CHAPTER 6 - AIR QUALITY EVALUATION

Transcription

1 CHAPTER 6 - AIR QUALITY EVALUATION AIR QUALITY OVERVIEW Motor vehicle emissions are a major contributor to air pollution across the nation and in the Tucson urban area. Approximately 60 percent of the total air pollutants within eastern Pima County come from motor vehicles, with the largest proportion being carbon monoxide (CO) emissions. To assist local jurisdictions in measuring and improving air quality, the U.S. Environmental Protection Agency (EPA) establishes maximum acceptable levels of pollution for six common air contaminants known as the National Ambient Air Quality Standards (NAAQS). These federal standards for outdoor or "ambient" air are set to protect public health. If an area measures air pollutant levels that violate these standards, that area is designated as a "non-attainment area" for that pollutant. When this happens, a non-attainment area plan must be developed and adopted to reduce emissions of that pollutant. The non-attainment area plan is incorporated in the State Implementation Plan (SIP) as a SIP amendment. The SIP must contain effective strategies for curtailing air pollution. For EPA approval, the plan must include financial and resource commitments for plan implementation. If a state is unable to develop an adequate plan, EPA is required to promulgate a Federal Implementation Plan (FIP). EPA designated part of the Tucson urban area a CO non-attainment area in This designation meant that the ambient CO concentration in the non-attainment area exceeded the NAAQS (9 parts per million for an 8-hour average), enough times to violate the federal health standard. Historically, these violations occurred only at congested intersections. The Tucson area has not violated the CO NAAQS since The Carbon Monoxide Limited Maintenance Plan for the Tucson Air Planning Area (CO LMP) was approved as a SIP amendment. EPA redesignated the region as a CO attainment area effective July 10, Continuation of this status relies on data obtained from monitoring and modeling procedures which estimate when emissions control measures should be added or removed. Air quality modeling currently indicates that the area will likely comply with the CO federal standards for at least 20 years without any additional CO transportation control measures (TCMs). PIMA ASSOCIATION OF GOVERNMENTS TIP FY

2 MAJOR DEVELOPMENTS The conformity determinations for the TIP and for the 2030 RTP were approved by FHWA and FTA in August PAG continues to comply with all legal requirements for transportation conformity determinations in effect at the time of this TIP report. EPA has not imposed any federal control measures for Pima County, but has included the PAG Travel Reduction Program, the Pima County Department of Environmental Quality (PDEQ) Voluntary No Drive Days Program and the State s Oxygenated Fuels Program as federally enforceable air quality control measures. Since these control measures are included in the Arizona SIP, they must continue to be implemented. Additional programs not mandated in the SIP amendment include a one-time only vehicle inspection failure waiver that was added via an Arizona statute. In 1999 and 2000, legislative funds were appropriated for the lawn and garden equipment replacement program. Since 1999, a voluntary vehicle repair and retrofit program (V2R2) has been in effect. Currently, V2R2 is funded through a grant from the Arizona Department of Environmental Quality (ADEQ). The 1991 Intermodal Surface Transportation Efficiency Act (ISTEA) required that a Congestion Management System plan be adopted. PAG has adopted such a plan which is called the PAG Mobility Management Plan (MMP). This Plan is implemented through a Memorandum of Understanding (MOU) among the PAG member jurisdictions, PAG and the Arizona Department of Transportation (ADOT). It was last updated in August SIP CONTROL MEASURES The air quality CO emissions reduction measures required in the SIP are as follows (in order of effectiveness): Federal Motor Vehicle Control Program (FMVCP) Arizona Inspection and Maintenance Program (I/M) Oxyfuels Program for Pima County (1.8% oxygen) PAG Travel Reduction Program PAG RideShare Program Pima County Voluntary No-Drive Days Program All legally enforceable commitments to other control measures outlined in the 1987 SIP revision have been completed. The EPA made the following statements in the January 28, 1991, FIP regarding the attainment and maintenance of the CO NAAQS in Pima County: "The 1987 Pima plan (CO SIP) projected attainment of the CO NAAQS in early 1990 and maintenance through 2000 relying solely on emission reductions from the FMVCP, PIMA ASSOCIATION OF GOVERNMENTS TIP FY

