you who makes what
decisions; as such, it is your “blueprint”
of the 3C process. 12 a
Transportation Plan (Long
Range):’3
This document sets the basic
transportation policy for the area. For
example, it may state whether
transportation policy will be oriented
toward transit or highways; whether
projects will emphasize access to the city
center, circle the city. or be aimed at
some other demographic rcgion; or what
the region’s transportation network will
look like many years in the future. It
may reflect a decision to emphasize
demand management through
transportation controls and efficiency
improvements to the existing system or
simply respond to demand by increasing
capacity. It must be “consistent with the
area’s comprehensive long range land
use plan. urban development objectives,
and the area’s overall social, economic,
223 C.F.R. §450.120 (1979). DOT has proposed to
amend these regulations to include more detailed
requirements for energy planning. See 45 Fed.
Reg. 30397 (May 7, 1980).
‘ Section 174 of the Clean Air Act requires that
the Air Quality Transportation planning
responsibilities be contained in a separate
document and approved b EPA in order to
qualify for Clean Air Planning funds. 42 U.S.C.
§7504 (1978 pamph.).
‘ 23 C.F.R. §450.116(1979).
12

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environmental, system performance and
energy conservation goals and
objectives.” 4
The EPA! DOT joint guidelines
require MPOs to consider long range
policies and facilities with potential for
reducing transportation-related emissions
in the long-range plan. A very important
requirement for MPOs in post-1982
attainment areas is a program for
evaluating post-1982 growth policies.
Alternative growth policies and! or
development patterns must be examined
to determine the potential for modifying
total transportation demand.’ 5 This ties
transportation planning directly into
land use planning, the “missing link” of
the traditional planning process.
Transportation Plan
(Systems Management):”
This document explains how existing
facilities will be used efficiently to
promote long range goals. It describes
low-cost, non-capital improvements to
the system such as preferential bus lanes,
bikeway programs, changes in tolls and
fare structure, and carpooling. it also
covers management and operational
improvements. Non-federally funded
management improvements must also be
listed.’ 7 Elements of this plan must
be included in the annual element of the
Transportation Improvement Program
(discussed below) for early
implementation. If this plan is contained
in a State Implementation Plan, it is
also called Transportation Control
Measures.
Transportation Improvement
Program (3-5 Year): 18
The Transportation Improvement
Program describes the projects which
will be implemented in the next three to
five years. It must be compatible with
the long range plan. it sets priorities for
construction, gives estimates of costs and
revenues, and explains why the projects
are recommended for priority treatment.
It should identify transportation control
measures and long range projects that
produce incremental reductions in
emissions and set priorities. 19 All
transportation-related elements of the
State Implementation Plan that require
funding should be in the Transportation
Improvement Program.
Transportation Improvement
Program (Annual Element):20
This is a compilation of improvements
slated for implementation in the
upcoming year. It is forwarded to the
State Highway Department or Secretary
of Transportation (if one exists), for
inclusion in the statewide “Program of
Projects” submitted annually to the U.S.
Department of Transportation for
approval. The Annual Element is the
launching pad. Once a project gets in the
Annual Element and funds are allocated
to it, the project is ready for
construction.
This, then, is the “3C process” and the
documents it produces. The thrusts of
the process are 1) to make
transportation planning comprehensive
in nature, 2) to decentralize planning by
giving supervisory power over the
process, through membership in the
MPO, to locally elected officials, and 3)
to emphasize short range incremental
improvements that complement
community development goals.
The connection made in this process
between comprehensive planning and
transportation planning provides the
potential for molding transportation
demand studies to community values
and needs. Rather than simply
participating in developing a
‘ CAA §176(d). 42 U.S.C. §7506(d)(l978 pamph.).
°23 C.F.R. §450.312 (1979).
comprehensive plan, members of the
MPOs can actually track
implementation of the plan by
monitoring the progress of projects from
the long range plan, through the 3-5
year element of the Transportation
Improvement Program, to the Annual
Element and then to construction. 2 ’
Newly perceived consequences of
previous planning decisions can be re-
evaluated on an annual basis and
adjustments made. Transportation
decisions on projects can change from
“yes or no” to “maybe”, with the
ongoing option to press down or let up
on the accelerator, or even turn back.
The membership requirements improve
citizen access, both through citizen
membership on the MPO and through
membership by locally elected officials;
and the new EPA/DOT citizen
participation requirements, discussed
below, will open up the MPO process to
citizens still further.
The success of the new structure is by
no means assured. State transit,
highway, and other transportation
agencies are reluctant to have a new
agency supervise implementation of their
projects. Similarly, particular localities
and municipalities, which have to
develop a close relationship with state
and federal officials to facilitate their
projects, do not now want these projects
scrutinized by a regional body such as
an MPO. The MPO structure, however,
has sustained legal challenge. Governors,
who designate MPOs within each state,
have been lobbied by state
transportation officials to designate state
transportation agencies as MPOs.
Citizens should therefore scrutinize
MPO membership to determine if it is
indeed comprised of “principal elected
officials of general purpose local
government” as required by federal
regulations. It is in your interest to
protect and improve this move toward
comprehensive urban transportation
planning.
2t Notice that there is a gap in the documentary
process. Although most major transportation
projects take much more than five years to plan,
there is no document outlining the planning during
the period 5-15 years in the future.
“23 C.F.R. §450.116(d) (1979).
‘ 5 Transportation—Air Quality Planning
Guidelines, United States Department of
Transportation and United States Environmental
Protection Agency. June 1978.
1623 C.F.R. §450.116(b)( 1979).
“23 C.F.R. §450.312(aX2) (1979).
“23 C.F.R. §450.312 (1979).
F .cc fl ?.ymcy
L ary
401
.;fl D .C 4
2 ’ 4
j46Q
13

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Citizen Action
If the MPO in your area is the
designated agency for clean air planning,
you have special rights regarding
participation in its activities (see p. 27).
If the MPO is not the designated clean
air planning agency, there should be an
agreement worked out between the two
agencies which assigns responsibility for
transportation related clean air planning
to the MPO, and which provides for
citizen participation in such planning.
Citizens should review each document
required in the 3C process (Long Range
Plan, Transportation Systems Manage-
ment Element, Unified Planning
Work Program, Prospectus, Trans-
portation Improvement Plan and
Annual Element) for compliance with
federal regulations. is the selection of
projects for implementation related to
regional transportation and land use
policy? Usually, it is not. Most new
construction projects are developed by
state and municipal highway and transit
officials who base their studies on
complex demand forecasts that are
unrelated to regional and community
values. The result may be the
development of plans for new highways
in the urban fringe, where growth is
occuring, even though the regional plan
calls for dense center development, more
transit assistance, and an emphasis on
projects that control growth of
transportation demand. In theory, the
MPO has the authority to reject projects
that do not conform to regional goals
simply by refusing to advance such
projects through the planning process to
construction. in reality, MPOs defer to
the localities that make up their
membership, including the fringe
communities that want more
construction.
The MPO presents a forum for
confronting the conflict between regional
goals and project proposals, and for
brokering a solution. But this cannot
happen if MPOs refuse to articulate
regional goals in the Long Range Plan,
or to evaluate projects for inclusion in
the Transportation improvement Plan or
Annual Element. The role of the citizen
is to focus MPO attention on these
issues, to make sure that “all the cards
are on the table” when decisions to
advance or delay projects are made, and
to hold public officials accountable for
their decisions. In the opinion of most
transportation planners, trend (forecast
demand) is destiny. Through the MPO
brokering process, citizens have the
opportunity to evaluate trends in light of
community goals, and if a conflict is
apparent, to say “no, let’s try something
different, such as land use controls or
the channeling of forecast demand to
existing routes.”
Air Quality and Urban
Transportation Planning
The 1970 Act required that each State
designate Air Pollution Control
Agencies in each sub-state area that had
an air pollution problem. These agencies
were to prepare the component parts of
the overall State Implementation Plan
(SIP) and obtain whatever agreements
were necessary for enforcement. 22 In
many regions the MPO itself was
designated as the agency with lead
responsibility for air quality planning. In
other regions a separate air agency was
either designated or established that
would coordinate with the MPO. In
either event, the MPO was assigned the
responsibility both to (1) prepare the
portion of the State Implementation
Plan containing strategies for control of
pollution from mobile sources (the
transportation control plan) and (2)
assure that the entire plan (stationary
and mobile source controls alike) was
“consistent” with the 3C planning
process. 23 If a State implementation
Plan was nor consistent with the 3C
process, the 3C process itself could not
be approved (“certified’ by DOT, and
federal transportation construction funds
could not flow to the area covered by
the MPO.24
When MPOs were assigned the
responsibility for advancement of
projects through the 3C process to
construction, it seemed appropriate to
grant MPOs similar authority for
meshing that selection process with clean
air goals. The assumption was ill-
founded. Problems arose regarding
consistency determinations, certification
reviews, and the MPO structure itself,
that prevented effective coordination
between air quality and transportation
planning. Resolving these problems will
be a gradual process as air quality and
transportation planning activities fold
22 CAA § IO5, 302(b). 42 U.S.C. §%7405(aX2).
7602(b).
2323 U.S.C. § 109 (j). 23 C.F.R. §770.204.
2423 C.F.R. §770.204(d).
14

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togetner in tne next severai years. I he
public has a large stake in assuring a
smooth and effective transition, and it is,
therefore, appropriate to review these
identified problems in the air
qualityj transportation planning process:
MPO Structure: Although municipal
planning organizations must endorse and
program projects in order for such
projects to get federal funding, MPOs
are essentially voluntary organizations,
with no independent governmental
authority to tax, zone, legislate, or spend
money other than on their own
activities. They are essentially forums for
mutual problem solving and cooperative
action, designed to surface conflicts
between the transportation proposals of
the participating agencies and
governmental units that make up their
membership. 25 They must also rely on
membership organizations to implement
the selected projects, and for the
information used in selecting projects.
Unless they are in urban areas of over
200,000 population, MPO planning
funds are channeled through the State,
which also screens the projects selected
by the MPO for inclusion in the State’s
Program of Projects before submission
to DOT. 2 6 This dependence on state
agency support of MPO activities makes
MPOs very sensitive to state desires in
project selection. Similarly, MPOs
depend on local governments for
planning support (MPO staffers are
often funded, at least in part, by
participating governments) as well as
implementation of most selected
projects, particularly transportation
system management strategies.
Cooperation, therefore, is an essential
25 Stronger Federal Direction Needed To Promote
Better Use of Present Urban Transportation
Systems, General Accounting Office, CED-79- 126
• (October 4, 1979) p. 23.
2623 C.F.R. Part 420 (1978).
ingredient of MPO success. Moreover,
the MPO has virtually no interest in
making a finding that planning does not
conform to federal 3C planning or air
quality consistency requirements since
the consequence of such a finding is a
cut-off of federal transportation funds to
the area. Finally, the MPO is often not
the only organization involved in
regional planning. A 1977 study of the
3C planning process found that, of 261
MPOs nationwide:
• only 35 also represented the recipients
of capital funds from the U.S. Urban
Mass Transportation Administration
(DOT);
• only 143 reviewed other federally
financed or permitted projects in the
region under the clearinghouse review
process established by 0MB Circular A-
95; and
• only 181 directed other comprehensive
planning activities in the region. 27
Because of the essentially voluntary
and cooperative nature of the MPO
process, success in selecting and
implementing transportation system
management strategies that support
clean air goals, as well as energy
Urban System Study, Report of the Secretary of
Transportation to the United States Congress (1977),
p. 42.
I
15

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conservation and urban revitalization
goals, depends on strong citizen
participation to assure that these
projects are advanced by the MPOs.
Consistency Review: The heart of the
effort to create a mutually-supportive air
quality/transportation planning process
during the 1970s was the “consistency
review process” established pursuant to a
mandate by Congress that DOT assure
consistency between air quality plans
and transportation projects. 25 DOT
implemented this responsibility by
requiring two types of consistency
reviews: specific transportation projects
were required to be consistent with the
approved State Implementation Plan in
the area where the project was located
(microscale consistency) and the 3C
process itself was required to be
consistent with the air quality planning
process in the region (mesoscale
consistency). Microscale consistency was
required for the approval of an
environmental impact statement for a
project; 29 mesoscale consistency was a
condition of certification of the 3C
process, and release of federal
transportation capital and planning
funds for the area. 3 ° The precise
definition of “consistency,” however,
both on the mesoscale and microscale
levels, was left to the agency responsible
for making the determination: the
Regional Federal Highway
Administrator for highway projects; the
MPO (with FHWA review) for process-
level determinations. This resulted in
much confusion. Some consistency
determinations were based solely on
“good faith” commitments by MPOs to
give due regard to clean air goals. Other
determinations were based on detailed
criteria designed to assure that
transportation plans, when implemented,
would not increase either total mobile
23 U.S.C. §l09(j) (1979).
23 C.F.R. §770.205 (1979).
°23 C.F.R. §770.204 (1979).
source pollutants or total area pollutants
nor delay attainment of federal air
quality standards. Still other areas
simply inquired whether any particular
transportation project was barred from
implementation by the terms of the
approved state implementation plan. If
not, the project was approved. In five
years of experience with consistency
review, DOT has declared only one
MPO planning process to be
inconsistent with clean air goals, 3 ’ and
has never refused to fund a highway
project on the basis of unacceptable air
quality impacts. (Note: these problems
have been addressed in new
“conformity” regulations jointly
proposed by EPA and DOT. See p. 25).
Another definitional problem existed
with regard to transportation system
management (TSM) projects. One
purpose of the 3C regulations was to
focus the attention of regional planners
on short-term management
improvements that could improve the
efficiency of the existing system and
promote national clean air goals in the
process. During certification, reviews
were made by DOT to determine if
TSM programming and implementation
were given priority. But few guidelines
were given on how to define a TSM
project. Consequently, some transit
officials thought all transit
improvements were such projects, even
high cost projects that added capacity,
such as a new transit line, a new high
occupancy vehicle lane, or highway
construction to reduce bottlenecks. Still
other officials considered rehabilitation
and maintenance—such as road
resurfacing and bridge replacement—to
be system management actions. 32 The
result was that many projects that had
little or nothing to do with the
‘Certification of the planning process conducted
by the Denver Regional Council of Governments
was revoked in October 1976. Certification was
restored in April of the following year.
326A0, Stronger Federal Direction Needed to
Promote Belier (ice of Present Transportation
System, CED-79-126 (October 4, 1979.)
achievement of air quality standards or
energy conservation were given priority
consideration under the vague rubric of
TSM.
3C Certification: Implementation of
the 3C planning regulations 33 identified a
fundamental problem: lack of either an
incentive or mechanism for resolving
conflicts. While MPOs were responsible
for endorsing planning activities and
projects, the voluntary nature of the
organizations required decision by
consensus. Therefore, instead of coming
to grips with the fact that member
organizations proposed many more
projects than could be built with existing
funds, many MPOs would not make the
hard choice of selecting some projects
over others. Instead, they simply
endorsed all projects (called
“overprogramming”). 34 Similarly, instead
of evaluating projects in light of regional
land use, energy, and policy goals,
MPOs would engage in elaborate “what
if” studies (i.e., “what if” we focused new
investments in densely populated areas,
or “what if” we attempted to
accommodate projected demand within
existing capacity?) but did not apply
regional policies when actually selecting
projects. Moreover, MPO endorsement
of its own planning activities and the
projects located within its jurisdiction
was the single most important criteria
for certification of the planning process
itself. Since an adverse finding meant no
federal transportation funding for the
region, a “don’t rock the boat” attitude
prevailed which discouraged people from
asking tough questions and demanding
good answers.
23 C.F.R. Part 450, 40 Fed. Reg. 42977
(September 17, 1975).
This is a violation of the 3C planning regulations
which state that the total amount of funds
approved for construction in the Annual Element
must be “reasonably consistent” with the amount of
Federal funds expected to be available to the area.
23 C.F.R. §450.312(d) (1979).
16

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Citizen Action
Figure 8 Comparison of Ridership (Passenger Miles/Gallon) to Capacity
Without a massive national
movement toward regional
government—an unlikely event in a
nation where both States and
localities jealously guard their
respective governmental respon-
sibilities—MPOs will remain
essentially voluntary organizations
and these problems of structure,
consistency and certification will
remain. While MPOs must assure
that air quality and transportation
planning are consistent, the difficult
“how” question is yet to be addressed.
That’s the job of citizens—asking the
tough questions.
Watch for plans that schedule more
projects than can be built.
Overprogramming destroys the whole
purpose of having a cooperative
decision-making forum since it is
essentially a decision not to decide.
Instead, the first projects to receive
approval of detailed design and
specifications get funded, regardless
of the project’s relationship to
regional goals. Demand that
programming be related to regional
policy, 35 even if this is no more than a
narrative statement in the
Transportation Improvement Plan or
Annual Element explaining how the
package of selected projects advances
regional goals.
The flip side of overprogramming is
the failure to program and implement
effective system management
strategies, as well as failure to plan to
reduce forecasted demand. Are alterna-
tive growth policies studied for their
effect on transportation demand?
Your insistence on planning to
minimize growth of new
transportation demand does not make
you “anti-growth,” it makes you “pro-
planning for growth.” The same
amount of growth can have a vastly
different effect on the existing
transportation system depending on
whether it is planned or unplanned.
35 This is also a requirement of the 3C planning
regulations. 23 C.F.R. §450.308 (1979).
, “
Figure 8 relates capacity to existing
use of that capacity by mode of travel.
Obviously, substantial growth in traffic
can be accommodated within existing
capacity if growth is planned to make
good use of that capacity.
Once you have a good plan, make sure
the MPO is programming transportation
management strategies which support
the plan. Federal regulations tie funding
of mass transit discretionary capital
grants to advancement and
implementation of system management
strategies in support of such grants. 36
Finally, solicit state transportation
agency support for MPO-endorsed
system management and public
transportation projects. If a State does
not concur with an MPO-endorsed non-
highway public mass transportation
project , it must explain that
49 C.F.R. Part 613. See also CAA §176(d), 42
U.S.C. §7506 (1978 pamph.) assigning priority
attention to TSM projects.
1 1
nonconcurrence in writing. 37
If the MPO refuses to address your
questions, write the certifying agencies 38
and ask that answers be provided as a
condition of federal certification. The
focus of citizen action should be to
make sure that “all the cards are on the
table” when programming decisions are
made that affect regional air quality,
growth, and energy use. When they are,
consensus decisionmaking is facilitated,
not jeopardized.
23 CF.R. §450.318(bXI).
Air (Jet)
Short Haul
Average All
Wide-Body
Passenger Miles/Gallon
D Seat Miles/Gallon
U E J Width Represents
I I Range of Estimates
High Speed
Ground
Auto
Average All
:; Average l.C.
Subcompact l.C.
E I
E
0
Rail (Suburb)
Commuter
“BART”
Suburban
0. 1
1-
Rail (l.C.)
Metroliner
Cross-Country
I
Bus
Urban
Suburban
I
A ” ra
II -
40 80
Passenger or Seat— Miles Per Gallon
Source: State and Regional Transportation Impact Identification and Measurement, Bigelow-Crain Associates
(1976), p. B-3
38 Certitication is conducted by the Regional
Administrators of UMTA and FHWA, in
consultation with EPA pursuant to a
“Memorandum of Understanding” (MOU) of June
14, 1978 (Appendix B). Often, however, FHWA
and UMTA will also consult with other DOT
regional representatives (Federal Rail road
Administration, Coast Guard, Federal Aviation
Administration) as part of the certification process.
All DOT regional representatives together are
called “Intermodal Planning Groups” or lPGs.
17

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The Clean Air Act
Amendments of 1977
In 1977 Congress undertook a major
revision of the Clean Air Act.’ Its basic
tructure survived, but increased
attention was gi en to controlling mobile
sources of pollution and the federal
enforcement hand was strengthened.
Here are a few of the improvements that
can be used to promote urban vitality:
First, The Act was extended to cover
clean air regions. This protects urban
areas from “industrial flight” by
eliminating the incentive for iolluting
industries to relocate in areas with less
stringent air quality controls. 2
Second, the statutory deadline for
attainment of national ambient
standards was pushed back to December
31. 1982 or, upon a showing that
attainment for carbon monoxide and
ozone was not possible by that date, not
later than December 31, l987. The
Amendments provided for identifying
those areas which had not yet attained
air quality standards. 4 and required
these “nonattainment areas” to revise
their implementation plans by January
1, 1979. EPA was directed to review
and either approve or disapprove these
revised plans by July 1, 1979.’
Third, the transportation,’ air quality
planning process was strengthened both
to integrate planning activities on the
federal (EPA! DOT) and regional
(state local) levels and to assure
implementation of effective
transportation control strategies. New
requirements included: (1) integrated
planning. (2) the adoption of virtually all
transportation control strategies that
were available and effective (3) measure-
ment of progress towards clean air goals
as a condition of continued state
implementation plan approval, (4)
adoption of Inspection and Maintenance
(I. M) programs. and (5) the
development and funding of
‘Pub. L. No. 95-95, 91 Stat. 685 (1977), as
amended by Pub. L No. 95-190,91 Stat. 1401-02
(1977) (technical and conforming amendments).
The Clean Air Act, originally codified at 42 U.s.c.
1857-1858a, was recodified at 42 U.S.C.
2 CAA 160 ci seq (Part C), 42 U.S.C. *7470
ci seq (1978 paniph.)
‘CAA *172(a). 42 U.S.C. *7502(a) (1978 pamph.).
4 CAA *107(d), 42 U.S.C. *7407(d) (1978 painph.).
‘Section 129(c) of Pub. L. No. 95-95 (uncodified).
‘CAA 1 10(aX3XA), (c) 42 J.S.C.
47410(aX3XA) (1978 pamph.).
comprehensive public transportation
plans to assure that tht. basic
transportation needs of urban areas
would not be totally dependent on
automobile transportation.
Fourth, new infOrmation requirements
were established. EPA was instructed to
develop and circulate “information
documents” explaining alternative
control measures and how communities
that had adopted these measures had
fared. 7 Citizen participation require-
ments were expanded beyond a right to
review and comment on implementation
plans to a right to participate in the
planning process itself. Local elected
officials were also given a greater role in
the compilation of the implementation
plan.
Fifth, tough sanction provisions were
imposed. DOT and EPA are now
required to withhold federal highway
and sewer funds if a State fails to make
reasonable progress towards adopting
and implementing an adequate air
pollution control plan. It is this new
responsibility of DOT to divert federal
transportation funds away from projects
that increase auto use (and auto
emissions), and towards projects that
reduce dependence on the private
automobile, that makes the 1977
Amendments so important to citizens
concerned about improving the
efficiency of urban transportation
systems.
7 CAA *108(f). 42 U.S.C. *7408(f) (1978 pamph.).
Current Clean Air Act
Requirements
The Clean Air Act, as amended, set new
clean air goals and required States to
document “reasonable further progress”
toward attainment by first conducting an
inventory of present emissions and then
establishing a continuing monitoring
process to track progress towards
achieving clean air goals. The control
strategy for attaining air quality goals
includes stationary source controls
(controls on emissions from all
stationary sources of pollution, such as
industrial smokestacks); and mobile
source controls (primarily automobiles—
but including buses, aircraft, and other
modes of transportation). For both,
minimum requirements must be met.
Each State with a nonattainment area
for a specific pollutant is required to
revise its implementation plan to explain
how these requirements will be met and
maintained. Since the deadline for plan
revision was July 1, 1979, present efforts
focus on approval and implementation
of these plans—two areas where citizen
assistance is needed. Figure 9 depicts
problem identification, strategy
development, implementation and
monitoring.
That’s a broad sketch of the Clean Air
Act as it stands today. Here are the
details:
Federal Air Quality Standards
The central feature and ultimate goal of
the Clean Air Act remains achievement
of National Ambient Air Quality
Standards. EPA is empowered to set
two types of standards. Primary
standards are set at levels which are
adequate to protect human health.
Secondary standards are set at levels to
protect human “welfare”—meaning all
18

