Transportation/Air Quality Issues in Rural AreasBack to Search Page
      Federal Highway Administration
      Transportation/Air Quality
      Issues in Rural Areas
      Final Report
      April 2003
      Prepared by
      Dye Management Group, Inc.
      500 108th Avenue NE, Suite 1700
      Bellevue, WA 98004



Federal Highway Administration
Transportation/Air Quality Issues in Rural Areas
Table of Contents

I. Introduction
  A. Background
  B. Approach
  C. Report Structure
II. Summary of Findings
III. Identification of Isolated Rural Areas
IV. Survey Results 
  A. Carbon Monoxide
  B. Ozone
  C. Particulate Matter-10
Appendix A: Survey A-1


Federal Highway Administration
Transportation/Air Quality Issues in Rural Areas


I. Introduction
Although air quality has been mainly an urban concern, it is beginning to become 
an issue that rural areas will also have to manage. Several rural counties have 
exceeded the national standard for one or more air pollutants. The purpose of 
this study is to increase understanding of how many rural areas are facing this 
problem and to identify the main causes for their exceeding air quality 
standards. The study also focuses on transportation's contribution to the air 
quality problems in rural areas and how these areas are meeting certain Clean 
Air Act requirements related to motor vehicle emission sources. In order to 
build this understanding, the research identified rural nonattainment and 
maintenance areas: how many are there, where are they, and are they isolated 
rural areas or donut areas? (These two different types of areas are defined in 
Section III.) Once the delineation of areas was accomplished, the study's 
in-depth evaluation of air quality and transportation conformity issues was 
restricted to only isolated rural areas.
The research reported in this paper accomplished the following:
  Determined if transportation is generating the pollutants in each isolated 
  rural area or if another source is primarily responsible for the pollutant. 
  Identified what analysis rural areas have conducted to meet the Clean Air Act 
  requirements for transportation conformity and the control measures they have 
  undertaken to address transportation-related sources of pollutants. 
  Assessed the resources and planning capabilities of isolated rural areas to 
  address the issue of conformity between transportation plans for their areas 
  and State Implementation Plans (SIPs). 
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A. Background
The conformity provisions of the Clean Air Act are intended to integrate 
transportation and air quality planning in areas that are designated by the US 
Environmental Protection Agency (EPA) as nonattainment or maintenance.1 The 
transportation conformity process establishes a connection between 
transportation planning and the emissions levels for transportation sources that 
are established in the SIP. These emissions levels (or "budgets") in the SIP 
represent the maximum amount of emissions that can be generated from on-road 
transportation sources (e.g., cars, trucks, public transit) and still allow the 
area to attain or maintain the air quality standards. Under the CAA, 
nonattainment and maintenance areas must demonstrate through the conformity 
process that emissions projected from their transportation investments, 
strategies, and programs will be at or below the emissions budgets in the SIP. 
In order to comply with the National Ambient Air Quality Standards, federal, 
state, and local governments must take action. These actions, or control 
measures, are typically identified in the SIP. Depending on the classification 
and severity of the air quality problem, some areas may find that they need to 
reduce emissions from transportation sources. One option for reducing emissions 
for on-road mobile sources is to limit vehicle miles traveled (VMT). VMT is the 
sum of distances traveled by all motor vehicles in a specified region. In order 
to address VMT, some states have included Transportation Control Measures (TCMs) 
as strategies that are specifically identified and committed to in the SIP. TCMs 
are strategies that are listed in Section 108 of the Clean Air Act and include 
projects such as public transit and ride-share programs. Areas might also invest 
in other technology-based strategies that will reduce transportation-related 
emissions such as inspection and maintenance and fuels programs. 



1 A nonattainment area is a region that does not meet (or that contributes to 
ambient air quality in a nearby area that does not meet) the national primary or 
secondary ambient air quality standard for the pollutant. The area must take 
specified actions within a certain time frame to reduce emissions and attain the 
National Ambient Air Quality Standards (NAAQS). A maintenance area is a region 
previously designated as nonattainment, and subsequently redesignated to 
attainment.
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B. Approach
To meet the objectives of this study, research was conducted to determine the 
classification of areas. A comprehensive survey was designed, administered, and 
analyzed. The entire process was overseen by officials from the FHWA and EPA 
Office of Transportation and Air Quality (OTAQ).
  Oversight
  Study oversight was provided by officials from the FHWA and EPA-OTAQ. The 
  following officials were involved in the study oversight: 
    Bob Gorman, FHWA 
    Dee Spann, FHWA 
    Cecilia Ho, FHWA 
    Angela Spickard, EPA-OTAQ 
  The oversight group provided input and validated the study at key points, 
  including study inception, survey design, and presentation of findings.
  Research and Analysis
  August 2001 data on rural nonattainment and maintenance areas was compiled 
  from the EPA Greenbook website (http://epa.gov/oar/oaqps/greenbk/). The EPA 
  Greenbook data included information on all nonattainment and maintenance areas 
  in the United States for six pollutants: ozone, carbon monoxide, nitrogen 
  dioxide, sulfur dioxide, particulate matter, and lead. The data also 
  distinguished between nonattainment and maintenance areas that are part of a 
  Metropolitan Planning Organization (MPO) and those that are not. In this 
  research, the three transportation-related pollutants examined were carbon 
  monoxide, ozone, and particulate matter-10 (PM-10). Although nitrogen dioxide 
  is also a pollutant emitted from transportation sources, there are no isolated 
  rural areas violating the nitrogen dioxide air quality standard. A list of 
  nonattainment and maintenance isolated rural areas was compiled.
  In order to differentiate between the isolated rural areas and the donut 
  areas, many sources of information were used. (The two types of rural areas 
  are defined in Section II.) The Association of Metropolitan Planning 
  Organizations (AMPO) was consulted for determining which geographic areas MPOs 
  covered. Organizational websites (where available) were used to determine the 
  exact coverage area of the MPO; an organization without a website was 
  contacted by phone. The MPO areas were mapped out, as were the nonattainment 
  and maintenance areas, to determine if the area was a donut or an isolated 
  rural area. The regional EPA offices were contacted by phone to verify the 
  list of isolated rural nonattainment/maintenance areas and the donut areas. 
  The Code of Federal Regulations was consulted to determine the current air 
  quality classification of the area and to incorporate any updates since the 
  Greenbook data was last updated in August 2001. The analysis and survey 
  conducted was based on designations as of mid January 2002.
  Survey
  In conjunction with the EPA and the FHWA, a survey was developed to determine 
  how isolated rural areas designated as nonattainment or maintenance for one or 
  more national ambient air quality standards are addressing air quality and 
  transportation conformity requirements. The survey specifically addresses 
  Ozone, Carbon Monoxide, and PM-10 isolated rural areas. The main questions 
  addressed in the survey are:
    Why are these isolated rural areas in nonattainment or maintenance (i.e., 
    what are the main sources of their air quality problems)? 
    How are these air quality problems being addressed by the different agencies 
    involved? 
    How are these areas meeting the transportation conformity requirements? 
  The survey was e-mailed to the state department of transportation and state 
  air quality agency for each area. In addition, regional FHWA and regional EPA 
  offices were also e-mailed a survey. The consultant team answered survey 
  respondents' questions and encouraged those who had not completed a survey to 
  do so.
  Interviews
  One jurisdiction from each pollutant nonattainment or maintenance area -- 
  Presque Isle, Maine; Fairbanks, Alaska; and Greenbrier County, West Virginia 
  -- was selected for a follow-up interview. These focused discussions were used 
  to clarify how the area has used the conformity process and to identify the 
  practical issues associated with different aspects of the process. The 
  interviews confirmed the conclusions the study team reached from the survey 
  data.
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C. Report Structure
This report is organized into the following sections:
  II. Summary of Findings. This section presents the general findings from the 
  surveys collected for all the isolated rural nonattainment and maintenance 
  areas that responded. 

