AgendaAlamo Area Council of Governments

Air Improvement Resources Technical Committee Meeting September 12, 2016 - 1:30 - 3:00 pm

Classroom 3-018700 Tesoro Drive

San Antonio, TX 78217-6228 

             

1. Meeting called to Order. 

2. Roll Call. 

3. Public CommentsThis time is for anyone to comment to the Advisory Committee on issues and items of concern. There will be nodeliberation or action on these comments. Time allowed is at the discretion of the Chairman, with three (3) minutesbeing customary.

 

4.   Discussion and appropriate action on the recommendation to Consider and act upon approvalof the July 11, 2016 minutes.

 

5.   Ozone Report 

6.   SIP 101 presentation by Dan Robicheaux, SIP Project Manager, TCEQ - Air Quality Planning. 

 

7.   Introduction to Transportation Conformity presentation by Tim Juarez, Metropolitan PlanningCoordinator, TXDOT - Transportation Planning & Programming Division

 

8. Next Meeting Date: 

A. Joint AIR Executive and Clean Air Force of Texas - Friday, Nov. 4, 2016, 10:00 am in San Marco 

B. Air Technical - Nov 11, 2016, 1:30 pm  

9. Adjournment. 

This meeting is accessible to people with disabilities. The accessible entrance is located at the front entrance of 8700 TesoroDrive. Accessible parking spaces are also available. Please contact AACOG for auxiliary aids and services for the hearingimpaired, including interpreters for the deaf, at (210) 362-5200 at least 48 hours prior to the meeting or by calling Texas Relay at7-1-1 for assistance.

Air Improvement Resources TechnicalCommittee Agenda Item # 4.

Meeting Date: 09/12/2016  Title: Consider and Act upon Approval of the July 11, 2016 Minutes

AGENDA ITEM DESCRIPTION:Discussion and appropriate action on the recommendation to Consider and act upon approval of the July11, 2016 minutes.

AttachmentsJuly 11, 2016 Minutes 

4. Consider and act upon approval of the July 11, 2016 minutes.

Minutes of the Alamo Area Council of Governments

Air Improvement Resources Technical Committee Meeting Monday, July 11, 2016 – 1:30 p.m. 8700 Tesoro Drive, Classroom 6-03

San Antonio, Texas 78217-6228

Present AIR Technical Committee Members Present AIR Advisory Members

Liza Meyer, Vice-Chair, City of San Antonio

Peter Bella, ImagineSA Angela Rodriguez, CPS Energy

Kyle Cunningham, SA Metro Health

Darcie Schipull, TxDOT

Al Rocha, San Antonio Water System

Andy Winter, Bexar County Steven Smeltzer, AACOG

Linda Vela, Alamo Area MPO

Guests Maria Gutierrez, Ph.D, JBSA Bill Frawley, TTI

Colin Leyden, Environmental Defense Fund Tim Juarez, TxDOT

Mario Bravo, Environmental Defense Fund

Mark Arvidson, JBSA

Ex-officio Members

Dan Robicheaux, TCEQ Austin

Members not present AACOG Staff

Andy Quittner, Chair, City of Sequin Alison Buck, VIA Metropolitan Transit Forrest Mims, Guadalupe County

Brenda Williams Nic Jones Lyle Hufsteteler

LeAnn Hosek, Wilson County

Maricela Díaz-Wells

Tom Hornseth, Comal County Lisy Velázquez Steven Smeltzer

Citizens to be Heard:

Ana Sandoval, Air Health Collaborative of

San Antonio

1. Meeting called to order Ms. Liza Meyer, AIR Technical Committee Vice Chair, called the meeting to order at 1:49 PM.

2. Roll call A quorum was achieved.

3. Citizens to be heard

4. Consider and act upon approval of the July 11, 2016 minutes.

There was a citizens to be heard. Ms. Ana Sandoval, Air and Health Collaborative of San Antonio, who said she will address her words on item 8A.

4. Approval of Minutes Ms. Darcie Schipull was unclear on item 8 on the approval of the May 9, 2016 minutes. Ms. Meyer said the last entry listed on item 3 should have read “The City of San Antonio proves San Antonio Tomorrow replace Mission Bexar Day with San Antonio Tomorrow,” instead of “The City of San Antonio proves San Antonio Tomorrow replace missing birth date with San Antonio Tomorrow.” Mr. Andy Winter made a motion, seconded by Ms. Darcie Schipull, to approve the May 9th, 2016 minutes with corrections. The motion carried unanimously.

5. Election of a 2nd Vice Chair. Ms. Meyer nominated Mr. Andy Winter to serve as 2nd Vice Chair. Ms. Meyer asked if there were any other nominations, and committee members did not have any other. Ms. Schipull made a motion, seconded by Ms. Kyle Cunningham, to approve Mr. Winter as 2nd Vice Chair. The motion carried unanimously.