3 the State I/M program without the loaded mode component, existing traffic flow improvements, and programmed road improvements. The Pima plan did not rely, for either attainment or maintenance, upon any of the additional measures being proposed in the plan (e.g., the travel reduction program) or later adopted by the State Legislature (e.g., the loaded mode I/M program and the oxygenated fuels program). Finally, new population and vehicle miles traveled (VMT) forecasts for the Pima area have recently been completed and are predicting substantially less growth in 1990 and future years than was assumed in the 1987 Pima plan. Combined, these three factors argue strongly that the 1987 Pima plan accurately predicted that attainment would occur in or before early Therefore, EPA concludes today that sufficient emission reductions have already been achieved in Pima County to assure that current CO emission levels are below those needed to attain the CO NAAQS, and that no additional federal measures are needed to ensure attainment. EPA performed hot-spot modeling using the approved hot-spot model, CAL3QHC, to determine if sufficient measures were in place to ensure maintenance in Pima County for the required 10-year period after plan promulgation, i.e., until early This hot-spot modeling showed that with the existing control strategy that ambient CO concentrations for the next 10 years would be well below the CO NAAQS even under worstcase meteorological conditions. Emission reductions from two control measures were explicitly included in the maintenance demonstration for Pima County. These control measures are the Arizona State Inspection and Maintenance program with the loaded-mode component and the oxygenated fuels program at 1.8 percent oxygen. Other measures in the SIP such as the Travel Reduction Program were not explicitly included in the maintenance demonstration; however, such measures will provide an extra margin of emission reductions for maintenance. EPA, therefore, finds that no additional controls are necessary for maintenance in Pima County." These EPA statements were based on a conservative use of the available data in most cases. The attainment demonstration was based on only two major control measures (three if the FMVCP is counted). Modeling was done in 1991 for two microscale sites using "worst case" meteorology. The results were as follows: the estimated ambient concentration in parts per million (ppm) CO for an 8-hour average was 6.4 ppm for the 22nd St./Alvernon intersection and 7.2 ppm for the Broadway/Craycroft intersection in the year EPA commented in the Technical Support Document, "These concentrations are well below the federal ambient CO standard of 9 ppm per 8-hour average. One thing to bear in mind is that all the modeling analyses were based on the worst case conditions. Therefore, the 8-hour average concentrations at these hot spots could be much PIMA ASSOCIATION OF GOVERNMENTS TIP FY

4 lower." It also should be noted that EPA's attainment demonstration for Pima County was based on "existing traffic flow improvements and programmed road improvements." Emission "milestones" were not established for the Tucson Air Planning Area (TAPA), however, the 1990 annual emissions inventory serves as a base-case because that is the year the CO NAAQS attainment was projected and achieved. If future annual emissions inventories can be held below that level, and hotspot problems avoided, maintenance of the CO NAAQS is assured. The long-range control strategy will be to continue programs that control mobile emissions and reduce per capita VMT. The continued implementation of PAG s RideShare and Travel Reduction Programs are the most significant local strategies targeting direct VMT reduction, with the added benefit of congestion management. THE ANALYSIS APPROACH Understanding and continued compliance with the SIP in Pima County are especially important. First, by reducing air pollutant emissions, a significant contribution is made to maintaining the health of the region's citizens. Second, by conforming to a federally approved air quality plan, the Tucson urban area will remain eligible for federally funded transportation projects. To assure compliance with clean air standards, an annual program of planning and evaluation has been established in Pima County. As part of this process, an air quality analysis of the regional TIP is performed, as prescribed by federal laws ( 109(j) of 23 U.S.C. and 176 of the Clean Air Act). This analysis demonstrates compliance with the state transportation conformity rule (R et seq.), assures that all transportation control measure commitments are implemented on schedule, and that the federal conformity requirements are met. With approval of the LMP, the need to meet an emissions budget and to demonstrate conformity, through modeling, is removed for the 10-year period of the LMP. The principal measure of compliance is the CO monitoring program, operated by PDEQ. In addition, PAG does an air quality evaluation of the TIP for comparative purposes and calculates the year 2011 CO emissions from mobile sources on the transportation network if all TIP projects are completed on schedule. The comparison for this TIP shows a CO emissions decrease of 42.6 tons from the 2007 baseline, assuming the TIP projects are completed on schedule. PAG also calculates the 2011 CO emissions assuming no network improvements (nobuild). All calculations of VMT, speed and CO emissions include an addition to the network system figures of 13 percent of VMT at 12.9 mph to account for local (non-network) travel. A supplementary air quality evaluation, required under the LMP, is conducted on the most congested hotspot intersections using the EPA-approved CAL3QHC PIMA ASSOCIATION OF GOVERNMENTS TIP FY