  III. Identification of Isolated Rural Areas. This section identifies which 
  rural areas are isolated and which areas are donut areas. 

  IV. Survey Results. This section presents a detailed summary of the survey 
  responses for isolated rural areas organized by pollutant. 

  V. Appendix A: Survey. This appendix contains the text of the survey 
  administered by Dye Management Group, Inc. in June 2002. 
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II. Summary of Findings
The following summarizes the major findings of a study that assessed the process 
and techniques that isolated rural nonattainment and maintenance areas have used 
to address the requirements of the conformity process. More details and 
definitions can be found in the body of this report.
  There are few isolated rural nonattainment or maintenance areas compared to 
  the total nonattainment or maintenance areas for each pollutant. 
  Isolated rural nonattainment or maintenance areas represent a small percentage 
  of the total nonattainment or maintenance areas, as shown in Exhibit II-1.
    Exhibit II-1: Number of Isolated Rural Nonattainment
    or Maintenance Areas Relative to
    Total Nonattainment or Maintenance Areas in 2001PollutantIsolated Rural 
        AreasTotal areasPercent Isolated Rural
        Carbon Monoxide31212
        Ozone314207
        PM-103710635

  The exhibit reinforces a predominant view that air quality is primarily an 
  urban concern. However, the portion of PM-10 areas that are isolated rural 
  areas is significant. 
  In only two cases were more than 5 percent of the PM-10 emissions attributed 
  to on-road mobile sources.
  Survey results indicated that in most of the isolated rural areas the PM-10 
  problem in an area are attributable to sources other than on-road mobile 
  sources such as point source (e.g., factories or power plants). Consequently, 
  transportation-related strategies did not really help these areas to attain 
  the PM-10 standard.
  Experience with PM-10 problems in other areas, confirmed through the survey 
  and telephone follow up with the isolated rural areas, indicates that more 
  frequent street sweeping, changing deicing materials or other fugitive dust 
  control measures can be effective in reducing PM-10 emissions. In the case of 
  Presque Isle, Maine, (a PM-10 nonattainment isolated rural area) switching 
  from a native sanding material to calcium chloride was very effective in 
  reducing PM-10 emissions. However, the cost of using the chemical in place of 
  the sand had prevented the local maintenance crews from switching for many 
  years.
  The isolated rural areas have limited staff resources to understand and 
  address the implications of nonattainment status.
  In general the isolated rural areas do not have professional air quality and 
  transportation planning staff. Local jurisdictions' responsibilities are 
  typically addressed through their public works department or county engineer 
  depending upon their organizational structure. They also rely on the expertise 
  of State Department of Transportation staff in addressing conformity issues.
  There is typically limited local data and planning information to perform 
  conformity analysis.
  The survey results indicate that in those few cases where analysis is 
  performed, traffic data and growth estimates are derived from traffic counts 
  and other traffic monitoring data reporting such as HPMS. Few areas indicated 
  that they collected local data.
  Interagency consultation is helpful when needed, but most survey respondents 
  have never held a meeting of all federal, state, and local agencies because 
  they have not had transportation projects, and therefore, have not needed to 
  determine conformity.
  Ten of the 18 survey respondents stated that there had never been a meeting 
  among all agencies for the area, while two respondents explained that they 
  have not needed consultation because the area has had no new projects. Three 
  respondents did not provide any information about consultation for their 
  isolated rural area.
  The three respondents that endorsed interagency consultation stated that the 
  process has been helpful in facilitating cross-functionality training and 
  resolving conformity issues. According to the Chief of EPA Region 4's Air 
  Planning Branch, interagency consultation has been very effective in Edmonson 
  County, Kentucky:
    Effective interagency consultation was the key to resolving this issue and 
    could have been used as the means to prevent any delay from occurring. 
    Because of this area's limited experience with conformity and the nature of 
    how transportation conformity is implemented in isolated rural areas (i.e., 
    until projects are seriously contemplated there is no need to do conformity 
    analysis), planning parties may not have allowed time for any resolution to 
    potential issues, and may not have effectively consulted with parties who 
    could work to resolve issues until there was no choice but for delay. In 
    this case, it was not until the area ran the conformity analysis and was not 
    able to demonstrate conformity to a budget developed with the Mobile 4.1 
    emissions model that the area realized that it would be beneficial for them 
    to have mobile emissions budgets developed with the new Mobile 5 emissions 
    model. The efforts for developing new emissions budgets is not extremely 
    burdensome but does require planning, review and approval on the part of 
    various agencies that may not have been alerted to this situation until it 
    was too late. 
    The Kentucky Transportation Cabinet and air quality partners in the Edmonson 
    County have gained a lot from their interagency coordination and communicate 
    on at least a monthly basis on this area and other areas in Kentucky, even 
    though the area has successfully demonstrated conformity. The partners are 
    taking a more proactive approach and discuss any upcoming projects that may 
    be considered for Edmonson County. In fact, this interagency consultation 
    discussion prevented KYTC (the Kentucky Transportation Cabinet) from 
    performing conformity analysis unnecessarily for Edmonson County in the 
    beginning of 2002. KYTC was under the impression that conformity 
    determinations for isolated rural areas have a three year expiration just as 
    in metropolitan areas. When this topic was discussed on the monthly 
    interagency consultation call, Kentucky transportation and air quality 
    partners were able to discuss and resolve this issue prior to KYTC beginning 
    work for this conformity determination.
    In this area, interagency consultation has been very beneficial. We all have 
    a better understanding of the role of each consultation partner with regard 
    to conformity. The air quality agencies are gaining more knowledge of the 
    transportation planning process, and the transportation agencies are gaining 
    more knowledge of the air quality process.
  Most areas reported no new Federal non-exempt transportation projects in the 
  past five years.
  Consistent with their rural nature, 11 areas indicated no regionally 
  significant projects. Only three survey respondents reported non-exempt 
  transportation projects requiring conformity analysis over the past five 
  years.2 Each of the three areas only had one such project. 
  Two areas used an analysis period shorter than the required analysis period in 
  their conformity determination.
  Although conformity analysis requires a 20-year analysis period, two areas 
  reported a shorter timeframe. One area reported analysis 10 years into the 
  future; another reported analysis 15 years into the future. 