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non-health related values, such as
property, vegetation and scenic value. 8
Based on documented research, these
standards are set at whatever level is
necessary to protect human health and
CAA §108(aX2), 42 U.S.C. §7408(aX2) (1978
pamph.). See South Terminal Corp. v. EPA, 504
CAA §109(b), 42 U.S.C. §7409(b) (1978 pamph.). F.2d 646 (1st Cir. 1974).
Figure 9 Flow Chart for SIP Revision to Meet Oxidant and Carbon Monoxide
Standards by 1987
welfare—without reference to the cost. 9
However, the cost factor has become
increasingly important as subsequent
research has revealed no threshold below
-
revised in light of the success of implementing the
measures. Loop B emphasizes that the SIP must
be periodically evaluated and revised in light of its
success in maintaining reasonable further progress
toward 1987 attainmenL If progress for any year
falls below the level required, the SIP must be
strengthened to compensate for this shortcoming.
Source: National League of Cities
There are two “feedback loops.” Loop A
recognizes that implementation of transportation
control measures will be highly dependent on the
planning process developed by the lead agency.
The planning process is depended on to develop
public and political acceptance of the measures.
The process should be continually evaluated and
which no effect on human health is
recorded and as the marginal cost of
removing pollution increases.
EPA designates both the pollutants ’°
and the standards.” The primary and
secondary standards for the “criteria
pollutants”’ 2 are shown in Figure 10.13
Action Tip
Due, in part, to a recognition of the
difficulties in determining health-based
standards and in controlling the
marginal cost of reducing air pollution,
Congress established a National
Commission on Air Quality to study
these problems. The Commission must
study benefit! cost trade-offs in air
pollution control and report its
recommendations to Congress by
March 1, 1981. It also has a broad
mandate to involve the public in its
deliberations. More information on what
the Commission is studying and how
you can get involved is available from
the Commission’s Office of Community
Liaison, 499 South Capitol Street, S.W.,
Washington, D.C. 20003.
‘°The establishment of NAAQS is actually a three
step process. The Administrator first publishes a
list of pollutants for which NAAQS are being
considered. CAA §108(aXl), 42 U.S.C. §7408(aXl)
(1978 pamph.). The Administrator next publishes a
“criteria document” summarizing available
scientific evidence on each pollutant on the list.
CAA §108(aX2), 42 U.S.C. §7408(aX2) (1978
pamph.). Finally, on the basis of the information
in the criteria document, the Administrator
promulgates primary and secondary NAAQS.
CAA §109(aXl), 42 U.S.C. §7409(axl) (1978
pamph.). The Administrator may from time to
time modify or issue new lists, criteria documents
and NAAQS. CAA §*l08(axl), (c), 109(bxl),
(bX2), (d), 42 U.S.C. § 7408(aXl), (c), 7409(bXl),
(bX2), (d) (1978 pamph.).
“CAA §*108(a), 109(a), 42 U.S.C. **7408(a),
7409(a) (1978 pamph.).
‘ 2 ”Criteria pollutants” are those seven pollutants
for which NAAQS have been established. They are
distinguished from “hazardous pollutants”
discussed subsequently.
‘ 3 NAAQS were first promulgated in 1971. 36 Fed.
Reg. 22384 (1971) 40 C.F.R. Part 50 (1978). The
lead standard was promulgated in 1978. 43 Fed.
Reg. 46258 (1978). The ozone standard was
relaxed in 1979. 44 Fed. Reg. 8202 (February 8,
1979).
—(_ Identify nonattainment and ICR areas
clinventory current emissions
g / oject emissions for each calender year through 1987. (Add emissions from
( growth; subtract reductions from federal motor vehicle control program.
l inspection and maintenance program, stationary source controls, and
.8 transportation control measures already committed to.)
, ‘ Develop emissions shortfall for each calender year through 1987 to achieve
‘reasonable further progress” line by 1982 and attain air quality standards
\ , by 1987
Develop and periodically revise emissions reduction goals for
transportation and stationary sources:
Transportation: Stationary Sources:
(primarily local) Iprimarily state)
( EPA develops information on “reasonabl ”\
available control technology” J
technology
I ,aluate progress
( Periodically review progress in
achieving emissions reduction goals
Attain standards
Develop (and periodically revise)llocall
agency planning process

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Figure 10 NatIonal Ambient Mr Quality Standards Designation of Air Quality -
____________________________________________________ Control Regions
Because air pollution does not respect
Substance Calculation nlmary-standard Secondarv-standard political boundaries, air quality planning
Photochemical Maximum 12 ppm same as primary must frequently cross city and even state
oxidants / (expected) lines in order to be effective. In
Ozone (03) in 1 hour recognition of this the Clean Air Act
provides for the entire country to be
Hydrocarbons Maximum in 160 microgm/m 3 same as primary divided in Air Quality Control Regions
(HC) (corrected 3 hours, (0.24 ppm) (AQCRs) which correspond roughly to
for methane) 6 a.m. -9 a.m. the major pockets of pollution.
The 1977 Amendments called for
Carbon Monoxide Maximum in 10 milligm/ m 3 same as primary States to identify those AQCRs, or
(CO) 8 hours (9 ppm)
Maximum in 40 milligm/ in 3 same as primary portions thereof, which did not attain
1 hour (35 ppm) the national ambient air quality
standards (NAAQS) for criteria
Sulfur Dioxide Annual geometric 80 microgm/ m 3 no standard pollutants. In these nonattainment areas
(SO 2 ) mean (0.03 ppm) the responsible jurisdictions and agencies
Maximum in 365 microgm/ m 3 no standard must work cooperatively toward
24 hours (0.14 ppm) reducing pollution to meet the
Maximum in no standard 1,300 microgm/m 3 standards. In clean air or attainment
3 hours (0.5 ppm) areas, the effort must be directed to
prevent any further deterioration of
Nitrogen Dioxide Annual arithmetic 100 microgm/m 3 same as primary existing air quality.
(NO 2 ) mean (0.05 ppm) In each AQCR is an air quality
agency designated to coordinate the
Particulates Annual geometric 75 microgm/m 3 60 micro n/ m 3 development of that region’s component
(TSP) mean (only a guide) of the overall SIP. For nonattainment
Maximum in 260 microgm/m 3 150 microgm/m 3 areas (within these AQCRs) that require
24 hours transportation strategies, a designated
lead planning agency, usually a regional
Lead Arithmetic mean 1.5 microgm/m 3 same as primary transportation-air quality planning
(Pb) over 3 Months agency provides the transportation
control plan portion.
Assessing Air Quality
An area is designated nonattainment for
a particular pollutant if the national
ambient air quality standard is violated
more frequently than allowed.
Accurately defining the air quality
problem (according to degree,
characteristics and sources) and
substantiating the progress achieved in
overcoming it, require the preparation of
an emissions inventory, monitoring of
ambient air quality and air quality
modeling.
Air quality monitoring directly
measures the actual concentration of
pollutant emission in the ambient
(overall) air. It involves the use of deli-
cate instrumentation which samples actual
air quality. Monitoring (a) determines
actual violations of the NAAQS and
assists in defining the area which is
20

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nonattainment for the violating
pollutant, (b) can be used to assure
compliance so that specific stationary
and mobile sources do not continue to
exceed standards and (c) can be
employed to track the progress in the
actual reduction of pollutant emissions
in overall air quality.
The emissions inventory must be an
accurate, comprehensive and current
assessment of the volume and source of
actual emissions from stationary and
mobile sources. This may be
accomplished by placing measuring
devices directly on pollution sources or,
more often the case, by estimation
(computing the rate of pollutant
emissions per level of activity by source).
A reliable baseline emissions inventory
enables planners to project the volume
of future emissions based upon expected
changes in population, economic and
industrial activity and travel patterns.
With an accurate picture of emissions,
the nonattainment area can quantify the
total amount of emission reduction
required to meet healthful NAAQS.
Technical, economic, social and political
factors are then weighed in determining
the emission reduction target necessary
to be achieved from each contributing
sector. It is important that citizens pay
careful attention to the techniques
employed in their area in determining
the severity of existing and projected air
pollution. Inappropriate analysis could
lead to a misrepresentation of the air
quality problem.
Given the amount and source of
emissions to be reduced, planning
agencies in the nonattainment areas can
then examine the emission reduction
potential of various stationary and
mobile source control strategies. The
emission reductions projected to be
achieved from these control strategies
are usually estimates derived from air
quality and transportation modeling.
Modeling, a mathematical representation
of real world conditions, can provide
further definition to the severity of the
air quality problem. It can help
determine the temporal and geographic
distribution of air pollution as well as
the expected amount of emission
reduction to be achieved per control
strategy. Large MPOs, in areas with
severe CO ailu J3 pIJuI 111a, aII !J
expected to employ more sophisticated
modeling.
Monitoring and modeling will both
contribute to the determination of
reasonable further progress—a concept
to which we now turn.
Reasonable Further Progress
Under the 1970 Act, a State’s
responsibility was limited to
implementing its plan. When, as a result
of Congressional action or litigation,
States were excused from implementing
certain elements of their plans, clean air
efforts floundered. Also, early
calculations of the effectiveness of
several control strategies proved
overrated in practice, reducing the
benefits gained from plans that were
implemented on schedule.
The 1977 Amendments require results,
not just plans. Approval plans must now
demonstrate “reasonable further
progress” towards attainment of air
quality standards during the course of
plan implementation.18 Reasonable
I8CAA *172(b), 42 US.C. *7502(b) (1978 parnph.).
Figure 11 Reasonable Further Progress
Current Ambient
Air Quality
Attainment
Level (NAAQS)
1979
iuiuici piugivss is iuiuicr u iiii u as
“substantial reductions (in emissions) in
the early years following approval or
promulgation of plan provisions . . . and
regular reductions thereafter . . . which
are sufficient in the judgment of the
(EPA) Administrator to provide for
attainment of the applicable national
ambient air quality standard” by the
required date.’ 9 EPA guidance further
defines the extent of reductions as
follows:
“Reasonable further progress will be
determined for each area by dividing the
total emission reductions required to
attain the applicable standard by the
number of years between 1979 and the
date projected for attainment (not later
than 1987). This is represented
graphically by a straight line drawn from
the emission inventory submitted in 1979
to the allowable emissions on the
attainment date. “20
In graphic form, “reasonable further
progress” is depicted in Figure 11.
‘ 9 CAA *171,42 U.S.C. *7501(1978 pamph.).
20 EPA memo, attachment 1 (Criteria for Approval
of 1979 State Implementation Plan Revisions for
Nonattainment Areas) at 3.
Attainment Deadline
1987)
S....

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Drawing a line on a graph doesn’t
accomplish much. Of importance is the
fact that failure to maintain reasonable
further progress requires revision of the
implementation plan to include
additional reasonably available control
measures which were previously
considered unnecessary to achieve air
quality standards. In addition,
transportation plans that call for
construction of projects that will result
in increased emissions (primarily new
highway construction) must be delayed
on a priority basis according to a
“contingency plan” established in the
State Implementation Plan approval
process. (See discussion under the
Conformity Requirement, p. 25.)21 This
combines a “first, do no harm” principle
with a commitment to periodically
review progress towards attainment and
adopt additional reasonably available
control measures on an “as needed”
basis.
Stationary Source Controls
Stationary source controls apply to both
new and existing sources of air
pollution. The minimum federal
requirements are set forth in Figure 12.
First, the Act establishes minimum,
national standards for certain categories
of new sources of pollution. These New
Source Performance Standards (NSPS)
establish a minimum level of control for
specific new sources regardless of where
the plant is built. 22
Second, additional controls are placed
on sources hich emit “hazardous air
pollutants”—pollutants which result in
an increase in mortality and serious
illness but for which no air quality
standards have been established. (These
include asbestos, beryllium, mercury,
arsenic, and vinyl chloride.) 23 These
National Emission Standards for
Hazardous Air Pollutants (NESHAP)
apply to both new and old industrial
sources in attainment as well as non-
attainment areas. 24
2 CAA §1’6(c) regulations (not yet promulgated).
22CAA §111,42 U.S.C. §7411 (1978 pamph.).
2M0 CF.R. Part 61(1978).
2 4 CAA §112. 42 U.S.C. §7412 (1978 pamph.).
Third, new sources locating in
nonattainment areas must be equipped
with pollution controls to assure the
Lowest Achievable Emission Rate
(LAER) for the pollutants causing the
violation. 25
Fourth, in addition to achieving
LAER, new sources locating in
nonattainment areas are subject to an
offset requirement whereby the source
must demonstrate that the pollution
expected to result from its operation is
offset by reductions in pollution from
existing sources elsewhere in the area. 26
Fifth, existing sources in nonattain-
ment areas, though not required to meet
the tougher LAER standards, are required
to apply Reasonably Available Control
Technology (RACT). This means the
level of control technology which is
reasonably available considering
technological and economic feasibility.
Sixth, because the lowest achievable
emission rate and the offset requirement
apply only to plants locating in polluted
areas, it was feared that new sources
CAA §4171(3), 173(2), 42 U.S.C. §47501(3),
7503(2) (1978 pamph.); 42 Fed. Reg. 55526.
26 An Offset Ruling was originally promulgated by
EPA in 1976. 41 Fed Reg. 55524, 40 C.F.R. part
SI, Appendix 5, revised, 44 Fed. Reg. 3274
(January 16, 1979). The 1977 Amendments,
however, adopted this policy as law. CAA
Amendments §4129(a), CAA §* 172(bX6), 173, 42
U.S.C. §%7502(bX6), 7503 (1978 pamph.).
would go to unpolluted, rural areas.
Consequently, the 1977 Amendments
require that new sources locating in
attainment (clean air) areas be required
to utilize the best available control
technology (BACT) to reduce pollution
from both hazardous and criteria
pollutants, and that States plan to
prevent significant deterioration of air
quality in these areas. 27 This requirement
for plants in clean areas, although
somewhat less stringent than the lowest
achievable requirement, is restrictive
enough to prevent the wholesale
relocation of plants from polluted to
nonpolluted areas.
Control of these stationary sources of
air pollution is of direct importance to
citizens interested in urban
transportation planning. Several
regulated pollutants are emitted from
both stationary and mobile sources.
Examples are hydrocarbons, nitrogen
oxides and particulates. The requisite
level of mobile source control necessary
to achieve air quality for these pollutants
therefore fluctuates according to the
level of success achieved in controlling
these pollutants from stationary source
controls and the decisions and tradeoffs
made in the political arena.
Mobile Source Controls
Inspection and Maintenance
Of all the measures aimed at reducing
transportation related pollution,
inspection and maintenance (I/M) is
sure to have the most immediate payoff.
While other control measures are
designed to induce greater transit
ridership, promote efficient use of
roadways, or reduce sprawl development,
1/ M focuses right on the tailpipe. By
requiring an automobile emissions
inspection (in the same way that many
States now conduct safety inspections) a
lid is put on the three enemies of an
effective technological solution to air
pollution: fuel switching, tampering and
poor maintenance.
27 CAA §4165(aX4), 169(3)173(2), 42 U.S.C.
§*7475(aX4), 7479(3), 7503(2), (1978 pamph.);
regulations at 39 Fed. Reg. 42510 (1974), 40
C.F.R. Part 52.21(dX2Xii).
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Recent studies demonstrate that I! M
has an impressive payoff in reducing the
auto-related pollutants—carbon
monoxide, hydrocarbons and ozone.
Research conducted by EPA shows that
emissions from tailpipes can be reduced
an annual average of 24 percent for
hydrocarbons and 34 percent for carbon
monoxide by repair of catalyst-type
automobiles which fail inspection. An
added benefit of J/M can be improved
fuel economy. Well-tuned engines result
not only in cleaner air, but better
mileage.
Generally, inspections may be
performed either by a state or local
municipal authority (centralized
program), or by licensed service stations
and garages (decentralized program). In
either case, the motorist brings the car
into the inspection facility and pays a
fee. A probe is inserted into the tailpipe
to measure emissions. If the emissions
are within standards prescribed by the
State, the motorist receives a certificate
of compliance or a windshield sticker. If
the car fails the test, the motorist is
given a statement of probable causes for
the failure. The motorist must then have
the vehicle tuned up or repaired and
return for reinspection.
1/ M is required in each of the 29
States which have received an attainment
deadline extension to 1987. (See
Appendix F for a complete list of these
nonattainment areas.) Of these, seven
have already put JIM programs into
operation. 28 J/M usually requires state
2S1/ M programs in operation prior to the Clean
Air Act 1979 requirement include:
ARIZONA: Mandatory since 1976, the contractor
operated program focuses on the counties
containing Phoenix and Tucson. One million
vehicles including trucks and motorcycles are
inspected annually.
CALIFORNIA: A voluntary state program has
been operated to obtain 1/ M data since 1975.
Since March 1979, 1/ M has been mandatory for
all vehicles in the greater Los Angeles area which
undergo change of ownership.
NEVADA: Inspections by licensed service stations,
garages and auto dealerships began in July 1974
for change of ownership vehicles in Clark County,
the home of Las Vegas. Mandatory If M began in
1980 for Clark County. Washoe County (Reno)
currently has a change of ownership program.
NEW JERSEY: A state-wide program tests
approximately 4 million vehicles annually at 38
permanent sites. Private garage reinspection for
failed cars is a special feature of this program.
Began in 1972 with voluntary maintenance; the
fully mandatory program commenced in February
1974.
OHIO: The city of Cincinnati began a program in
p75. Emission inspection was added to an existing
safety inspection program.
OREGON: Portland tests almost 600,000 vehicles
biennially with a combination of permanent and
mobile facilities. The state-operated program began
in July 1975 after one and a half years of
voluntary program.
RHODE ISLAND: The statewide program began
with inspection and voluntary maintenance in
1977. Fully mandatory 1/ M through certified
private garages began January 1, 1979. Emission
tests are performed in conjunction with safety
inspection.
legislation and citizens should track the
progress of such legislation, where
needed, through to enactment. But J/M
alone will not solve the problem of
transportation-related air pollution. This
will require a basic restructuring of our
urban transportation system to manage
and control growth in transportation
demand while maintaining present high
levels of mobility.
Transportation Control Measures
As noted above, States that cannot
achieve air quality standards solely
through controls on stationary
(industrial) sources for carbon monoxide
and ozone by 1982 are required to adopt
control strategies for mobile
(transportation) sources of pollution.
These mobile source strategies are called
Transportation Control Measures
(TCMs)29 and make up one element of
the State Implementation Plan. 3 ° A
critical problem with the 1970 Act was
the uncertainty of state and local
officials over their responsibility to
adopt and implement controls on auto
use. Since MPOs were responsible for
implementing these controls through
their programming responsibilities, and
since MPOs were voluntary
organizations that relied on the good
will of member localities for their
effectiveness, there was little incentive to
require measures that would meet with
29TCM5 replace the term “Transportation Control
Plan” (TCP) used in the 1970 Act. The change was
made simply to emphasize that TCPs are one
element of a SIP, not a separate plan. The terms
TCM and TCP are used interchangably in this
manual. Transportation System Management
(TSM) strategies developed through the
transportation planning process are TCMs if they
are included in the SIP.
30 The term “element” refers to any part of a
document. A SIP will be divided into elements for
each AQCR within the state. (Thus the California
SIP will contain a Los Angeles Element, a San
Francisco Bay Element, and so on.) An element
for a given area may in turn, be divided into
smaller elements for each of the major
requirements of the Act. (Thus the Los Angeles
Element might contain a Transportation Control
Plan Element.).
Figure 12 Technological Requirements on Stationary Sources
4
Nonattainment Attainment
Regions Regions
New or Modified Sources LAER BACT
NSPS NSPS
NESHAP NESHAP
Existing Sources RACT
NESHAP NESHAP
23

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local opposition, such as parking taxes,
reduction in the availability of parking,
gasoline taxes, etc. More direction was
needed.
In 1977, Congress provided this
direction by requiring nonattainment
areas to “provide for the implementation
of all reasonably available control
measures (RACM) as expeditiously as
practicable.” 3 ’ Moreover, Congress
statutorily designated 18 different
control strategies (see Figure 13) and
directed EPA to prepare information
documents explaining the “processes,
procedures, and methods” necessary to
put these strategies “on line.” 32 For
purposes of study, all measures
contained in these information
documents are reasonably available. 33
This means that, if a nonattainment area
chooses not to adopt one of these
strategies, it has the burden of
demonstrating why the excluded strategy
is not reasonably available. Conclusory
assertions of infeasibility are
unacceptable. 3 ’ The analysis of
reasonability should include a discussion
of the impact of each strategy, or
package of strategies, on air quality,
health, and welfare, as well as their
economic, social, and energy effects. 35
Basic Transportation Needs
Despite the best efforts of federal,
state, and local officials to implement
plan requirements as soon as possible,
attainment of air quality standards
for transportation-related pollutants
may not be possible by December 31,
1982. Therefore the Amendments
provide for an extension of the
attainment deadline to as long as
‘CAA §172(bX2), U.S.C. §7502(bX2) (1978
pamph.).
32CAA §108(l), 42 U.S.C. §7408(1) (1978 pamph.).
‘ 3 Transportation-Air Quality Planning Guidelines,
U.S. Environmental Protection. Agency and U.S.
Department of Transportation, June, 1978. p. 22.
34 Memorandum: Criteriafor Approval of 1979 SIP
Revisions, From: the Administrator, To: Regional
Administrators, I-X, Date: February 24, 1978, p. 9.
CAA §172(bX9), 42 U.S.C. §7502(bX9) (1978
pamph.).
Figure 13 Reasonably Available
Transportation Control Measures
Source: U.S. Environmental Protection Agency
and U.S. Department of Transportation,
“Transportation..Air Quality Planning
Guidelines,” June 1978
December 31, 1987 upon a finding by
the EPA Administrator that
attainment is impossible by the end of
1982. Twenty-nine states have
received such extensions.
However, there are additional
requirements for States that request
such delays. The most important
requirement is that such States agree to
prepare, fund, and implement a plan to
“establish, expand, or improve public
transportation meast res to meet basic
transportation needs, as expeditiously as
practicable.” 36 These plans were to be
prepared and approved by July 1, 1979,
and are therefore a current requirement
for all plans with an attainment date
beyond December 31, 1982.
What are “basic transportation
needs”? This is a question that should be
answered in the State Implementation
Plan, since the basic transportation
needs of each nonattainment area vary
according to the severity of existing
pollution and the quality and quantity of
existing public transportation in the
region. However, the parameters of a
good basic need plan should be set by
first calculating how great a shift in
travel from single passenger automobile
to other modes is required to meet
National Air Quality Standards (called
the “modal split”). Basic needs, then,
refers to whatever level of public
transportation is necessary to
comfortably accommodate all the people
who will be shifted to public
transportation modes to achieve the
requisite modal split. The State
Implementation Plan must contain
funding commitments to accommodate
this level of public transportation use.
CAA §1 l0(aX3XD), (cX5XB), 42 U.S.C.
§ 7410(aX3XD), (cX5XB) (1978 pamph.).
1. Inspection! Maintenance
programs
2. Vapor recovery
3. Improved public transit
4. Exclusive bus and carpool lanes
and areawide carpool programs
5. Private car restrictions
6. Long range transit improvements
7. On-street parking controls
8. Park and ride fringe parking lots
9. Pedestrian malls
10. Employer programs to encourage
car and vanpooling, mass transit,
bicycling, and walking
11. Bicycle lanes and storage facilities
12. Staggered work hours (flexitime)
13. Road pricing to discourage single-
occupancy auto trips
14. Controls on extended vehicle idling
15. Traffic flow improvements
16. Alternative fuels or engines, and
other fleet vehicle controls
17. Other than light duty vehicle
retrofit
18. Extreme cold start emission
reduction programs
24

