Noise & Air QualityNEPA ClassSeptember 2015Office of Environmental ServicesNoel Alcala, PE, Noise and Air Quality Coordinator
Air Quality Regulations- Why do we do what we do?? • Clean Air Act (CAA) of 1970 and 1990- protect and improve the nation’s air quality • CAA requires development of State Implementation Plan (SIP) & requires fed actions to conform to SIP’s purpose • SIP- Defines how States will comply with CAA and improve AQ (requires demonstration of “conformity”) • Conformity- project must not cause new AQ violation, worsen existing violation, or delay timely attainment • Attainment- meets or is cleaner than AQ standards (NAAQS) • SIP explains the strategy for attaining/maintaining the NAAQS, reducing air pollution, AQ management program
What air quality episodes led to the CAA? • Donora, PA- 1948 • Poza Rica, Mexico- 1950 • London- 1952 • New York- 1953 & 1963 • All of the above
Which human system is most directly affected by air pollution? • Circulatory • Digestive • Respiratory • Nervous • All of the above are equally affected
The primary responsibility for enforcing the NAAQS belongs to who? • States • USEPA • Congress • FHWA • All of the above
Air Quality Pollutants required to be addressed in your NEPA Document • Carbon Monoxide (CO) • Ozone (O3) • Particulate Matter (PM 2.5) • Mobile Source Air Toxics (MSAT) • O3 and PM apply to certain areas; MSAT applies statewide
Air Quality Guidances • USEPA/FHWA policies and guidance documents for PM2.5, MSAT analyses • ODOT Flow charts for PM2.5, MSATs, O3 • AQ Webinars: http://epa.gov/air/oaqps/eog/broadcast.html#airdata021212 • NHI Webcourses
Non-Attainment & Maintenance • Geographic areas that require specific air pollution controls, analysis, programs, etc… • Nonattainment- worse than the NAAQS • Maintenance- formerly in nonattainment and under a maintenance plan
Baseline Transportation Conformity Requirements for PM and O3 • All projects must be listed in the State Transportation Improvement Program (STIP) and/or the Transportation Improvement Plan (TIP) (MPO list) for NEPA approval • See ODOT-OSPPM website for more details (STIP list, TIP list, STIP process) • Regional vs Project Level air quality requirements. • Regional/Planning level PM2.5 and O3 addressed in TIP.
CO Analysis Determination • Entire state of Ohio is now in attainment for CO since 3/5/14. CO is not an issue and no analysis is required.
Ozone Confirmation • No requirement to perform project level analysis for ozone at this time • Verify that the project is in the STIP/TIP- NEPA document can not be approved unless in STIP/TIP • Verify project scope has not significantly changed • Include discussion in NEPA document- is project in Non-Attainment or maintenance for ozone?
PM 2.5 • PM2.5- (soil, dust, vehicle emiss, smokestacks, etc) focus is on diesel trucks/emissions • Applies to nonattainment areas • Nonexempt projects with ADT>=125,000 and diesels>=8% AND there is a significant increase in the number of diesel trucks from DYNB to DYB • Estimation of future PM2.5 concentrations • 12 ug/cubic m (annual; was 15ug/cubic m); 35 ug/cubic m (24 hr) thresholds • Dispersion modeling required- MOVES and AERMOD (AMS/EPA Reg Model) • Follow USEPA Quantitative PM2.5 Hotspot Guidance dated 12/12 and updated PM2.5 process flowchart
Dispersion modeling is the….. • Measured distance of pollutant dispersion for a given source • Method to estimate the ground level concentration of pollutants from a source • Standard rate of pollutant dispersion at predetermined atmospheric conditions • Method for regional AQ policymakers to reach an AQ goal • None of the above
PM2.5 Project Categories • Exempt • Nonexempt and no hotspot analysis required • Nonexempt and a hotspot analysis is required
Projects exempt from PM2.5 analysis • Projects could be exempt from PM2.5 analysis under 40CFR93.126 list of projects (i.e. intersection improvements, bridge replacements- no added capacity, pavement resurfacing/rehabilitation, etc)
Projects not exempt from PM2.5 analysis but do NOT require a PM2.5 Hot-spot analysis These projects require coordination with OEPA, USEPA, FHWA- OES does this) Informational items to be provided to OES for coordination are P&N, Project Description, project sponsor, FY for construction, verification that project is on STIP/TIP, existing and design year ADT and truck %, and aerial mapping showing the preferred alternative For new auxiliary lane projects, <1 mile threshold
Projects not exempt AND require a PM2.5 Quantitative Hot-spot Analysis • When ADT>125,000 and diesels>8% AND expansion of an existing highway that has a significant increase in the number of diesel trucks from DYNB to DYB • Follow USEPA PM2.5 Guidance Manual • Pre-coordination with agencies to discuss approach • Document coordination required with agencies • PI requirement- Provide Hot-spot analysis report on project’s website with comment period and make report available for review and comment at NEPA PI meeting
The primary mobile source of air pollution in the USA is what? • Diesel trucks • Automobiles • Airplanes • Lawn mowers • Motorcycles
MSATs • Required under FHWA Interim Guidance on Air Toxics Analysis in NEPA Documents (February 3, 2006, Sept 30 2009 memorandum, 12/6/12 update) • Priority Transportation Toxics- suspected cancer-causing pollutants from vehicles • Linked to heart disease and asthma • Statewide Implementation (all projects/counties) • Three levels of potential MSAT effects (No, low, higher) • Project types and prototype language provided for each level of analysis • Follow MSAT process flowchart
MSATs No Potential MSAT Effects • No sensitive land uses within approx 500’ of the project (homes, hospitals, churches, etc)- Identify in the Project Initiation Package • Exempt from analysis- NEPA exempt or CE C1 and possibly CE C2 • Include prototype language (from FHWA/USEPA guidance doc- Appendix A) in NEPA document
MSATs Low Potential MSAT Effects • Requires “Qualitative” Analysis • Capacity adding project with <140,000 DYADT, new interchange, new road, relocates lanes closer to sensitive areas, expansion of intermodal center • Provide project info and traffic info- Vehicles mi travelled (VMT), % difference betw Ex and DYB • Required OEPA review and consultation • Discuss results in NEPA document
MSATs Higher Potential MSAT Effects • Requires “Quantitative” Analysis- are there meaningful differences in MSAT emissions between base case year, OYB, OYNB, DYB, DYNB • Confirm requirement with OES and agencies • Capacity adding projects with DYADT > 140,000 • Requires air quality modeling • Required OEPA review and concurrence • Discuss results in NEPA document
Air Quality Requirements?- Example Projects • Project in DEL Cty with 145,000 DYADT is resurfacing and widening narrow pavements. What is required for PM2.5, MSAT? • Project in LOR Cty is a widening from 2-4 lanes. DYB ADT is 130,000 and truck % is 15%. DYNB truck % is 16%. What is required for PM2.5, MSAT? • Project in SUM Cty is replacing a bridge, no added thru lanes, DYB ADT is 200,000. What is required for PM2.5, MSAT? • Project in CUY Cty is adding capacity on IR77. Ex 2015 ADT is 150,000. 2035 DYB ADT is 180,000. 2035 DYB diesels are 30%. 2035 DYNB diesels are 15%. What is required for PM2.5, MSAT?