6. Ozone Report

Mr. Steven Smeltzer reminded the committee that the 2014-2016 three year ozone average exceeds the standard, and as a result the area is in violation of the Clean Air Act. Mr. Smeltzer mentioned the region has two monitors, CAMS58 and CAMS23, that each have a three-year average of 71 ppb, which is not good for our region. Mr. Smeltzer updated the committee with information on CAMS58. He confirmed that an automated gas chromatograph (AutoGC) was recently installed at CAMS58, which has been collecting continuous ambient VOC data since June 1, 2016. With the CAMS58 AutoGC, VOC concentrations can now be measured continuously and since the monitor already records NOx, the monitor will be useful in analyzing the VOC/NOx sensitivity in ozone formation. Mr. Smeltzer reported that in regards to the boundary issues, the AIR Executive Committee made a recommendation to TCEQ, and the TCEQ Commissioners are scheduled to take up the boundary issue at their August 3, 2016 meeting. The agenda for the meeting is scheduled to be posted on July 15th.

A. H.R. 4775 – 114th Congress (2015-2016) – Ozone Standards Implementation Act of 2016

Mr. Smeltzer talked about H.R. 4775, which amends the Clean Air Act by revising the National Ambient Air Quality Standards (NAAQS) program. The bill delays the implementation of the ozone NAAQS (published in 2015) and extends until October 26, 2025, the deadline for the Environmental Protection Agency (EPA) to designate state areas as attainment, nonattainment, or unclassifiable areas with respect to the 2015 ozone NAAQS. Mr. Smeltzer reported that the bill also changes the review cycle for criteria pollutant NAAQS from a 5-year review cycle to a 10-year review cycle. The bill passed the House, is under review by the U.S. Senate, and has been referred to a Committee on Environment and Public Works.

7. Implementation of the Approved Bylaws. Ms. Maricela Díaz-Wells discussed work that was performed by AACOG staff subsequent to approval of the revised bylaws during the last AIR Executive Committee meeting (May 25), She informed the committee of the current actions that have taken place since the bylaws were approved which included, sending membership invitation letters, new officer elections for the Alternate Vice-Chairs on all committees, upcoming elections on all three committees in January 2017, an absent member report was created and a membership review was completed, the absent member report is updated monthly for tracking purposes. Ms. Díaz-Wells thanked all members for the designation documentation she had been receiving to ensure adequate information for all AIR Committees.

4. Consider and act upon approval of the July 11, 2016 minutes.

8. Other Items A. Consider and Act upon EPA’s new guidelines for methane gas emissions.

Mr. Colin Leyden, Environmental Defense Fund, presented the next item. He encouraged the committee to consider the resolution included in the meeting packet in support of the new standards for methane pollution, and then forward to the AIR Advisory and AIR Executive Committee for approval. Mr. Leyden summarized EPA’s new guidelines and actions for methane gas, which include three final rules that will curb emissions of methane, smog-forming volatile organic compounds (VOCs) and toxic air pollutants from new, reconstructed and modified oil and gas sources, while providing greater certainty about Clean Air Act permitting requirements for the industry. The EPA also carried out the Administration’s commitment to regulate methane emissions from existing oil and gas sources. Methane from oil and gas industry comes packaged with other pollutants: VOCs and several pollutants known as “air toxics.” On May 12, 2016, the EPA took steps under the President’s Climate Action Plan to cut methane emissions from the large oil and natural gas industry and keep the Administration on track to achieve its goal of cutting methane emissions from the oil and gas sector by 40-45% from 2012 levels by 2025. Ms. Ana Sandoval, Air and Health Collaborative of San Antonio, spoke as a Citizen to be Heard. She said that Air and Health Collaborative of San Antonio is a group of health, environmental and public health professionals concerned about the impacts of air pollution on human health in its community. As you know San Antonio currently suffers from ozone exceedances and moderate PM (Particulate Matter) levels, these conditions affect the most sensitive among our population on bad air quality days but chronically affect all of our population on most days. This is why we are concerned about air pollution’s concern on human health. Ms. Sandoval said she was at the AIR Technical Committee meeting to express support on item 8A, the resolution in support of EPA’s new guidelines for methane gas emissions, and she would like to commend the committee for exclusively acknowledging and prioritizing the importance of public health in this resolution, and she hopes to continue to see the committee consider and value the importance of human health in their future air quality planning activities. Mr. Leyden had a few things to add to the resolution, such as Clause 6, where it reads “upwind communities,” should read “downwind communities,” the correction would need to be made on the resolution and he is open to adding a clause on the resolution that relates to climate change and global warming. Ms. Meyers asked if AACOG would allow to assess or dedicate time to work on anything related to methane gas emissions. Ms. Brenda Williams replied that it is not on their grant. Ms. Meyers then asked if AACOG is on the TCEQ dollar at this moment and time, and Ms. Williams said yes. Therefore Ms. Meyer said to the committee that this is not an item for discussion at this meeting. She added that methane is not a criteria that they could discuss and it is not within the TCEQ contract. The committee asked if the VOCs (Volatile Organic Compounds) could be discussed, and Ms. Meyer replied that VOCs could be discussed, but methane as it stands, it could not be discussed. Ms. Meyer also said she was concerned that we would need to go back to our particular agencies, to ask if methane and climate change could be discussed. Mr. Leyden asked if that was applicable to the Clean Power Plan as well, and Ms. Meyer replied that Clean Power Plan is different as it relates to NOx and in this case, the climate action agenda is not something we can discuss. Mr. Leyden said that he is having difficulty seeing the difference between the Clean Power Plan, which addresses NOx, when this rule also addresses VOCs as a major component. Ms. Meyer replied that while it may seem to be indirect and a secondary pollutant, methane seems to be the main pollutant that he is addressing. Mr. Leyden encouraged Ms. Meyer to read the EPA materials available, and Ms. Meyer advised for Mr. Leyden to speak to AACOG on the limitations and restrictions on their scope, which does not include methane as a subject of discussion.