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Citizen Action
Reasonably Available Control Measures,
Reasonable Further Progress, and Basic
Needs all require citizen enforcement.
The Reasonably Available Control
Measures requirement emphasizes the
importance of analysis and full
documentation of decisions not to adopt
strategies that Congress has made
presumptively available. Politically
difficult strategies are often the most
effective. Request (1) copies of the
information documents (available from
your regional EPA office), (2) a list of
all transportation control measures
under study by your MPO, and (3) full
documentation of strategies not adopted.
Many strategies are very effective in
promoting energy conservation as well
as clean air, and you may well be able to
reduce political opposition by stressing
their energy-savings qualities. If the
State Implementation Plan commits only
to studying a strategy rather than
implementing it, is further study really
needed? Is the study relevant to the
reasonableness of the strategy? What are
the criteria for separating reasonable
from unreasonable strategies? Has the
agency responsible for implementation
agreed to implement the strategy if the
study results are positive? Have
strategies been grouped for greater
cumulative impact? By what date?
Is legal authority necessary to implement
a strategy? If so, has that authority been
obtained? Remember the problem of
equity: who pays and who benefits? For
other questions, see the “SIP Review
Checklist” in Appendix D. Reasonable
Further Progress also requires citizen
vigilance. It cannot be determined
without a comprehensive and accurate
inventory of actual emissions from all
sources in a region for use as the level
from which progress is measured. Ask
for a copy of the emissions inventory.
How was it computed?
There are several ways of calculating
needed emission reductions, from a
simplistic, hand calculated “linear
rollback” model to very sophisticated
“air quality diffusion” models. Linear
rollback models fail to take into account
the chemical interaction between
pollutants. Consequently they understate
the amount of emission reduction
needed to meet the standards for certain
pollutants, such as ozone. For this
reason, rollback should not be used for
ozone modeling in areas that have
sufficient planning resources, and
sufficient pollution, to justify more
accurate modeling techniques. Is your
modeling done according to “state of the
art” techniques? Should it be? To what
extent will vehicle miles traveled grow
in your region? What are the major
generators of that growth? Do you agree
with the selection of projects to be
delayed in the event reasonable progress
is not made? Should the funds for these
projects be transferred to transportation
projects with positive air quality
impacts?
The basic needs requirement reflects
an understanding by Congress that
transportation controls will not work if
people are not given a comfortable, low-
cost alternative to automobile travel.
Good basic needs plans hold the promise
of achieving dramatic improvements in
air quality (and energy conservation) at
little cost in mobility. How are basic
needs defined in the implementation
plan? Do you agree? Does the plan
calculate the modal split necessary to
achieve air quality standards? Can the
basic needs plan accommodate the
percentage of the split assigned to public
transit modes? Are there commitments
to fund the plan? Several types of
highway funds are transferable to public
transit (incuding urban Interstate and
Urban Systems funds). 37 Does the plan
commit to the transfer of highway funds
to fund basic needs or is funding totally
dependent on the receipt of federal
transit funds? This is important since
highway funds are distributed by
formula and are therefore more or less
guaranteed, while most UMTA capital
funds are discretionary grants distributed
on an “as needed” basis and therefore
much more tentative. The plan should
include a discussion of the willingness of
state and local officials to transfer
highway Construction funds to public
transit in the event federal transit
funding of the basic needs plan is not
obtained.
23 U.SC. **103(eX4) . 142 (1978), __________
Integration of Clean Air and
Transportation Planning:
The Citizen’s Role
The Conformity Requirement
The “consistency” review between air
quality and transportation planning
required since 1970 by the Federal-Aid
Highway Act was, as noted earlier,
inadequate. Air quality planning under
the Clean Air Act was often conducted
by a State or regional agency that had
little or no communication with either
the MPO or any of the agencies charged
with implementing the air quality plan.
This gap in coordination was addressed
by the 1977 Amendments which
required, whenever feasible, that MPOs
themselves prepare the implementation
plans for their regions. 38 Moreover,
MPOs were to enter into agreements
with implementing agencies designating
responsibility for implementation as a
condition of receipt of transportation air
quality planning funds. Finally, the 3C
process was to be coordinated with the
air quality planning process and such
coordination was to be taken into
account during the annual 3C
certification review.
EPA and DOT worked together to
implement the joint planning mandate
outlined in the Amendments through
joint publication of Transportation Air
Quality Planning Guidelines in June
l978. These guidelines provide, among
other things, for (1) interagency
cooperation establishing lead
responsibility for transportation/clean
air quality planning, (2) involvement of
local elected officials, (3) public
information and consultation, and (4)
evaluation of alternative packages of
transportation system management
projects to meet clean air goals. These
‘CAA §174(a), 42 U.S.C. §7504(a) (1978 pamph.).
39 Transportation-Air Quality Planning Guidelines,
U.S. Environmental Protection Agency and U.S.
Department of Transportation, June, 1978.
25

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guidelines also explain how 3C planning
documents should be modified to
incorporate air quality planning
requirements. (See p. 10 for a discussion
of the 3C process.) EPA and DOT have
also entered into a “Memorandum of
Understanding” providing for joint
review and approval of both State
Implementation Plan revisions (formerly
an EPA exclusive duty) and 3C
certifications (formerly a DOT exclusive
duty). A copy of this Memorandum is
included as Appendix B.
A particular effort was made to
improve the transportation/air quality
consistency review process.
“Consistency” was replaced by the 1977
Amendments with “conformity”, and it
is now the affirmative responsibility of
the preparing agency (DOT) to
demonstrate conformity between
federally-sponsored projects and clean
air plans. EPA and DOT have issued
joint guidelines explaining both how
conformity reviews are to be conducted
and how conformity is to be measured. 40
The conformity determination, like the
consistency determination it supersedes,
is made at two levels. The overall
planning program must be found to
conform to air quality requirements
(program level conformity) and
individual projects must be found to
conform to the SIP (project level
conformity). On the program level, the
conformity determination is made at the
first instance by the MPO and is
reviewed by DOT and EPA as part of
the 3C certification process (see
DOT EPA Memorandum of
Understanding, Appendix B).
Essentially, program level conformity
reviews the MPO program to make sure
that the MPO is executing its
responsibilities under the SIP, including
(I) inventories, (2) state and local
consultation, (3) evaluation and
implementation of all selected control
strategies on schedule, and (4) air quality
monitoring to determine if reasonable
further progress (RFP) is being made
towards clean air goals. As long as the
40 As we go to press, final regulations implementing
the conformity requirement have not been
promulgated. However, on April 1. 1980. EPA
announced in an advance notice of proposed
rulemaking that it intended to require all federal
agencies to adopt regulations to assure conformity
of their actions with SIPs. On June 12, 1980, EPA
and DOT adopted Procedures for Conformance of
Transportation Plans. Programs and Projects with
Clean Air Act State Implementation Plans. The
discussion of conformity included in this book is
based on this document which is intended to serve
as the basis for a subsequent rulemaking.
MPO is implementing its responsibilities
under the SIP, program level conformity
is assured. If it is not, however, 3C
certification will be revoked and federal
transportation construction funds to the
area will be halted until the deficiencies
are corrected.
This is essentially the same penalty
that may be invoked by EPA upon the
failure of a nonattainment area to adopt
an adequate SIP in the first instance (see
Sanctions, p. 28). The difference is that
it is a review of SIP implementation, not
adoption, and it is a finding by the
MPO and DOT, not EPA. Project level
conformity is assured through inclusion
of the project in a conforming program.
As long as the emissions (total pollutant
burden) generated by a project are
accounted for in a conforming program,
the project will be found to conform to
clean air requirements.
An additional feature of the new
conformity regulations is the
requirement that MPOs develop
contingency plans. These plans focus on
reasonable further progress (RFP), the
standard measurement of SIP
effectiveness. Despite the best efforts of
all participants in the planning process
to adopt and implement an adequate
v i ’
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Section 175 Grants
SIP, RFP may not be maintained due to
overly optimistic pay-offs from specific
control strategies, tampering with
emission control devices, fuel-switching,
or some other unforeseen event. In such
a situation EPA can direct that a SIP be
revised to add more clean air strategies
and, hopefully, to regain RFP. In
anticipation of such an event, MPOs
must establish a list of locally-selected
projects that are expected to add to the
total pollutant burden of the area. This
list is called the contingency plan. If
EPA directs that a SIP be revised due to
the failure of an implemented SIP to
maintain RFP, and f a project is in the
contingency plan, then the project must
be delayed until a revised SIP is
adopted, unless the project is already
under construction.
This is all a bit complicated. If you
still have questions after consulting these
regulations, contact your Regional office
of EPA or DOT for further explanation.
One additional point, 3C certification is
possible even if a State Implementation
Plan is not fully implemented, as long as
“reasonable efforts” are made to
integrate clean air and transportation
planning. However, if EPA finds that
state and local officials are not making
reasonable efforts to develop and
implement a plan that meets statutory
requirements, it may request DOT to
prohibit further project approvals
unrelated to safety, mass transit, or
clean air, until such reasonable efforts
are demonstrated. 4 ’ Reasonable efforts
are also a condition of certification.
41 CAA §176(a). 42 U.S.C. 7506(a) (1978 pamph.).
(regulations not yet promulgated).
Congress has earmarked $50 million to
help MPOs develop and implement
transportation control strategies. 42 These
funds are in addition to other funds
authorized by the Clean Air Act for plan
development 43 and by various
transportation statutes for support of 3C
transportation planning. The majority
of these funds are apportioned to areas
over 200,000 population that are
nonattainment for carbon monoxide or
ozone. 45
Applications for funds are filed with
UMTA (DOT) regional offices.
Requirements for funding include:
• Assurance that MPOs and local officials
will exercise a controlling influence over
expenditure of funds.
• Inclusion of the air quality planning
elements required by the EPA-DOT
Joint Planning Guidelines of June 1978
in the Unified Planning Work Program.
• Compliance with EPA-DOT
Expanded Guidelines for Public
Participation (discussed below).
The funds are to be used to identify
effective transportation control measures
and to evaluate these measures to
determine if they are “reasonably
available” for implementation, not to
develop new air quality models or
conduct modeling. These activities
should be funded out of regular
planning funds. They may also be used
to fund citizen participation in the
transportation control evaluation
process.
Public Participation
The 1977 Amendments require the lead
agency preparing the State
Implementation Plan to develop
“methods to assure participation by the
public in all phases of the planning
process.” 46 EPA and DOT issued joint
guidelines in June 1980 to meet this
requirement. The guidelines recommend
that lead agencies devote 10 to 30
percent of their allocated Section 175
planning funds to carry out an effective
citizen participation program. The
guidelines also recommend that an ad
hoc or established citizen panel be
included in the development of the
citizen participation program and that a
percentage of the funds be passed
46 CAA § 108(e)(4), §7408(e)(4), (1978 pamph.).
42 These grants are made under the authority of
CAA § 175, 42 U.S.C. §7505 (1978 pamph.).
CAA §105, 42 U.S.C. §7405 (1978 pamph.).
44 There are, generally, Highway Planning &
Research (HPR) funds and PL funds, allocated
pursuant to 23 U.S.C. §112, 307 (1978) and
UMTA planning funds, allocated under Section 8
of the Urban Mass Transportation Act, 49 U.S.C.
§1607 (1978).
45 Each EPA Regional Office is also allocated
$300,000 for distribution to areas under 200,000 on
a discretionary basis.
27

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through to the citizen groups affected by
transportation-air quality strategies so
that they may more effectively
participate in ongoing planning and
implementation. Lead agencies must
develop a “citizen participation work
program” as well as performance criteria
by which to judge the effectiveness of
citizen participation efforts in
contributing to pla3l implementation.
Documentation of citizen participation,
and lead agency response to citizen
inquiries, is required.
While public participation was
confined under the 1970 Act to a right
to notice and an opportunity to
comment on proposed plans, States and
lead agencies must now provide
opportunity for public endorsement
throughout the planning process and,
particularly, at the following “key
decision points”
• adoption of the work program for
inclusion in the 3C Unified Planning
Work Program;
• adoption of the public participation
plan;
• adoption of transportation control
measures f systems management strategies
for inclusion in the 1982 State
Implementation Plan;
• impact analysis of measures or
packages of measures;
• removal of a control measure or
system management technique from a
previously approved plan;
• rejection of a control measure or
system management technique as not
reasonably available;
• conformity determinations;
• MPO endorsement of 3C planning
elements, 3-C certification, and adoption
of the State Implementation Plan.
This does not mean that public hearings
are required at each of these “key
decision points.” It does mean, however,
that the ongoing citizen participation
program must allow for citizen
involvement in these decisions, with the
specifics to be worked out by each MPO
and contained in a public participation
plan.
Once the SIP is developed, however, a
public hearing is required on all
elements of the proposed plan.
Moreover, before EPA approves a plan,
the Administrator is required to
publish the proposed plan, or the
notice of its availability, in the Federal
Register and to solicit public comment. 47
The final adopted plan must be
accompanied by a response to each
significant comment received. 45
Finally, in a most important
provision, the Act allows citizens to
bring a private legal action, upon notice
to the Administrator, against any
polluter or governmental agency for
failure to comply with an emissions
limitation or a federal or state
compliance order, and against the
Administrator for failure to enforce a
State Implementation Plan. 49 Federal
judges may award attorneys’ fees and
litigation costs to any party whenever
the court deems such an award
appropriate. 50 Congress recognized that
the best plan is worthless if it is not
enforced, and gave the public a central
role to play in enforcement.
Sanctions
Dirty air, urban decay, and energy waste
are not inevitable by-products of
modernization. Nor have federal, state,
and local governments remained neutral,
leaving the natural process of urban
development to the private sector.
Controls on oil and gas prices, favorable
tax treatment to single-family home
owners, federally-assisted highway and
sewer programs to serve
suburbanization, incentive zoning on
the state and local level—these policies
and others have contributed, in a
sometimes complex, often subtle manner,
to present patterns of urban growth.
More often than not, the contribution
has been to provide present benefits—
cheap energy, more access, low-cost
housing—while deferring payment to
some future millenium when all debts
for consumption of our natural resource
base will be excused. But the bill has
now come due.
How will this bill be paid? Clearly,
changes in growth patterns, business
habits, and even personal lifestyles are
required. Incentives, wise investment
decisions, and creative planning can
CAA *304(a). 42 U.S.C. *7604(a) (1978 pamph.).
SOCAA §304(d), 42 U.S.C. §7604(d) (1978 pamph.).
47 CAA §307(dX5), 42 U.S.C. *7607(dX5) (1978
pamph.).
4 CAA *307(dX6), 42 U.S.C. *7607(dX6) (1978
pamph.).

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solv. many of our urban development
problems. But the switch from an
economic system that rewards resource
consumption to a system that favors
resource conservation will inevitably
meet resistance from the beneficiaries of
now outdated policies. In such cases, the
stick is mightier than the carrot. This
means sanctions.
Most sanctions under the Clean Air
Act are directed at private polluters
from stationary sources. However, two
sections of the Clean Air Act provide for
sanctions against responsible govern-
ments which refuse to adopt
reasonably available strategies to control
air pollution. The Clean Air Act requires
the withholding of federal assistance for
highway 5 ’ and sewer construction 52 —two
programs that often support urban
sprawl and, with it, air pollution—upon
a finding by EPA that the state, the
MPO, or the responsible locality has
failed to make “reasonable efforts”
toward development and implementation
of an acceptable plan.
Due to the possibly severe
consequences of a cut-off of highway or
sewer funds, EPA has formulated a two-
step enforcement process. Instead of
imposing sanctions immediately upon a
finding that a plan fails to meet all
requirements of the Clean Air Act, EPA
has chosen instead to issue “conditional
approvals’s for inadequate plans. 53 A
conditional approval is the bureaucratic
equivalent of a shot-across-the-bow.
Inadequacies in a plan are identified and
the State or locality is put on a time
schedule for compliance. If, however,
compliance is not forthcoming,
imposition of sanctions is automatic. 54
Since EPA has a non-discretionary duty
to impose sanctions if compliance
schedules are not met, violation of
schedules contained in conditional
approvals are subject to citizen
enforcement actions under the citizen
Suit provisions of the Clean Air Act.
5 ’CAA §176(a), 42 U.S.C. §7506(a) (1978 pamph.).
52 CAA §316. 42 U.S.C. §7616 (1978 pamph.).
“EPA Guidance of June 8, 1979.
44 Fed. Reg. 67182 (November 23, 1979).
Citizen Action
The heart of the joint planning process
is adherence to a common commitment
to prepare, adopt, and implement an
adequate plan in a timely fashion. This
requires a great deal of support from
state, local, and federal transportation
officials. Solicit their support. If you
have an idea for a systems management
project in your neighborhood with
positive air quality impacts (i.e., a new
bus line, an auto-free zone, a joint
development project, etc.) ask these
officials to help prepare preliminary
feasibility studies. Request that these
studies be included in the work program
and in the plan. Review projects in the
contingency plan; do you agree with the
selections? Is EPA adequately
monitoring implementation? Is
reasonable further progress being
maintained? If not, should the plan be
revised? Where you support a particular
project for reasons of air quality, energy
conservation, or neighborhood
revitalization, these projects, once in a
plan, must be given priority for
implementation. 5 Are they? Again,
consensus is the key to a successful joint
CAA §176(d), 42 U.S.C. §7506(d) (1978 pamph.).
planning process so your efforts to
constantly educate all participants in the
process of the positive impacts of
systems management projects, and the
priority status granted these projects by
statute, are needed to assure successful
implementation of an effective plan.
Make sure citizen participation funds
are spent to educate citizens on the “key
issues” for resolution, not simply to sell
the plan to the public after all the issues
are resolved. Ultimately, these issues
must be decided by the MPO and the
agencies charged with implementing the
plan, not citizens. But you have a right
to be there when decisions are made,
and to hold public officials accountable.
Implementation of sanctions for failure
to make “reasonable efforts” toward
approving and implementing a plan is a
recognition that everybody in the
process—including citizen participants—
have failed to do their part in achieving
consensus. While sanctions may be
necessary in those few cases where the
process completely falls apart, they
should not be relied on as a primary
strategy for forcing action without first
exhausting every available opportunity
to make the joint planning process work.
:;‘ ..J
.,. :c , \.; •ii
29

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Putting the Law to Work:
Opportunities For
Urban Revitalization
The European Experience
The proof of the pudding is in the
eating. The success of the new air
quality! transportation planning process
will be measured in results. Is it possible
to cut our transportation energy use per
capita in half while maintaining our
standard of living? Can we clean up the
air and maintain high levels of mobility?
Will downtown areas again bustle with
nightiife and commercial activity? Can
urban historic sites be preserved? Is it
possible to revitalize cities while still
providing housing for those of low and
moderate incomes? Can we restrain
suburban sprawl and protect our
remaining parks, open space and prime
agricultural lands? If our cities are to be
saved, these are the challenges we face in
the 1980’s. But we need not sail
uncharted seas. We have a map: the
European experience.
In a sense it is unfair to compare
urban transportation systems in the
United States with those of Western
Europe. The differences—demographic,
historic, and cultural—are great. In
Europe, population density is ten times
the population density of the United
States. Open land is scarce. With
virtually all oil imported, energy costs
are high. In the U.S. abundant energy
resources—and price controls—have
kept energy costs low. Per capita income
in the U.S. is still substantially higher
than in most European nations. Higher
U.S. income levels combined with lower
land and energy costs, contribute
substantially to the spread land use
patterns characteristic of this country.
In Europe, land use patterns were set
before introduction of the automobile—
often before introduction of any form of
mechanized travel. In the U.S., rail,
transit, and highway improvements have
been used as frequently to open up new
territory for development as they have to
serve such development. Moreover, the
destruction caused by two World Wars
fought on European soil in this century
has caused development to focus on
rehabilitation and renovation of
downtown areas. In contrast, U.S.
development has spread rapidly to
suburban and exurban areas. The focus
on rehabilitation caused European cities
to preserve and upgrade existing
streetcar systems. In the U.S., our
eagerness to develop new lands resulted
either in the neglect or conscious
destruction of these systems. These
historical distinctions are dramatically
reflected in the grid maps (Figure 14) of
Paris and Los Angeles, cities of similar
size but dissimilar history.’
Los Angeles, for example, tore down a 700 mile
electrified trolley network in the 1940’s in favor of
buses.
Figure 14 Pans and Los Angeles: Comparison of Land Use and Population Density
Source: Jorge Arango. The Lrhani:ation of the Earth, Beacon Press, (Boston, 1970) p. 59.
km
0
Paris
(Dense Center Pattern)
Same Scale,
Approx. same Population
Los Angeles
(Sprawl Pattern)
Pacific Ocean
0
MiIe —
10
20
30

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These continental differences,
however, rapidly are being overtaken
by events. Automobile ownership as a
percentage of the population is
rapidly increasing. In West Germany,
for example, automobile ownership
skyrocketed from 81 per 1,000
population in 1960 to 290 per 1,000
population in 1977 (the U.S. figure
was about 500 per thousand in 1977).
Higher incomes are stimulating
Europeans to move out of cities,
resulting in the incipient breakdown
of traditional high density land
development along main
transportation axes towards the more
scattered development characteristic
of the U.S. Noise and air pollution
are accentuated in narrow European
streets where much of the commercial
activity takes place in open air
markets. Both Europe and the U.S.
face a severe and debilitating
dependence on imported oil, as the
skyrocketing bill for imported oil
reduces employment and adds to
inflation on both continents. We are
all become nations of limits.
Despite the inherent advantage of
historical dense center development
patterns that European nations hold
over the U.S., they point the direction
in which American cities must move
to meet present environmental and
energy mandates. Here are some
lessons from the old continent and
how you can apply those lessons to
your city.
Automobile Management: Auto use
management is not a new concept in
Europe. Over 120 cities in 14
countries have large pedestrian zones
in their historic cities. 2 Pedestrian
malls (auto-free zones) and
automobile management strategies are
measures that must be given priority
if they are contained in your State
Implementation Plan and
transportation improvement plan.
2 Organization for Economic Cooperation and
Development, Survey on Pedestrian Zones. Report
to the Group of Experts on Traffic Policies for the
Improvement of the Urban Environment (Working
Document) Paris, April 5. 1978.
Resistance to exclusive bus lanes and
controls on auto use in downtown
areas comes from user groups and
suburban communities that want
unrestricted access to core areas. Such
restrictions, however, have been
declared constitutional by the U.S.
Supreme Court. 3 Resistance can also
be expected from owners of
commercial buildings concerned
about loss of business. Well-planned
pedestrian malls, however, can result
in dramatic increases in commercial
activity. In Cologne, Germany, for
example, shopkeepers initially
opposed the closing of two primary
downtown streets but later were so
pleased with the results that they
formed an organization which
contributed 60 percent of the cost for
repaving and lighting improvements.
Your success in promoting a
pedestrian mall will hinge on your
ability, through education and
planning, to overcome the natural
resistance of owners, user groups, and
suburban communities which
influence transportation decision
making in your city.
Promotion of Public Transit:
European cities have pioneered
improvements in the operation of
public transit systems, while in the
U.S. our federal public transit
programs have focused almost
exclusively on capital assistance.
Exclusive bus lanes, exclusive bus
streets, and priority signalization for
buses have improved bus speed and
reliability in Europe up to 25 percent.
Areawide transit passes in Paris,
Hamburg, Stockholm, Munich and
Dusseldorf provide unlimited access
to the entire public transit system on
a monthly basis. Today, 1.5 million
such passes are sold each month in
Paris. In Stockholm, where private
car ownership is 370 per 1,000
population, almost three out of every
four trips to the downtown area are
made by public transit. The transit
3 Couniy Board of Arlington City, Va. v. Richards,
98 S.Ct. 24 (1977).
31