5 microscale model using current year traffic conditions. The microscale air quality analyses determine if any TIP projects are likely to affect or be affected by congested intersections. Analyses are performed annually for intersections most likely to violate CO NAAQS. In 2005, the intersections with the highest average daily traffic (ADT) and the worst level of service (LOS) are as follows: 22 nd Street/Kolb (#1 highest ADT) Ina/Oracle (#2 highest ADT) Broadway/Kolb (#3 highest ADT) Valencia/Kolb (#1 worst LOS) Golf Links/Kolb (#2 worst LOS) Speedway/Craycroft (#3 worst LOS) In addition, 22nd Street/Alvernon and Golf Links/Kolb intersections were modeled for comparison to monitored values. 22nd Street/Alvernon was modeled for historical purposes. The Golf Links/Kolb monitor was installed in 2002, to comply with the LMP. It ranked as No. 2 worst LOS. The most recent microscale analyses (using CAL3QHC) are presented below (worst at top) showing the 8-hour average CO concentration in ppm (the 8-hour NAAQS is 9 ppm): Table 6-1 Intersection Emission Rates for 2005 INTERSECTION 8-HOUR AVERAGE CONCENTRATION (background of 0.55 ppm, persistent factor of 0.54) 22 nd Street/Kolb 3.9 ppm Speedway/Craycroft Golf Links/Kolb Broadway/Kolb 3.7 ppm 3.5 ppm 3.4 ppm 22 nd Street/Alvernon 3.3 ppm Ina/Oracle Valencia/Kolb 3.1 ppm 2.9 ppm Reductions in CO emissions from the non-roadway elements such as carpooling and mass transit have previously been estimated for the Regional TIP using data compiled from PAG's Travel Reduction / RideShare Programs, the City of Tucson's Department of Transportation and Sun Tran. Emission reductions were calculated using methods developed in the Pima County Air Quality Control District's (now PDEQ) Reasonable Further Progress Reports ( ) and PAG's report on the System for Monitoring Progress Toward Emission Reduction Goals (1983). Since no emissions budget is required for conformity purposes, programs that result in emissions reductions are detailed in the following section. PIMA ASSOCIATION OF GOVERNMENTS TIP FY

