600 NORTHEAST GRAND AVENUE	PORTLAND, OREGON 97232 2736
TEL 503 797 1700	FAX 503 797 1794

July 23, 2002

United States Senate

Committee on Environment and Public Works

Washington, D.C. 20510-6175

Attention: Chris Miller

Dear Mr. Miller:

The following are Metro and Oregon Department of Environmental Quality (DEQ) responses to the conformity case study questions raised in the July 3,2002 letter from the Senate Committee on Environment and Public Works:

Differences in Timing of Schedules

Question: Describe how the different schedules for the SIP, TIP, Conformity, etc. and the impacts of data changes on out year emissions affect your ability to develop effective and timely transportation and air quality plans. Provide a timeline or narrative description of your various schedules.

Response: The SIP mobile source element is updated infrequently. The last SIP included the “Maintenance Plans for CO and Ozone” and was acknowledged by the State EQC in 1996. It will not have to be updated until 2006. The MTIP is updated every two years and occasionally is amended such that it requires a conformity determination. The RTP is updated every three years, and includes a conformity determination. The major issue we deal with regarding timing is trying to align, to the degree possible, any required conformity actions. To the extent that the action occurs on schedule, we are experienced enough that we can adequately manage conformity determinations. It does become problematic (time consuming and expensive) when we conform our long-range plan six months prior to a TIP conformity, which can occur due to schedules, project needs.

Question: What impacts have these schedules had on investments in highway and safety projects, construction costs, and air quality projects and activities.

Response: Required conformity has caused slight three to four month delays in projects, which may or may not affect project cost and schedule (dependent on construction season, interest rates that apply to bond financing, etc). The schedules have no impact on project selection.

Question: What has been your experience coordinating your SIP and conformity processes with SIP submittals or updates?

Response: Since the Clean Air Act Amendments of 1990 and ISTEA, requiring air quality conformity in its current state, we have had only a single SIP submittal and update. It followed the completion of our 1995 long-range plan and the associated travel networks and forecasts were used both for the SIP and long-range plan. In other words, our timing was fortunate and we were able to use “off the shelf” analysis for SIP conformity.

MOBILE6 versus MOBILE5 Projections

Question: Compare and contrast your MOBILE5 and MOBILE6 emission projections

Response: Metro has not used MOBILE6 for any conformity estimates to date. To this point, Metro has only used MOBILE6.2 for estimating emission rates for air toxics work. Furthermore, we have added detail to the stratifications of emission rate categories such as county-specific vehicle fleet age characteristics, separated emission rates by roadway functional class, updates to fuel type, ambient temperatures, and I/M programs. Therefore, even if we had MOBILE6 emission rates (or resulting total motor vehicle emissions) for CO, NOx, and VOC, we would not be able to make apples to apples comparisons between the results without rerunning MOBILE5 with the updated stratifications. Oregon DEQ has not determined exactly how they will be applying the new Mobile 6 model, but initial runs appear to be consistent with what EPA anticipated. More specifically, Mobile 6 emissions to be higher than Mobile 5 emission prior to 2005 (approximately) then progressively lower thereafter.

Question: How does the increase in near term emissions (through 2010) from MOBILE6 affect your conformity status?

Response: Metro has not done any conformity work using MOBILE6, thus we have no basis to make an evaluation of how it affects our conformity status. However, Oregon DEQ expects that increased emissions in the near term should not jeopardize conformity if the last Mobile 5 conformity determination is timed occur near the end of the two year phase in period for Mobile 6.

Question: How will your air quality planning process take the new MOBILE6 into account, and will the SIP be updated before or after the new MOBILE6 projections?

Response: The Portland Metropolitan area is still working with budgets that were established using MOBILE5. The Oregon Department of Environmental Quality is planning to update the budgets using MOBILE6 sometime later this year. At that time, Metro will begin using MOBILE6 for subsequent conformity work. Portland’s Carbon Monoxide and Ozone maintenance plans must be reworked and resubmitted to EPA by the end of 2004. Those plans will include new, lower emission budgets based on Mobile 6, but those budgets are not likely to take effect until approximately 2006.

Question: Will the new eight-hour NAAQS likely lead to an increase or decrease in your vehicle emissions budget?

Response: The new eight-hour ozone standard will probably not affect the motor vehicle emissions budgets by much.