4. Consider and act upon approval of the July 11, 2016 minutes.

Ms. Schipull suggested for the item to be placed on the table for the next meeting and possibly have AACOG further research with TCEQ on that position. Ms. Meyer stressed the importance of knowing what AACOG can and cannot do with the state dollars and this discussion is not within their scope parameters. Ms. Díaz-Wells addressed the committee and said she believes that AACOG acts as an administrative agent to the committees and the committees are independent of AACOG, as they do not answer to the AACOG Board of Directors in any way. Ms. Meyer said, “But this is paid for by TCEQ dollars, there’s time, and your time is paid by TCEQ dollars, and you need to abide by those provisions within their contract.” Mr. Leyden asked if AACOG had violated the contract, and Ms. Williams replied no, AACOG had not developed nor presented the item, and no TCEQ dollars had been spent on the issue; however, AACOG can talk to TCEQ staff and ask for their opinion on the matter. Mr. Leyden asked what language should be used to reword the resolution, Ms. Meyer replied to replace anything related to methane and change it to VOC. Ms. Meyer said that we need to be sensitive to everyone’s agencies. Ms. Schipull said that due to her not being familiar with the rules or further implications, she would not be able to vote on this resolution today. After further discussion, the committee decided to table the item for the next AIR Tech Committee meeting, until there is further investigation on the resolution and having go back to everyone’s respective agencies. Ms. Darcie Schipull made a motion, seconded by Mr. Al Rocha. The motion carried unanimously.

B. Status of the Ozone Advance Update (Due at end of July) Ms. Williams gave a status on the Ozone Advance Update. She explained that the purpose of the Ozone Advance is to encourage regions in attainment to take early actions, as the program provides a structure for the emission reduction strategies. She encouraged members to provide updates to the strategies their respective organizations have/intend to implement and provide input on any other topics that should be included.

C. Status of the Cost of Non-Attainment RFP

Mr. Smeltzer gave a status on the Cost of Non-Attainment RFP. He mentioned the RFP was released on April 6, 2016 and was kept open for 30 days. Notices were sent to 60 different firms, with little results and due to this AACOG sent a request for quotation on a small purchase order and distributed to firms that expressed interest. One response was received and AACOG is currently working with the firm to complete the project. Mr. Smeltzer reported that he received an email from Mr. Forrest Mims which requested an item on the next agenda to inquire in regards to the importance of the cost of attainment, which is as important to the cost of non-attainment.

D. Anti-Idling Ordinance Update Mr. Andy Winter briefed on the Anti-idling Ordinance and mentioned that six representatives of Bexar County conducted outreach at truck stops by speaking to several truck drivers. He reported that most drivers were very cooperative and understanding in regards to the information given on anti-idling. Mr. Winter reported that Bexar County will return to counting idlers again and compare with the last results, to see if the strategy is working.

9. Next Meeting, Sept 12, 2016

The Committee will meet on Sept 12, 2016

10. Adjournment

4. Consider and act upon approval of the July 11, 2016 minutes.

There being no further business to discuss, there was a motion by Mr. Winter, seconded by Ms. Cunningham to adjourn the meeting. The meeting was adjourned at 2:42 p.m.

Air Improvement Resources TechnicalCommittee Agenda Item # 5.

Meeting Date: 09/12/2016  Title: Ozone ReportPresented by: Steven Smeltzer, Environmental Manager 

AGENDA ITEM DESCRIPTION:Ozone Report

DISCUSSION:Since April 8, 2016, San Antonio has been in violation of the 2015 ozone National Ambient Air QualityStandards (NAAQS). 

FINANCIAL IMPACT:N/A

RECOMMENDATION:N/A

AttachmentsOzone Report 

BACKGROUND/HISTORY: In October 2015, the Environmental Protection Agency (EPA) promulgated its revised ozone NAAQS. The annual fourth-highest daily maximum 8-hour concentration, averaged over three years, measured at each monitor within an area must not exceed 70 ppb. The chart below shows that the monitors at San Antonio Northwest C23 and Camp Bullis C58 each have a three-year average of 71 ppb.