6 SUMMARY OF EMISSIONS REDUCTION MEASURES PAG RIDESHARE PROGRAM The RideShare Program was established in 1974 and is administered by PAG. It offers a free computer-matching service for people interested in carpooling to work or college. At the close of 2005, the RideShare carpool database contained more than 24,000 active registrants representing over 500 employment locations. The carpool database changes daily with the receipt of new applications for matching, requests for rematching, changes to the registrant s information and deletions. In 2003, PAG conducted a database user s survey indicating that 29 percent of the RideShare applicants were actively carpooling. In 2005, RideShare averaged over 2,200 carpool lists sent to commuters each month. At the beginning of 2004, RideShare instituted an Internet-based application system for commuters seeking a carpool matching list. Since inception, more than 500 commuters have registered for carpool matching through the PAG Web page. In 2002, RideShare launched the first regional guaranteed RideHome program for carpoolers. RideHome provides a safety net to the carpooler by offering 4 taxi rides per year for emergency purposes. In 2003, the RideHome was expanded to include Sun Tran bus riders from the Get On Board program. In 2005, over 240 vouchers were distributed for use by commuters. Data from the 2003 American Community Survey, released in March 2005, indicate that carpool use in Tucson is significantly higher than the national average (Tucson, 12.2 percent and United States, 10.4 percent). PAG TRAVEL REDUCTION PROGRAM (TRP) Travel Reduction Ordinances (TROs), creating the regional Travel Reduction Program (TRP), are in place for each of the following jurisdictions: Pima County, the cities of Tucson and South Tucson, and the towns of Oro Valley, Marana and Sahuarita. The goals of the Ordinances are to reduce traffic congestion and improve air quality. The TRP is implemented through PAG, working with major employers, defined as an employer with 100 or more full-time equivalent employees at a single or contiguous site, or an employer with less than 100 employees can voluntarily participate in the TRP. Employers in the TRP encourage their employees to reduce the vehicle miles traveled in the home to work commute trip through the use of alternate modes or adjusted work schedules such as compressed workweeks or teleworking. The TROs mandate that each employer appoint a Transportation Coordinator, distribute air quality information, survey employees and submit an annual travel reduction plan. During 2005, 283 employment sites with 113,342 employees in the program completed PIMA ASSOCIATION OF GOVERNMENTS TIP FY

7 the TRP survey process and met the other TRO mandates. The number of employees and sites in the TRP continue to rise as a result of Tucson s population and economic growth. Employees participating in the TRP represent 29 percent of the total regional workforce in Pima County. For the 2005 TRP year, 46 percent of the sites met their TRO goal by increases in alternate mode usage (AMU) or reduction in vehicle miles traveled (VMT) to the work site. All TRP indicators were positive, AMU increased, and VMT held the line after a two year decrease, and impact savings from the program significantly increased. Travel Reduction Program participants using alternate modes and special programs during the 2005 program year helped to improve the environment by saving: 89.6 million miles 4.5 million gallons of gasoline 36.3 million dollars 3.9 million pounds of pollution The table below shows regional results comparing the base year (1989) result with the results of 2004 and This provides a picture of the performance of the program over the 16-year history. Table 6-2 Travel Reduction Program 1989, 2004 & 2005 Regional Survey Results AMU% Regional Goal N/A AMU% VMT (goal=reduction) Survey Response Rate % Number of Sites Number of Employees 77, , ,242 AMU: Alternative Mode Usage in daily home-work commute (carpool, bus, bicycle, walk, vanpool, or special programs) VMT: Regional average weekly one-way motor Vehicle Miles Traveled factored by mode ridership The 2006 TRP survey was suspended by the PAG Regional Council while PAG reviewed recommendations to expand travel demand management strategies for the region. TRP employers were notified to begin the 2006 TRP year with continuation of the plan requirement due nine weeks from their start date, with a Transportation Coordinator and distribution of air quality and alternate mode information. PIMA ASSOCIATION OF GOVERNMENTS TIP FY