2 The remaining four survey respondents did not answer the survey question 
related to non-exempt transportation projects. While these could be areas that 
did not have non-exempt projects, it is possible that the survey respondent did 
not know the answer to the question.
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III. Identification of Isolated Rural Areas
Federal regulations separate rural areas into two types: isolated rural areas 
and donut areas. For purposes of this survey, the distinction between an 
isolated rural area and a "donut" area is as follows. An isolated rural area is 
an area that is not part of the emissions analysis of any Metropolitan Planning 
Organization's (MPO) transportation plan or transportation improvement program 
(TIP). A "donut" area, on the other hand, is an area that is inside a 
non-attainment or maintenance area boundary, but is outside the metropolitan 
planning boundary (40CFR93.109(g)).
The following tables show the rural areas currently (March 2003) in 
non-attainment status.
  Exhibit III-1: Carbon Monoxide Nonattainment or Maintenance Rural Areas
  (March 2003)StateEPA RegionIsolated Rural AreasDonut Areas
      Alaska10Fairbanks 
      Oregon Grants Pass
      Klamath Falls 



  Exhibit III-2: Ozone Nonattainment or Maintenance Rural Areas (March 
      2003)StateEPA RegionIsolated Rural AreasDonut Areas
      Connecticut1Windam County (Greater Connecticut Area) 
      Maine1Hancock & Waldo CountiesCumberland County (Greater Portland Area)
      Knox & Lincoln Counties 
      New Hampshire1Cheshire County 
      New York2Essex County
      Jefferson CountyMontgomery and Greene Counties (Albany-Schenectady-Troy 
      Area)
      Maryland3Kent & Queen Anne's CountiesCalvert and Charles Counties 
      (Washington, DC-MD-VA)
      Virginia3White Top Mountain (Smith County) 
      Delaware3Sussex County 
      Pennsylvania3Crawford County
      Franklin County
      Juanita County
      Lawrence County
      Northumberland County
      Schuylkill County
      Snyder County
      Susquehanna County
      Warren County
      Wayne County 
      Virginia3White Top Mountain (Smith County) 
      West Virginia 3Greenbrier County 
      Georgia4 Coweta, Forsyth and Paulding Counties (Atlanta Area)
      Kentucky4Edmonson CountyPortion of Hancock County (Owensboro area)
      Paducah (Livingston and Marshall Counties)Scott County (Lexington Area)
      South Carolina4Cherokee County 
      Tennessee4 Rutherford, Sumner, Williamson and Wilson Counties (Nashville 
      area)
      Michigan5Allegan County 
       Muskegon
      Ohio5Clinton CountyAshtabula and Portaqe Counties (Cleveland-Akron-Lorain 
      area)
      Columbiana County 
      Preble County 
       Delaware and Licking Counties (Columbus area)
       Greene and Miami Counties (Dayton-Springfield area)
       Stark County (Canton area)
      Louisiana6Grant Parish
      Lafourche Parish
      St. James Parish
      St. Mary Parish 