-------
pass is even more attractive in
StockPiolm because it can be claimed
as a deductible expense by all
taxpayers who live more than 12
miles from their place of work (in the
U.S. home-to-work travel is not
deductible). In Hamburg, the
emphasis is on service. Its entire
1,250-mile, five mode (subway,
trolley, commuter rail, bus, ferry)
integrated transit system operates on
one timetable with fringe-to-core
service guaranteed in no more than 45
minutes, with peak-period headways
(waiting time at any stop) of 5
Action Tip
You probably cannot afford to go to
Europe to study these traffic
management strategies yourself.
However, there are publications that
can get you and your MPO started.
The Rediscovery of the Pedestrian. 12
European Cities (1976) provides an
excellent description of European
pedestrian mall initiatives and is
available from the Superintendent of
Documents, U.S. Government
Printing Office, Washington, D.C.
20402, Stock No. 023-000-00374-4,
price: $1.80. Two organizations
concerned with the transfer of
technology on urban mobility
between Europe and the U.S. are the
Organization for Economic
Cooperation and Development, 1750
Pennsylvania Ave., N.W.,
Washington, D.C. 20006, and The
German Marshall Fund of the United
States, 11 Dupont Circle, N.W.,
Washington, D.C. 20036.
minutes. Comprehensive schedules for
all five systems are published twice a
year and sold at newsstands, with
pictorial symbols for foreigners. Rate
structure, timetables, and routings are
constantly reevaluated to adjust to
changing demography, travel patterns,
and work habits.
Public transit in Europe emphasizes
operational improvements, integrated
planning, and marketing of services
over new construction. Flexibility is
guarded in order to provide service
levels appropriate to the needs of the
community. The availability of
consumer information (to attract
patronage) and reliability (to retain
patronage) are as essential to the
success of the system as a new rail
line or modern buses and trains. In
your city, these operational and
service improvements are essential
components of the comprehensive
public transportation plan to serve
basic transportation needs required in
all post-1982 non-attainment areas
(see BTN Plans, page 24). If you live in
such an area, study your basic
transportation needs plan to see if it
takes full advantage of the lessons
available from European transit
systems.
A footnote on energy. Europeans
use only 34 percent of the energy
Americans use per capita on
transportation. 4 In the area of
passenger transportation, Western
Europe uses only 26 percent of the
energy we use per capita to maintain
personal mobility. 5 In fact, 55 percent
of all the energy in the world that is
used to maintain mobility is expended
in the U.S.6 Clearly, efficiency
improvements in urban mobility are a
crucial priority in the U.S. And the
effort to achieve efficiency is being
made—through transportation systems
management and transportation
control planning.
4 Regional Transportation Energy Conservation
Data Book, ORNL-5435 (1978), p. 400.
5 1d., p. 406.
61d p. 404.
Transportation Systems
Management
The purpose of Transportation
Systems Management is to meet
future growth in transportation
demand through efficiency
improvements, thereby avoiding the
need to build new systems to meet
this demand. However, it also refers to
actions that control growth in
demand and divert traffic away from
areas where high traffic levels are
inappropriate. In systems
management planning, all modes—
automobiles, public transit,
pedestrians, taxis, buses, and
bicycles—should be considered as
elements of one single urban
transportation system. Efficiency
improvements on one mode may
result in restraints on another mode
within any particular traffic corridor.
Therefore, systems management
means restraints on traffic (such as
exclusion of through traffic from
residential neighborhoods) as well as
traffic flow improvements. The
FIgure 15 Residential Street Use
Source: Fred Van Antwerp, The Restraint of
the Automobile in Established Residential
Areas: An Implementation Policy Analysis,
Pennsylvania Transportation Institute,
Pennsylvania State University, University Park,
PA 16801 (1979), p. 59.
32

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identification of management options
within any particular area, and the
brokering of a solution acceptable to
alt users of the transportation system
in that area, is the challenge of
systems management planning.
It won’t be easy. One urban arterial
highway, for example, may serve as
the right-of-way for more than just
automobiles. There may be a lane
reserved for high-occupancy-vehicles
such as carpools and vanpools, an
exclusive bus lane, a track for light
rail vehicles (trolleys), or a bikeway.
Similarly, in urban residential areas,
or areas of mixed residential!
commercial use, a street may serve
several different purposes. It may
serve as a way for travel within the
neighborhood, between neighbor-
Selected TSM Measures
Actions to ensure the efficient use of
existing road space through
(1) Traffic operations improvements
to manage and control the flow of
motor vehicles, such as:
Channelization of traffic
One-way streets
Better signalization and progressive
timing of traffic signals
Computerized traffic control
Metering access to freeways
Reversible traffic lanes
Other traffic engineering improvements
(2) Preferential treatment for transit and
other high-occupancy vehicles, such as:
Reserved or preferential lanes on freeways
and city streets
Exclusive lanes to bypass congested points
Exclusive lanes at toll plazas with
provisions for no-stop toll collection
Conversion of selected downtown streets
to exclusive bus use
Exclusive access ramps to freeways
Bus preemption of traffic signals
Strict enforcement of reserved transit
rights-of-way
Special turning lanes or exemption of
buses from turning restrictions
(3) Appropriate provision for pedestrians
and bicycles, such as:
Bicycle paths and exclusive lanes
Pedestrian malls and other means of
separating pedestrian and vehicular traffic
Secure and convenient storage areas for
bicycles
Other bicycle facilitation measures
(4) Management and control of parking
through:
Elimination of on-street parking,
especially during peak periods
Regulation of the number and price of
public and private parking spaces
Favoring parking by short-term users over
all-day commuters
Provision of fringe and transportation
corridor parking to facilitate transfer to
transit and other high-occupancy vehicles
Strict enforcement of parking restrictions
(5) Changes in work schedules, fare stnic-
ture and automobile tolls to reduce peak-
period travel and to encourage off-peak
use of transportation facilities and
transit services, such as:
Staggered work hours
Flexible work hours
Reduced transit fares for off-peak transit
users
Increased peak-hour commuter tolls on
bridges and access routes to the city
Actions to reduce vehicle use in congested
areas through:
Encouragement of carpooling and
other forms of ride sharing
Diversion, exclusion and metering of auto-
mobile access to specific areas
Area licenses, parking surcharges and
other forms of congestion pricing
Establishment of car-free zones and
closure of selected streets to vehicular
traffic or to through traffic
Restrictions on downtown truck delivery
during peak hours
Actions to improve transit service,
:hrougk
Provision of better collection, dis-
tribution and internal circulation services
(including route-deviation and demand-
responsive services) within low-density
areas
Greater flexibility and responsiveness in
routing, scheduling and dispatching of
transit vehicles
Provision of express bus services in coor-
dination with local collection and dis-
tribution services
Provision of extensive park-and-ride serv-
ices from fringe and transportation cor-
ridor parking areas
Provision of shuttle transit services from
CBD fringe parking areas to downtown
activity centers
Encouragement of jitneys and other
flexible paratransit services and their
integration in the metropolitan public
transportation system
Simplified fare collection systems and
policies
Provision of shelters and other passenger
amenities
Better passenger information systems and
services
Actions to increase internal transit
management efficiency, such as:
Improving marketing
Developing cost accounting and other
management tools to improve decision-
making
Establishing maintenance policies that
assure greater equipment reliability
Using surveillance and communications
technology to develop real time
monitoring and control capability

-------
hoods, or merely as a conduit for
through travel from the suburbs to
the city. It also may serve as a
playground for children in the area, a
right-of-way for telephone, water and
sewer lines, and a bikeway. While the
non-transportation uses to which
residential streets are put may suggest
that restraints on access and use are
appropriate, provisions must be made
for fire and police vehicles, and
ambulances. Finally, a street may
represent one type of opportunity to
an urban planner, who may want to
line it with trees, make it into a
pedestrian mall, or eliminate it for
development, but a quite different
type of opportunity to an
urban transportation planner or
traffic engineer who might want to
widen it to serve through traffic,
make it a one-way street to facilitate
flow, or eliminate certain users (i.e.
trucks) for purposes of safety.
These competing claims to streets
can cause conflict. Figure 15
summarizes the conflicts that may
arise on the uses to which a
residential street may be put.
Systems management plans must
address these conflicts through the 3C
brokering process established by the
MPO. Since many systems management
projects may be of little interest beyond
the neighborhoods in which they are
proposed, a mechanism should be
established with the MPO to allow
neighborhood groups to use the
technical assistance available with 3C
planning agencies to both (1) identify
systems management projects that serve
neighborhood needs, and (2) evaluate
these projects in light of regional goals,
such as clean air and the development of
an efficient, integrated urban
transportation system. The column on
Selected TSM Measures lists strategies
that should be considered within the 3C
process and evaluated for their ability to
promote the regional goals identified by
the MPO. 7
Many systems management strategies,
of course, double as transportation
control measures for inclusion in State
Implementation Plans. If a systems
management strategy is included in a
State Implementation Plan, it must be
given priority for implementation by the
MPO. 8 Since systems management
strategies have relatively low
implementation costs, funding should
not be a problem. (If the MPO or state
transportation agency says funding is a
problem; look at the list of new
construction projects in the
implementation plan. All federal-aid
urban projects are transferable to
support systems management strategies.
Is transfer necessary?). However, the
feasibility of systems management
strategies varies widely with the
demography and size of the urban area
involved. For example, carpool lanes
and tolls may be appropriate for large
cities with discrete access points—such
as New York City—but inappropriate
for a small city (50,000-100,000) with
unlimited access from every direction.
Costs of administration of systems
management strategies are another
factor in selection. Finally, if a systems
management strategy is proposed
primarily for its contribution to clean air
goals, its ability to actually reduce
emissions becomes of greater importance
than if it is proposed as a transportation
service improvement or neighborhood
auto restraint project as well. In such
cases, the air quality pay-off should be
well documented. Also, make sure the
transportation control measure proposed
is consistent with the air pollution
problem involved. Transit management
improvements (projects that encourage
commuters to switch from autos to
transit) will address regional air
pollution problems such as ozone, while
roadway assignment improvements
(reversible lanes, one-way streets, car
pool lanes, etc.) will address the more
localized site problems, or hot spots, of
carbon monoxide.
The great number of available systems
management strategies, the great number
of interests involved, and the dual role
of air pollution! traffic management,
places a premium on planning. Systems
management planning is very adaptable
to citizen participation since these
strategies are developed primarily for
particular sections of the community and
count on citizen support for their
success. Make sure your locality has the
legal authority to implement strategies
that involve auto restraints, and adopts
the strategies with the active involvement
of citizens in the project area.
DOT is placing increasing emphasis
on systems management as a primary
purpose of federal-aid transportation
assistance as large new construction
projects become less needed and less
affordable. Citizens should therefore
look to state and federal transportation
agencies, as well as EPA and the MPO,
for increased assistance in developing
and implementing systems management
projects. For information on the 18
systems management strategies that are
“reasonably available” by virtue of their
identification in the Clean Air Act itself
(see p. 24), ask for a copy of the
“Information Do ment” prepared for
these measures from your regional EPA
office.
‘See Appendix F for list of areas which have
received an extension.
*CAA *176(d), 42 JJ.S.C. *7506(d) (1978 painph.).
34

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Figure 16 Characteristics of Some Commonly Implemented TSM/TCP Measures
Ap abl e
City Size
TSN STRATEGIES AND TACTICS
Strategy Taetics
Area Scale of Air
Appication Quality In pac’s
A.
Traffic
Operations
1. Intersection and Roadway Wideru.rig
j)(j
I
1 1 ItI
—
- —
2. One—Way Streets
- —
3. Turn Lane Installac .on
- —
B.
.
Tra2fic
Siqnaliza - .
tion
-
4. Turui.ng Moven%eOt anc Lane Use Restr ct .ons
-
.
I
- - - —
-- -r — ——
d
- - F - - -
- - xl*
- I — - - —
x — —
S. New Freeway Lane Us .n; S ouloers
1. Local Intersection Siqnal Isnrovement
:
. Arterial S .gnal Syster
1 1


3. Area Sic j Systen
4. Freeway Diversion and Adv’sory S gn n5
5. Freeway Surveillance and COntrol
C.
0.
E.
.
1
Pedestrian
end Bicycle
Roadway
A . s sigr ent
RoUte
Diversion
Par k ng
Manaq ent
Transit
Ooerations
1. Widen Sidewalks ) -I -— 4
2. Pedestri.an Grade Separation - - - - — . - . . —
3. B kewavs : — . . . . —
4. Bike Storaqe : —
Pe a str .an Control ear: .ers j - -
1. Exclusive Bus Lane — Arterial I
a) Take—a—Lane
hI Add—a—Lane —
2. Bus—Only Street - I 1 )c )• — I —
3. Contra—Flow Bus Lane - - - —
4. Reversihie Lane Ssytens - I- - L . — —
5. Freeway NOV Bynass 1 1 — —
6. Exclusive NOV Lane — Freeway I i T —
a) Take-a-Lane X IX x j
hI ?.oo-a-L .ane I - . .L x
1. Area Licensinc 1 j yJ x
2. Auto Restt cte lor.es : i .1x1_ — - —
3 Pedestrtar Y.alls lxT• X I — —
4. r j j . — -:
1. curb Pcrkirtg Restrictions I xI x I
2. Aes .denttal Parx .ng Control xf xt •
3. Cf —Street ?erx. . Resrrtc tcns xix x x - —
4. OV Pre erentLal ark .ng II Gxt - - x_ - - - —
5. Parking Rate Chances I ix x —P -- - - -
1. Bus Route and Sci edu2e ModifiCations -1 xJyI xI x
2. Exoress Bus $ervtce I x L —
3. Bus Trafftc 33.rnal Preenot .on I .1?(...L.L. - —
4. Bus Tern .nais X I t —
K.
Transit -
Manacement
5. S j lizted Fare Col ,ection I -
1. Marketinc Proorar x I
2. MaJntenance lrtrcvarnan .
—
X —
.
I_
•—
3.Ve eFletrovene n
lx i
.
3.
K.
L.
Znee odal
Coor .nat .on
C ercial
Vehicles
Work
Schedule
Pricing
4. Cce.rata.or .s Mcn .tortnc ?rotran
1. Perk—Rads !atilitte
2. Transfer provemer.ts
1. Op—Street oa i n Zones
2. Off—Street Load .nc Areas
3. Pea . - —hour Co—Street Load n; Pro i: oo
4. Truck Route Systen
1. Staocered Work Hours and Flex
-. T x — —
1 L 1 i• -
1 I • fx j— I - I - —
Tt —
ixI _ _
N - x - I - —
I ) i j - — —
j
X
-
2. 4-Day Week - X xf x — —
.. Peak—Hour Tolls - I i I . k.. X
2. Low—Occupancy Ve:r tcle Toils — j I ix XI F x - —
3. Gasoline Ta T1 L x x - —
4. Pea ,c/Cff—ea.. Trensit Fares . - - - —
5. Elderly and Nand .capoed Fares
J X —
‘ .
—
ratra stc
.
6. Reduce Trar s Fares - I I I
r— -—
1. .arcool Mator. nç ?roctar$ Ixxp
I. .anuooi Prorraru - X
3.t a/ Group?.rir? r ocra cs -
— .X Xl
Z.criev SerVtce
o C...OCZ.V art re.nd,.raooed Serv.tce 1- --— - lx IX I
X 1 - —

x
X
:::
It
. —
. i -
Source: iRK & Associates and Peat, Marwick. Mitch lI & C0. Material pro ared for
FIIWA Measures of Effectiveness for Multi—Modal Urban Traffic Management Project. June ]78. fDCeft)
35

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Plans to Meet Basic
Transportation Needs
The concept and requirements to meet
basic transportation needs (BTN)
represents the “bottom line” of a city’s
commitment to clean air, energy
efficiency and individual choice in
meeting mobility needs. It is probably
one of the more significant decisions
concerning the form and direction of
future urban growth facing severely
polluted cities today. It provides both
the opportunity to redress past mistakes
and the potential for compounding these
mistakes. If done correctly, it provides
support for the neighborhood-level
improvements discussed elsewhere in this
manual and assures the success of
automobile restraint measures. If done
poorly, it could mean both severe
financial hardship and widespread public
disaffection for transportation control
measures that discourage auto use, while
providing no alternative for meeting the
travel needs of an urban population.
BTN plans—comprehensive public
transportation plans—are a required
component of every State
Implementation Plan which provides for
attainment of federal air quality
standards after December 31, 1982.
Since 29 States have been granted
Action Tip
Neighborhood groups may make use of
a variety of strategies to control and
divert traffic in residential areas.
Described in Figure 17 are physical
restraint devices that may qualify for
funding as systems management
strategies. A more detailed description of
these devices may be found in the U.S.
DOT publication, The Restraint of the
Auto,nobik in American Residential
Neighborhoods, available for $7.00 from
National Technical Information Service,
5285 Port Royal Road, Springfield, Va.
22161, Order No. PB287-485-A5.
Another recent publication, Improving
the Residential Street E,svironment, is
available from the Environmental
Division, Federal Highway
Administration, 400 Seventh Street,
S.W., Washington, D.C. 20590.
attainment extensions, 9 BTN plans
should already be developed and
progressing toward implementation in
nonattainment areas within these States.
Check to see if your State
Implementation Plan includes a BTN
plan. If not, request guidance from your
Regional EPA and DOT offices on the
criteria for basic transportation needs
plan development and approval and
request discussion of the requirement at
the next MPO meeting.’° Here are some
issues that need to be addressed.
Inventory of existing service: The first
step is to determine what you have to
work with. What are the assets of your
present municipal transportation system?
These assets can be subdivided into two
general subcategories: physical assets
and quality of service. Physical assets
are just that: track and line structures,
“rolling stock” (trains, buses, subways,
trolleys, etc.), depots, signals,
communications, repair facilities, etc.
Quality of service can be measured by
how well the system performs
(performance standards) and includes
such things as security, average
headway, reliability, capacity, lighting
and noise levels, cleanliness, availability
of travel information, comfort, and
convenience. The subjective nature of
some of these performance standards
underscores the importance of citizen
participation in establishing the
9 Sce Appendix F.
‘°To date, EPA has proposed the disapproval of
only one 8TN plan (New York City). For a good
exposition of BTN plan requirements, see the
proposed disapproval statement found at 45 Fed.
Reg. 43794 (June 30, 1980).
Figure 17 PhysIcal Restraint Devices
LJ
n n fi
Diagonal Diverter Semi-Diverter
J L
nyfi
nfl
Cul-De-Sac
Star Diverter
4 bdL
Jc.L
nfl
nn
Choker
Traffic Circle
LJ L
n nllr
Forced Turn
Median Barrier
Source: Fred van Antwerp. The R.s*raint of the Automoblie ri
Established Raisdential Areas: An lvr lementation Policy Analysis.
Pennsylvania Transportation Institute. Pennsylvania State University,
University P.& PA ieeoi (19 ).
36

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inventory, for it will reflect what the
community wants out of its public
transportation system.”
Inventories cost money. Clean air
planning funds (Section 175 funds) may
be dedicated to such inventories, as may
3C planning funds. Perhaps a special
appropriation from your city council or
state legislature is needed. Broad-based
metropolitan-wide citizen groups may
choose to undertake preliminary surveys
on their own to demonstrate the need
for a structured effort. Solicit the help of
y,ur city planning department. Does it
have a transportation division? Who is
responsible for mapping long-range
transit strategy? The answer may be
shocking: no-one. Transit authorities are
so financially hard-pressed in this
country that often the sole planning
focus is on “keeping the trains moving.”
A basic transportation needs plan
requires a hard look at the future, as
well as the present.
Basic needs What are the “basic
transportation needs” of your
community? This is a tough question,
and one deserving of vigorous debate
where the basic needs requirement
pertains. The trick is to focus the
discussion on quantifiable needs, not
purely descriptive statements such as
“fast, clean, efficient, safe.” A
declaration that “the region should have
the best transit system that it can
afford” 2 is unacceptable, for it is totally
dependent on subjective judgments as to
what is “affordable” and subordinates
transportation needs to fmancial needs.
Instead, the focus should be on system
performance. In general terms basic
needs require thai public transportation
be improved to the point where its
inadequacy is not a factor in
implementing policies designed to induce
sh fls from private to public
transportation.’ 3 In short, if lack of
adequate public transit is the
justification for labelling a
transportation control measure “not
reasonably available,” public transit
must be improved to the point that it
becomes “reasonably available.”
When developing a basic needs
statement, it is helpful to keep in mind
what a public transit plan cannot do.
First, it cannot duplicate the privacy,
security, comfort, flexibility and point-
to-point service available from
automobile travel. Second, it cannot
change past land use decisions which, by
influencing population densities, strongly
influence the level of public
transportation service any given area can
support. Third, it cannot change people’s
inclination to choose the form of
transportation which best meets
individual needs. What it can do,
however, is to reduce or eliminate
barriers that channel decisions regarding
individual transportation needs away
from selecting public transportation.
These include:
Time: What is the total time necessary to
travel from work? See description of the
Hamburg, Germany experience, page 32.
Level of Service: Waiting time at stops
often determines patronage. A line with
six trips per hour (10-minute
headways) may lose virtually all its
patronage if service is reduced to two
trips per hour (30-minute headway).
Basic needs service levels will rise for
peak level service (perhaps to 5-minute
headways) and decline for off-peak
service.
Accessibility: Transit won’t be used if it
is not accessible. Where are the stations
and bus stops located with respect to
residential areas? Is there a focused
effort to tie service levels to residential
density? The basic needs statement
should establish basic service levels for
the various population densities
throughout the system.
Security: In a recent two-week period
the New York subway system
experienced a rape, two muggings, and
one death when no assistance was
provided a heart attack victim. Such
experiences have a devastating effect on
transit patronage. Lighting, police, and
emergency assistance alarms are all
quantifiable performance standards for
security.
These are only examples of relatively
objective basic needs standards. Similar
standards can be established for other
measures of acceptable transit services
such as comfort, efficiency and
cleanliness. The use of polls may be
appropriate to test public perceptions of
the major impediments to transit travel
that block successful implementation of
auto restraint measures. Finally, while
public transit cannot change past land
use decisions, it can influence future
decisions. Development follows
availability of transportation, and vice-
versa. Wise selection of transportation
investments can act as a brake on
increases in transportation demand, and
encourage dense development along
transportation axes that meet basic
needs (see Joint Development, page 40).
This, in turn, may force a change in the
basic needs statement to accommodate
the increased patronage that
accompanies such development.
1 I & excellent example of a serious effort at
developing a public transportation inventory for
New York City is A New Direction in Transit,
published by the New York City Planning
Commission in December 1978. It is available
from the Transportation Division, Department of
City Planning, New York City.
‘ 2 Rejection of New York SIP: 44 Fed. Reg. 5694
(Jan. 29, 1979).
13 Letter from EPA Administrator Douglas M.
Costle to Governor Hugh L. Carey, dated June 20,
1978; see also Memorandum: Draft Guidance on
Public Transportation Plan Required by Section
I 1O(aX3XD) and 1 10(cX5) of the Clean Air Act,
From: David 0. Hawkins, Assistant Administrator
for Air and Waste Management, To: Regional
Administrators, Region l-X, Date: April25, 1978.
L rz -y R .)om 21.i 4
r r ç P i—213
W * gton, D.C. 2 )46
37