8 VANPOOL INCENTIVE PROGRAM (VIP) The TRP staff continues to promote and implement the Vanpool Incentive Program (VIP) developed in 2002 with a Contributor Agreement with Enterprise Rent-A-Car, Inc. to administer a $400 monthly subsidy per van to qualified TRP employees. The VIP has 17 vans on the road with growing interest among other TRP employees regarding vanpools. The current participants are: Raytheon Missile Systems (2 vans), Federal Correctional Institution (4 vans), Indian Health Services Sells (9 vans), Town of Marana (1 van), and Ventana Medical Systems (1 van). Annual savings from these vans are: 949,920 miles, 47,496 gallons of gasoline, 351,489 dollars, 27,138 pounds of pollution and 155 parking spaces. CLEAN CITIES PROGRAM The Clean Cities program is a national effort, sponsored by the U.S. Department of Energy (DOE), to increase clean fuel vehicle usage for the purpose of reducing the country's dependence on foreign petroleum sources and improving air quality. The Tucson Regional Clean Cities Coalition received its DOE designation in August 1999 as the 73rd such coalition in the nation (there are now 85 Clean Cities). The local 60 member coalition consists of representatives from major utilities and other fuel providers, private companies, including vehicle dealers, and fleet owners, and a variety of government agencies. The coalition developed a five-year plan (pending renewal), approved by DOE, which continues to be executed under the direction of a local steering committee with the assistance of a full-time PAG staff manager. The DOE is currently broadening Clean Cities to focus on four new elements: fuel blends, truck idling, fuel economy and hybrids. Tucson Clean Cities has been selected to assist in the emphasis of promotion of fuel blends, in addition to its current clean fuel promotion. The Clean Cities Program maintains a fuel-neutral position with respect to the promotion and use of all clean fuels. Currently, regional emphasis is placed on the use of biodiesel, E85, compressed natural gas (CNG), propane, hybrid electric, and truck and school bus idle reduction. The Coalition is working closely with school districts to implement clean fuel driver training programs, with clean fuel vehicles, and a curriculum directed at all types of fuel options to educate young drivers on alternatives to using petroleum fuel. The Coalition has also been working with the University of Arizona to implement an extensive E85 program with current FlexFuel Vehicles (FFVs) in their fleet. The number of clean fuel vehicles in the region continues to grow: 1,874 clean fuel vehicles were reported in 2002; 2,439 in 2003, 3,063 in 2004, and 3,568 in 2005 with a total gasoline gallon equivalent displaced of 2,961, gallons. Clean fuel vehicles are gaining acceptance and popularity as fleet managers and the general public become aware of the benefits of owning and operating them. In addition, state and federal agencies and fuel providers are mandated by the Energy Policy Act of 1992 to procure a percentage of their fleet as clean fuel vehicles annually. PIMA ASSOCIATION OF GOVERNMENTS TIP FY

9 A major obstacle to the proliferation of clean vehicles is having adequate clean fueling infrastructure. The electric vehicle infrastructure is adequate at this time with five electric recharging stations throughout the metropolitan area, plus one in Casa Grande to facilitate travel between Tucson and Phoenix. However, due to the introduction of the hybrid vehicle, the all-electric non-neighborhood vehicles and electric charging stations have been significantly scaled back. Propane refueling stations are available throughout the region. One drawback in the region has been the lack of public-access CNG refueling stations. The region has 11 restricted-access (business/government) CNG stations and one public access CNG station located at the Tucson International Airport. It was opened in September 2003 and a second is planned for the downtown area. A public-access biodiesel outlet was also opened in May 2003, and a second public access biodiesel station opened in Oracle, Ariz., in August of The state s first retail ethanol E85 station opened in December 2004 and since then, two more have opened in Tucson, three in Sierra Vista and several are planned for Maricopa County after the July 1, 2006 timeframe. The Tucson Region Clean Cities Coalition's Steering Committee meets bi-monthly to network, exchange information and pursue the goals and objectives of the Clean Cities Plan that was adopted in 1999 and re-established through a re-designation by the US DOE in Staff provides support to the steering committee, coordinating and participating at community outreach events to promote clean vehicles and fuels and acting as a clearinghouse for the Clean Cities Program to advocate use of clean fuel vehicles. VOLUNTARY VEHICLE REPAIR AND RETROFIT PROGRAM The purpose of Pima County Department of Environmental Quality (PDEQ) Voluntary Vehicle Repair and Retrofit (V2R2) Program is to reduce vehicle-related emissions by providing a financial incentive to the owners of older, high emitting vehicles to repair the vehicles to pass the state emissions test. The V2R2 Program was established through state legislation in 1998 and the program began repairing vehicles in Pima County in On average, emissions are reduced by 81 percent per vehicle. To date, over 3,360 vehicles have been repaired with a corresponding reduction of approximately 1,120 tons of emissions per year for the life of the repairs. To qualify for the V2R2 Program, legislatively-set criteria must be met including the following: the vehicle must fail the state emissions test; the vehicle must be 12 years of age or older; the vehicle must have been registered in the state of Arizona during the last 12 months without a break in registration for more than 60 days; the vehicle must be titled in Arizona; the vehicle owner must pay the first $150 of repairs; and the vehicle must be operational and in good mechanical condition. If the vehicle meets these criteria and is entered into the Program, PDEQ will pay up to an additional $550 for emissions-related repairs or up to an additional $650 for emissions-related repairs and retrofit kit installation. Funding for the V2R2 Program is provided through a grant from the ADEQ. PIMA ASSOCIATION OF GOVERNMENTS TIP FY