* Current as of Sept. 12, 2016; ozone values validated by TCEQ through May

DISCUSSION: There have been two regionally significant elevated ozone events so far in 2016. These are events that have a major effect on the regional design value, but may not necessarily contain days that exceed 70 ppb. The first of these events in early April caused the preliminary (not yet validated by TCEQ) design value at CAMS 58 to exceed 70 ppb, despite the highest average 8-hour ozone being only 64 ppb. The second significant elevated ozone event occurred in the first week of May. CAMS 23 reported 8-hour ozone levels in excess of 70 ppb on two days: 73 ppb on 5/5 and 71 ppb on 5/6. Both of the events were discussed in greater detail at the last AIR Tech meeting. So far, the 2016 ozone season has been cleaner than the 11-year average (2005-2015) with only two days reporting 8-hour average ozone over 70 ppb at any monitor. For the first time since 2004, CAMS 58 has not recorded a maximum daily average 8-hour ozone in excess of 70 ppb in the first three months of ozone season. However, because of the 2015 ozone season, it did not take much for CAMS 58 to exceed the 70 ppb design value for 2016. Data from 2005 to 2015 show that there are two distinct peak periods during the ozone season. The first peak lasts from early May until the end of June. The second peak lasts from August until early October. The month of July has historically been the “cleanest” month of the ozone season. The graph below shows the seasonal distribution of > 60 ppb ozone days and > 70 ppb ozone days at CAMS 58 Camp Bullis. Although we are currently in the cleanest part of the ozone season, the statistically worst part of the season is still ahead. Late August is the semi-monthly period that has historically seen the greatest frequency of high ozone days. On average, we can expect between two and three days over 70 ppb at CAMS 58 during August 16 – 31.

Monitor Site 4th Highest Reading, ppb Current* 3 Year

Average 2014 2015 2016*

Camp Bullis C58 72 80 63 71

San Antonio NW C23 69 79 66 71

Calaveras Lake C59 63 68 60 63

The following graph shows the Design Value trend from 2006 to 2015. There has been a downward trend since 2013 at all monitors. The overall 10-year trend is also downward, but not consistently so.

Monitor Site 4th Highest Reading, ppb

Design Value 2013 2014 2015

Camp Bullis C58 83 72 80 78

San Antonio NW C23 76 69 79 74

Calaveras Lake C59 69 63 68 66

OTHER UPDATES:

An Automated Gas Chromatograph (AutoGC) has recently been installed at Camp Bullis CAMS

58. It has been collecting continuous ambient VOC data on 48 compounds since June 1, 2016.

The AutoGC is being maintained by Orsat, who also maintains the other two AutoGCs in the

AACOG region: CAMS 1038 in Floresville and CAMS 1070 in Karnes City. There is another

monitor that records 84 VOC concentrations in canister samples every 6th day at Old Hwy 90

CAMS 677. With an AutoGC now at CAMS 58, VOC concentrations downwind of the urban core

can now be measured continuously. Because CAMS 58 also records NOx, the monitor will be

useful in analyzing the VOC/NOx sensitivity in ozone formation.

FUTURE ATTAINMENT DESIGNATION:

Under section 107(d) of the Clean Air Act (CAA), the EPA will make the designations determinations and nonattainment area boundary decisions in the final action that designates all areas for the 2015 ozone standards. The guidance is located here: https://www.epa.gov/sites/production/files/2016-02/documents/ozone-designations-guidance-2015.pdf On Feb. 25, 2016, EPA provided guidance on area designations for the 2015 ozone national ambient air quality standards (NAAQS). The anticipated timeline of important milestones to the initial ozone area designations process for the 2015 ozone NAAQS are provided below.

Anticipated Timeline for the 2015 Ozone NAAQS Designations Process

Milestone Date

The EPA promulgates 2015 Ozone NAAQS October 1, 2015

States submit recommendations for ozone designations to the EPA

No later than October 1, 2016

The EPA notifies states concerning any intended modifications to their recommendations (120-day letters)

No later than June 2, 2017

The EPA publishes public notice of state recommendations and the EPA’s intended modifications and initiates 30 day public comment period

On or about July 10, 2017

States submit additional information to respond to the EPA’s modifications of a recommended designation

No Later than August 7, 2017

The EPA promulgates final ozone area designations No later than October 1, 2017

The EPA recommends that States refer to the following for area designations for the 2015 Ozone NAAQS when preparing their recommendations on area designations. The five factors identified in the Guidance for Area Designations for the 2015 Ozone NAAQS are listed below, along with data and data sources that may be useful in evaluating each area on a case-by-case basis and in making boundary recommendations. The following is not an exclusive list of factors, data, or sources of data that could be considered in assessing an area. EPA is providing this list as a useful tool for the designations process, and it should not be construed as representing a decision by EPA to rely solely on this list for final designation determinations. EPA intends, at a minimum, to evaluate these factors, data and/or data sources in making final determinations regarding area designations for the 2015 Ozone NAAQS. If a state does not submit designation recommendations, then the EPA will promulgate the initial designations that the agency deems appropriate. Factor 1: Air Quality Data:

The air quality analysis is an examination of available ambient ozone air quality monitoring data, including the annual design value calculated for each area based on air quality data for a 3-year period.