  Exhibit III-3: PM-10 Nonattainment or Maintenance Rural Areas 
      (2003)StateEPA RegionIsolated Rural AreasDonut Areas
      Maine1Presque Isle (Aroostook County) 
      Illinois5Oglesby (La Salle County) 
      Indiana5Vermillion County 
      New Mexico6 Anthony (Dona Ana County)
      Colorado8Telluride (San Miquel County)
      Pagosa Springs (Archuleta County)
      Canon City (Fremont County)
      Aspen (Pitkin County)
      Lamar (Prowers County)
      Steamboat Springs (Routt County) 
      Montana8Columbia Falls (Flathead County)
      Whitefish and vicinity (Flathead County)
      Kalispell (Flathead County)
      Polson (Lake County)
      Libby (Lincoln County)
      Lame Deer (Rosebud County)
      Thompson Falls and vicinity (Sanders County)
      Ronan area (Lake County)
      Butte (Silver Bow County)Ronan
      Wyoming8Sheridan County 
      Arizona9Douglas (Coachise County)
      Paul Spur (Coachise County)
      Hayden/Miami (Gila and Pinal Counties)
      Payson (Gila County)
      Mohave County 
      Nogales (Santa Crus County) 
      California9Mammoth Lake (Mono County)
      Owens Valley (Inyo County)
      Mono Basin (Mono County) 
      Alaska10Juneau 
      Idaho10Sandpoint (Bonner County)
      Shoshone County (excluding Pinehurst)

      Pinehurst (Shoshone County) 
      Oregon10Lake County
      Grants Pass (Josephine County)
      LaGrande (Union County)
      Klamath County (Klamath Falls area) 
      Washington10Wallula (Walla Walla County) 

The study team surveyed a sample of the isolated rural areas identified in the 
exhibit.
IV. Survey Results
The survey was administered to a sample of the carbon monoxide, ozone, or PM-10 
nonattainment or maintenance isolated rural areas. The survey was sent to 41 
isolated rural areas: 2 carbon monoxide nonattainment or maintenance areas, 6 
ozone nonattainment or maintenance areas, and 34 PM-10 nonattainment areas. 
(Grant's Pass, Oregon is both a carbon monoxide maintenance area and a 
particulate matter nonattainment area.) For each area, the survey was sent to 
the corresponding:
  State department of transportation (DOT). 
  State and/or local air quality agency. 
  FHWA Division and EPA Regional offices. 
A total of 18 surveys were completed, for an overall response rate of 43 
percent. However, response rates differed according to pollutant: 100 percent 
for ozone; 50 percent for carbon monoxide; and 32 percent for particulate 
matter-10. Below are general conclusions from all surveys, as well as 
conclusions drawn for each of the pollutants.
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A. Carbon Monoxide
Only one of the two carbon monoxide maintenance or nonattainment areas responded 
to the survey, as shown in Exhibit IV-1. 
  Exhibit IV-1: Carbon Monoxide Nonattainment and Maintenance Isolated Rural 
  AreasStateCountyArea NameStatusClassEPA RegionCompleted Survey
      AlaskaFairbanks EdFairbanksNonattainmentSerious10No
      OregonJosephineGrants PassMaintenanceN/A10Yes

Over 50 percent of Grants Pass's carbon monoxide emissions is caused by on-road 
mobile sources. VMT is projected to grow 0.8 percent per year between 1993 and 
2015, as determined by a model developed in collaboration between the Rogue 
Valley Council of Governments and the Oregon Department of Transportation. 
Grants Pass has a maintenance SIP, which contains one transportation control 
measure: wintertime oxygenated fuel. The survey respondents also indicated that 
the one federal action that has helped the area maintain air quality standards 
is improved vehicle emissions standards on new cars.
Grants Pass used the less than 1990 test and the build/no-build test in its last 
conformity determination. For years beyond the timeframe of the SIP, Grants Pass 
uses the budget test and demonstration using air quality modeling. It is not 
clear from the survey responses why Grants Pass appears to have used both the 
budget test and an air quality modeling demonstration for conformity in years 
past the SIP. 
Grants Pass, like all Oregon local jurisdictions, is required to develop a 
transportation system plan (TSP) and receives financial support to do so. This 
requirement has likely led to an improved capacity to handle planning efforts 
such as the conformity process.
While the sample size for carbon monoxide nonattainment and maintenance areas is 
small, there may be opportunity for Fairbanks to learn from Grants Pass. Since 
both areas are in EPA Region 10, EPA officials could coordinate a meeting 
between officials in both areas.
  Comments on the Process
  A survey respondent from the FHWA Division office made the following comment:
    The FHWA Division must rely heavily on the Oregon DEQ and USEPA for 
    information on how and when areas are designated as non-attainment or 
    maintenance areas and how conformity needs to be addressed in each. If new 
    guidance were developed, the most useful would be something that could make 
    it easier to track the status of each specific area. Often when changes in 
    requirements are published in the Federal Register, it can be difficult and 
    time consuming to determine which areas are impacted and the actions that 
    may be needed.
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B. Ozone
All six isolated rural areas in nonattainment or maintenance for ozone, in the 
survey sample, completed the survey. The areas are listed in Exhibit IV-2.
  Exhibit IV-2: 2002 Ozone Nonattainment and Maintenance Isolated Rural Areas 
      StateCountyArea NameStatusClassEPA RegionCompleted Survey
      DelawareSussexSussex CountyNonattainmentMarginal3Yes
      KentuckyEdmonsonEdmonson CountyMaintenanceN/A4Yes
      Livingston and MarshallPaducahMaintenanceN/A4Yes
      New YorkEssexEssex CountyNonattainmentMarginal2Yes
      VirginiaSmythWhite Top MountainNonattainmentMarginal3Yes
      West VirginiaGreenbrierGreenbrier CountyNonattainmentN/A3Yes

Four ozone nonattainment or maintenance areas have SIPs; two areas (White Top 
Mountain and Sussex County) do not. For emissions dealing with ozone, areas list 
precursors: nitrogen oxides (NOx) and/or hydrocarbons (VOC). On-road mobile 
sources of NOx ranged from 0 percent for White Top Mountain to 87 percent for 
Greenbrier County. On-road mobile sources of VOC ranged from 0 percent for White 
Top Mountain to 53 percent for Greenbrier County. Exhibit IV-3 shows the full 
results of the survey.
  Exhibit IV-3: Percentage of Emissions from On-road Mobile SourcesArea 
      NameNOx VOC
      Sussex County 21%22%
      Edmonson County63%36%
      Paducah, Kentucky33%3%
      Essex CountyN/AN/A
      White Top Mountain0%0%
      Greenbrier County87%53%
      Notes:N/A = not reported

      Sussex County, White Top Mountain, and Greenbrier County use 1990 data. 
      Paducah and Edmonson County use 2002 data.

