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 time-line or narrative
description of your various schedules.
The Transportation Plan, and SIP must use the latest planning assumptions at the time of each update. Because these documents are updated at different frequencies, we commonly encounter several mismatch issues in regards to planning assumptions. For example, the SIP budget for Northern Kentucky and the SIP budget for Southwest Ohio were last revised in 1999. Since then, OKI has incorporated new advancements in our travel forecasting model and revised our vehicle fleet mix. Our most recent Transportation Plan, the 2030 Plan adopted in September 2001, included these new assumptions. We were able to pass conformity, but only due to off-model CMAQ credits. Since then, we anticipate three major new assumptions on the horizon; 1) new population projections based on the 2000 Census, 2) further enhancements to the travel forecasting model, and 3) MOBILE6. We have several rapid growth counties in the region, resulting in a significant increase in the population projections and hence VMT through 2030. Improvements in our travel forecasting model have also resulted in higher VMT’s. Without the ability to modify the SIP budget, OKI anticipates serious difficulties in passing future conformity tests. Any future unforeseen changes in several projects’ scope and schedule we cause us to amend our Plan, and conformity will be in jeopardy. Aligning the update schedules for the SIP, TIP and Plan would allow us to make quality traffic forecasts while being able to more accurately determine whether our transportation decisions are improving air quality.
What impact have these schedules had on investments in
highway and safety projects, construction costs, and air quality projects and
activities?
Making air quality conformity determinations is a complex
task requiring significant staff resources, and allowance for adequate
opportunity for public comment. This
leads to some reluctance to amend the TIP/Plan for changes or additions of
non-exempt projects. Major amendments
are frequently delayed so that we may analyze a combination of several changes
to non-exempt projects at the same time.
What has been your experience coordinating your SIP and
conformity processes with SIP submittals or updates?
Coordination is difficult when dealing with two states and
two federal regions. The SIP update
process is the responsibility of the state air quality agencies. Coordination among the state air agencies
and the federal regions is difficult.
We are working the states, FHWA-Kentucky Division, FHWA-Ohio Division,
EPA Region 4 and EPA Region 5 to try to reach a better understanding of
coordination procedures.
We were pleased that the two states were able to have
concurrent SIP update processes in 1999.
Due to differing legal constraints and priorities, it is not likely that
both states will have a concurrent process for the next SIP update. Ohio EPA is revising their SIP to address
certain area source deficiencies. OKI
is currently working to provide Ohio EPA with a revised mobile source budget
that can be included in the SIP revision.
We will be using the latest planning assumptions to develop that
budget. There is no requirement for Kentucky
to revise their SIP or mobile source budget.
The result for the region will be two separate budgets created with two
different sets of planning assumptions.
This will likely increase the difficulty in making conformity
determinations.
Compare and contrast your MOBILE5 and MOBILE6
projections. How does the increase in
near term emissions (through 2010) from MOBILE6 affect your conformity status?
|
|
VOC |
NOx |
|
2010 Region |
-6% |
+18% |
|
2030 Region |
-40% |
-40% |
Preliminary results for the OKI region have shown that
MOBILE6 causes NOx projections to increase by 18% for 2010 (our maintenance
year). VOC projections for 2010
decrease 6%. For 2030, VOC and NOx
projections decrease by 40% with MOBILE6.
We will not be able to pass conformity with MOBILE6 if the existing
budgets are maintained.
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?
Not sure when SIP budgets will be updated with
MOBILE6. Ohio is currently in the
process of revising SIP, with new mobile source budgets, using MOBILE5.
Will the new 8-hour NAAQS likely lead to an increase or
decrease in your vehicle emissions budget?
It is likely that the new 8-hour NAAQS would lead to a
decrease in our vehicle emissions budget.
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?
Nearly all of the controls with the most significant impact
have already been implemented in the OKI region. Currently we have an inspection and maintenance program in
Northern Kentucky and Southwest Ohio.
Reformulated gas is used in Northern Kentucky, oxygenated fuels in
Southwest Ohio. We have also
implemented a region-wide Intelligent Transportation System called ARTIMIS that
has significantly reduced vehicle delays due to traffic incidents. Upcoming federal requirements for cleaner
heavy-duty diesel engines and cleaner gasoline will help. We don’t anticipate any additional controls
to be implemented locally.
Our 2030 Plan recommends the adoption and implementation of
comprehensive land-use and transportation policies that support SOV
alternatives, such as transit use, biking and walking.
Would these controls be sufficient to address the potential
increase in emissions projected under MOBILE6?
Not sure.
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 emission reduction credits
for each.
TCM and CMAQ type projects play a role in helping us meet
conformity targets. However, there are
no required TCMs in our SIP.