Factor 2: Emissions and Emissions-Related Data:

The emissions analysis examines emissions of precursors (NOX and VOCs) that form ozone in the county with the violating monitor and in nearby counties. Emissions data indicate the potential for a source to contribute to observed violations, making it useful in assessing boundaries of nonattainment areas.

Factor 3: Meteorology: The evaluation of meteorological data helps to determine the effect on the fate and transport of emissions contributing to ozone concentrations and to identify areas potentially contributing to the monitored violations. One basic meteorological analysis involves assessing potential source-receptor relationships in the area using summaries of emissions, wind speed, and wind direction data. A more sophisticated assessment involves modeling air parcel trajectories to help understand complex transport situations. The HYSPLIT (HYbrid Single-Particle Lagrangian Integrated Trajectory) modeling system may be useful for some areas to produce trajectories that illustrate the 3-dimensional paths traveled by air parcels to a violating monitor.

Factor 4: Geography/Topography:

The geography/topography analysis includes an examination of physical features of the land that might define the airshed and, therefore, affect the formation and distribution of ozone over an area. Additional analyses may consider topographical features that cause local stagnation episodes via inversions.

Factor 5: Jurisdictional Boundaries:

Existing jurisdictional boundaries may be considered for the purposes of providing a clearly defined legal boundary and carrying out the air quality planning and enforcement functions for nonattainment areas. Examples of jurisdictional boundaries include, but are not limited to: counties, air districts, metropolitan planning organizations, and existing nonattainment areas. If an existing jurisdictional boundary is used to help define the nonattainment area, it must encompass all of the area that has been identified as meeting the nonattainment definition. Where existing jurisdictional boundaries are not adequate to describe the nonattainment area, other clearly defined and permanent landmarks or geographic coordinates should be used.

TCEQ Commissioners are schedule to take up the boundary issue at their August 3, 2016 meeting. The agenda for the meeting is scheduled to be posted on July 15 and will be available at https://www.tceq.texas.gov/agency/agendas/comm

Air Improvement Resources TechnicalCommittee Agenda Item # 6.

Meeting Date: 09/12/2016  Title: SIP 101

AGENDA ITEM DESCRIPTION:SIP 101 presentation by Dan Robicheaux, SIP Project Manager, TCEQ - Air Quality Planning. 

DISCUSSION:“A SIP is an enforceable plan developed at the state level that explains how the state will comply with airquality standards according to the Federal Clean Air Act. The Federal Clean Air Act (FCAA) is the legal foundation for the national air pollution control program.The FCAA requires each state to produce and regularly update a SIP. The FCAA also requires that SIPsinclude a description of control strategies, or measures to deal with pollution, for areas that fail to achievenational ambient air quality standards (NAAQS). Finally, this Act grants powers of enforcement to theEPA.The FCAA grants the EPA power to establish national air quality standards, to approve or rejectSIPs, to replace SIPs with federal implementation plans (FIPs) when deemed necessary, and to monitorachievement of goals laid out in SIPs and FIPs. National Ambient Air Quality Standards (NAAQS) are established by the EPA as directed by the FCAA.These standards measure six outdoor air pollutants:

ground-level ozone (O3) particulate matter (PM) lead (Pb) nitrogen dioxide (NO2)carbon monoxide (CO)sulfur dioxide (SO2) 

 These "criteria pollutants" are commonly occurring air pollutants that can injure health, harm theenvironment and cause property damage. The NAAQS set nationally acceptable levels of concentrationsof these pollutants. Since SIP revisions are mandatory in nonattainment areas, or areas that fail to meet(or attain) the NAAQS, the need for SIP revisions is based on NAAQS.”[1]

[1] TCEQ, June 15, 2016. “SIP: Introduction”. Austin, Texas. Available online: http://www.tceq.state.tx.us/airquality/sip/sipintro.html.Accessed: 09/07/2016.

FINANCIAL IMPACT:N/A

RECOMMENDATION:N/A

AttachmentsSIP 101 

AACOG AIR Technical Committee • SIP 101 • September 12, 2016 • Page 1

SIP 101

Air Quality Division

Dan RobicheauxSIP Team, Air Quality Planning Section,

Air Quality Division

Presented to the AACOG AIR Technical Committee

September 12, 2016

AACOG AIR Technical Committee • SIP 101 • September 12, 2016 • Page 2

Overview

• Ozone NAAQS and Designations

• Implementation of the Standard

• Potential Marginal Nonattainment

• Conformity (Transportation and General)

• Requirements for Higher Classifications

AACOG AIR Technical Committee • SIP 101 • September 12, 2016 • Page 3

2015 Eight-Hour Ozone NAAQS

• On October 1, 2015, the EPA lowered the National Ambient Air Quality Standard (NAAQS) for ground-level ozone to 70 parts per billion (ppb).