Using historical data from the federal Highway Performance Monitoring System 
(HPMS), VMT growth in Edmonson County is determined to be 2.28 percent annually 
from 2000 to 2020. HPMS data was also used to determine the annual increase of 
VMT in Paducah, which is 2.05 percent for Marshall County and 2.11 percent for 
Livingston County. None of the other areas reported VMT information, and none of 
the four areas with a SIP employ transportation control measures. However, 
several areas listed federal actions that have helped the area attain or 
maintain the air quality standards. Exhibit IV?4 lists those effective federal 
measures cited by the areas.
  Exhibit IV-4: Effective Federal Measures for Attaining or Maintaining Air 
  Quality StandardsArea NameMeasures Cited
      Sussex CountyNone.
      Edmonson CountyAll measures, including federal vehicle emission controls 
      and fleet turnover.
      PaducahFleet turnover, non-road rules, the national low emission vehicle 
      program (NLEV), and heavy duty diesel program.
      Essex CountySection 126 rule for NOx transport.
      White Top MountainNone.
      Greenbrier CountyFederal Motor Vehicle Control.Program (FMVCP), Heavy Duty 
      Diesel Rule, and small spark ignition gasoline engines.

For those areas with SIPs, Exhibit IV-5 lists conformity tests used both in 
their conformity determination and in the years beyond the timeframe of the SIP. 
(Only two areas provided information.)
  Exhibit IV-5: Conformity TestsAreaLast DeterminationDeterminations in 
      Years Beyond Timeframe of SIP
      Budget testLess than 1990 testBuild/no build testNo-greater-than 1990 
      testBudget testLess than 1990 testBuild/no build testNo-greater-than 1990 
      testDemonstration using air quality modeling
      Edmonson CountyX   X    
      PaducahX   X    
      Total Number2   2    

Both Edmonson County and Paducah reported having non-exempt transportation 
projects in the past five years. Edmonson determined conformity for its project 
in 1999. Paducah failed in 1998 to determine conformity due to an increase in 
VMT, but eventually the area was able to make a conformity determination in 
Spring 2002 after revising its SIP to incorporate new data.
  Comments on the Process
  A state transportation engineer commented on the survey: "A recent ruling that 
  an isolated rural area need only do conformity when adding a new project will 
  help." The same engineer noted that "It doesn't seem appropriate to be 
  spending so many resources and creating local headaches over adding a minor 
  amount of VMT when the mobile contribution to pollution in the area is so 
  small anyway. For most isolated rural areas, the primary contribution is 
  likely coming from outside the area, so why not focus attention and resources 
  on the real problem?" 
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C. Particulate Matter-10
Only 11 of the 34 PM-10 nonattainment and maintenance areas, in the survey 
sample, completed the survey, as shown in Exhibit IV-6.
  Exhibit IV-6: 2002 PM-10 Isolated Rural Nonattainment and Maintenance 
      AreasStateCountyArea NameStatusClassEPA RegionCompleted Survey
      MaineAroostookPresque IsleMaintenanceN/A1Yes
      ColoradoSan MiguelTellurideMaintenanceN/A8No
      ArchuletaPagosa SpringsMaintenanceN/A8No
      FremontCanon CityMaintenanceN/A8No
      PitkinAspenNonattainmentModerate8No
      ProwersLamarNonattainmentModerate8No
      RouttSteamboat SpringsNonattainmentModerate8No
      MontanaFlatheadColumbia FallsNonattainmentModerate8No
      FlatheadFlathead County; Whitefish and vicinityNonattainmentModerate8No
      FlatheadKalispellNonattainmentModerate8No
      LakePolsonNonattainmentModerate8No
      LincolnLibbyNonattainmentModerate8No
      RosebudLame DeerNonattainmentModerate8No
      SandersSanders County (part); Thompson Falls and 
      vicinityNonattainmentModerate8No
      Silver BowButteNonattainmentModerate8No
      WyomingSheridanSheridanNonattainmentModerate8Yes
      ArizonaCochiseDouglasNonattainmentModerate9No
      CochisePaul SpurNonattainmentModerate9No
      GilaHayden/MiamiNonattainmentModerate9No
      GilaPaysonNonattainmentModerate9No
      MohaveMohave CountyNonattainmentModerate9No
      PinalHayden/MiamiNonattainmentModerate9No
      Santa CruzNogalesNonattainmentModerate9No
      CaliforniaMonoMammoth LakeMaintenanceN/A9Yes
      InyoOwens ValleyNonattainmentSerious9Yes
      InyoSearless ValleyNonattainmentModerate9Yes
      MonoMono BasinNonattainmentModerate9Yes
      AlaskaJuneau EdJuneauNonattainmentModerate10No
      IdahoBonnerSandpointNonattainmentModerate10Yes
      ShoshonePinehurstNonattainmentModerate10Yes
      OregonLakeLake CountyNonattainmentModerate10Yes
      JosephineGrants PassNonattainmentModerate10Yes
      UnionLaGrandeNonattainmentModerate10Yes
      WashingtonWalla WallaWallulaNonattainmentSerious10No