10 GAS CAP REPLACEMENT PROGRAM PDEQ began implementation of the Gas Cap Replacement (GCR) Program in FY 04/05 with funding through ADEQ and a subsequent grant from the Gila River Indian Community. The goal of the program is to reduce volatile organic compounds (VOCs) from mobile sources in southern Arizona. The objective of the GCR program is to provide replacement gas cap vouchers for leaky vehicle gas caps and work to locate vehicles with faulty gas caps that are not required to take the annual state emissions test. To date, 9,157 gas caps have been tested with 315 failures, which is a 3.4 percent failure rate. From research provided by existing programs around the U.S., the potential reduction of air pollution per leaky gas cap replaced is figured at 11.2 pounds of VOCs per year and 4 pounds of benzene per year. Using the number of vouchers distributed through the GCR program, it is estimated that up to 4,788 pounds of air pollution have been eliminated per year. Additionally, with the potential for as much as 30 gallons of gasoline evaporating per leaky gas cap, up to 9,450 gallons of gasoline will be saved per year through this program. VOLUNTARY NO-DRIVE DAY (CLEAN AIR) PROGRAM PDEQ s Voluntary No-Drive Day (Clean Air) Program is a state-mandated program that began in 1988 to address CO violations in Pima County. The goals of the national award-winning program are to increase awareness of air quality issues and encourage actions to reduce air pollution. The Clean Air Program uses several methods to achieve its goals including: Community Outreach - speakers bureau, Air Pollution Advisories, Smoking Vehicle Hotline ( ), PDEQ Web site ( near real-time air quality information Web site ( with hotline (882-4AIR) in English and Spanish, outreaches at community events and major employers, Gas Cap Testing and Replacement Program, advertising and media relations. School and Youth Programs - classroom presentations, teacher training, development and distribution of air quality curricula, Annual Art Contest, Kids for Clean Air Club (over 3,000 members), and working with ADEQ on a School Bus Idling Reduction Program. Annual Public Events - sponsorship or co-sponsorship of events such as Walk Our Children to School Day, Car Care Checkup, Clean Air Fair, and Earth Day. During the 2005/2006 fiscal year, approximately 3,336 individuals attended Clean Air Program presentations, over 106,700 participated in community events, 14 educators received air quality curricula or training, over 78,950 mailings delivered program materials, over 311,350 requests for information (as opposed to hits ) were made to the PDEQ Web site, over 618,000 requests for information were made to the Air Info Now PIMA ASSOCIATION OF GOVERNMENTS TIP FY

