

MEMORANDUM

Date:		February 15, 2012
Subject:	Summary of EPA Regional Office Survey about MOVES Transition for Regional Conformity Analyses 
From:	Meg Patulski, State Measures and Transportation Planning Center, OTAQ
To:		Docket EPA-HQ-OAR-2011-0393

      In February 2011, EPA's Office of Transportation and Air Quality (OTAQ) surveyed its EPA Regional Offices to determine the status of state and local agency transition to using MOVES in regional conformity analyses.  This survey was based on a cursory review of existing information already available to the EPA Regions including:   
   * The status of discussions about the transition to MOVES through the interagency consultation process, 
   * Whether state and local agencies had gained competency and technical expertise in using MOVES for either regional conformity analyses or SIP development, and 
   * Any possible or anticipated revisions to SIP motor vehicle emissions budgets with MOVES.  
The information below summarizes the results of OTAQ's informal survey.
Overview:
      In February 2011, there were approximately 100 nonattainment and maintenance areas for the 1997 ozone national ambient air quality standard (NAAQS) and 37 nonattainment areas for the 1997 annual PM2.5 NAAQS in states outside of California.   Under the transportation conformity rule at that time, these areas were required to begin using MOVES in regional conformity analyses when the MOVES grace period ended in March 2012.  Many of these areas had already submitted state implementation plans (SIPs) based on MOBILE6.2.  EPA had already approved maintenance plans for nearly 70 ozone areas. 
1997 Ozone NAAQS Areas:
      Based on the results of the informal survey, approximately 80% of ozone areas (80 areas) needed additional transition time for regional conformity analyses with MOVES.  The remaining ozone areas (about 20 areas) involved miscellaneous situations, e.g., isolated rural areas that did not anticipate making a conformity determination in the near future. 
1997 Annual PM2.5 NAAQS Areas:
      Based on the results of the informal survey, approximately 81% of PM2.5 areas (30 areas) needed additional transition time for regional conformity analyses with MOVES.  The remaining PM2.5 areas involved miscellaneous situations, e.g., EPA had previously found regional emissions to be insignificant so a regional conformity analyses was no longer required. 
Additional Details: 
      The majority of ozone and PM2.5 areas had not yet begun to use MOVES for conformity purposes for several reasons.  Start-up issues included:  building technical capacity in-house at an MPO or obtaining staff elsewhere (e.g., from state DOT); other constraints on emissions modeling staff; and data collection and reformatting MOBILE data for use in MOVES.  Re-planning issues included having the necessary time (after a MOVES regional conformity analysis was completed) to either update the transportation plan and transportation improvement program and/or revise an existing approved or adequate MOBILE-based SIP motor vehicle emissions budget with MOVES.  Many Regions believed it would take at least a year (and sometimes longer) for states to update any SIP budgets with MOVES, once MOVES was used for regional conformity analyses.  States have different processes for developing SIPs depending on state law and other factors (e.g., accommodating interagency consultation and public involvement).  