We have taken “off-model” credit for three CMAQ projects
and one STP project in our Transportation Plan. The projects include the Kentucky and Ohio elements of ARTIMIS
(Advanced Regional Traffic Interactive Management and Information System) and
continuation of OKI’s efforts to promote ridesharing. Details of off-model credits are provided in the table below.
|
Project |
Funding Source |
2010
Daily VOC reduction (tons) |
2010
Daily NOx reduction (tons) |
2020
and 2030 Daily VOC reduction (tons) |
2020
and 2030 Daily
NOx reduction (tons) |
|
Ohio ARTIMIS |
STP |
0.54 |
1.14 |
0.27 |
0.45 |
|
Ohio RideShare |
CMAQ |
0.20 |
0.17 |
0.10 |
0.07 |
|
Kentucky ARTIMIS |
CMAQ |
0.14 |
0.30 |
0.07 |
0.12 |
|
Kentucky RideShare |
CMAQ |
0.05 |
0.05 |
0.03 |
0.02 |
What percentage of total emission reductions do they
represent?
The emission reductions from the four projects represent 2%
of regional VOC emissions and 3% of regional NOx emissions in 2010.
Are there CMAQ projects in your plan for which you have not
applied any on or off model emission reductions?
There are at least 6 other CMAQ projects in our TIP/Plan
for which we have not taken off-model credit.
We estimate that the total VOC and NOx emissions of these projects
represent less than ½ of 1% of regional emissions.
If your area has experienced a conformity lapse, describe
the affect this has had on transportation and air quality planning, funding
process, preconstruction, and construction.
The region experienced a 9-day conformity lapse in October
2001. Because of the short duration of
the lapse, only one project was impacted.
The design phase of a bridge project in Middletown, OH was delayed
approximately 2 weeks.
When projects were reactivated, after USDOT approved your
conformity determination, what impact did this have on funding, project
completion dates, personnel, renegotiation of contracts, updating old
information, etc?
No impact.
What impact did the March 1999 US Court of Appeals decision
to eliminate the EPA “grandfather” provision from the conformity regulations
have on your transportation investments?
The March 1999 decision has not impacted any projects in
our region.
How has
conformity analysis helped improve the quality of estimates of motor vehicle
emissions for SIPs to better protect public health?
The conformity requirement
has prompted us to continually update certain planning assumptions such as VMT
mix and vehicle age distributions.
How
accurate and consistent have estimates of regional motor vehicle emissions been
when compared with each other over time and with actual experience?
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?
Estimates of regional
motor vehicle emissions have changed over time due to changes in planning
assumptions including demographic and socioeconomic conditions, changes in the
analysis years, and new updates to the MOBILE model. Output from the travel and emission models provides our best
estimate of the actual regional motor vehicle emissions. The Ohio EPA and the Kentucky Division of
Air Quality maintain detailed records of monitored pollutant concentrations.
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?
The OKI Travel Demand Model is a traditional 4-phase
sequential model (trip generation, trip distribution, modal choice and trip
assignment) with a feedback process from trip assignment phase to trip
distribution phase. In this model, the
capacity constrained algorithm is utilized in the trip assignment phase. The assignment algorithm considers the
effect of changes in roadway capacity on the degree of congestion and thus the
travel speed of the roadways, which in turn affect the distribution of the traffic
loads among the roadways in the roadway network. In addition, the feedback process allows the impact of change in
roadway capacity on trip distribution (where trips should be sent) and modal
choice (which transportation should be used) to be properly considered. The speeds and traffic loads determine the
amount of emission. With the speed and
traffic load reflecting the impact of the changes in roadway capacity, the impact
of capacity changes on emissions is properly reflected as well. In summary, OKI’s model adequately reflects
how changes in highway capacity will affect total travel and emissions.
How well have your region’s travel models tracked actual
experience with growth in vehicle miles of travel (VMT)?
The growth in vehicle miles of travel is mainly due to the
growth and distribution in population as well as the increase in automobile
ownership. In the OKI Travel Demand
Model, the estimation of population and its distribution closely follow the building
permits issued and land development plans.
The auto ownership trend is tracked and forecasted into the future. Thus the amount of trips and distance
traveled are properly simulated in the model.
Please include an indication of how sensitive your/these
models are to effects of induced traffic.
Highway improvements that add capacity to a specific
corridor or a regional transportation network will attract increased levels of
vehicle traffic. The model is very
sensitive to the effects of added roadway capacity. The model will divert the traffic to the roadways with new and/or
added capacity. In addition, changes in
the transportation system (highway or transit) cause travelers to change their
transportation mode (drive-alone, share-ride or transit) and/or
destination. OKI’s model simulates
these effects too.