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Transit User Panels
Commitments: The Clean Air Act gives
funding of basic needs plans priority
status. In fact, all federal, state, and
local funds that qualify for expenditure
on basic needs plan implementation
must be so used, insofar as they are
necessary to meet the basic needs
requirement) 4 This requirement is the
complement of the requirement that
reasonably available control measures be
given similar priority status in MPO
project programming,’ 5 and reflects an
understanding by Congress that it makes
little sense to implement controls on
auto use if alternative means of mobility
remain unavailable.
A first step in establishing
commitments is to inventory all
available federal, state and local funding
for any part of the basic needs plan. The
obvious sources are federal highway and
transit funds, state transportation
authorizations and budgets, bonding
authorizations of state or regional
revenue bond authorities, and municipal
authorizations and budgets. Study
restrictions on the use of such funds.
Federal transportation assistance is
becoming mcreasingly flexible. Up to 50
percent of federal highway apportion
for primary, secondary, and urban
system programs are interchangeable (23
U.S.C. §120.) Moreover, federal
interstate highway funds within or
linking urbanized areas can be
transferred to public transit, as can
urban systems funds )6 If funds are
available for basic transportation needs
implementation pending local request,
they are not rendered unavailable simply
because local officials have not made
such a request. They must be placed in
the ledger of available funds. Basic
transportation needs plans, since they
are so closely tied to comprehensive
urban development plans, may well
qualify for funding outside the
‘ 42 U.S.C. §7410(cX5XB) (1978 paniph.).
‘ 42 U.S.C. §7506(d) (1978 pamph).
“23 U.S.C. §*l03(eX4), 142 (1970).
traditional transportation financing pot.
The U.S. Department of Housing and
Urban Development (HUD) provides
funding for regional master planning) 7
Comprehensive Employment and
Training Act (CETA) funds could be
used to hire a basic needs planner. HUD
also operates an Urban Development
Action Grants Program that may be
used to promote joint development
around transit lines. The Economic
Development Administration may
provide project assistance for joint
development projects in support of a
basic needs plan. A full inventory of
federal urban assistance programs is
available from the federal government.’ 8
Combine this inventory with your
inventory of state and local programs
and then approach your local elected
officials through the MPO for
commitments to use these funds in
support of the basic needs plan.
Meeting basic transportation needs is
an on-going process. The three basic
activities necessary to meet BTN
requirements (inventory, plan
development, funding commitments) are
not sequential. All three activities can
and should proceed simultaneously.
Your MPO and regional DOT and EPA
offices can provide more information on
how to participate in the basic
transportation needs planning process in
your area.
“Section 701. Housing and Urban Development
Act of 1968.
Catalog of Federal Domestic Assistance
should be available for $20 from the Super-
intendent of Documents, U.S. Government
Printing Office. Washington, D.C. 20402. Another
publication. Neighborhood Oriented Programs of
the Federal Government: A Compendium of
Funding and Technical Assistance Resources for
Neighborhood Organizations (October 1979) is
available from the Office of Neighborhood
Development, HUD-401, Department of Housing
and Urban Development. Washington, D.C. 20410.
The commuting community includes
those who prefer. public transit, the
totally transit dependent, the “sunshine
patrons,” and the autophiles. It is the
sunshine patrons who determine the
success or failure of public transit
service. These are the fickle “maybe’s:” f
they don’t have to wait in the rain; if
they have the right change; if they know
how to make the right connection; if
they don’t have to watch five buses go
by full before boarding; tf the driver
doesn’t close the door in their face; etc.
These patrons are extremely service
sensitive. If they wait in the snow for
thirty minutes just once for a bus that is
supposed to come every ten minutes,
they may abandon transit altogether.
More than in most commercial opera-
tions, a successful transit program
depends on “keeping the customer
satisfied.” This lesson was lost, however,
in the post World War II era as
reductions in transit ridership caused
service cutbacks which, in turn, drove
more people away from transit into the
arms of the increasingly attractive auto
commute.
The skyrocketing cost of car owner-
ship and use, however, coupled with our
critical national energy and environ-
mental agenda, has presented public
transit with a second chance to win back
some of its sunshine patrons. But transit
operators must keep close to the pulse of
citizen concern. A “User’s Panel”—a
group of commuters who volunteer to
oversee transit operations—is one means
of tapping that concern. Polls are
another, but the advantages of users’
panels over polls are that (1) citizens will
initiate new ideas while polis merely
reflect, and (2) citizens are enormously
conscientious. Give them responsibility
and a mandate to protect the public
trust and they will work hard to meet
that responsibility. London has a formal
users’ panel made up of citizens who are
generally elected to supervise transit
decisionmaking. Boston has made sev-
eral attempts to form a users’ panel, but
has been unable to institutionalize the
38

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process.’ 9 A big problem is selection.
Election is a cumbersome process, but
appointment by transit officials risks co-
option. The selection process is an issue
each community must address on its
own.
If you are successful in establishing a
users’ panel, three areas where you can
contribute significantly in decision-
making are fare structures, routing and
scheduling, and quality of service:
• An optimalfare structure should be
low enough to attract patronage, be
affordable to low-income users, yet
cover costs of operation. However, due
to a generally perceived commitment to
provide at least some service at all hours
to the complete system, revenues will not
cover costs. The issues then raised
include: What is an acceptable deficit?
How much off-peak (nonrush hour)
service should be provided? Will fare
increases actually reduce revenues
through loss of patronage? What about
zone fares versus flat rates? How about
free transit (total subsidization through
taxation), or are free pass programs
better (selective subsidies to the poor,
elderly, handicapped)? These are all
public issues which should be answered
in light of community values and
commitment to public transit service. As
such, they need to be opened to public
debate.
• Routing and scheduling are also
public issues. An observer of the Boston
bus system commented, “These buses go
from where people no longer live to
where they used to work.” With
changing demographic patterns, both the
routes and the frequency of service must
constantly change. However, these
decisions are often made haphazardly by
managers who see only red ink and
terminate service instead of asking why
people have gone elsewhere. The users’
panel should find out how routing and
scheduling decisions are made and how
they can be made responsive to citizens’
concerns.
‘ 9 For information on the Boston experience.
contact the Boston Consumer Council, One City
Hall Plaza, Boston, Massachusetts.
• The quality of service provided is of
equal importance to the availability of
service. Over-heated (or freezing) buses,
drivers who won’t wait for people
running to catch an empty bus, dirty
stations and no schedules will all push
people back into their cars. How does
your local bus authority handle com-
plaints—by phone, or do they make you
write? Do they keep records of com-
plaints and seek to remedy persistent
abuses or is it more of a public relations
effort? These are all pertinent issues for
a users’ panel.
Members need not be formally elected, 20
and a process should be established for
rapid turnover of membership (at least
33 percent a year) to maintain idea flow
and prevent members from becoming
part of the management.
User panels are a new idea, at least in
this country. But they are an excellent
way of keeping transit systems close to
the communities they serve, and can,
therefore, contribute significantly to
urban revitalization effort. One warning:
user panels probably should not be given
management or budgetary authority.
Their job is to hold the system
accountable, not to become the system
they are charged with keeping an eye on.
20 Selection could be conducted similar to the jury
system, except that a pool of “volunteer
conscriptees” could be used instead of voter rolls,
developed by distributing sign-up cards to patrons.
Action Tip
A key ingredient in public transportation
is information. Where do the lines go?
What are the connections? What do all
the numbers and pictures on signs mean?
How much do the various trips cost
(very important in “correct change only”
systems)? What cultural, scientific and
tourist attractions are accessible by
public transit? What special programs
are available? How does one register a
complaint? A users group in Boston, in
conjunction with the transit authority,
has published a citizens’ manual
answering such questions, and more.
Car-Free in Boston is a model consumer
information publication and is available
for $1.50 (including postage) from the
Association for Public Transportation,
P.O. Box 192, Cambridge, Mass. 02138.
, ..:

t : ;
TRANSIT AND CAR POOL SELECTOR
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39

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Joint Development
Joint development takes two forms. The
first type of joint development of
different modes of transportation
facilities (multimodal development) is a
direct outgrowth of the 3C planning
process described elsewhere in this
manual. Examples of multimodal
solutions to transportation problems
that use highway rights-of-way to
accommodate both transit and highway
facilities include 1-66 in Arlington,
Virginia and the Century Freeway (1-10)
in Los Angeles. A second type of joint
development involves simultaneous
construction of transportation
projects and nontransportation facilities
as part of a single urban development
plan. Since multimodal planning is
adequately discussed elsewhere in this
booklet (see p. 10), the following
discussion focuses on joint development
of transportation and commercial or
residential “urban revitalization”
projects.
The impetus for this second type of
joint development springs from Presi-
dential initiatives taken to structure a
National Urban Policy, such as Presi-
dent Carter’s Special Message to Con-
gress on Urban Policy 2 ’ and four
Executive Orders issued implementing
this policy. 22 The goal of these initiatives
is to stem the flow of out-migration that
has resulted in at least five U.S. cities
(Buffalo, Cleveland, Detroit, Pittsburgh,
and St. Louis) losing over 20 percent of
their population within the last five
years. Since highway construction was
singled out in this urban initiative as
“the most powerful direct federal action
that has contributed to metropolitan de-
centralization and central city decline,” 23
the help of DOT was solicited. In 1979
“Urban Polic)r Message from the President of the
United States Transmitting Proposals for a
Comprehensive National Urban Policy, Rouse
Documcnt No. 95-309, Dated: March 27, 1978,
Referred: April 3, 1978.
“Executive Orders 12072-12075,43 Fea’ Rag.
36869-79 (1978).
“U.S. Department of Rousing and Urban
Development, The President’s National Urban
Policy Report (1978) at 101.
DOT Secretary Brock Adams, acting
pursuant to the Presidential Directive
and his authority to set National
Transportation Policy 24 , announced a
five-point Urban Transportation Policy
that emphasized joint development. 25 In
addition, DOT has earmarked UMTA
funds for urban initiatives that empha-
size joint development, intermodal trans-
fer facilities and transit malls. 26 Finally,
the Federal Highway Administration
and UMTA have issued a joint directive
to all Regional DOT Administrators and
Directors requiring the assessment of
urban transportation projects, including
development impacts, impacts on tax
revenue, property, sales and income,
impacts on public expenditures required
to support the project and the develop-
ment shifts induced by the project, and
impacts on community employment. 27
The joint development initiative is still
evolving, but bears considerable promise
as an urban revitalization, energy con-
servation, and air quality initiative.
Primary responsibility for its imple-
mentation on an inter-agency level lies
with the Federal Regional Councils,
loose organizations consisting of the
representatives of various federal
agencies in each region of the country.
In particular, HUD, Department of
Labor, and Economic Development
Assistance programs can be “targeted”
to support joint transportation! urban
development. On the national level, the
Interagency Coordinating Council in the
White House lends additional support to
joint development projects.
2449 U.S.C. §1702.
“The policy was announced in a speech delivered
at the Kennedy School of Government,
Cambridge, Massachusetts, on February 13, 1979.
The five points were: (I) joint development, (2)
energy assessments, (3) minority employment. (4)
urban rehabilitation, and (5) urban transportation
planning reforms.
S200 million in discretionary UMTA funds have
been set aside for these projects in 1980. Awards
will be made on a competitive basis. Contact your
Regional UMTA office for more details.
Memorandum, “Improving the Urban
Transportation Decision Process” from Lillian
LiBurdi, Acting UMTA Administrator and Karl
Bowers, FHWA Administrator, to Regional
UMTA and FHWA Administrators (October 11,
1979).
If you are a member of a business
group or a neighborhood organization
interested in promoting development in
conjunction with on-going trans-
portation improvements, contact your
MPO and the relevant members of the
Federal Regional Council in your area.
There are other means to encourage
joint development. San Francisco, for
example, grants building height benefits
to buildings connected to BART sta-
tions. In illinois, the State DOT is
engaged in joint efforts with railroads to
develop airspace over rail yards for
housing and industry. Maryland en-
courages urban homestead ing in surplus
highway right-of-way acquisitions. Port-
land, Oregon, has combined transit
improvements with pedestrian amenities
to create “transit malls” with very
positive impacts for local businesses.
These federal and state initiatives to
promote flexibility and joint use indicate
that the greatest current impediment to
joint development in urban areas is a
lack of general public understanding of
joint development opportunities.
Action Tip
DOT has prepared a publica-
tion describing successful joint
development projects and listing joint
development activities in every State. It
also includes a bibliography. Highway
Joint Development and Multiple Use,
FHWA (1979) is available from the
Superintendent of Documents, U.S.
Government Printing Office,
Washington, DC 20402. (Stock No.
050-002-00105-1).
40

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Developing a Shopping Mall
Policy
Regional shopping malls, or suburban
shopping centers, are now almost as
familiar as supermarkets. Springing up
at every interstate or arterial road
interchange, they seem to be a natural
and unchangeable aspect of the
American landscape.
Not true. In fact, suburban shopping
centers are a relatively recent addition to
the American scene and are not even our
own idea; they were first proposed by
Austrian architect and planner Victor
Gruen in 1943. However, America
offered all the ingredients for spectacular
implementation of Gruen’s vision: cheap,
sparsely populated land, abundant
energy supplies, and an economy that
escaped the devastation of World War
II. In this agreeable environment,
shopping centers boomed. There are
now approximately 1,000 regional
shopping centers with over 400,000
square feet of gross leasable space. Most
of these are enclosed malls. There are
several thousand additional older, open
regional shopping centers of between
100,000-400,000 gross leasable space.
Gruen’s vision, however, never
materialized. He envisioned centers of
mixed uses, including medical offices,
clubs, circulating libraries, post offices,
and specialty shops closely tied to
nearby greenbelted housing develop-
ment. While the concept has been
realized in such “new town” community
developments as Columbia, Maryland,
and Reston, Virginia, promoters soon
realized that the profit lay in
merchandising, not mixed use. Cheap
transportation put no premium on
proximity of home to shop, while
commercial agglomerations provided the
convenience of one-stop shopping. The
result: huge centers devoted exclusively
to retail sales which required enormous
parking capacity, widened highway
access, and more traffic control and
police support.
Recently, municipal and regional
planners have begun to put statistics
together on the effect of suburban malls
on existing communities. In Saginaw,
Michigan, construction of the Fashion
Square Mall on the edge of town
resulted in a 24 percent decrease in
property values in the central business
district within five years, while
assessments went up in the remainder of
the city 23 percent. Burlington, Vermont
predicts a 40 percent drop in commercial
sales if a similar shopping center is
constructed in neighboring Williston.
The threat is greatest to medium-size
cities that do not have the amenities
(i.e., parks, museums, theaters, public
transit systems) that complement as well
as attract downtown commercial
activity, and has caused Victor Gruen to
attack his own intellectual progeny as
“premeditated murder of (the) city.”
With 10,000 of our 40,000 cities now
designated as “economically distressed,”
the statistics appear to support this
allegation.
President Carter recognized the threat
to downtown urban areas represented by
these shopping centers and took two
actions that provide citizens with
handles for action.
First, on August 2, 1979, the President
issued his Second Environmental
Message. In that message he recognized
that our national transportation
investment policies could affect
suburban sprawl and directed the
Secretary of Transportation to give
“careful review” to “any transportation
proposals which would encourage urban
sprawl... or which would tend. to
attract jobs out of our urban areas.”
DOT soon issued a directive to all
regional federal transportation officials
requiring a review of federally-assisted
transportation projects on the “economic
vitality of the central city”—including
development, tax revenue, public
expenditure, employment, accessibility,
and environmental impacts. 28 On
November 29, 1979, newly-appointed
DOT Secretary Neil Goldschmidt
rejected a proposal to construct a
beltway around Dayton, Ohio, on the
grounds that it would adversely affect
the city’s economy. Citizens can now
request assessments of transportation
projects proposed primarily to serve the
traffic needs of suburban malls.
Second, on November 26, 1979, the
White House announced a “Community
Conservation Guidance” policy directed
specifically at controlling suburban
shopping malls. The guidance provides
that, at the request of a community
affected by a regional shopping mall
proposal, all federal agencies involved in
providing infrastructure support through
federal funds or permits for the project
must prepare a “community impact
analysis.” This analysis must include an
assessment of the impacts of the
suburban mall on existing business
districts in the area. If the analysis
demonstrates that significant negative
consequences will result from the mall
development the federal agencies
involved are required to re-think their
support for the mall. (The Community
Conservation Guidance is reproduced in
full in Appendix C.)
Clearly, these initiatives represent no
final solution to the shopping mall
problem. But they do focus the attention
of decisionmakers on the energy, health
air quality, and economic problems they
may be creating. Citizens in Boulder,
Colorado have requested DOT to review
a proposed mall on the ground that
required improvements to an adjacent
federal-aid highway to accommodate
28 Memorandum from Karl S. Bowers, FHWA
Administrator and Lillian LiBurdi, Acting UMTA
Administrator, to all FHWA and UMTA Regional
Administrators, October 11, 1979.
41

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Interstate Transferz9
mall traffic constitute an “encroach-
ment” on the highway system and require
federal approval. In Montpelier,
Vermont, citizens have asked EPA to
prevent a neighboring town from
increasing its sewage treatment capacity
to accommodate a shopping mall so
long as the existing sewage treatment
plant continues to violate federal clean
water requirements. Often, shopping
mall projects involve development funds
from HUD, or require a permit to fill
wetlands from the U.S. Army Corps of
Engineers. All these federal “handles”
are sufficient to invoke the President’s
Community Conservation Guidance with
local political support. And, when
looking for this support, don’t forget the
Chamber of Commerce, a group that
should have a particular interest in
protection of urban economic vitality.
Since the creation of the Federal --
Highway Trust Fund in 1956, receipts
from gasoline taxes have, by law, been
devoted exclusively to construction of
highways and highway-related facilities.
However, in 1973 the Federal-Aid
Highway Act was amended to permit
“transfer” of urban interstate highway
projects to alternative mass transporta-
tiOfl3O projects and, in a further amend-
ment, permitted transfer to other
highway projects as well. Substitute
mass transit projects receive 85 percent
federal funding out of general revenues,
not out of the Highway Trust Fund. 3 ’
Transfer occurs in three steps: first, an
interstate segment is withdrawn; second,
a broad outline (called a concept
program) of substitute projects is
approved; third, individual projects are
approved and federal funding is
provided.
An interstate segment may be
withdrawn only if four criteria are met. 32
First, the segment must either be (a)
within an urbaü area, (b) have portions
partially within and partially outside but
in close proximity to the same urban
area, or (c) pass through and connect
urban areas within a State. 33 Second, the
segment must not be essential to
‘ 9 The discussion in this section is based on draft
regulations found at 45 Fed. Reg. 2296 (January
10, 1980). Final regulations are expected to be
issued by November 1980. Contact your DOT
Regional Office for more details.
°23 U.S.C. § 103(eX4). This so-called “interstate
transfer provision” should not be confused with
the so-called “Howard-Cramer transfer” provision
which permits the addition of new interstate
mileage in exchange for withdrawal on
nonessential segments. 23 U.S.C. §103(eX2). The
exchange of one Interstate highway for another
was abolished in the 1976 Highway Act.
3 1 Proposed: 23 C.F.R. *476.314(f). 45 Fed. Reg.
2296, 2305 (January 10, 1980).
“In addition to these four primary criteria are the
following technical requirements:
• The segment must not have been added to the
interstate system after May 5, 1976 in substitution
for segments withdrawn under 23 U.S.C.
§ 103(eX2).
• The segment must not be a federal-aid primary
system road upgraded to interstate status pursuant
to 23 U.S.C. §139.
• The segment must not be a toll bridge, tunnel
or approach.
“Proposed: 23 U.S.C. §476.302(a). 45 Fed. Reg.
2296, 2303 (January 10, 1980).
completion of a unified and connected
interstate system. 34 Third, the segment
must not be open to traffic. 35 This bars
transfer of proposed expansions of
existing interstate segments. Fourth, the
withdrawal request and concept program
must be approved prior to September
30, 1983.36
The first step in the transfer process is
submission of a withdrawal request.
DOT cannot initiate the transfer. The
request must be made by the Governor,
local governments and MPOs within
whose jurisdiction the segment would
have been located. 37 However,
unanimous local consent is not required.
DOT regulations provide simply that
there be “substantial support” for the
transfer. 38
Once the request is made, two DOT
components—the Federal Highway
Administration (FHWA) and UMTA—
will jointly determine whether the
segment meets withdrawal require-
ments. 39 Upon approval of withdrawal.
the state’s share of interstate highway
money will be adjusted downward to
reflect the withdrawal. 4 °
The next phase in the transfer
procedure is submission by the Governor
of a “concept program” which outlines
proposed substitute projects and
accounts for all unobligated funding
made available by the transfer. 4 ’ The
“Proposed: 23 U.S.C. §476.306(aX2). 45 Fed. Reg.
2296, 2304 (January 10, 1980).
“Public L. 96-144 (December 13, 1979). Proposed:
23 U.S.C. §476.302(bX5). 45 FerL Reg. 2296, 2303
(January 10, 1980).
36 Proposed: 23 C.F.R. §476.302(c). 45 Fed. Reg.
2296, 2303 (January 10, 1980).
“Proposed: 23 C.F.R. §476.304. 45 Fed. Reg.
2296, 2303. (January 10, 1980). - -
“Proposed: 23 C.F.R. §476.304(b). 45 Fed. Reg.
22%, 2303 (January 10, 1980).
“Proposed: 23 C.F.R. §476.306(a). 45 Fed. Reg.
2296, 2304 (January 10, 1980). However, FHWA
alone determines whether the segment is essential
to completion of a unified and connected interstate
system. Proposed: 23 C.F.R. §476.306(aX2). 45
Fed. Reg. 2296, 2304 (January 10, 1980).
40 Proposed: 23 C.F.R. §476.306(b). 45 Fed. Reg.
22%, 2304 (January 10, 1980).
4 1 Proposed: 23 C.F.R. §476.308(a). 45 Fed. Reg.
22%, 2304 (January 10, 1980).
42

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proposed substitute projects may include
mass transit projects or non-interstate
highway projects in any combination. 42
The only requirements are: (1) that the
substitute projects must serve the same
general area from which the interstate
segment was withdrawn; and (2) that
they be developed in accordance with
the existing urban transportation
planning requirements. 43 While approval
of the concepts program by FHWA and
UMTA must occur prior to September
30, l983, it is not a final, binding
proposal, and adjustments may be made
after the 1983 deadline. 45
Once the concepts program is
approved, individual highway and mass
transit projects may be advanced to the
annual element of the transportation
improvement plan. 46 The FHWA or
UMTA may approve individual
substitute projects to the extent that
adequate appropriations are available. 47
Upon approval of a substitute project
for construction, the federal government
is obligated to provide 85 percent of the
cost of the substitute project. 48
That is the process for interstate
transfer. At first glance, it appears that
transfer is a simple trade of interstate
dollars for substitute project dollars, and
that States are free to base their decision
on the merits of the transfer. In fact, it’s
not exactly an even trade.
First, the federal! state funding ratio
declines from 90 percent to 85 percent.
That may not sound like a big
difference, but from the local perspective
it means that the State must now put up
$1.50 for every dollar it was putting up
for the interstate project. That 50
percent increase may be enough to
trigger a “thumbs down” from budget-
conscious local governments.
Second, the guarantee of federal
dollars from the Highway Trust Fund is
transformed into a promise to
appropriate funds from general revenues
at some uncertain time in the future.
This is a critical distinction. States are
permitted to spend federal highway
dollars prior to actual appropriation of
funds since the funding is guaranteed
through the Trust Fund. However, when
a segment is withdrawn and another
project substituted, funds must actually
be appropriated through the annual
budget process before they can be spent
on the substitute project. So long as
Congress appropriates adequate sums of
money every year, this presents no
problem. But, as the interstate transfer
provision becomes increasingly popular,
appropriation levels may be exceeded.
Should this occur, States will have to
wait in line for funding of substitute
projects. 49
49 1t should be remembered that Federal Aid Urban
System (FAUS) funds are totally transferable, and
substitute projects, including public transit
projects, may be funded out of the Highway Trust
Fund. 23 U.S.C. §142 (1978).
Action Tip
DOT has established an outreach
program to explain the transfer process
to local governments and citizens. You
may learn more about interstate transfer
by contacting either the Office of
Interstate Reports, Federal Highway
Administration, 400 7th Street, S.W.,
Washington, D.C. 20590, or the U.S.
Conference of Mayors, 1625 1 Street,
N.W., Washington, D.C. 20006.
42 Proposed: 23 C.F.R. §476.2(bX7), (8). 45 Fed.
Reg. 2296, 2303 (January 10, 1980). N.B., Prior to
1976, substitute projects were limited to mass
transit improvements. Toll roads, however, are not
permitted. Proposed: 23 C.F.R. §476.304(bX3). 45
Fed. Reg. 2296, 2303 (January 10, 1980).
43 Proposed: 23 C.F.R. §476.308(aXl), 476.310(a).
45 Fed. Reg. 2296, 2304 (January 10, 1980).
“Proposed: 23 C.F.R. *476.308(b). 45 Fed. Reg.
2296, 2304 (January 10, 1980).
45 1d.
“Proposed: 23 C.F.R. §450.310(f), 450.318(a). 45
Fed. Reg. 2296, 2305 (January 10, 1980).
47 Proposed: 23 C.F.R. §476.314. 45 Fed. Reg.
2296, 2305 (January 10, 1980).
“Id.