Additional Vehicle Emission Controls

Question: What additional existing controls could be implemented in your area to significantly reduce vehicle emissions, e.g., inspection and maintenance, reformulated fuels, diesel retrofit, TCMs?

Response: Additional existing controls that could be implemented include diesel retrofits and elimination of an emissions allowance set aside for industrial growth.

Question: Would these controls be sufficient to address the potential increase in emissions projected under MOBILE6?

Response: The available controls would probably not be adequate to avert a conformity crisis if we had to immediately demonstrate conformity using Mobile 6.

Role of Transportation Control Measures

Question: What role do TCMs play in helping to meet attainment? Please list the TCMs and CMAQ projects in your plan, and the associated “off” or “on” model emissions reductions credits for each.

· Response: The Metro 240 Growth Concept. Metro has adopted integrated land use and transportation system plans that modeling predicts will decrease reliance on single occupant vehicle travel. A 5.0 percent VMT reduction credit is associated with inclusion of Metro’s code-based Growth Concept enforcement mechanisms in the Maintenance Plan (code provisions related to Requirements for “Accommodation of Growth”; “Regional Parking” ratios (minimum and maximum permitted amounts); and “Retail in Employment and Industrial Areas”). The actual emissions reductions vary by pollutant and year but in 2010, a five percent VMT reduction equated to HC, NOx and VOC reductions of approximately 6.4, 5.4 and 6.6 percent, respectively.

· DEQ Employee Commute Options (ECO) Rule. Employers of 50 persons or more must submit plans showing mechanisms for achieving 10 percent VMT reductions from employees. The credit was originally pegged at a 1.0 percent reduction of emission in 2010 but was reduced to 0.5 percent based on realized mode shift indicated in annual surveys administered by ECO program staff.

Question: What percentage of total emission reductions to they represent?

Response: The region must provide annual transit system service increases averaging 1.5 percent annually, and an equal increase of service in the Downtown core. There is no emission credit associated with this requirement. Additionally, the South/North Light Rail Concept, or an equivalent transit system enhancement must be operational by 2007. (The Westside MAX extension was completed, as required.)

The region must add no less than 28.0 miles of regionally significant bikeways by 2006. Reasonable progress on this task is defined as funding no less then 5.0 miles of improvements each biennium. There is no emissions credit associated with this requirement.

The region must add no less than 9.0 miles of regionally significant pedestrian facilities by 2006. Reasonable progress on this task is defined as funding no less then 1.5 miles of improvements each biennium. There is no emissions credit associated with this requirement.

Question: Are there CMAQ projects in your plan for which you have not applied any on or off model emissions reductions?

Response: CMAQ funds have been used to meet the funding based TCMs noted above, though other sources have also been used and not all CMAQ funds have been dedicated to these purposes. No on or off model credit is taken for any CMAQ funded projects, although emissions reductions attributable to CMAQ projects are calculated to demonstrate CMAQ program eligibility.

Impacts of Conformity Lapse

Question: If your areas has experiences a conformity lapse, describe the effect this has had on transportation and air quality planning, funding process, preconstruction and construction.

Response: Our area has not experienced a lapse.

Role of Motor Vehicle Emission Estimates and Models

Question: How has conformity analysis helped improve the quality of estimates of motor vehicle emissions for SIPs to better project public health?

Response: Conformity analysis requirements have caused Metro to implement a more rigorous process (programs to continually implement demand model improvements and strive to ensure that functions used for speed estimation reflect observed data) by which VMT, speed, and resulting motor vehicle emissions are estimated. Conformity requirements have not affected the way motor vehicle emissions factors are generated for SIPs.

Question: How accurate and consistent have estimates of regional motor vehicle emissions been when compared with each other over time and with actual experience?

Response: Regional motor vehicle emissions seem to be valid, reliable and consistent. The following table illustrates the historical profile and consistency of emissions estimates of recent conformity runs:

TIP Conformity Emissions Estimates – Historical Summary
	1990 Budget (est. 1995)	1990	1998	2000
CO (000s lbs)	1812	1795	814	828
VOC (tons)	92	88	41	42
NOx (tons)	75	64.5	52.3	51

Question: How have official estimates of motor vehicle emissions in your metropolitan region changed over the past 10-20 years, and how well have they tracked actual emissions in years past?