All 11 PM-10 nonattainment or maintenance areas reported having a SIP. The 
contribution of emissions from on-road mobile sources to the areas' air quality 
problem varied and was difficult to determine in some areas. For Presque Isle, 
Maine, on-road mobile-sources, including road dust, was estimated to be 61% of 
the area's total PM inventory in 1994; more recent estimates show that the 
percentage of direct emissions only is estimated at 7.3 percent. For Mammoth 
Lakes, direct emissions from transportation sources has been determined to be 
less than 1%, however, emissions from resuspended road dirt and cinders is 
estimated to be 56.1% of the areas' emissions inventory. Unfortunately, survey 
information did not indicate what percentage of the resuspended road dirt was 
from roads versus what percentage is from cinders. Exhibit IV-7 illustrates the 
percentage of on-road mobile emissions by area.
  Exhibit IV-7: Percentage of Emissions from On-road Mobile SourcesArea 
      NameYear of InventoryPM-10
      Presque Isle (Maine)199461*
      Sheridan (Wyoming)1988N/A
      Mammoth Lake (California)1988Less than 1
      Owens Valley (California)1995Less than 1
      Searless Valley (California)N/ALess than 1
      Mono Basin (California)N/ALess than 1
      Sandpoint (Idaho)19943
      Pinehurst (Idaho)19882
      Lake County (Oregon)N/AN/A
      Grants Pass (Oregon)198610
      LaGrande (Oregon)19865
      Notes:N/A = not available

An interview with Presque Isle revealed problems with the 1994 measurement, 
which included road sand with on-road mobile sources. The percentage of direct 
emissions from on-road mobile sources is 7.3 percent.
However, several areas listed TCMs, shown in Exhibit IV-8.
  Exhibit IV-8: Transportation Control MeasuresArea NameTCM Cited
      Presque Isle (Maine)Removing de-icing and anti-icing materials as soon as 
      possible from roads.
      Sheridan (Wyoming)Limiting sand and gravel usage and removing them as soon 
      as possible from a road after snow.
      Mammoth Lake (California)Restricting parking, increasing transit 
      ridership, and reducing vehicle traffic.
      Owens Valley (California)None.
      Searless Valley (California)None.
      Mono Basin (California)None.
      Sandpoint (Idaho)Aggressive street sweeping program and anti skid material 
      specs.
      Pinehurst (Idaho)None.
      Lake County (Oregon)Paving gravel roads.
      Grants Pass (Oregon)None.
      LaGrande (Oregon)Controlling fugitive dust (winter road sanding, paving 
      gravel streets, etc.).

Interestingly, the most frequently listed TCMs do not fit the commonly used 
definition of TCM, which includes actions to adjust traffic patterns or reduce 
vehicle use. Only three of the 11 areas that responded to the survey noted 
effective federal measures relating to VMT and tailpipe emissions, as reflected 
in Exhibit IV-9.
  Exhibit IV-9: Effective Federal Measures for Attaining or 
  Maintaining Air Quality StandardsArea NameMeasures Cited
      Presque Isle (Maine)None.
      Sheridan (Wyoming)None.
      Mammoth Lake (California)VMT cap, phase out of non-certified wood stoves 
      and fireplaces, mandatory wood burning curtailment.
      Owens Valley (California)N/A
      Searless Valley (California)N/A
      Mono Basin (California)N/A
      Sandpoint (Idaho)Tier II, CAFE standards, OBD etc. -- improving fuel 
      economy and emission rates.
      Pinehurst (Idaho)Tier II, CAFE standards, OBD etc. -- improving fuel 
      economy and emission rates.
      Lake County (Oregon)CMAQ funds used to pave gravel roads (to reduce 
      transportation-related fugitive dust).
      Grants Pass (Oregon)N/A
      LaGrande (Oregon)Reducing transportation-related fugitive dust by paving 
      gravel roads.
      Notes:N/A = not available

Only three PM-10 nonattainment areas reported having ever made a conformity 
determination, and only one of these areas has done so within the last five 
years. All three cited the build/no build test in their latest determination, 
and two of the three noted the build/no build test in years beyond the timeframe 
of their SIP. Exhibit IV-10 summarizes the responses.
  Exhibit IV-10: Conformity TestsAreaLast DeterminationConformity in 
      YearsBeyond Timeframe of SIP
      Budget testLess than 1990 testBuild/no build testNo-greater-than 1990 
      testBudget testLess than 1990 testBuild/no build testNo-greater-than 1990 
      testDemonstration using air quality modeling
      Sandpoint (Idaho)  X   X  
      Pinehurst (Idaho)  X   X  
      Grants Pass (Oregon) XX     X
      Total Number 13   2 1

Only Sandpoint reported having a non-exempt transportation project in the past 
five years. It determined conformity for its project in 2000.
  Comments on the Process
  According to a Division FHWA Transportation Engineer who completed the survey:
    Rural areas by their very nature (small, sparsely populated, relatively low 
    traffic volumes and densities, and infrequent capacity expansion projects) 
    should have minimal transportation related air quality problems. To the 
    extent that the above generalization is accurate, it begs the question of 
    why a regional level analysis is currently expected for such areas. Perhaps 
    consideration should be given to evaluating, and as necessary, analyzing 
    such areas at the project level, only. Since there is no PM-10 modeling 
    process, this would effectively limit the analysis to CO.
  According to a state environmental agency transportation specialist who 
  completed the survey:
    One of the biggest holes in modeling transportation emissions for conformity 
    purposes is VMT and speeds. Transportation and Air Quality agencies often 
    must rely on minimal or spotty data to base speed and VMT assumptions. As an 
    example, the statewide transportation emissions inventory is based on VMT 
    extrapolated from Federal Highways Statistics. The conformity process and 
    the quality of associated air quality analysis would be vastly improved with 
    consistent and reliable VMT and speed data. Rural areas would greatly 
    benefit if FHWA could expand the monitoring done for the Federal Highways 
    Statistics.
Back to Table of Contents