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Bicycles
The biggest obstacle to acceptance of
bicycle transportation as a legitimate
recipient of transportation planning and
construction funds is attitude. Not
funding limitations—all federal highway
capital funds qualify for bikeway
expenditure. Not weather—i 3 percent of
all vehicle trips are made by bicycle in
cold and blustery Madison, Wisconsin.
Not time—over 60 percent of all U.S.
trips were five miles or less in 1978. But
attitude. Bicycle transportation does not
require sophisticated planning or design,
nor is there much money in bikeway
construction. Bikes do not require a Jot
of resources to manufacture or maintain.
They also require no fuel. But they have
little status. Bike transportation is
perceived to be hazardous (and is, where
not properly planned). “Bikes are for
kids” was the attitude expressed by a
transportation planner in—of all
places—Boston. But bikes are not just
for kids. In 1968, adult (lightweight)
bike sales were less than 2 million,
compared to almost 6 million for
children’s bikes (20 inches or less). In
1974, adult bikes outsold children’s bikes
11 million to 4 million. 50
Bikes can play a vital role in
addressing some of the problems of
urban areas. They contribute nothing to
pollution. Bikeways place no
development pressure on open space,
nor do they encourage commercial or
residential flight from cities. If placed
along sewer interceptor lines, abandoned
railroad rights-of-way, or on a “shared”
roadway, bikeways take no land off the
tax rolls. The advantages of bicycle
transportation to users are also obvious.
Bicycles provide door-to-door service.
They have low capital and operating
Th cycIing and Air Quality. EPA (1979) p. 12.
costs. The only energy they use is what
it takes to make the bike and feed the
driver and they help keep people in
shape in the bargain.
Despite these advantages, there is a
general lack of interest in bicycle
transportation within the professional
transportation community. Admittedly,
there are some very real limitations on
use of bikes, such as safety, convenience,
speed, and comfort. But these limitations
can be overcome. The energy shortage
may help break down this lack of
interest. The National Energy
Conservation Act of 1978 called for a
study—now completed by the U.S.
Department of Transportation—of the
energy conservation potential of bicycles.
Furthermore, the experience of other
countries documents that this disinterest
can be overcome. While less than 1
percent of all home-to-work trips in the
U.S. are made by bicycle, the figure
ranges from 9 to 61 percent in 10
medium-sized European cities as noted
in Figure 18.
Figure 18 Mode of Home-to-Work Trips
Source: flicycling and Air Quajity, EPA (1979)
In fact, bicycling accounts for over 40
percent of all trips in many parts of The
Netherlands, and well over 10 percent of
all trips in such major European cities as
Copenhagen, Nice and Grenoble. While
differences in temperature, topography
and income explain, to some extent, the
large gap in the relative acceptance of
bicycle transportation in Europe and the
U.S., the fact remains that “(o)ne of the
major differences between the U.S. and
[ the] northern European environment is
the traditional acceptance and use of the
bicycle as an adult mode of
transportation.” 5 ’
If you are interested in promoting
bicycle transportation you must
overcome the skepticism that exists
among both providers and users of
transportation in American cities. Don’t
be discouraged. It is, after all, a matter
of attitude, a natural bias against
changing the status quo. When planners
protest that bike ridership is not
‘Bicycling and Air Quality. (1979), p. 21.
Percentage of trips by mode
European
city
France
Year
Public
trans-
Foot Cycle Car port
Germany
Netherlands
Lille
Lyon
Marseille
Nancy
Orleans
Bremen
Tilburg
Rotterdam
Zaanstad
Other
1976
1976
1976
1976
1976
1970
1972
1971
1974
8
19
16
15
9
24 19 49
23 9 47
29 10 45
23 11 51
18 23 50
29 22 —49---
9 61 28
20 22 25
10 40 37
United
Kingdom
2
29
2
Stevenage 1976 19 9 50 20
4
II
44

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sufficiently high to justify construction
of special facilities (i.e. bike routes,
shelters, parking facilities), point out
that low ridership is often due to lack of
facilities. Studies in urban areas have
indicated a tremendous latent demand
for bikeways—if facilities are provided
they will be used. Demand for cars was
also low—until there were paved roads
on which to drive them. In New York
City alone, 130;000 people commute to
work by bike, a tenfold increase since
1975.52
Once you are successful in extracting
an acknowledgement that bicycle
transportation is here to stay, you will
meet the next objection—no funds.
Don’t believe it. Bikeways are considered
highways under federal law, thus
qualifying States for federal
reimbursement for 75-90 percent of their
costs. In fact, it is federal policy that all
federally-assisted highway construction
should give “full consideration” to
accommodating bicycle traffic and that
“every effort” should be made to
minimize conflicts between motorized
and non-motorized traffic on federal-aid
roads. 53 Separated or non-separated
bikeways can be constructed with all
federal-aid highway construction funds
as long as (I) they are constructed
within the right-of-way of the highway
and (2) they are constructed
concurrently with the highway
improvement (even if the improvement is
resurfacing, restoration, or rehabilitation
of the existing route). 54 The bikeway
should be planned as an integral part of
the highway project and proceed from
planning to construction with the
highway project itself.
Moreover, highway funds can be used
to construct separate bikeways outside
an existing right-of-way and independent
of any concurrent highway construction
“Wall Street Journal, Friday, March 14, 1980, p.
“23 C.F.R. 652.5.
23 U.S.C. §217, 23 C.F.R. 652.7.
as long as the purpose of the bikeway is
to accommodate traffic that would
normally have used a federal-aid
highway. 55 The only limitation on use of
federal-aid funds for these separate
bikeways is a $2.5 million per year state
cap and a $45 million per year national
cap, of which less than 10 percent is
actually spent. This cap applies only to
separated bikeways constructed
independently of a highway project.
There is no cap on concurrent
highway/bikeway projects.
Both separated and unseparated
bikeway construction is funded out of
regular highway funds, which means that
these bikeways must compete for funds
that are already planned, if not
committed, to highway cónstruction.
Recognizing that bikeways often lose in
such a contest, Congress, through the
23 C.F.R. 652.7.
Surface Transportation Assistance Act of
1978, authorized grants in the amount
of $20 million per year through
1982 for exclusive use in (1) bikeway
construction or (2) nonconstruction
(education) projects that can reasonably
be expected to enhance the safety and
use of bicycles. 56 These funds are
disbursed on a discretionary basis, do
not need to comply with standard
highway planning regulations (except
that, in urban areas, they must be
approved by the MPO), and are in
addition to the regular highway funds
that are distributed (“apportioned”) to
States by formula. 57 Section 141 of the
Act also states that no new highway can
56p.L. 95-599, §141(c) (Nov. 6, 1978). 72 Stat.
2689. Congress appropriated $4.0 million for this
program in FY 1980. The FY ‘81 proposed budget
has no funding for this program.
57 See proposed regulations on distribution of these
funds. 45 Fed. Reg. 952 (January 3, 1980).
45

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cut or destroy a bike route without
providing an adequate alternate route.
The federal highway aid program is
not the only source of funds for
bikeways. Special funds are available to
convert abandoned railroad nghts-of-
way to bikeways. 8 Also, federal funds
are available on a 50/50 matching basis
from the Department of Interior for
bikeways that are included in a State
Comprehensive Outdoor Recreation
Plan.” Nevertheless, the biggest pot of
money for bikeways is the highway
construction pot. Highway planning
funds that are distributed to MPOs to
do transportation planning are also
available for bikeway planning. ’ 0
Finally, funds made available to
promote highway safety through driver
education programs can also be used to
promote bicycle safety.” It is up to you
to trace these programs through your
State Department of Transportation and
MPO to make sure some of these funds
are allocated to bikeway planning and
construction, and to bike safety
programs.
Once you have identified available
funding sources, promote bicycle
programs as a reasonably available
control measure for inclusion in the
State Implementation Plan. Once a bike
programis in the plan’ 2 it must be
included in the transportation program
of the MPO. Apart from this
requirement, here are some other ways
to promote bikeway programs in your
city:
5 Scction 809(b). Rail Revitalization and
Regulatory Reform Act of 1976. See regulations at
49 C.F.R. Part 266, January 4, 1978. Applications
should be made to U.S. Department of Interior
through your State Office of Rail Planning.
‘Your State Department of Natural Resources, or
whatever state office deals with the U.S.
Department of Interior, should have such a plan.
Contact your regional office of the U.S. Heritage,
Conservation, and Recreation Service (HCRS),
U.S. Department of the Interior, for more details.
‘°23 U.S.C. §307(c) (1978).
6123 U.S.C. §402 (1978).
‘ 2 Bikeway programs are one of 18 identified
reasonably available control measures in the Clean
Air Act. CAA §108(f), 42 U.S.C. §7408(f) (1978
pamph.).
Lobby your State Department of
Transportation to establish a special
bicycle planning office with a mandate
to make sure all transportation
projects—highway and transit alike—
give full consideration to
accommodation of bikes.
Establish a bike coordinator’s office in
the Governor’s office. The Governors of
most States have a special office that
monitors all federal assistance to the
State. The coordinator would follow all
bikeway assistance to the State from the
Federal Highway Administration, the
Federal Rail Administration, the
Department of Interior, and other
federal agencies.
Develop a comprehensive network of
safe bicycle routes for your city. One
route may not generate much use, but a
system of routes will work wonders.
Elements of the system may include:
• Bikeways along abandoned railroad
rights-of-way
• Bikeways along stream beds and
through recreational parks and
interconnecting, lightly-traveled streets
• Bicycle streets or bicycle boulevards
closed to traffic
• Bike lanes on existing streets which
take up a whole lane of traffic
Design policies for all newly constructed
roads and bridges that will reduce
hazards and increase mobility for
bicyclists by allowing enough space in
the right-of-way for cyclists to travel
safely.
Work for increased enforcement of
traffic laws related to bicycles to reduce
car/bicycle accidents.
Encourage education programs for both
motorists and adult cyclists. The
program for cyclists could include both
on-bike training in traffic skills and
bicycle handling, and classroom
instruction in such areas as route
selection and equipment maintenance.
The program for motorists would cover
road-sharing techniques, and could be
included in drivers’ education curricula,
State-issued drivers’ manuals, and
licensing written exams.
Eliminate obstacles and bottlenecks
which hinder bicycling in urban and
suburban areas.
Then get the plan included in the
implementation plan and adopted by the
MPO:
• Ask transit authorities for bike racks
and storage facilities at mass transit
stations, and the right to take bikes on
trains and subways during non-rush
hours.
• Draft city ordinances requiring
parking garage space for bicycles and
safe parking facilities at city buildings.
Bike transportation has suffered from
neglect. Now, however, there is much
new interest in bikeways to promote
energy conservation, clean air, and
“livable” cities. With the new
requirement of the Clean Air Act that
bikeway programs be funded as a clean
air strategy, the opportunity presently
exists to establish a permanent role for
bicycle transportation in urban
transportation systems.
46

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Three-C Planning Process: Compre-
hensive, Continuing, and Cooperative
Executive Order A-95: Clearinghouse
Review
Annual Element of the Transportation
Improvement Plan, usually TIP/AE
Administrative Procedure Act
Air Quality Control Region
Best Available Control Technology
Basic Transportation Needs
Clean Air Act
Clean Air Act Amendments of 1977
Central Business District
Council on Environmental Quality
Code of Federal Regulations
Draft Environmental Impact Statement
U.S. Department of Energy
U.S. Department of Transportation
Environmental Impact Statement
Empirical Kinetic Modeling Algorithm
U.S. Environmental Protection Agency
Federal Reporter, Second
Federal-Aid Urban System
Federal Register
Federal Reporter Supplement
Final Environmental Impact Statement
Federal Highway Administration
Hydrocarbons
High occupancy vehicle
U.S. Department of Housing and Urban
Development
Interstate Cost Estimate
Inspection and Maintenance
Indirect Source Review
Lowest Achievable Emissions Rate
Light Rail Transit
Memorandum of Understanding
Metropolitan Planning Organization
National Ambient Air Quality Standards
National Commission on Air Quality
National Environmental Policy Act
National Emission Standards for
Hazardous Air Pollutants
Nitrogen Dioxide
Nitrogen Oxides
New Source Ban
New Source Performance Standards
Ozone
Office of Management and Budget
Part D of the Clean Air Act
Lead
Preliminary engineering
Prevention of Significant Deterioration
Approval of Plans, Specifications and
Estimates
Parts per million
Public Law Number
Reasonably Available Control Measures
Reasonably Available Control
Technology
Reasonable Further Progress
Right-of-way
State Highway Agency
State Implementation Plan
Sulfur Dioxide
Sulfur Oxides
Statutes at Large
Transportation Control Measure
Transportation Control Plan
See 3-C
Transportation Improvement Plan
Transportation Improvement Plan!
Annual Element
Transportation Systems Management
Total Suspended Particulates
Urban Mass Transportation
Administration
United States Code
United States Code Annotated
Unified Work Program
Unified Planning Work Program, same
as UWP
Vehicles Miles Traveled
Volatile Organic Compounds
3C
Appendix A
Acronyms and Abbreviations
.
An explanation of most of these
provided in the Glossary.
terms
is
Pb
PE
PSD
PS&E
Approval
ppm
Pub. L. No.
RACM
RACT
RFP
ROW
SHA
SIP
SO2
SOx
Stat.
TCM
TCP
THREE-C
TIP
TIP/AE
TSM
TSP
UMTA
U.S.C.
U.S.C.A.
UWP
UPWP
VMT
VOC
A-95
AE
APA
AQCR
BACT
BTN
CAA
CAAA
CBD
CEQ
C.F.R.
DEIS
DOE
DOT
EIS
EKMA
EPA
F.2d
FAUS
Fed. Reg.
Fed. Supp.
FEIS
FHWA
HC
HOV
HUD
ICE
I/M
ISR
LAER
LRT
MOU
MPO
NAAQS
NCAQ
NEPA
NESHAP
NO 2
NOx
NSB
NSPS
O
0MB
Part D
47

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Appendix B
Memorandum of Understanding Between the
Department of Transportation and
the Environmental Protection Agency
Regarding the Integration of Transportation and
Air Quality Planning
Introduction
The Clean Air Act Amendments of 1977 were signed into
law by the President on August 7, 1977; These Amendments
require state and local governments to develop for all areas
where national ambient air quality standards have not been
attained, revisions to state implementation plans (SIPs). The
revised SIPs must be submitted by the State to the
Environmental Protection Agency (EPA) by January 1, 1979.
These revised plans must provide for attainment of the
national ambient air quality standards by 1982 or, in the case
of areas with severe photochemical oxidant or carbon
monoxide problems, not later than 1987. The revised plans
must also provide for incremental reductions in emissions
(“reasonable further progress”) between the time the plans are
submitted and the attainment deadline.
In many major urbanized areas of the country the revised
SIPs will require transportation controls, i.e. strategies
designed to reduce emissons from transportation-related
sources by means of structural and operational changes in the
transportation system. A mechanism is required that will
enable state and local governments to: (I) develop a wide
range of alternative transportation control strategies, (2)
analyze the air quality and other impacts of the strategies, and
(3) select among the alternatives in a timely and informed
manner.
Federal transportation planning requirements in urbanized
areas are implemented by the Department of Transportation
(DOT) through a joint delegation of authority to the Federal
Highway Administration (FHWA) and the Urban Mass Trans-
portation Administration (UMTA). The FHWA and UMTA
provide funds to States and local governments to plan, develop,
and improve transportation systems and services. In urbanized
areas improvements are implemented according to a continu-
ing, comprehensive, and cooperative transportation planning
process carried out pursuant to FHWA/ (JMTA joint regula-
tions, It is this context that “DOT” is utilized in this docu-
ment. In order to effectively achieve the objectives of the 1977
Clean Air Act Amendments, the DOT and Environmental
Protection Agency (EPA) agree that the transportation-related
air quality planning requirements of EPA will be integrated
with the transportation planning process administered by the
DOT. Closer integration of the planning requirements of DOT
and EPA will ensure the timely consideration of air quality
concerns and will reduce potentially duplicative, overlapping,
and inconsistent activities at the State and local level. DOT
administers other planning programs through other administra-
tions (e.g., FAA and FRA) which have lesser impact on air
quality but may be subject to future discussion.
Purpose
This Memorandum of Understanding, developed pursuant to
the President’s request, is designed (I) to establish certain prin-
ciples which DOT and EPA agree to follow in the preparation
of more detailed regulations and administrative procedures
required to achieve the objective of integrating the air quality
and transportation planning processes; (2) to identify specific
areas of agreement with regard to the joint administration of
the air quality aspects of the planning process.
Principles that Will Guide the Integration of the Air
Quality and Transportation Planning Processes
The reduction of air pollution is an important national goal
and must be among the highest priorities of the transportation
planning process in areas not meeting primary Air Quality
Standards. However, the transportation planning process must
also consider other national and local objectives such as mobil-
ity, safety, energy conservation, urban economic development,
full employment and orderly metropolitan growth.
It is the affirmative responsibility of federal, State and local
agencies involved in funding or conducting transportation
planning and implementation to ensure that evaluation of an
adequate range of alternative transportation control strategies
is conducted in order to furnish local, State and federal officials
with an adequate basis on which to reach informed decisions.
Any transportation planning activities conducted pursuant to
this agreement must continue to provide for an adequate pro-
cess of consultations with an involvement of the general pur-
pose local government, responsible State agencies and the pub-
lic as called for in the joint UMTA! FHWA Urban Transporta-
tion Planning regulations.
It is the objective of the activities undertaken pursuant to this
agreement to contribute to the maximum extent feasible, in
combination with other emission reduction measures, to a re-
duction of emissions necessary to meet the prescribed air quali-
ty standards.
Joint Administration of the Air Quality Aspects of the
Urban Transportation Planning Process
The Department of Transportation and Environmental Protec-
tion Agency agree to modify existing procedures concerning
the administration of the urban transportation and air quality
planning processes in nonattainment areas as follows:
DOT and EPA regional/division offices will have the opportu-
nity for joint review of and concurrence in the Unified Work
Program (UWP) required pursuant to paragraph 450.114 of
the Joint Planning Regulations (23 CFR 450), to ensure that
adequate air quality planning tasks are included in the planning
programs. Any disagreements at the regional level shall be re-
ferred to the DOT Secretary for resolution. Before making his
final decision on the UWP, the Secretary will consult with the
EPA Administrator and will notify EPA of the disposition of
its Comments, with appropriate supporting materials. In addi-
tion, where an MPO has failed, without adequate reason, to
carry out the analysis or other activities committed in its
Unified Work Program, DOT will prescribe conditions which
will require specified remedial actions to be taken in order to
correct the identified failure in the UnifIed Work Program.
DOT and EPA will develop in the near future a document
identifying appropriate categories of remedial actions.
DOT and EPA regional! division offices will have the opportu-
nity for joint review of transportation plans (including TSM
48

