Conformity Analysis
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CONFORMITY ANALYSIS TO BE ADOPTED FEBURARY 2020 DEVELOPED AS PART OF THE SACRAMENTO AREA COUNCIL OF GOVERNMENTS’: 2020 METROPOLITAN TRANSPORTATION PLAN AND SUSTAINABLE COMMUNITIES STRATEGY AND AMENDMENT #18 TO THE 2019-22 METROPOLITAN TRANSPORTATION IMPROVEMENT PROGRAM SACOG STAFF Renée DeVere-Oki, Program Manager for Regional Air Quality Planning Shengyi Gao, Data and Modeling Analyst José Luis Cáceres, Project Manager-2019/22 Metropolitan Transportation Improvement Program Matt Carpenter, Director of Transportation Services Bruce Griesenbeck, Data and Analysis Manager Clint Holtzen, Planning Manager ii TABLE OF CONTENTS Executive Summary 1 Conformity Requirements 1 Conformity Tests 2 Findings of the Conformity Analysis 2 Conformity Determination for the 2016 Metropolitan Transportation Plan and Sustainable Communities Strategy Amendment #2 and the 2019-22 Metropolitan Transportation Improvement Program 4 Overview of the Physical Environment 4 Introduction 5 Background 5 Conformity Approach 6 Financial Constraint 6 Inclusion of all Federal and Regionally Significant Projects 7 Latest Planning Assumptions 7 Land Use Assumptions 7 Transportation System 8 Latest Emissions Model 8 Modeling Documentation 9 Air Quality Emissions Analysis 10 Years of Analysis 10 Analysis Techniques 11 Emission Calculations 12 Emissions Budget Test for Ozone (ROG and NOx) 12 Emission Forecasts for the Sutter Buttes Ozone Nonattainment Area 12 Emissions Budget Test for PM10 13 Interim Baseline Test for the Sacramento PM2.5 Nonattainment Area 13 Emissions Budget Test for the Yuba City-Marysville PM2.5 Nonattainment Area 13 Implementation of Transportation Control Measures 13 Public Participation Process 14 Resolution of Approval for the 2016 MTP/SCS Amendment #2 and the 2019-22 MTIP 14 Conclusion 14 iii APPENDICES Appendix A: Conformity Checklist Appendix B: Transportation Project Listing Non-Exempt Project Listing Exempt Project Listing Eastern Solano County Project Listing Appendix C: Conformity Analysis Documentation Figure 1-Air Quality Conformity Geographies by Nonattainment Area Table 1-SACOG Air Quality Conformity Emissions Analysis Table 2-Population and Employment Assumptions, and VMT Estimates Table 3-Emission Estimates for Ozone Conformity Analysis Table 4a and 4b- Ozone Conformity Analysis (options based upon budget approval) Table 5a-PM10 Emissions Estimates and Conformity Test Table 5b-Paved Dust Calculation Table 5c-Road Construction Dust Emission Rates Table 5d-Road Construction Dust Seasonal (Winter) Table 6a- PM2.5 Emissions Estimates and Conformity Test Table 6b- PM2.5 Conformity Analysis for Yuba City‐Marysville Area Table 7-Air Quality Conformity Assumptions Appendix D: Timely Implementation Documentation for Transportation Control Measures Appendix E: Charge of the RPP Appendix F: Resolution of Adoption and Public Notice Resolution of Adoption Public Notice Appendix G: Response to Public Comments iv EXECUTIVE SUMMARY The Sacramento Area Council of Governments (SACOG) is the designated Metropolitan Planning Agency for the Sacramento Region and is responsible for all regional transportation planning activities in Sacramento, Sutter, Yolo, and Yuba Counties, and in El Dorado and Placer Counties outside of the Tahoe Basin. For purposes of conformity, SACOG is responsible for the analysis of transportation activities in that area and in eastern Solano County. Presented in this report is the Conformity Analysis for the 2020 Metropolitan Transportation Plan and Sustainable Communities Strategy Amendment (2020 MTP/SCS) and Amendment #18 to the 2019-22 Metropolitan Transportation Improvement Program (MTIP). The conformity demonstration requirement is described in the Clean Air Act Section 176(c) (42 U.S.C. 7506(c)) and U.S. Environmental Protection Agency (EPA) transportation conformity regulations (40 CFR 93 Subpart A). Transportation conformity ("conformity") is a way to ensure that Federal funding and approval goes to those transportation activities that are consistent with air quality goals set for ozone, particulate matter, or nitrogen dioxide. The analysis presented in this report demonstrates that the 2020 MTP/SCS meets the criteria specified in these regulations. CONFORMITY REQUIREMENTS Conformity must be demonstrated in “all nonattainment and maintenance areas for transportation-related pollutants for which the area is designated nonattainment or has a maintenance plan” (40 CFR 93.102). The following are the designations within the Sacramento region: • 2008 8-Hour Ozone (including the ROG and NOx precursors) Severe-15 Nonattainment Area: o The Sacramento Metropolitan Area (Sacramento, Yolo and portions of El Dorado, Placer, Sutter, Solano Counties) and o The Sutter Buttes Area (Sutter County). The 2008 ozone standards classify the Sutter Buttes Area as an unclassified/attainment area for ozone, effective July 20, 2013. • 2015 8-Hour Ozone (including the ROG and NOx precursors) Moderate Nonattainment Area: o The Sacramento Metropolitan Area (Sacramento, Yolo and portions of El Dorado, Placer, Sutter, Solano Counties). o The Sutter Buttes Area (Sutter County). The 2015 ozone standards classify the Sutter Buttes Area as a marginal nonattainment area for ozone, effective June 4, 2018. • Particulate Matter (PM10) Maintenance Area (Sacramento County) • 2006 Fine Particulate Matter (PM2.5) Nonattainment Area and Maintenance Area: o Nonattainment Area - Sacramento Area (Sacramento and portions of Yolo, Solano, Placer and El Dorado Counties) o Maintenance Area -Yuba City-Marysville Area (Sutter and a portion of Yuba County) Under a determination of conformity, the following criteria are applied: 1. The latest planning assumptions and emission models are used. 2. The transportation plan and program pass an emissions budget test using a budget that has been found adequate or been approved by EPA or an interim emissions test where budgets have not been established. 1 3. The transportation plan and program provide for the timely implementation of transportation control measures (TCMs). 4. Interagency and public consultation is part of the process. SACOG follows the interagency review process described in SACOG’s Public Participation Plan. The dedicated interagency forum for this process is the bi-monthly Regional Planning Partnership meeting. Upon reaching a determination finding that is approved by SACOG’s Board, the conformity analysis is submitted to Federal Highway Administration (FHWA) and Federal Transit Administration (FTA) for final approval. The Conformity Checklist developed by FHWA contains items required for completing a determination. This list is included for reference in Appendix A. CONFORMITY TESTS Federal conformity regulations describe two types of tests; an emissions budget test and an interim emissions test. To run an emissions budget test, a region must have budgets in place that have been found adequate for transportation conformity purposes, or are contained in an approved air quality implementation plan. Predicted emissions for the 2020 MTP/SCS must be less than or equal to these budgets. The second test, an interim emissions test is used when approved or adequate budgets are not in place and the region is in nonattainment. Predicted emissions for the 2020 MTP/SCS and MTIP must be less than or equal to emissions predicted in the baseline scenario. Applicable air quality implementation plans and conformity tests are further described within the text. FINDINGS OF THE CONFORMITY ANALYSIS A regional emissions analysis was conducted for the years 2020, 2022, 2023, 2024, 2026, 2027, 2035, and 2040 for each applicable pollutant. See Appendix C, Table 1, for the analysis years for each pollutant. Each analysis utilized the latest planning assumptions and emissions models. The conclusions of the SACOG analysis are: • Ozone: The Analysis determined that the implementation of the 2020 MTP/SCS and the MTIP would result in less total regional on-road vehicle-related emissions (ROG and NOx) than the emissions budget found adequate by the EPA in the 2009 Sacramento Regional 8-Hour Ozone Attainment and Reasonable Further Progress Plan, 2013 SIP Revisions. This analysis has used these budgets for demonstration of the 2008 and 2015 standards; and the 1997 standard as necessary. This draft contains both approved and pending approval Ozone budgets. At the time of adoption, the analysis, the approved budgets will be used. • PM10: The Analysis determined that the implementation of the 2020 MTP/SCS and the MTIP would result in less total regional on-road vehicle-related emissions than the emissions budget found adequate by the EPA in the 2010 PM10 Implementation/Maintenance Plan and Re-designation Request for Sacramento County. • PM2.5: The Analysis determined that the total regional on-road vehicle-related emissions associated with implementation of the 2020 MTP/SCS and the MTIP for the analysis years are projected to be less than or equal to the emissions for the Baseline scenario, satisfying the test established in Interim Transportation Conformity Guidance for 2006 PM2.5 NAAQS Nonattainment Areas in the Sacramento area. The Analysis also found that implementation of the 2020 MTP/SCS and the MTIP would result in less total regional on- 2 road vehicle-related emissions than the emissions budgets found adequate by the EPA in the 2014 Yuba City-Marysville PM2.5 Maintenance Plan and Re-designation Request. • TCMs: The implementation of the 2020 MTP/SCS and the MTIP will not impede the timely implementation of the TCMs identified in the