Appendix A: Survey

This appendix contains a copy of the survey used to collect the data for this 
report.
FHWA Transportation/Air Quality Issues in Rural Areas
Background
FHWA is interested in assessing how isolated rural areas that have been 
designated non-attainment or maintenance for one or more air quality standards 
are addressing their transportation conformity related issues. FHWA has assigned 
Dye Management Group, Inc. the task of identifying and describing current 
practices. FHWA and EPA are considering developing additional guidance on how to 
conduct conformity determinations in these areas, so your responses are 
important to us. As part of this effort, we are seeking your collaboration to 
participate in a survey.
The three main questions we hope to answer through this survey are:
  Why are these isolated rural areas in non-attainment or maintenance (i.e., 
  what are the main sources contributing to their air quality problems)? 
  Who is involved in the transportation planning and conformity processes for 
  these isolated rural areas and what are each agency's roles? 
  How are these air quality problems being addressed by the different agencies 
  involved? 
The attached questionnaire, a product of the substantial collaboration from the 
Federal Highway Administration (FHWA) and Environmental Protection Agency (EPA), 
was designed to gather information on the identified issues of interest. For 
each isolated rural area a questionnaire will be sent to the corresponding state 
department of transportation (DOT), the state and/or local air agency, the 
Division FHWA and Regional EPA offices, and any other applicable state or local 
agency.
Rural Areas Defined
By definition, an isolated rural non-attainment or maintenance area is not part 
of, or contiguous to, a metropolitan area having a population of 50,000 or more. 
In other words, if an area is inside a non-attainment or maintenance area 
boundary, but is outside of the metropolitan planning boundary, then it is 
considered a "donut area," not an isolated rural area (see 40 CFR 93.109(g)). An 
isolated rural area's transportation projects are not part of the emissions 
analysis of any MPO's transportation plan or TIP (see 40 CFR 93.109(g)). 
Isolated rural areas are not required under federal regulation to establish a 
Metropolitan Planning Organization (MPO) or to develop transportation plans and 
transportation improvement programs (TIP) as a result of their population size.

FHWA Transportation/Air Quality in Rural Areas
Questionnaire
Name: _______________________________________________________________
Position: _____________________________________________________________
Organization: _________________________________________________________
Telephone: __________________ E-mail:___________________________________
  General
  [Area Name] has been designated as a [nonattainment area or maintenance area] 
  for [ozone, carbon monoxide, or particulate matter-10].
  Please verify that the designation(s) and pollutant(s) listed above for this 
  area is/are correct. If not accurate please correct as appropriate.
  ____________________________________________________________________________________
  ____________________________________________________________________________________
  ____________________________________________________________________________________
  ____________________________________________________________________________________
  State Implementation Plan and Air Quality
    Does this area have a SIP? ______Yes ______ No 
    If this area has a SIP, what control measures in the SIP help the area show 
    attainment? 
    ____________________________________________________________________________________
    ____________________________________________________________________________________
    ____________________________________________________________________________________
    ____________________________________________________________________________________
    If this area has a SIP, what are the emissions inventories for each source 
    sector (e.g., on-road mobile, stationary, etc.) listed in the isolated rural 
    area's SIP? Please answer this question separately for each pollutant or 
    each precursor of each pollutant for which an area is designated. For your 
    response, please choose the inventory year closest to 2002 and indicate the 
    units for each pollutant / precursor (e.g., tons per day, tons per year). 
    Or, if available, copy and attach a table listing of the emissions 
inventory.

    Year of Inventory = ___________
    Units of Inventory = ___________
          Sector:Inventory:
          On-road mobile sources_______________________________
          Others? Please list._______________________________

    What federal actions/measures (e.g., federal vehicle emissions controls; 
    fleet turnover) are helping the area attain or maintain the air quality 
    standard(s)? 
    ____________________________________________________________________________________
    What is the projected population growth in this isolated rural area? Please 
    provide the growth rate and indicate over what period of time this rate 
    applies (e.g., 2000-2020). 
    ____________________________________________________________________________________
    ____________________________________________________________________________________
    What is the projected growth rate of vehicle miles traveled (VMT) in this 
    isolated rural area? Please indicate the time period for which the VMT rate 
    applies. 
    ____________________________________________________________________________________
    How is VMT information determined for this isolated rural area? 
    ____________________________________________________________________________________
    ____________________________________________________________________________________
    Is speed information determined? If so, how? 
    ____________________________________________________________________________________
    ____________________________________________________________________________________
    What agency determines the VMT and speed information for this isolated rural 
    area? 
    ____________________________________________________________________________________
    Have the difficulties in demonstrating conformity ever resulted in the area 
    not being able to implement/approve a new transportation project? 
    ___________ Yes ___________No
    If yes, for how long was this project delayed? (If a project has been 
    delayed on more than one occasion, please specify how long for each delayed 
    project.) 
    ____________________________________________________________________________________
  Transportation Planning and Conformity
    Is this isolated rural area implementing any transportation control measures 
    included in the SIP to address its air quality problem?              
    Yes________ No ________ 
    If so, what is/are the specific transportation control measures that this 
    area is implementing?
    ____________________________________________________________________________________
    Given that before a new Federal non-exempt project can be approved or funded 
    in an isolated rural area, a conformity determination is required. How many 
    non-exempt transportation projects for this isolated rural area in the past 
    5 years required FHWA/FTA approval? 
    2001 ________________________________________
    2000 ________________________________________
    1999 ________________________________________
    1998 ________________________________________
    1997 ________________________________________
    Did you determine conformity in any of these years: 
    1997 Yes_____________No, _______ if no, why not? 
    ___________________________________
    1998 Yes_____________No, _______ if no, why not? 
    ___________________________________
    1999 Yes_____________No, _______ if no, why not? 
    ___________________________________
    2000 Yes_____________No, _______ if no, why not? 
    ___________________________________
    2001 Yes_____________No, _______ if no, why not? 
    ___________________________________
    How many years into the future were analyzed for the last conformity 
    determination performed for this area? 
    ____________________________________________________________________________________
    What type of SIP(s) does this isolated rural area have and for what years do 
    they have motor vehicle emissions budgets (if applicable)? Please check all 
    that apply. 
          _______
          This area does not have a SIP 

          _______
          This area has a SIP, but it does not have motor vehicle emissions 
          budgets (e.g., a limited maintenance plan.)