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elements) in nonattainment areas required pursuant to para-
graph 450.116 of the Joint Planning Regulations, to ensure
that air quality considerations are adequately addressed. DOT
and EPA will consult with the planning agency on how air
quality related planning deficiencies will be corrected. DOT
will also explicitly consider EPA comments in taking subse-
quent actions on program approvals and will notify EPA of
the disposition of its comments, with appropriate supporting
materials.
DOT and EPA regional/division offices will have the opportu-
nity for joint review in connection with the annual planning
certification required pursuant to paragraph 450.122 of the
Joint Planning Regulations, on the adequacy of the planning
process to address air quality considerations. DOT and EPA
will consult with the planning agency on how air quality re-
lated planning deficiencies will be corrected. DOT will also
explicitly consider EPA comments in making any certification
decisions and will notify EPA of the disposition of its com-
ments, with appropriate supporting material.
DOT and EPA regional 1 1 division offices will have the opportu-
nity for joint review of the Transportation Improvement Pro-
grain (TIP) and its annual element required pursuant to para-
graph 450.118 of the Joint Planning Regulations for consist-
ency with the air quality elements of the transportation plan
and/or the SIP. DOT will explicitly consider EPA’s comments
in program approvals, and will notify EPA of its disposition
of the comments. If EPA disagrees with the disposition of its
comments, the-procedures for resolution set forth in Adden-
dum I to this memorandum will be followed.
DOT and EPA regional! division offices will have the opportu-
nity for joint review of the revised SIPs, for compliance with
the objectives of statutes administered by DOT (e.g., Title 23
USC and the Urban Mass Transportation Act) to provide for
mobility and for safe and efficient transportation. EPA will
explicitly consider DOT comments in approving or disapprov-
ing SIP revisions, and will notify DOT of its disposition of the
comments, with appropriate supporting materials. If DOT dis-
agrees with the disposition of its comments, the procedures
for resolution set forth in Addendum 2 to this memorandum
will be followed.
DOT and EPA agree to work toward greater coordination in
the administration of their respeceive grants for local planning
activities by including these grants in the UWP, to ensure that
such grants support effectively the related objectives of both
agencies while avoiding duplication and overlapping planning
activities.
DOT and EPA will take appropriate steps to alter their
existing internal procedures and to issue a joint appendix to
the existing transportation planning regulations to implement
the above understandings.
DOT and EPA agree to consult one another in the develop-
ment of criteria and procedures required by Section 176 of the
Clean Air Act, including insuring that all major capital im-
provement projects are consistent with the SIP.
Signed in Washington, D.C. this 14th day of June, 1978.
Department of Transportation
By: Brock Adams
Environmental Protection Agency
By: Douglas Costle
Addendum I
If the EPA Regional Administrator disagrees with the disposi-
tion of his comments by DOT, he will so notify the DOT
Regional! Division Administrator within seven days. In such a
case, the DOT Regional/ bivision Administrator will not ap-
prove the element or elements of the TIP in disagreement untiI
so advised by headquarters.
Within 30 days after the EPA Regional Administrator noti-
fies DOT of his disagreement, the EPA Administrator will
notify the Secretary of Transportation if the EPA Administra-
tor disagrees with the DOT field staff disposition of EPA
comments, and the reason for the EPA Administrator’s dis-
agreement.
If such notification is received within 30 days, the Secretary
of Transportation will carefully consider the EPA Administra-
tor’s views and in the event of disagreement will notify the
EPA Administrator of the disposition of his comments, with
appropriate supporting materials before making his decision.
Addendum 2
If the DOT Regional! Division Administrator disagrees with
the disposition of his comments by EPA, he will so notify the
EPA Regional Administrator within seven days. In such a
case, the EPA Regional Administrator will not approve the
SIP until so advised by headquarters.
Within 30 days after the DOT Regional! Division Adminis-
trator notifies EPA of his disagreement, the Secretary of
Transportation will notify the EPA Administrator if the
Secretary of Transportation disagrees with the EPA field staff
disposition of DOT comments, and the reason for the
Secretary’s disagreement.
If such notification is received within 30 days, the EPA Ad-
ministrator will carefully consider the Secretary of Transporta-
tion’s views and in the event of disagreement will notify the
Secretary of the disposition of his comments, with appropriate
supporting materials before making his decision.
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Appendix C
Community Conservation Guidance
Preface
This Community Conservation Guidance provides implement-
ing procedures for an important aspect of several of President
Carter’s policy initiatives, including his “urban policy”, energy
policy, and his policy of targeting federal assistance to those
areas and people that need them most. This guidance is pre-
dicated on the belief that public and private investment ought
to build upon existing resources to the greatest extent possible
in order to avoid unnecessary and costly duplication and
waste.
It is critically important that federal policies, grants, and
decisions not have unintended effects of eroding existing com-
mercial centers whether they be located in center cities or the
suburbs or rural areas. Moreover, federal programs should
not work at cross-purposes with each other in achieving the
national goals of the President’s Partnership to Conserve
America’s Communities. State and local leaders are virtually
unanimous in recommending that there be a process through
which officials can insure that federal policies and practices
will be reviewed when there is strong reason to believe that
such policies and practices will erode existing community re-
sources and investments, wherever they are located.
The Conservation Guidelines provide such a process without
creating any new regulations or additional bureaucracy. There
will be no excessive delays, extra staff requirements or paper-
work associated with this guidance. In fact, the process out-
lined is characterized by rapid review, consultation, and deci-
sion-making without prejudgement in those instances in which
(a) a private development is being significantly aided by federal
actions or monies, and (b) a local community identifies in as
much detail as possible how such federal actions or monies
will result in damage to existing commercial areas.
The Community Conservation Guidance is not intended to
delay or prevent any specific industry, type of development, or
group from pursuing its legal and private economic purposes.
Rather, it is a specific example of the implementation of the
Carter Administration’s policies and goals for the efficient and
effective operation of federal programs.
Background
President’s Partnership to Conserve America’s
Communities
Guidance provided in this memorandum should be understood
in the context of the many actions which have been taken to
carry out the President’s numerous policy commitments to re-
duce or eliminate federal actions which contribute to un-
planned urban sprawl; to conserve energy; to target limited
funds; and to encourage federal actions which help strengthen
urban area economies and their downtown areas. These ac-
tions include the four Executive Orders issued by the Presi-
dent on August 16, 1978, and the numerous pieces of legisla-
tion proposed to the Congress during the last two-and one-
half years, all associated with the President’s “urban policy.”
Several agencies, consistent with the thrust of the President’s
Executive Order 12074 have agreed to subject their major pro-
grams and activities to ommunity impact analyses prior to
initiating them in order to avoid inadvertent possible negative
impacts on cities and their residents. These analyses will cover
the effect of federally-assisted projects on central cities and
surrounding communities and will result in greater consistency
between federal aid and national policies.
Introduction
Initiatives to Strengthen Existing Business Districts
Healthy existing commercial areas are essential to a commu-
nity’s overall well-being. As commercial centers, they are vital
sources of jobs, goods and services and tax revenues. Histori-
cally, Congress and the Executive Branch have made signifi-
cant commitments to help localities preserve and strengthen
their present commercial areas. President Carter’s policy initia-
tives in economic and community development renew and re-
inforce that commitment.
Federal efforts to assist in the revitalization and growth of
older commercial areas have ranged from subsidizing the
development of, or improvements to, costly infrastructure to
providing loan guarantees and grants for the development or
rehabilitation of commercial areas and establishments. They
have included activities aimed at eliminating traffic congestion
and expanding transportation options, reducing environmental
and safety problems, and actions to increase employment and
training assistance to private sector businesses to hire the
structurally unemployed.
Part I: Strengthening Older Commercial Areas
This Administration, consistent with the President’s New Part-
nership to Conserve America’s Communities, is committed to
help older distressed areas (whether city, town, or suburb) pre-
serve and protect their investment in existing commercial
areas. As relevant, it is resolved to assist all communities, in
partnership with all levels of government and the private sec-
tor, enhance the economic vitality of older commercial, cul-
tural, service and job needs of urban residents.
To improve this Administration’s ability to encourage,
through appropriate federal action, the development and/or
redevelopment of healthy older commercial areas:
• The President’s Interagency Coordinating Council (IACC)
will encourage closer cooperation with respect to federal
programs directed at helping revitalize older commercial
areas. Agencies will be asked to work together to (a)
simplify current guidelines governing economic and com-
munity development assistance programs in order to
improve their responsiveness to locally defined needs;
and (b) facilitate strategic use of economic and com-
munity development programs in order to build public/
private partnerships directed at older commercial area
revitalization.
• State, areawide, and local governments will be encouraged
to use available federal technical and planning assistance
programs to develop comprehensive policies and growth
strategies responsive to the overall revitalization needs of
existing older commercial areas.
• Federal agencies should review their present policies, proce-
dures and regulations for the purpose of identifying which of
their key policies, programs and activities now provide (and
could provide with revisions) direct and/or indirect assistance
to older commercial areas for revitalization needs. Agencies
should change their policies and programs, if necessary, to
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permit a more effective and s rategic response to such revi-
talizatton needs.
• Each agency administering programs relevant to revitaliza-
tion of older commercial areas and central business districts
will be asked to consult on a continuing basis with relevant
private sector and public interest groups, as well as with state
and local governments in order to improve the administra-
tion of their programs.
Part II: Community Conservation
As indicated in the President’s national policies, unplanned
sprawl can often be wasteful of our Nation’s resources. It re-
quires heavy expenditures of scarce public resources for often
under-utilized infrastructures; it consumes valuable land; and it
leads to the wasteful use of limited energy resources. It can
weaken the economic, social and environmental health of exist-
ing communities.
Federal as well as state and local actions have sometimes
unintentionally reinforced or supported unplanned sprawl and
related decentralizing trends. And, while most large commer-
cial developments on the fringe of our urban areas have
responded well to the needs of a growing population, some
have drained economic vitality from existing business districts
in small, medium, and large communities. This can create en-
vironmental problems as well as contribute to a reduction of
jobs and services available to center city populations, particu-
larly low-moderate income and minority households.
The primary objective of the guidelines enumerated below is
to encourage, through appropriate federal, state and local ac-
tion, the targeting of limited resources on the redevelopment
andJ or development by the private sector of older commercial
areas. In order to accomplish this, they are aimed at discourag-
ing major federal actions that will directly lead to the con-
struction of those, and only those, large commercial develop-
ments that clearly and demonstrably weaken existing commu-
nities, particularly their established business districts. Federal
actions, where relevant, should help assure the location of
large commercial developments in areas consistent with state,
areawide and local plans and the provisions of the President’s
Policy to Conserve America’s Communities.
To accomplish these goals, the Administration will under-
take the following steps:
• If the chief elected official of an affected community formal-
ly requests it,t federal agencies will prepare a community
impact analysis of pending federal actions 2 which might lead
I The formal request by local officials must, at a minimum, include the follow-
ing: ( I) a statement indicating why local officials are concerned with the fede-
ral action; (2) evidence of city! town council or, where relevant, county super-
visor or commission support; (3) a statement establishing the link between the
federal action and the development of the large commercial development; (4)
a statement describing the local officials’ perception of the effect the commer-
cial development will have on the business district; (5) a statement illustrating
local, public and private actions which have been taken, which are being
taken, and which will be taken to strengthen the economic vitality of existing
commercial areas; and (6) a statement indicating that local government has
sought to discuss or negotiate the concerns expressed with the applicant for
federal action which is in question. Conversely, an applicant who seeks to re-
spond to the possibility of negative community impact before beginning a pro-
ject can petition the governing body of the affected jurisdictions to request a
community impact analysis.
2 Action is defined in NEPA Regulations, 1508.17. “Actions” refer only to ac-
tions which will be approved and/ or initiated subsequent to the effective date
of the policy. It is not the intent of this policy to initiate community impact
analyses on approvals which have already been granted or on actions which
have already been initiated by federal agencies.
to a large commercial development inside or outside the
boundaries of the affected community. Such an analysis will
be prepared within 45 working days from receipt of the local
officials’ request.
• Community impact analysis should be directed at determin-
ing the consequences (positive and negative) 3 of the pending
federal action on the existing business districts of the com-
munities requesting it, as well as on the community itself. It
should also indicate the general impact of the pending federal
action on the surrounding metropolitan area and the area
where the federal action is to take place.
The community impact analysis should acknowledge, and not
duplicate, relevant and available local demographic, economic
and market studies. It should be considerate of the views of
appropriate local public officials, community groups and pri-
vate sector leadership, and where relevant, developers of
affected large commercial developments concerning, particular-
ly: (a) the effect of the pending federal action; (b) the econo-
mic health of the business district(s) of the community request-
ing the analysis; and (c) the willingness and desire of the public
and private sector from the community requesting the analysis
to work together to strengthen development and revitalization
opportunities in the existing business district(s).
• If the community impact analysis demonstrates that signifi-
cant negative consequences will result from the pending fed-
eral action, the federal agency responsible for the action
should consider modifications or mitigating options consis-
tent with relevant statutes, the Agency’s mission and the Pre-
sident’s national policies.
• As part of the President’s program to reduce paperwork and
to avoid burdening state and local officials and the private
sector with unnecessary red tape, community impact analyses,
when prepared, should be coordinated with the requirements
of NEPA regulations. 4 Whenever possible, the information
required to be compiled under 40 CFR S 1502 should be
utilized in preparing community impact analyses. t Similarly,
information used to compile Clearinghouse Community Im-
pact Analyses pursuant to Circular A-95 should be used
whenever possible in preparing community impact analyses
resulting from this policy.
Each federal agency will provide periodic reports to the
IACC descriptive of its performance with respect to implemen-
tation of the initiatives described in this memorandum.
3 Negaiive impact shall include, but not be limited to, the following (I) signifi-
cant loss of aggregate jobs; (2) significant reduction in tax base; (3) significant
loss of employment opportunities for minorities; and (4) significant impact on
strengthening population decentralization trends and increasing use of energy;
and (5) a significant adverse impact on future Cost and availability of retail
goods and services.
NEPA regulations and the reference to 40 CFR S 1502 refer to regulations
promulgated as a result of the National Environmental Policy Act, the Envi-
ronmental Quality Act of 1970, and related Executive Orders.
5 Although much of the information utilized in community impact analyses and
environmental impact statements will be the same, the community impact
analysis is not technically or legally an environmental impact statement since it
is prepared pursuant to this guidance, rather than pursuant to NEPA.
The White House
November 26, 1979
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Appendix D
Checklist for Review of
Transportation Portions of
1979 SIP Submissions
How to Use the Checklist
Applying this checklist will produce a detailed record of EPA’S
review of the transportation portion of 1979 SIP submissions.
Certain requirements which relate to both transportation and
non-transportation (such as definition of nonattainment areas)
have been included in both the transportation and non-trans-
portation checklists. However, certain items not related to
transportation (such as VOC regulations for 11 source catego-
ries) have not been included in the transportation checklist.
Therefore, both checklists should be used in reviewing the en-
tire SIP.
This checklist contains 19 major requirements. The first 18
requirements are taken directly from Table 1 of the EPA-DOT
Transportation-Air Quality Planning Guidelines. The identifi-
cation in parenthesis after each major requirement (e.g., A.3)
corresponds to the item in Table I of the Planning Guidelines.
Each major requirement contains one or more sub-elements
that provide for a more detailed review. Acceptable/deficient
judgments are required only for the major requirements.
Judgments on the adequacy of the sub-elements should contri-
bute to decisions about the approvability of major require-
ments. A summary table of major requirements is provided.
The detailed checklist [ should containi the following columns:
• Criteria for Transportation Planning - List of major review
requirements followed by sub-elements.
• EPA review - identification of EPA reviewer.
• A/D - Acceptable! Deficient checks for major elements.
• Location in SiP - Identifies location of information in the
SIP (e.g., volume, pages).
• Comments - Reviewer comments (e.g., actions required to
correct deficiencies; inapplicability of specific requirements
for particular areas).
One possible review procedure could include these steps:
• Read through the submission quickly to become familiar
with the format and general contents. Read both the transpor-
tation and non-transportation portions of CO and ozone
submissions.
• Fill in the column “Location in SIP” for each item on
the checklist. This will identify the location of information
and information not submitted. The State and lead agency
should be informed immediately if required information
is absent and requested to submit the information as
quickly as possible.
• Go through the checklist to review each item in detail.
Keep a detailed written record of your review using addi-
tional pages to supple*ient column space where necessary.
When deficiencies are identified, the State and lead agency
should be notified immediately rather than after the entire
review is complete. Regional Offices should make the neces-
sary efforts to have the deficiencies remedied.
• Sumarize review results on the “Summary Evalua-
tion” provided at the beginning of the detailed checklist.
Detailed Checklist
Criteria for Transportation Planning
Definition of nonattainment area and geographic area covered
by transportation control. (A. 1)
• Does the submission contain a description of the geo-
graphic area for transportation controls?
• Is the nonattainment area used for transportation
planning consistent with that used for stationary source
planning?
Accurate, comprehensive, and current emissions inventory.
(A.2)
• Does the submission contain a current (base year) emis-
sions inventory for:
hydrocarbons
carbon monoxide
• Is the base year for the transportation inventory the
same as for stationary sources?
hydrocarbons
carbon monoxide
• Are the latest EPA emission factors used?
• Are all parameters and assumptions (such as % cold
start) documented?
• Is the transportation source inventory fully integrated
with the stationary source inventory?
hydrocarbons
carbon monoxide
Estimation of emission reductions needed to demonstrate
standard attainment by 1982 and 1987 (including emission
growth projections) (A.3)
Determination of whether federal new car standards and
stationary source controls demonstrate attainment by 1982.
Demonstration of need for attainment deadline extension to
1987 (A.4)
• Does the submission contain documentation of current
1982 and 1987 travel demand and VMT estimates?
• Does the submission contain a demonstration that the
NAAQS for oxidants cannot be met by 1982 with application
of all reasonable measures?
Is there a single demonstration that combines mobile and
stationary source emissions and uses the same oxidant
design value?
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Are estimates of emission reductions from measures which
can be implemented by 1982 included?
Are modeling procedures and assumptions documented?
• Does the submission contain a demonstration that the
NAAQS for carbon monoxide cannot be met by 1982 with
application of all reasonable measures?
Is the demonstration based on evaluation of CO hotspots?
Are estimates of emission reductions from measures which
can be implemented by 1982 included?
Are the modeling procedures and assumptions documented?
• Does the submission contain estimates of emission
reduction potential from reasonably available measures?
Are modeling techniques (air quality and travel demand)
documented?
Are carbon monoxide impacts based on an evaluation of
hotspots?
Are emission reduction estimates reasonable?
Are 1982 and 1987 emission reduction estimates included?
• Does the submission take credit for measures imple-
mented after August 7, 1977? If so, is there any documenta-
tion that the emission reductions actually occurred?
• Does the submission contain a complete package of
adopted measures and measures for future study which,
when added to stationary source measures, demonstrates
attainment by 1987?
oxidants
carbon monoxide
• Are emission growth projections to 1982 and 1987 specifi-
cally quantified?
oxidants
carbon monoxide
Designation and certification of a lead agency for nonattain-
ment areas. (8.1)
• Has a lead agency been designated?
• Has the EPA Regional Office concurred?
• Does the submission document the designation process?
Identification of agency tasks and responsibilities. (B.2)
• Have initial emission reduction targets been assigned to
stationary and mobile sources?
• Is there a process for periodic review of the targets?
• Does the submission contain a description of the process for
determining consistency! conformity?
• Does the submission contain a description of the 3C
process in the region?
• Does the submission contain a description of the project
programming process in the State?
• Does the submission contain memoranda of understanding
or other informal but written joint acknowledgment of
understanding of reponsibilities among State and local
agencies participating in the planning process?
Schedule for comprehensive analyses of alternatives and demon-
stration that analysis is underway. (B.3)
• Does the submission contain a description of the alternative
analyses as it appears (or will appear) in the UPWP?
• Does the submission contain documentation that the alterna-
tive analyses has begun? If not, is there a schedule showing
when the analyses will begin?
• Does the submission show that the analyses will be complete
by July 30, 1980? If not, is there justification for completion
at a later date?
Schedule for adoption of reasonably available measures. (B.4)
• Does the submission contain a commitment to study addi-
tional measures?
• Is there a schedule for study, adoption and final
implementation?
• List all committed studies in Table 1 along with their sche-
dule for eventual implementation and indicate whether
commitment is adequate.
Are the studies included as part of the UPWP?
If not, is there a schedule showing when the
UPWP will be formally modified?
Commitment to justify decision not to adopt difficult, but
reasonably available measures. (B.5)
• Does the submission contain a commitment to justify deci-
sions not to adopt difficult but reasonably available
measures?
• Do UPWP work items for study of specific measures in-
clude as end products either a recommendation to imple-
ment measures or justification not to implement?
Process for public interest group and elected official consul-
tation and involvement in: defining transportation-air quality
issues, establishing the planning process, development and
analysis of alternatives. (8.6)
• Does the submission contain a description of the process for
public interest group and elected official consultation as it
appears (or will appear) in the UPWP? Is this process com-
parable to that in the EPA-DOT Planning Guidelines?
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ldentification of estimated financial and other resources
necessary to carry out the process described by the EPA-DOT
Transportation-Air Quality Planning Guidelines. A commit-
ment to the first year of the process should be demon-
strated in the UPWP. (B.7)
• Has the UPWP been formally modified to include all trans-
portation-air quality planning activities?
• If not:
Is there a schedule for revision of the UPWP?
Does the submission contain a description of work items
which will appear in the UPWP?
Does the work program identify all federal, State and
local agencies participating in funding the air quality
planning activities and the amount of funds each agency
is committing to the process during FY 79?
• If the UPWP has not been formally modified: • Does the work program contain all elements specified in the
Does the submission contain the information which will EPA-DOT transportation-air quality planning guidelines?
appear in the UPWP?
Is there a schedule showing when the UPWP will be formally Emission reduction estimates for adopted measures and! or
modified? packages of measures. Rough estimates of annual emission re-
ductions through 1987 for packages of measures currently
being developed and analyzed. (C.2)
• Does the submission contain an estimate of the cost and
manpower requirements to carry out the process?
• Does the submission identify measures or packages of mea-
sures for future study?
• Does the submission contain annual emission reduction esti-
mates and provide a Reasonable Further Progress schedule
which combines stationary and mobile source emissions?
Preliminary identification of analytical methodologies for de-
• Was the transportation portion of the plan included in the pub- termining air quality, travel, economic, energy, social, etc. ef-
lie hearings held by the State? fects of plan provisions. Summary of public comment on such
methodologies. (C.3)
• Was the submission reviewed by the A-95 agency?
• Does the plan contain an evaluation of health, welfare, econo-
mic, energy and social effects?
• Does the plan identify methods to be used in future planning
• Has the UPWP been modified to include provisions for pro- evaluations of air quality, etc. impacts?
gress reporting?
• Does the plan contain a summary of public comment on these
• If the UPWP has not been modified: proposed methods?
Is there a schedule for modification?
Is the information which will appear in the UPWP included? Commitment to: (I) accelerate implementation of transportation
improvements in current or recent annual element, (2) incremental
Schedule of activities leading to implementation of 1/ M. (B. 10) phase-in of additional reasonable measures. (C.4)
• Is there a request for an extension of the attainment date for •
CO or oxidants beyond 1982? If so, does the submission
contain a commitment to an Inspection and Maintenance
Program which meets the requirements of the July 17, 1978
memo from David G. Hawkins to Regional Administrators,
“inspection and Maintenance Policy’?
Commitment to use (insofar as is necessary) available grants
and funds to establish, expand or improve public transporta-
tion measures to meet basic transportation needs as expedi-
tiously as practicable. (B. II)
Review of commitments to implement measures.
On Table II list all measures for which there is a commit-
ment to implement, along with the air quality impact, key
interim steps and dates leading to implementation, and the
expected date of implementation and your determination
of whether the commitment is adequate.
Does the submission propose to delete any transportation
measures from the currently approved SIP? If so, list the
measures proposed for deletion on Table Ill and indicate
whether the deletion can be approved.
• Is there a request for an extension of the attainment date for CO Excerpted from the EPA “Checklist for Review of Transportation
or oxidants beyond 1982? If so, is this commitment included in Portions of 1979 SIP Submissions, “September 21, 1978.
the submission?
U PWP air quality-related transportation planning tasks being
performed by each agency during FY 79. (C.l)
• Does the submission contain documentation showing that the
UPWP has been modi%ied to include air quality planning activi-
ties?
• Does the submission show that funds have been committed
to at least the first year of the process in the UPWP? If not,
is there a schedule for obtaining funding commitments?
Evidence that the SIP was adopted by the State after reasona-
ble notice and public hearing. (B.8)
Provisions for progress reporting throughout the planning and
implementation period. (B.9)

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Appendix E
Glossary
3C Planning Process
The “comprehensive, continuing and co-
operative” transportation planning
process required by the Federal-Aid
Highway Act of 1962. 42 U.S.C. §134
(1978 pamph.).
A-95 Clearinghouse Review
Established by Office of Management and
Budget (0MB) circular No. A-95. This
review facilitates cooperation between
federal agencies and state and local
governments in the evaluation, review, and
coordination of all federal assistance
programs and projects.
Acid Rain
Through a series of complex chemical
reactions in the atmosphere pollutants
such as NOx and SOx can be converted
into acids, which may return to earth as
either rain or snow. This acidic precipita-
tion is commonly referred to as acid rain.
Action Plan
A document prepared by each State which
describes the organization to be utilized
and the processes to be followed in the
development of federal-aid highway
projects.
The Administrator
Refers here to the chief officer of the U.S.
Environmental Protection Agency. His
duties include the promulgation of regu-
lations and the enforcement of the Clean
Air Act.
Air Quality Control Region (AQCR)
Because air pollution does not conform to
political boundaries, the Clean Air Act
empowered EPA to divide the country into
AQCR5 to facilitate air quality planning.
CAA §l07(bX2), 42 U.S.C. §7407(bX2)
(1978 pamph.).
Ambient Standards
Ambient standards measure the overall
quality of the air we breathe regardless of
where the pollution comes from. The term
“standard” is a bit misleading, because
ambient standards are not legally enforce-
able in and of themselves. Rather they set
the ultimate goals. Ambient standards may
be contrasted with emission standards
which set limits on the pollution which
may be emitted from specific, individual
sources.
Annual Element (AE or TIP! AE)
A list of transportation projects for im-
plementation during the first year of the
Transportation Improvement Program
(TIP). It includes all highway and public
transportation projects for urban areas.
Anthropogenic
Describes those pollutants which are
created by man. Distinguished from
naturally occuring or nonanthropogenic
pollutants.
Appropriation
An act of Congress which makes funds
available for expenditure with specific
limitations as to amount, purpose, and
duration. An appropriation act permits
money previously “authorized” to be
obligated (spent).
Attainment Areas
Those areas which have achieved NAAQS.
PSD rules apply to these areas to insure
that the good air quality is maintained.
These areas are distinguished from non-
attainment areas.
Attainment Deadline
The deadline by which the Clean Air Act
requires States to have achieved NAAQS.
Attorneys’ Fees
Traditionally each party in a lawsuit
bears his! her own litigation expenses,
regardless of the outcome of the suit. The
Clean Air Act, however, contains
provisions for the awarding of attorneys’
fees and other costs of litigation (such as
expert witness fees) of one party to the
other party at the judge’s discretion. This
enables citizens to recover their costs if the
action they bring is meritorious. On the
other hand, there is a danger that costs
defending the suit might be assigned to the
citizens if the judge determines that the
suit was brought frivolously. CAA
§ 304(d), 307( 1), 42 U.S.C. § 7604(d),
7607(f) (1978 parnph.).
Authorization
An authorization act sets an upper limit
on the amount of money which may be
appropriated to an agenc y. The authoriza-
tion itself does not permit the agency to
obligate (spend) the money. Only when a
subsequent appropriations act is passed
may funds be obligated.
Background
Not all pollutants are caused by man;
certain low levels of air pollutants occur
naturally. These nonanthropogenic (non-
manmade) pollutants make up what is
termed the background. For example, if
man completely stopped all polluting
activities, the background level of
naturally occuring ozone would be .04
ppm. The NAAQS level is set well above
that at .12 ppm. Polluted urban areas to-
day often experience levels at 3.0 ppm.
Basic Transportation Needs (BTN)
The Clean Air Act requires States which
will not be able to meet NAAQS by 1982 to
adopt comprehensive measures to improve
public transit to a level which meets “basic
transportation needs.” This is interpreted
as that level which provides.an attractive
alternative to the automobile. CAA
§*1 l0(a)(3)(D), (cX5XB), 42 U.S.C.
§ 74 l0(aX3XD), (cX5XB) (1978 pamph.).
Best Available Control Technology
A stationary source requirement under
the Clean Air Act. Major new (and modi-
fied) stationary sources of pollution
locating in PSD areas are required to apply
“Best Available Control Technology”
(BACT) to reduce air pollution from both
criteria and hazardous pollutants. CAA
§ l65(aX4), 169(3), 42 U.S.C.
§*7475(aX4), 7479(3) (1978 pamph.). The
determination of what level of control con-
stitutes BACT will be made on an ad hoc
basis for each new source, but in no event
will BACT be less stringent than NSPS or
NESHAP. 39 Fed. Reg. 42510 (1974), 40
C.F.R. Part 52.2l(dX2Xii).
Bubble Policy
This policy is similar in concept to the
offset policy in that it balances pollution
from one source against compensating
reductions made elsewhere. However, the
offset policy applies to new sources in
nonattainment areas, while the bubble
policy applies to existing sources in these
areas. The term “bubble” derives from
the concept of placing an imaginary bub-
ble over a plant and determining compli-
ance on the basis of total plant emissions.
Thus, placing controls irs excess of what
is required in one part of the plant may
compensate for placing less control else-
where. In so doing the firm may be able
to achieve the same emission improve-
ments more economically.
Budget (or Contract) Authority
Empowerment by the Congress which
allows federal agencies to incur obliga-
tions to spend or lend money. This em-
powerment is generally in the form of ap-
propriations. However, in the highway
program it is in the form of “contract
authority.” Budget (or contract) authority
permits agencies to obligate funds which
were previously “authorized.”
Capital Costs
That monetary cost generally associated
with initiating a particular transport
operation including, for example, acquisi-
tion of land, construction, and purchase of
fleet, but not including operating costs or
maintenance.
Carbon Monoxide
A colorless, odorless, very toxic gas
produced by any process that involves the
incomplete combustion of carbon con-
taining substances, One of the major air
pollutants, it is primarily emitted through
the exhaust of gasoline powered vehicles.
Certification of the Planning Process
Recognition by the Federal Highway
Administration and the Urban Mass
Transportation Administration that trans-
portation planning in urbanized areas is
being conducted in a “continuous, co-
operative, and comprehensive” fashion
(the 3C process). Such certification is
required for federal financial participation
in transportation projects.
Citizen Suit
A provision snler the Clean Air Act (and
other legislation) enables private citizens
to bring a legal action (called a citizen suit)
to enforce the Act. CAA §304(a), 42
U.S.C. §7604(a) 1978 pamph.).
Clean Air Act (CAA)
The piece of legislation passed in 1970 and
amended in 1974 and 1977 which provides
the basis for federal control of air pollu-
tion. Pub. L. No. 91-604, 84 Stat. 1676
(1970), Pub. L. No. 93-319, 88 Stat. 246
(1974), Pub. L. No. 95-95, 91 Stat. 685
(1977), Pub. L. No. 95-190, 91 Stat.
1401-02 (1977) (technical and conforming
amendments).
Citations to the Clean Air Act are some-
times confusing. The 1970 Act, which
provided the basic framework of current
air quality law, was officially titled The
Clean Air Act Amendments of 1970. How-
55

