July 30, 2002

Thank you for the opportunity to comment on California’s experience integrating air quality and transportation planning as required by the Clean Air Act. Over the years, we have been able to meet the Act’s transportation conformity requirements through the cooperative efforts of agencies at the local, state, and federal level. At the same time, we are encountering some process challenges that need to be addressed. We are looking at this issue in the context of California’s longstanding and successful air pollution control program – a program that will now address global warming as a result of the passage of State legislation recently signed by Governor Davis.

The concept of transportation conformity is a simple one – the air pollutant emissions from the transportation sector must be consistent with air quality plans for a region. This is critical to ensure that we meet health-based air quality standards in the required timeframe. The process itself requires looking at today’s emissions and well as those in the future. This is necessary to ensure that we continue to make clean air progress as our population and economy grows.

Over the last twenty years, reducing air pollution from the transportation sector has been essential to California’s dramatic progress in improving air quality in the Los Angeles area -- historically the nation’s smoggiest region. For transportation, that progress is largely due to cleaner vehicle technology. A new car in 2010 will emit only one tenth the ozone forming pollution of a 1990 model. As a result, transportation control measures that reduce travel have shown less benefit than anticipated.

Also, there is little flexibility for transportation agencies in terms of implementing transportation control measures once they are in the air quality plan. This discourages innovation because new, more effective measures cannot replace a measure that proves to be infeasible. In terms of complying with the conformity requirements, we believe the focus should be on the emission reduction goal rather than the implementation of a specific transportation control measure.

In addition to transportation control measures, there is another important mechanism to address air pollution from the transportation sector – the federal Congestion Mitigation and Air Quality program. We strongly support these funds as a means for transportation agencies to provide significant emission reductions in a cost-effective way. There are many cleaner technologies that can be funded to reduce both ozone and particulate pollution from the transportation sector.

The most difficult problem with the current conformity process is the inability to take new information into account in a workable way. Air quality plans or “SIPs” must define the emission target needed to achieve clean air as defined by national air quality standards. That emission target is based on the state of the science at the time the air quality plan is done. Once approved by the U.S. Environmental Protection Agency, the SIP is the federally enforceable benchmark for transportation conformity purposes. There is no requirement to update a SIP prior to the deadline for meeting the air quality standard.

On the other hand, transportation plans must be updated routinely. And, as a practical matter, changes in individual transportation projects are proposed often monthly in major urban areas. These changes typically trigger a process that requires new information to be used in the conformity analysis. When the SIPs have not been updated with the same information, the inherent inconsistency may derail the process.

In California, we face this issue virtually statewide. As a result, we will be revising 23 SIPs over the next year or so. And while this will put us back on a consistent process track in the near-term, it is a major undertaking that will not in itself provide air quality benefits. What we want to avoid in the future is the triggering of a comprehensive SIP update each time new information becomes available. Under today’s rules, this is the only way to avoid conformity problems as the science improves.

We believe it is more appropriate to comprehensively revise air quality plans when the underlying facts have changed so substantially that the approach to meeting the air quality standard must be revised. Otherwise, we need the option of a streamlined mechanism to respond to new information. For example, a streamlined mechanism could be appropriate when a region is close to meeting the standard, emissions are declining, and the strategies in the air quality plans are all being implemented. In this type of transitional situation, a reconciliation of “old” and “new” vehicle emission estimates would make more sense than a comprehensive plan revision.

For regions that have a long way to go to meet the air quality standards, more frequent plan updates will be needed. For example, we recognize that the air quality plan for the Los Angeles region needs a comprehensive update. A number of new studies are available, including improved data related to motor vehicle emissions and travel. From a process standpoint, what these situations demand is the ability to link the timing of transportation plans and conformity with the completion of new air quality plans.

In conclusion, California is pursuing statewide SIP revisions as a means to provide the necessary consistency between air quality and transportation plans. But we want to use our resources more effectively to protect both our federal transportation dollars and the integrity of our clean air plans. We believe that with some focused process changes we can accomplish both.

Thank you again for the opportunity to be here. I would be pleased to answer any questions you may have.

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