          _______
          Attainment SIP.

          What are the budget years, if budgets exist: 
__________________________

          _______
          15 percent SIP.

          What are the budget years, if budgets exist: 
__________________________

          _______
          9 percent rate of progress SIP.

          What are the budget years, if budgets exist: 
__________________________

          _______
          Maintenance Plan.

          What are the budget years, if budgets exist: 
__________________________

    Which of the following conformity test(s) did the isolated rural area use in 
    its last conformity determination? Please mark all that apply. 
    _______ Budget test.
    _______ Less than 1990 test.
    _______ Build/no-build test.
    _______ No-greater-than 1990 test.
    Which method below is being used to determine conformity in the years beyond 
    the timeframe of the SIP? 
    _______ Budget test.
    _______ Build/no-build test.
    _______ Less than 1990 test.
    _______ No-greater-than 1990 test.
    _______ Demonstration using air quality modeling (same modeling used in the 
    SIP).
    What agency runs the emissions analysis for this isolated rural area? What 
    agency prepares the travel estimates (e.g., estimating VMT)? 
    ____________________________________________________________________________________
    How many times since January 1997 has this isolated rural area determined 
    conformity? What were the dates (month and year) on which the conformity 
    determination was made for this area? 
    Number of determinations since 1997: 
    _________________________________________
    Dates on which these conformity determinations were made: 
    _________________________________
    What triggered the need for these conformity determinations? A new 
    transportation project, or some other reason? 
    ____________________________________________________________________________________
    ____________________________________________________________________________________
    Has this isolated rural area ever had difficulty demonstrating conformity 
    (i.e., they cold not pass their conformity test as listed above)? If answer 
    to this question is No, please skip to question 3-l below. 
    ______ Yes _______ No
    For what analysis years did this area have difficulty demonstrating 
    conformity? 
    ____________________________________________________________________________________
    What was the nature of this area's conformity difficulties? Please check all 
    that apply. 
    ________ Population grew faster than anticipated.
    ________ New data/information on fleet resulted in higher emissions.
    ________ Control measures ended because of a sunset date. If yes, which 
    measures?
    ____________________________________________________________________________________
    ________ Control measures ended with the end of the SIP. If yes, which 
    measures?
    ____________________________________________________________________________________
    Other? Please explain briefly: 
    ____________________________________________________________ 
    ____________________________________________________________________________________
    Why was this area not able to meet the SIP budget(s)? Please check all that 
    apply. 
    ________ SIP was based on an earlier version of emissions factor model.
    ________ SIP was based on older data that was updated for the conformity 
    determination.
    ________ Area was experiencing unanticipated growth. 
    ________ A control measure not being implemented; which measure? 
    ____________________________________________________________________________________
    Other? Please explain. 
    ____________________________________________________________________________________
    If this area has experienced conformity difficulties, have the difficulties 
    been successfully addressed and resolved? ______ Yes ______ No. 
    If yes, what factors contributed to this outcome? (Choose all that apply 
    from the two categories below: Revision to SIP and Revisions Transportation 
    Projects.)
    Revision to SIP
    _________ Identifying a safety margin and applying some or all of it to the 
    budget.
    _________ Adding transportation control measures in the SIP. Which measures? 

    _________ Adding emission reduction control measures. Which measures?
    ____________________________________________________________________________________
    _________ Updating the budget with new data (e.g., population, employment, 
    etc.).
    _________ Updating the budget with a new emissions factor model.
    _________ Other? Please briefly explain:
    ____________________________________________________________________________________
    Revision to Transportation Projects
    _________ Eliminating, changing scope of or delaying transportation 
projects.
    _________ Adding transportation control strategies (but will not be included 
    in the SIP). Which strategies?
    ____________________________________________________________________________________
    _________ Adding other emissions reduction measures (not already in the 
    SIP). Which measures?
    ____________________________________________________________________________________
    _________ Adjusting assumptions for new federal rules (e.g., Tier 2 new 
    vehicle emissions standards). 
                       Which rules?
    ____________________________________________________________________________________
    _________ Other? Please briefly explain:
    ____________________________________________________________________________________
    What resources are available, in terms of number of staff, their skill level 
    and the amount of planning funds, at the local level to demonstrate 
    conformity to the SIP? 
    ____________________________________________________________________________________
  Interagency Consultation
    Who actually does the modeling and/or approves the conformity determination 
    for the isolated rural areas? 
    ____________________________________________________________________________________
    ____________________________________________________________________________________
    What federal, state and local agencies are involved in the consultation 
    process for this isolated rural area? 
    ____________________________________________________________________________________
    ____________________________________________________________________________________
    What are the consultation procedures for this isolated rural area? Please 
    check all that apply. 
          _______
          A meeting among all agencies is held prior to a conformity analysis 
          (i.e., when a new project is initiated). 

          _______
          A meeting among all agencies is held after the analysis is performed, 
          but prior to FHWA approval of the conformity determination. 

          _______
          A meeting among all agencies is only held if the conformity analysis 
          indicates that the area might have difficulty demonstrating 
conformity.

          _______
          There has never been a meeting among all agencies for this area. 

          _______
          Other? Please explain other consultation procedures applicable to this 
          area.

    ____________________________________________________________________________________
    ____________________________________________________________________________________
    ____________________________________________________________________________________
    ____________________________________________________________________________________
    Has the consultation process helped resolve difficulties related to 
    demonstrating conformity for a new project? 
    _____ Yes _____ No 
    Why or why not? Please briefly explain:
    ____________________________________________________________________________________
    ____________________________________________________________________________________
    Other Comments on the Process 
    ____________________________________________________________________________________
    ____________________________________________________________________________________
    ____________________________________________________________________________________
    ____________________________________________________________________________________
    ____________________________________________________________________________________
    ____________________________________________________________________________________
    ____________________________________________________________________________________
    ____________________________________________________________________________________
    ____________________________________________________________________________________
    ____________________________________________________________________________________
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