• Based on preliminary air monitoring data for 2015, the Dallas-Fort Worth, Houston-Galveston-Brazoria, San Antonio, and El Paso areas are measuring levels above the 2015 ozone standard. – State recommendations based on the 2015 Design

Value – Final EPA designation expected to be based on the

2016 Design Value

AACOG AIR Technical Committee • SIP 101 • September 12, 2016 • Page 4

Recommended Nonattainment Areas Under the 2015 Ozone Standard

AACOG AIR Technical Committee • SIP 101 • September 12, 2016 • Page 5

State Designation Recommendations

• Approved by the commission on August 3, 2016, the recommendation has been submitted to the governor’s office for consideration.

• Recommendations are due to the EPA by October 1, 2016.

• The EPA’s 120-day notice is expected on June 2, 2017.

AACOG AIR Technical Committee • SIP 101 • September 12, 2016 • Page 6

Potential Classification Ranges

Example Classification ThresholdsBased on Percent-Above-Standard Approach

0.070 parts per million (ppm)

Marginal 0.071 up to 0.081 ppmModerate 0.081 up to 0.093 ppmSerious 0.093 up to 0.105 ppmSevere – 15 0.105 up to 0.111 ppmSevere – 17 0.111 up to 0.163 ppmExtreme 0.163 ppm or more

AACOG AIR Technical Committee • SIP 101 • September 12, 2016 • Page 7

San Antonio 4th High Values and Classification

2014 4th

high (ppb)

2015 4th

highPreliminary 2016 4th high

Preliminary 2016 DesignValue

69 79 66 71

Monitoring data indicate a preliminary 2016 Design Value of 71 ppb, which would likely result in a classification of marginal nonattainment.

AACOG AIR Technical Committee • SIP 101 • September 12, 2016 • Page 8

TimelineOctober 2015 New Primary Ozone Standard: 70 ppb;

Secondary standard same as primary

September 2016 EPA to propose implementation rule

October 2016 State designation recommendations due to the EPA

June 2017 EPA sends letter to states with proposed nonattainment area designations

October 2017 EPA to sign (finalize) designations and classifications;EPA to finalize implementation rule

October 2019 Emissions Inventory State Implementation Plan (SIP) revisions due for all nonattainment areas

October 2020-2021 Attainment Demonstration SIP revisions due

AACOG AIR Technical Committee • SIP 101 • September 12, 2016 • Page 9

Potential Attainment Deadlines

Based on Section 181(a)(1) of the Federal Clean Air Act:

Marginal 2020

Moderate 2023

Serious 2026

Severe 2032 or 2034

Extreme 2037

AACOG AIR Technical Committee • SIP 101 • September 12, 2016 • Page 10

Nonattainment: Federal Requirements

AACOG AIR Technical Committee • SIP 101 • September 12, 2016 • Page 11

Emissions Inventory

Identifies:– Types of emissions sources present in an area

Stationary Point Sources Area Sources Non-Road Sources On-Road Sources

– Amount of nitrogen oxides (NOX) and volatile organic compounds (VOC) emitted

– Types of process and control devices employed at each plant or source category

The Federal Clean Air Act (FCAA) requires states to submit emissions inventory information for all relevant sources in nonattainment areas.

AACOG AIR Technical Committee • SIP 101 • September 12, 2016 • Page 12

Emissions Inventory SIP Revision

• Required for all nonattainment areas, regardless of classification

• Due two years after the effective date of a nonattainment designation

• Provides current and comprehensive data on emissions contributing to nonattainment

• Establishes a Base Year Inventory for the nonattainment area

AACOG AIR Technical Committee • SIP 101 • September 12, 2016 • Page 13

Transportation Conformity

• Ensures that metropolitan transportation plans, transportation improvement programs, and projects funded by the Federal Highway Administration or Federal Transit Administration are consistent with the air quality goals established in the SIP and do not:• cause new NAAQS violations;• worsen existing NAAQS violations; or• delay achievement of interim milestones or timely

attainment of the NAAQS.

• Required for new nonattainment areas one year after effective date of designation and at least every four years in nonattainment and maintenance areas.

AACOG AIR Technical Committee • SIP 101 • September 12, 2016 • Page 14

General Conformity• Ensures that federally funded actions in nonattainment

and maintenance areas that are not covered under transportation conformity are consistent with air quality goals established in the SIP

• Required for new nonattainment areas one year after effective date of designation

• Triggered when emissions from federal action are expected to equal or exceed de minimis thresholds (40 CFR §93.153)

Designation / Classification Threshold

Nonattainment / Marginal 100 tpy

Nonattainment / Moderate 100 tpy

Nonattainment / Serious 50 tpy

Nonattainment / Severe 25 tpy

Nonattainment / Extreme 10 tpy

Attainment (Maintenance) 100 tpy

AACOG AIR Technical Committee • SIP 101 • September 12, 2016 • Page 15

Attainment Demonstration SIP Revision

Describes in detail the strategies and emissions control measures that show how a nonattainment area will improve air quality and meet the NAAQS by the attainment deadline

Components of an attainment demonstration include:

– Monitoring data– Emissions inventory– Photochemical modeling– Control strategy

AACOG AIR Technical Committee • SIP 101 • September 12, 2016 • Page 16

Components of an Attainment Demonstration:Control Strategy Development

• Existing state, local, and federal strategies are considered.