11 web site, over 1,450 calls were processed for the Smoking Vehicle Hotline, and over 148,500 educational brochures or items were distributed to the public. The PDEQ annual telephone survey, used to gather information from the public and evaluate the Clean Air Program, indicates that there are key differences in attitudes and behaviors related to air quality among those aware of the Clean Air Program and those who are not. Among other findings, individuals who are aware of the Clean Air Program are 16 percent more likely to have taken action to reduce air pollution. Those aware of the Clean Air Program are 47 percent more likely to be carpooling or combining automobile trips and are four times as likely to be walking to work. According to FMR Associates, Inc., the independent consultant who performs the survey, these findings strongly suggest that the Pima County Clean Air Program clearly increases awareness, belief, and actions related to improving air quality. CONFORMITY OF THE TIP In order for PAG and the U.S. DOT to determine that this TIP is in conformity with the applicable air quality implementation plan (the Arizona State SIP), the TIP must meet the conformity requirement findings in Arizona Administrative Code R et seq. This TIP is derived from, and consistent with, the 2030 PAG RTP as amended. As described in previous TIPs, the following three conformity findings are required: PAG finds by adoption of this TIP that the TIP provides for, or does not impede, the implementation of all TCMs in the applicable SIP on the schedule set forth in the SIP. PAG also finds by adoption of this TIP that CO emission levels, microscale and regional, resulting from implementation of the TIP will not interfere with maintenance of the CO NAAQS throughout the maintenance area during the period covered by the program. In addition, PAG finds, by adopting this TIP that implementation of the program would not cause or contribute to a violation of the CO NAAQS anywhere within the maintenance area during the period covered by the program. The Clean Air Act Amendments of 1990 requires that the TIP conform to the "applicable air quality implementation plan's" (SIP's) purpose of eliminating or reducing the severity and number of violations of the NAAQS and achieving expeditious attainment of such standards; and that TIP activities will not cause or contribute to any new violation of any standard in any area, increase the frequency or severity of any existing violation of any standard in any area, or delay timely attainment of any standard or any required interim emission reductions or other milestones in any area. The CO NAAQS was attained in The TIP projects are not expected to contribute to any new violation of the CO NAAQS or delay any required emission reductions or other milestones in any area. PIMA ASSOCIATION OF GOVERNMENTS TIP FY

12 EPA promulgated a final rule on April 24, 2000, to redesignate the Tucson Air Planning Area (TAPA) to attainment for the CO NAAQS and to approve a maintenance plan that will insure that the area remains in attainment. EPA confirmed in the rule that no emissions budget test is needed to demonstrate conformity as long as the maintenance plan is followed and no violations of the CO NAAQS occur. Compliance under the LMP is determined by continued monitoring of the existing system with the additional monitoring requirements. PDEQ is the designated air quality control agency for Pima County and is responsible for monitoring the CO levels. In Pima County, CO mobile source emissions estimates are calculated by PAG using MOBILE6.2 emission factors. The MOBILE6.2 emission factors are developed from local data, to the extent possible, including state I/M program, oxyfuels program, and local (County) vehicle registration distribution. PAG uses the most recent census population data for 2000 in combination with State and local land use, transportation and traffic data to generate vehicle miles traveled (VMT), vehicle hours traveled (VHT) and congestion levels. All these updated data sources were used for the air quality evaluation of this TIP. Year Table 6-3 Summary of Carbon Monoxide Emissions Modeling Results for the TIP Total Vehicle Miles Traveled Regional Carbon Monoxide Emissions (tons/day) Comments ,020, TIP Start Year ,526, TIP End Year PAG finds by adopting this TIP that the Regional Transportation Improvement Program for FY is in conformity with the SIP. PAG also affirms by adopting this TIP that it is consistent with the 2030 RTP as amended. CONFORMITY OF THE PLAN PAG is the designated air quality planning agency and the metropolitan Planning organization (MPO) for the region and, as such, maintains close, cooperative relationships with the U.S. EPA, ADEQ, ADOT, and PDEQ. Coordination of regional transportation planning with air quality planning has been carried out for many years. In April 1993, the procedures, methods and responsibilities for air quality planning were incorporated in a Memorandum of Agreement (MOA) between PAG, ADEQ, ADOT and PDEQ. That MOA was updated in August The PAG Regional Council and the U.S. Department of Transportation made a conformity determination for the 2030 PAG RTP in It was found to be in conformity with the SIP following procedures outlined in the federal transportation conformity rule (40 CFR Part 93) and the State of Arizona conformity rule (R PIMA ASSOCIATION OF GOVERNMENTS TIP FY

13 et seq.). Under the CO LMP, modeled results serve as a guide to the region for future air quality planning as compliance under the LMP is determined by continued monitoring of the existing system with the additional monitoring requirements. In summary, the Regional Council of Pima Association of Governments finds, by adopting this TIP, that the TIP and all projects contained in this TIP are in conformity with the applicable implementation plan, the Arizona SIP. PIMA ASSOCIATION OF GOVERNMENTS TIP FY

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