Response: Estimates of motor vehicle emissions have generally decreased as federal and state regulations have become progressively more stringent. Because we do not monitor mobile source emissions separately from other sources, there is no way to accurately compare projected emissions with actual emissions. A subjective impression, however is that the two are not inconsistent. The following tables illustrate the consistency of future year model projections for emissions estimates of recent conformity runs:

TIP Conformity Emissions Estimates – 2010 Model Year
	2010 Budget (est. 1995)	2000	2002
CO (000s lbs)	760	645	644
VOC (tons)	40	32	32
NOx (tons)	52	50.9	50.9

TIP Conformity Emissions Estimates – 2020 Model Year
2020 Budget (est. 1995)	1999		2000		2002
CO (000s lbs)		842		740		728
VOC (tons)		40		37.6		37
NOx (tons)		59		58.7		58.2

Metro does not have the data to demonstrate the comparisons between modeled and actual observed emissions.

Role of Transportation Models

Question: Has conformity analysis been supported by adequate regional transportation analysis models that accurately reflect how changes in highway capacity affect total travel and air pollution emissions?

Response: Metro’s transportation demand modeling process includes many features that take into account changes in, among many other things, highway capacity and its effects on total travel and air pollution emissions.

§ Metro’s demand model is multi-modal. This means that any changes in highway capacity which result in changes in travel time, relative to other modal attributes, affects the choice of both destination and mode of transportation. For example, adding a new lane on a freeway improves travel time through that corridor. All else being equal, the auto mode becomes relatively more desirable than other modes. In addition, the improvement in accessibility to areas served by that freeway attracts more trips to those areas.

§ The model is sensitive to the urban environment. The mix of households and employment opportunities influence the choice of destination and mode.

§ We use the EMME/2 software for assignment of trips onto the highway network. It uses an equilibrium capacity restrained assignment algorithm to determine path choice for trips. An iterative process is used to reach equilibrium travel times among path choices between TAZ (Transportation Analysis Zone) pairs.

§ In addition, we maintain a comprehensive region-wide count database for validation and calibration purposes to ensure that the model is producing accurate and reasonable outputs.

Question: How well have your region’s travel models tracked actual experience with growth in vehicle miles of travel (VMT)?

Response: The following shows how VMT estimated using Metro’s travel demand model has tracked actual growth in VMT between 1985 and 2000.

	Region's Model Estimated VMT
	vs.
	Regional HPMS Derived ("actual") VMT
	Model*		HPMS
	FAU	Total Modeling Region	FAU	Total Region**
1985	14,922,127	n/a	14,140,000	n/a
1990	17,970,876	19,282,419	17,970,000	22,400,000
1994	n/a	24,685,960	n/a	26,500,000
2000	n/a	28,485,076	n/a	31,500,000
* - Model does not include truck trips or external trips
** - HPMS Total Region is the Portland-Vancouver, OR-WA Urbanized Area (UZA 27)

Question: Please include an indication of how sensitive your/these models are to effects of induced traffic.

Response: Comparing local survey data through time has shown that trip generation rates generally remain stable with changes in travel times. So, it is assumed that induced demand refers to additional trips choosing a certain destination or mode based on improvements in accessibility resulting from increases in highway capacity, but not necessarily an increase in the total universe of trips in the system. Our model responds to changes in infrastructure in destination choice and mode choice by an iterative process of feeding output travel times back to the beginning of the model, and rerunning until equilibrium is reached.

For example, we use generic existing travel times for input into an initial model run. Let’s assume a new development with households and employment is added to the region. The new opportunities presented by this development will attract more trips to the area. Given the additional trips, the resulting travel times in this area will show increased congestion. These more congested travel times are then fed back to the beginning of the model and the model is rerun. This time, the increased congestion (or slowed travel times) will reduce the attractiveness of the destination and may also make non-auto modes more desirable for this destination. If capacity is added to the highway network serving this development (improving travel times), then more iterations of the model will show additional trips attracted to this area and changes in mode share chosen by people who travel there.

Thank you for the opportunity to participate in this survey. Please feel free to contact Mike Hoglund at 503-797-1743 if you have any questions, or require further assistance.

Sincerely,

Andrew C. Cotugno

Planning Director, Metro

cc: Mike Hoglund, Metro

Dick Walker, Metro

Tom Kloster, Metro

Annette Liebe, DEQ