• Analysis is done to determine the type and need for emissions reductions to attain the NAAQS if necessary.

• Rules are adopted and incorporated into the SIP as needed.

• Contingency measures are included in the plan to be implemented if the area fails to attain the standard by the attainment date.

AACOG AIR Technical Committee • SIP 101 • September 12, 2016 • Page 17

Control Strategy Development:RACT and RACM

Federally required control measuresReasonably Available Control Technology

(RACT)– Lowest emissions limitation that a particular source

is capable of meeting by the application of control technology that is reasonably available considering technological and economic feasibility

Reasonably Available Control Measures (RACM)– Helps advance attainment of the NAAQS– Considers technological and economic feasibility as

well as enforceability and practicality

AACOG AIR Technical Committee • SIP 101 • September 12, 2016 • Page 18

SIP Development

Initial research phase– Data collected and modeled, control strategies

proposed and tested, and the revision drafted– Typically requires 1-4 years

TCEQ's formal rulemaking process– Publication of the proposal, public meetings, hearings,

review of public comments, and adoption by TCEQ's commissioners

– Takes at least one year– Legally binding and enforceable under state law once

rule is adopted by the commissionSubmitted to the EPA for review and approval

– Federally enforceable after it has been approved by the EPA

AACOG AIR Technical Committee • SIP 101 • September 12, 2016 • Page 19

Consequences of Failing to Develop an Approvable SIP

Failure to submit or implement a SIP or submission of a SIP that is unacceptable to the EPA can result in:

– start of a federal implementation plan (FIP) clock;

– SIP call; or

– EPA sanctions or other penalties on the state.

Sanctions can include cutting off federal highway funds and setting more stringent pollution offsets for certain emitters.

AACOG AIR Technical Committee • SIP 101 • September 12, 2016 • Page 20

Contact Information

Dan Robicheaux– SIP Team, Air Quality Planning Section– (512) 239-4959– daniel.robicheaux@tceq.texas.gov

Contact the SIP Team or join our e-mail list– http://www.tceq.texas.gov/airquality/sip/sipcontact.html

Questions?

Air Improvement Resources TechnicalCommittee Agenda Item # 7.

Meeting Date: 09/12/2016  Title: Introduction to Transportation Conformity

AGENDA ITEM DESCRIPTION:Introduction to Transportation Conformity presentation by Tim Juarez, Metropolitan PlanningCoordinator, TXDOT - Transportation Planning & Programming Division

DISCUSSION:The air quality provisions of the Clean Air Act (CAA) and the metropolitan transportation planningprovisions of Title 23 and Title 49 of the United State Code require a planning process that integrates airquality and metropolitan transportation planning. The goal of transportation conformity is to ensure that Federal Highway Administration (FHWA) andFederal Transit Administration (FTA) funding and approvals are given to highway and publictransportation activities that are consistent with air quality goals. The CAA requires that MTPs, TIPs, and Federal projects conform to the purpose of the State ImplementationPlan (SIP)"   

FINANCIAL IMPACT:N/A

RECOMMENDATION:N/A

AttachmentsIntroduction to Transportation Conformity 

TxDOT-SAT August 22, 2016

TRANSPORTATION CONFORMITY

AACOG – AIR Tech Committee

August 22, 2016

TxDOT-SAT August 22, 2016

Topics Covered

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What is Transportation Conformity

Responsibility for Making a Conformity Determination

Frequency for Making a Transportation Conformity

Key Elements of a MTP & TIP Conformity Determination

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3

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TxDOT-SAT August 22, 2016

Reminder: San Antonio Air Quality Timeline (Estimated)

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Oct 2015: EPA Ozone NAAQS Decision – 70 ppb identified standard

Oct 2016: Governors propose nonattainment areas –

TCEQ proposed Bexar County only

Oct 2017: EPA designates nonattainment areas

Dec 2017 to June 2018: AAMPO Develops Metropolitan Transportation

Plan (MTP), Transportation Improvement Program (TIP), Conformity

Document and conducts public involvement process

June 2018: Consultative Partners to Receive MTP, TIP and Conformity

Documents

Oct 2018: Transportation Conformity Determination Due

TxDOT-SAT August 22, 2016

Designation of Non-Attainment Areas

Designation of Non-Attainment Areas

• EPA will designate areas as nonattainment if they exceed the approved NAAQS

• Transportation plans, programs, and projects which are developed, funded, or approved by the United States Department of Transportation (DOT), and by metropolitan planning organizations (MPOs) or other recipients of funds (40 CFR 93.), must follow established policy, criteria, and procedures for demonstrating and assuring conformity

• The MPO and its governing body, shall make conformity determinations for all Metropolitan Transportation Plans (MTPs), Transportation Improvement Programs (TIPs), regionally significant projects, and all other events as required (40 CFR Part 93, Subpart A and sub-sections)

• Once determined locally by the MPO, the MPO will submit to the Consultative Partners, the approved MTP, TIP and Transportation Conformity documents

• Upon completion of the transportation conformity determination review process (including consultation, public participation, and all other requirements), Federal Highway Administration (FHWA) and Federal Transit Administration (FTA) will issue a joint conformity finding, indicating the transportation conformity status of the document(s) under review.