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ever, it is usually referred to as the Clean
Air Act (CAA), the 1970 Act or simply the
Act. It was modified extensively by the
Clean Air Act Amendments of 1977,
referred to as the 1977 Amendments or
simply the Amendments. Depending on
context, the terms Clean Air Act and the
Act may refer either to the 1970 Act alone
or to the current body of law made up of
the 1970 Act as modified by the 1977
Amendments.
Specific sections in the Act may be
referenced either by the section number
(“f’) within the original 1970 Act or the
section number within the United States
Code or U.S.C. (a compilation of all
federal statutes). One final complication:
the 1977 Amendments changed the num-
bering system for the Act within the U.S.C.
Thus, the reader may find the requirement
that States submit a State Implementation
Plan cited in three ways: as §110 of the
Act, as §l857c-5 of the U.S.C. (prior to
1977) and as §7410 of the U.S.C. (sub-
sequent to 1977).
Code of Federal Regulations (C.F.R.)
An annual compilation of all federal
regulations.
Comments
During the rulemaking process, federal
agencies are required to allow the public
to comment on proposed actions (such as
approval of a SIP or the imposition of
sanctions). Usually a period of 30 or 60
days is allowed for comments to be sub-
mitted. No particular form is required for
these comments.
Community Impact Analysis
This is an analysis prepared upon local
request by federal agencies pursuant to
the President’s Community Conservation
Guidance of November 1979 (See Appen-
dix C). It is designed to assess the impact
of federal support (primarily highway
and sewer infrastructure) for proposed
suburban mall construction on existing
business districts. If it demonstrates that
significant negative consequences are
likely to result from suburban mall con-
struction, the federal agencies are re-
quired to reconsider their position with
regard to government support for the
mall.
Criteria Pollutants
These are the pollutants for which
National Ambient Air Quality Criteria
have been established by EPA. EPA has
established criteria for seven pollutants:
sulfur dioxide (S02), nitrogen dioxide
(N02), carbon monoxide (CO), non-
methane hydrocarbons (HC), photo-
chemical oxidants measured as ozone,
(Os), lead (Pb), and particulate matter
(TSP for “total suspended particulates).
Dispersion
Refers to the technique of “reducing”
pollution simply by dispersing it over a
large area rather than actually reducing
the total amount of pollution. (This may
be accomplished, for example, by placing
taller chimney stacks on industrial
sources.) It was once thought that if the
pollution was spread thin enough, its
hazard would be eliminated; but
phenomena such as “acid rain” demon-
strate that dispersion spreads the problem
around rather than eliminating it.
Dispersion Modeling
A sophisticated, computerized method of
calculating the amount of pollution reduc-
tion necessary to achieve NAAQS. Dis-
persion modeling differs from simpler
models in that it takes into account the
location and timing of the pollution.
Element
An element is a part of a document. A SIP
will be divided into elements for each area
within the State. For example, the
Colorado SIP will contain a Denver
Element. The Denver Element may, in
turn, be divided into elements for each of
the major requirements of the Act, such as
TCP element.
Emission Inventory
This is a summary of all emissions of
pollutants measured within a given
AQCR. It is an assessment of the current
situation against which the area develops
its SIP. It is required by CAA * I 72(bX4),
42 U.S.C. §7502(bX4) (1978 pamph.).
Emission Limitations
This term is generally used with reference
to stationary rather than mobile sources.
It is an inclusive term referring to any type
of control or strategy to reduce emission of
air pollutants. The Clean Air Act
empowers the Administrator to establish
emission limitations (in the form of
specified control technologies) for new
stationary sources (42 U.S.C. §7411, CAA
§111) and requires states to establish
additional emission limitations. (42 U.S.C.
§74 10 (aX2XB), CAA §110 (aX2XB).
Emission Standards
This is a specific type of emission limita-
tion which places a limit on the amount
of a particular pollutant which may be
emitted by sources. The Clean Air Act
empowers the Administrator to establish
emission standards for hazardous air p01-
lutants (42 U.S.C. §74 12, CAA §112) and
for mobile sources (CAA §202, c i seq.. 42
U.S.C. §7521, ci. seq.. (1978 pamph.).
Environmental Impact Statement
(EIS, DEIS & FEIS)
A detailed statement outlining the
impacts on the human environment of all
major federal projects with significant
impacts. Required pursuant to the
Environmental Policy Act (NEPA). 42
U.S.C. 0*4321 ci seq. (1978) Also called a
a “Section 102 Statement” in referencee
to the particular section of NEPA that
requires preparation of the statement.
Agencies first publish a draft EISI
for public comment. The DEIS is
followed by a final EIS (FEIS).
Expenditures (Outlays)
A term signifying disbursement (spending)
of funds by a federal agency.
F.2d
An abbreviation for Federal Reporier,
Second a series of books containing cases
decided in the federal Courts of Appeals.
Fed. Supp.
An abbreviation for the Federal Supple-
men:, a collection of cases from the
federal District Courts.
Federal-Aid Highway Act
Actually a series of acts, passed every two
years beginning in 1950, and more recently
called the Surface Transportation Assistance
Act. Codified at 23 U.S.C.
Federal-Aid Highway Program
Those programs for the construction of
federal interstate, primary, secondary, and
urban systems highways. Other federally-
supported highway programs, such as
Forest Highways, Highway Beautifica-
tion, etc., are not included under this term.
Federal-Aid Systems
The four Federal-Aid Systems are the
interstate system, the primary system, the
secondary system and the urban system.
Federal Highway Administration
(FHWA)
The agency within the Depaitment of
Transportation which is given respon-
sibility for federal highways.
Federal Register
A daily publication of the federal govern-
ment which lists all the proposed and final
regulations of all federal agencies. These
regulations are later included in the
Code of Federal Regulations.
Fiscal Year
The time period beginning October I and
ending September 30 of the subsequent
calendar year. Fiscal years are designated
by the calendar year in which they end.
Hazardous Pollutants
Hazardous pollutants are pollutants
which are shown to result in an increase in
mortality and serious illness, but for which
no NAAQS have been established. They
include asbestos, beryllium, arsenic,
mercury and vinyl cloride. EPA establishes
emission standards for these pollutants
which apply to all industrial sources.
However, unlike the criteria pollutants,
the States do not develop plans to reduce
hazardous pollutants as part of their
SIPs. CAA §112,42 U.S.C. §7412
(1978 pamph.). 40 C.F.R. Part 61
(1978).
Headway
The frequency of transit service on any
given route, calculated in terms of time
elapsed between service at any one station.
Heavy Rail
See Rapid Rail.
High Occupancy Vehicle Lanes
(HOV Lanes)
Special lanes on urban highways
designated for use only by carpools and
buses (high occupancy vehicles).
56

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Hydrocarbon
Any of a vast family of compounds con-
taining carbon and hydrogen in various
combinations. They are precursors to the
production of photochemical oxidants.
Inspection and Maintenance (1/ M)
A requirement under the Clean Air Act
that automobiles be periodically
inspected to insure that their emission
control devices remain functional. CAA
§ 172(bXlIXB),42 U.S.C. §7502(b)(11)
(B) 1978 pamph.).
Inversion
The phenomenon of a layer of cool air
trapped by a layer of warmer air above it so
that the bottom layer cannot rise. This
causes a serious problem in polluted
areas because the contaminating sub-
stances cannot be dispersed.
Land Use Patterns
The trends in land development which
result from certain infrastructure invest-
ments. For example, urban highways
facilitate low density suburban sprawl,
while subways encourage high density
development.
Light Rail (LRT)
Light rail transit is a mode of electric
train transportation utilizing track laid
directly on the streets, rather than in sub-
way tunnels and elevated structures (as in
the more efficient but also more costly
“rapid rail’ .
Linear Rollback
This is the simplest of all modeling tech-
niques for determining the amount of
pollution reduction necessary to achieve
NAAQS. The model assumes a given pro-
portion between amount of hydrocarbons
emitted and amount of ozone formed, and
does not take into account interactions
among pollutants and consequently under-
estimates the reduction in hydrocarbons
necessary to achieve the ozone standard.
Long Range Transport
Refers to the movement of air pollutants
across great distances.
Long-Range Transportation Plan
A map showing transportation facilities
that are projected for the next 15-20 years.
It is the long range companion to the TIP.
Lowest Achievable Emissions Rate
(LAER)
This is a stationary source requirement
which applies to new sources in nonattain-
ment (dirty air) areas. CAA §*l7l(3),
173(2), 42 U.S.C. §j750l(3), 7503(2)
(1978 pamph.).
Metropolitan Planning
Organization (MPO)
The organization responsible for compre-
hensive transportation planning in urban
areas. MPOs frequently cross city and even
state boundaries and therefore rely on the
cooperation of several government bodies
for their effective operation. 23 U.S.C.
§134, 23 U.S.C. §l04(f)(3), and 49 U.S.C.
**1602(aX2), (cXl)l, 49 U.S.C. §1603(a),
and 49 U.S.C. §1604(g). In metropolitan
areas it usually serves also as the air quality
agency. CAA § 174,42 U.S.C. §7504(1978
pamph.).
Mobile Sources
Refers to transportation sources of
pollution (as opposed to stationary or
industrial sources).
Modal Split
A measure of the relative use of various
modes of transportation, e.g. the split
between use of highways and mass transit.
Mode
A particular system of transportation,
e.g., rail, automotive, or bicycle.
Modeling
Techniques for estimating the amount of
pollution reduction necessary to achieve
NAAQS. Models currently in use include
dispersion modeling, EKMA, and
rollback.
National Emission Standards for
Hazardous Air Pollutants
(NESHAP)
A stationary source requirement under
the Clean Air Act. These are emission
limitations applicable to specified haz-
ardous pollutants emitted from both new
and existing stationary sources.
National Environmental
Policy Act (NEPA)
The Act which requires the preparation
of an EIS. 42 U.S.C. § 432l, et. seq.
(1978).
New Source Ban (NSB)
A ban on new stationary sources of
pollution went into effect on July 1, 1979
for those States which failed to submit an
approvable revised SIP by that time.
CAA § 1 lO(aX2XI), 42 U.S.C.
§74lO(aX2XI) (1978 pamph.).
New Sourc Performance
Standards (NSPS)
A stationary source requirement under
the Clean Air Act. These are minimum
national emission standards which apply
to specified categories of new (and
modified) stationary sources. NSPS apply
equally in attainment and nonattainment
areas. CAA §111, 42 U.S.C. §7411
(1978 pamph.). As of 1979 the Administra-
tor had promulgated NSPS for some two
dozen categories of sources.
Nitrogen Oxides
Pollutant gases formed from nitrogen
and oxygen in the atmosphere during the
operation of internal-combustion
engines.
Non-anthropogenic
Describes those pollutants which occur
naturally in the environment and make up
the “background” level of pollution.
Nonattainment Areas
These are areas which have failed to meet
NAAQS. They are required under the
1977 Amendments to submit revised SIPs
to achieve NAAQS by 1982 (or under
some circumstances by 1987).
Obligations
Commitments made by federal agencies to
pay out money, as distinct from the actual
payments, which are “outlays.” Gen-
erally, obligations are incurred after
the enactment of budget authority. How-
ever, since budget authority in the
highway program is in the form of contract
authority, obligations are permitted to be
incurred immediately after apportion-
ment.
Offset Policy
A new source locating in a nonattain-
ment area must (in addition to meeting
certain technological requirements) dem-
onstrate that the pollution which will re-
suit from its operation will be offset by
cleaning up or closing down existing
pollution sources in the area. The result-
ing offsets must be greater than the pol-
lution to be added by the new plant so
that a net improvement in emissions is
achieved.
Operating Costs
Costs incurred in running a trans-
portation system, e.g., labor and main-
tenance costs.
Ozone (03)
Part D
A pungent, colorless, toxic gas composed
of three molecules of oxygen. Although
ozone occurs as a natural phenonemon in
the stratosphere where it serves as a
protective shield against radiation, it
is a dangerous pollutant when found in the
air we breathe.
This refers to the portion of the Clean Air
Act added by the 1977 Amendments which
deals with the new requirements for
revision of SIPs.
Photochemical Oxidants
PPM
Those pollutants which are created in the
air from other chemicals in the presence
of sunlight. The most common (and most
easily detected) photochemical oxidant is
ozone. The NAAQS for photochemical
oxidants was recently changed to include
only ozone.
Parts per million.
Precursors
Chemicals which precede the formation of
pollutants in a chemical reaction. For
example, HC is a precursor of 03.
Prevention of Significant Deterioration (PSD)
Many parts of the country have air
quality which is better than national
standards. The prevention of significant
deterioration (PSD) requirements of the
Clean Air Act require that these clean
air regions maintain their purity rather
than slipping down to NAAQS levels.
Promulgate
When an agency issues a final deter-
mination in a rulemaking, it is said to
promulgate a regulation.
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?Tospectus
A document which outlines the scope of
the planning program, procedures to be
uSed in carrying out the elements of the
planning process, a breakdown of the
functional responsibilities of all
participating agencies, and a list of
products expected to be delivered by the
end of the program year in terms of major
milestones.
PS&E Approval
Approval of the Plans, Specifications and
Estimates for a federal-aid highway
project. This obligates federal funds for a
project and allows the state highway
department to let construction contracts
to bid.
Pub. L. No.
Public Law Number. Each act of Congress
is assigned a Public Law Number as soon
as it is signed into law. These laws are
first published in the Statutes at Large and
later codified (or organized) into the
Unued States Code.
Rapid Rail
Rapid rail transit is a mode of electric
train transportation which relies on track
laid in subway tunnels or on elevated
structures. It is distinguished from the
much less expensive “light rail”. Rapid
rail is sometimes referred to as “heavy
rail.”
Reasonable Further Progress (RFP)
— The i977 Amendments require each
revised SIP to assure gradual improve-
ment of air quality each year prior to the
attainment deadline. These incremental
gains are referred to as RFP. CAA
§ l7l(l), 172(bX3), 42 U.S.C. §47501(1),
7502(bX3) (1978 pamph.).
Reasonably Available Control
Measures (RACM)
RACM are measures aimed at reducing
air pollution from transportation sources.
All nonattainment areas are required to
revise their SIPs to include all such
measures which are reasonably available.
CAA §172(bX2), 42 U.S.C. §7502(bX2)
(1978 pamph.). These control measures
make up the Transportation Control Plan
(TCM) required by CAA * I 10(aX2XB),
42 U.S.C. §7410(aX2XB) (1978 pamph.).
RACM are distinguished from
“reasonably available control technology”
(RACT) which applies to stationary
sources.
Regulations
Agencies may be empowered under acts
of Congress to promulgate regulations
interpreting the laws. For example, the
Clean Air Act is a law passed by Congress
which created the concept of NAAQS.
But it is the Administrator of the EPA
who passes regulations designating certain
chemicals as criteria pollutants and
establishes air quality standards for them.
These regulations are Inst published in the
Federal Register, and later collected in the
annual Code of Federal Regulations.
Ru lem n nking
The process by which agencies promulgate
regulations is called ruleniiiking.
Rules Synonymous with regulations.
Section 134
Refers to section 134 of title 23 U.S.C.
(Federal-Aid Highway Act of 1962) in
which Congress declared that transporta-
tion planning be based on a compre-
hensive, continuing, and cooperative
(3C) process.
The Secretary
Refers here to the chief officer of the U.S.
Department of Transportation.
Standaed Metropolitan Statistical
Area (SMSA)
An SMSA defines the broad metropolitan
region (generally a city and its suburbs)
which make up an economically and
socially integrated unit. It is the unit
used in transportation planning which is
analogous (but not necessarily identical)
to the AQCR used in air quality planning.
Standing
Traditionally courts will not permit a legal
action to be brought by someone who is
not involved in the legal dispute (that is,
by someone who was not him! herself
“injured”). This has frequently made
it difficult for citizens to bring suit against
governments or polluters because the dis-
pute does not directly involve the citizen.
However, the Clean Air Act does away
with this requirement and permits a broad
range of citizen suits. CAA §304, 42
U.S.C. §7604 (1978 pamph.).
Stat.
This is an abbreviation for Statutes a:
Large, a cumulative collection of all acts
of Congress. Laws are first published in the
Statutes at Large, and later codified (or
organized) into the United States Code.
State Implementation Plan (SIP)
The Clean Air Act requires each State to
develop a SIP which outlines strategies
for attaining air quality standards
(NAAQS) within the State. The 1977
Amendments require nonattainment areas
to revise their SIPs.
Stationary Sources
Refers to industrial (rather than trans-
portation-related) sources of pollution.
Sulphur Oxides
Pungent, colorless gases formed
primarily by the combustion of fossil fuels.
Sulfur oxides may damage the respiratory
tract. They may be convened in the
atmosphere into acid rain.
Three-C Planning Process
See 3-C Planning Process.
Title
The term “title” may refer either to an
entire volume of the United States Code
or to a single chapter within an Act. (The
Clean Air Act, unlike many other laws, is
not divided into titles, but rather into
subchapters, parts and sections.)
Transferable Highway Projects
Proposed highway projects located in
urban areas whose funds may be
transferred at local request to public
transit projects.
Transport
This refers to the shifting of pollution
from its source to another area. Ozone
and particulate matter are subject to
long distance transport.
Transportation Control Plan (TCP)
The Clean Air Act requires a TCP as part
of the SIP. These transportation controls
are aimed at reducing transportation-
related emissions by discouraging private
use of the automobile. CAA § I lO(aX2XB),
42 U.S.C. § 7 4l0(aX2XB) (1978 pamph.).
The 1977 Amendments required that the
Transportation Control Plan (TCP) be
expanded to include all RACM. CAA
*l72(bX2), 42 U.S.C. §7502(bX2) (1978
pamph.).
Transportation Improvement Plan (TIP)
A document prepared by the MPO which
lists all highway projects planned for the
next three to five years. Those planned for
the upcoming year are included in the
“annual element” of the TIP.
Transportation System Management (TSM)
These are strategies for improving the
efficiency of existing roads and highways
without major new capital investment.
Trust Funds
Funds established by law to account for
receipts (money) which are held by the
Government and earmarked for specific
purposes and programs. These receipts are
not available for the general purposes of
the Government. The Highway Trust
Fund is comprised of receipts from
certain highway user taxes (e.g., excise
taxes on gasoline, rubber, and heavy
vehicles) and reserved for use for highway
construction and related purposes.
Unified Planning Work Program
(UPWP or UWP)
A document covering all work activities
of the State and local agencies involved
with the continuing transportation
planning process. Also known as the
Unified Work Program (UWP).
United States Code (U.S.C.)
A collection of all federal laws issued
annually. A similar collection is called
United States Code Annotated
(U.S.C.A.).
Urban Mass Transportation Administration
(UMTA)
The agency within the Department of
Transportation given responsibility for
urban mass transit.
Vehicle Miles Traveled (VMT)
A measure of the total amount of road
use for a particular highway or geo-
graphical area. This is a rough approxima-
tion of the pollution generated along a
particular corridor (but it fails to take
into account the fact that two short trips
produce more pollution than one long
one).
Volatile Organic Compounds (VOC)
These are precursors to photochemical
oxidants. There are numerous VOC which
contribute to the generation of photo-
chemical oxidants, but NAAQS have
been established only for the biggest
offender: hydrocarbons (HC). (In
chemistry, the term “organic” refers to a
compound containing carbon.).

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Appendix F
Post-I 982 Nonattainment States
Twenty-nine states shown in the map
(shaded area) have requested and re-
ceived extensions to 1987. These states
are required to implement inspection and
maintenance programs, to adopt
comi5rehensive measures to provide for
basic transportation needs, to analyze
and implement all reasonably available
transportation control measures, and to
establish a program for the alternatives
analysis of new sources of pollution for
their urbanized areas over 200,000 in
population.
The following metropolitan nonattain-
ment areas are included within those 29
states:
Albuquerque, NM; Allentown! Bethle-
hem Easton, PA; Aurora Elgin. IL;
Atlanta, GA; Baltimore. MD; Charlotte.
NC: Chicago, IL; Chicago suburbs, IN;
Cincinnati, OH; Cincinnati suburbs, KY:
Cleveland, OH; Colorado Springs. CO:
Connecticut (statewide); D.C. suburbs,
MD; D.C. suburbs, VA; Denver, CO;
Detroit, MI: Fresno, CA; Houston, TX;
Las Vegas, NV; Los Angeles, CA; Louis-
ville, KY; Louisville suburbs. IN: Massa-
chusetts (statewide); Memphis. TN; Nash-
ville, TN; New Jersey (statewide); New
York, NY: Philadelphia, PA; Phoenix,
AZ; Pittsburgh, PA; Portland, OR and
Vancouver, WA; Rhode Island (statewide);
Richmond, VA; Sacramento, CA; St.
Louis, MO; St. Louis suburbs, IL; Salt
Lake City, UT; San Bernardino! Riverside,
CA; San Diego, CA; San Francisco Bay
area, CA; Scranton/ Wilkesbarre, PA;
Seattle, WA; Tucson, AZ: Ventura, CA;
Washington. DC; Wilmington, DE; Wis-
consin (southeast portion).
Source: Office of Transportation and Land Use Policy.
EPA, August 1980
Mich
Del
DATE DUE
HIGHSMITH #45115
59
MJ.S. GOVERNMENT PRINTING OFFICE: 1980 311132/100 1-3

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