• The effective date of the conformity determination for an area is the date of the joint conformity finding made by FHWA-FTA.

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TxDOT-SAT August 22, 2016

What is Transportation Conformity

The air quality provisions of the Clean Air Act (CAA) and the metropolitan transportation planning provisions of Title 23 and Title 49 of the United State Code require a planning process that integrates air quality and metropolitan transportation planning.

The goal of transportation conformity is to ensure that Federal Highway Administration (FHWA) and Federal Transit Administration (FTA) funding and approvals are given to highway and public transportation activities that are consistent with air quality goals.

The CAA requires that MTPs, TIPs and Federal projects conform to the purpose of the State Implementation Plan (SIP).

The transportation conformity process assesses the compliance of the MTP, TIP, or federal projects with the SIP

Conformity to the purpose of the SIP means FHWA and FTA funding and approvals are given to highway and transit activities that will NOT cause:

– any new violations of the air quality standard,

– increase the frequency or severity of violations of the standard, or

– delay timely attainment of the standard or any interim milestone.

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TxDOT-SAT August 22, 2016

Frequency Requirements for Transportation Conformity

Conformity determinations must be made at least every four years

– May occur more often if metropolitan transportation plans or TIPs are updated more frequently or amended with non- exempt projects.

– Certain SIP actions relating to motor vehicle emissions budgets (MVEB) may require an updated conformity determination within 24 months.

Conformity must be demonstrated within 12 months of EPA’s designation of an area as nonattainment.

For project- level conformity, a project must:

– come from a conforming metropolitan transportation plan and TIP,

– its design concept and scope must not have changed significantly from that in the metropolitan transportation plan and TIP, and

– it addresses potential localized emissions impacts.

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TxDOT-SAT August 22, 2016

Conformity Lapse

If a conformity determination is not made according to the required frequency requirements, areas have a one-year grace period after the missed deadline before a conformity lapse applies.

– (This one-year grace period does not apply to newly designated nonattainment areas.)

During the 12-month grace period, only transportation projects in the most recent conforming metropolitan transportation plan and TIP can be funded or approved.

Once an area is in a conformity lapse, the use of Federal transportation funds is restricted to certain kinds of projects and no new non-exempt projects can be amended into the metropolitan transportation plan/TIP.

– “Exempt projects” include safety projects and certain mass transit projects, TCMs from an approved SIP, and project phases that were authorized by the FHWA/FTA prior to the lapse.

The FHWA and FTA do not reduce the amount of funding a State receives if there is a lapse; however, use of Federal funds is restricted during the lapse.

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TxDOT-SAT August 22, 2016

Key Elements of a MTP / TIP Conformity Determination

One way to understand transportation conformity is to know the key

requirements and how they interact. The major components of a conformity

determination include:

– Interagency Consultation

– Public Involvement

– Latest Planning Assumptions and Emissions Model

– Regional Emissions Analysis

• Motor Vehicle Emissions Budget

– Timely Implementation of Transportation Control Measures

– Fiscal Constraint

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TxDOT-SAT August 22, 2016

Reminders

Transportation conformity will have a significant impact on the transportation

planning process.

Upon designation of nonattainment, Alamo Area MPO will have 12 months to

demonstrate conformity for their MTP.

The TPB and MPO staff must be involved in the air quality planning process

and be knowledgeable of the federal and state rules and regulation.

Going forward, the TPB and MPO staff must ensure that emissions

inventories, emissions budgets, and TCMs are appropriate and consistent

with the transportation vision of a region.

If transportation conformity cannot be determined, projects and programs

may be delayed.

Transportation Conformity: A Basic Guide for State and Local Officials

http://www.fhwa.dot.gov/environment/air_quality/conformity/guide/

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TxDOT-SAT August 22, 2016

Contact Information

Timoteo “Tim” Juarez, Jr.

MPO Coordination

TXDOT – Transportation Planning & Programming Division

Work: 512.486.5028 | tim.juarez@txdot.gov

Bill Frawley, AICP

Research Scientist

Texas A&M Transportation Institute

Work: 817-462-0533 | B-Frawley@tti.tamu.edu

Todd Carlson, AICP

Assistant Research Scientist

Texas A&M Transportation Institute

Work:817-462-0517 | tcarlson@tamu.edu

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