Technical Guidance for TG-POL-01-08 Qualitative Hot Spot Analysis for PM2.5 February 4, 2008 This technical guidance provides general guidelines for performance of a qualitative hot spot analysis for particulate matter during the preliminary design phase of the project. PM2.5 assessing procedures, coordination requirements, and mitigation measures contained herein are based on the guidelines collaborated by the US Environmental Protection Agency and the FHWA, entitled Transportation Conformity Guidance for Qualitative Hot Spot Analyses in PM2.5 and PM10 Non-Attainment and Maintenance Areas dated March 2006, and USEPA s Final Rule (71F12468). All highway projects developed in conformance with the above and this document shall be in conformance with the above mentioned guidance. This standard procedure is applicable to federally funded projects. Areas of air quality and areas sensitive to particulate matter concentrations should be identified in the Red Flag Summary. Should the project area not be in an area of air quality or not have sensitive areas in the vicinity of the project, no PM2.5 Hot spot analysis is required. Should a PM2.5 Qualitative Analysis be warranted, it should be done in Step 3 of the PDP for minor projects or in Step 6 (Assessment of Feasible Alternatives) for major projects. 1.0 Analysis Criteria There are two levels of analysis for PM2.5. Projects are divided into two categories: 1) Those that have no potential to meet the minimum traffic criteria listed in the aforementioned guidelines and are not considered being in an area of air quality and 2) Those that meet traffic criteria and are in an area that is designated nonattainment for PM2.5. There are various criteria that determine whether a PM Hot Spot analysis is warranted. 1. Projects classified as having no meaningful affect on PM are typically those classified by the ODOT environmental process as exempt or Categorical Exclusion Level 1. Projects that have no meaningful affect must also satisfy the following criteria: a. Projects exempt under the Clean Air Act Conformity Rule 40CFR93.126. b. Projects that do not add capacity to an existing roadway or involve new roadways on new alignment. Projects that meet the above criteria shall require no further analysis. 2. Projects that qualify for a qualitative PM analysis must be considered to be in an area of air quality and satisfy all three of the following criteria. a. Projects must be located in an area designated non-attainment for PM2.5 and: b. Projects must have one or more sections that have a design year traffic volume that exceeds 125,000. In the case of an interchange modification that adds capacity, the project ADT will be the sum of the design year traffic on both roads and:
c. The project must have a total design year truck percentage that meets or exceeds 8 percent. 1.1 PM2.5 and PM10 Analysis Two methods of PM qualitative analyses are listed in the guidance. The methods are considered examples and can be substituted for other methods. Elements of both methods may be combined for a given Hot-Spot analysis. The method chosen will be affected by the characteristics of a particular project, the project location, and available information. 1. Comparison to another location with similar characteristics. Chapter 4 Sec. 4.1(a) of the guidance. 2. Data from air quality studies for the proposed project location Chap. 4 Sec. 4.1(b) of the guidance. 1.2 Mitigation Emission control measures, such as retrofit or anti-idling measures may mitigate any potential increase in PM2.5 emissions at the proposed project s location. The impact of Phase-in of national rules and regulations that EPA has promulgated, such as heavy duty diesel rules that are currently being implemented should also be considered. Potential mitigation measures can be found in Appendix C however other measures may be possible. 1.3 Report Requirements The Hot-spot analysis should include a summary of the method and data that were used, such as: A description of the analysis method chosen A description of the type of PM2.5 emissions A description of the existing conditions pertaining to the project location A description of the changes in these factors that will result from the project for future scenarios, including changes in the surrounding environment that will affect PM2.5 air quality, traffic and emissions A description of the analysis year examined A discussion of any mitigation measures that will be implemented with there expected effects A conclusion for how the proposed project meets 40CFR93.116 and 93.123 conformity requirements The analysis should be done in Step 3 of the PDP for minor projects or in Step 6 (Assessment of Feasible Alternatives) for major projects and submitted to The Office of Environmental Services. OES will initiate the Inter-Agency Process as listed in the USEPA guidance. 2
2.0 Project Screening Process The OES had developed a project screening process through the Inter-Agency Process in collaboration with the Federal Highway Administration (FHWA), the Environmental Protection Agency (EPA) and the Ohio Environmental Protection Agency (OEPA). This process is outlined in Table 1. The OES will provide a list of nonexempt projects that are not projects of air quality as outlined in Table 1 to the consulting parties and request a conformity determination from the Ohio FHWA Division Office for all projects on the list. Projects of air quality will require a qualitative hot spot analysis and an individual request for conformity determination from the Ohio FHWA Division Office. Authority The Environmental Protection Agency (EPA) final rule (71 FR 12468) established March 10, 2006 establishes the transportation conformity criteria and procedures for determining which transportation projects must be analyzed for local air quality impacts in PM2.5 non-attainment and maintenance areas. A Hot-Spot analysis is defined in 40 CFR 93.101 Scope This interim procedure is intended for use by the Division of Planning, the Office of Environmental Services, ODOT District offices, the Office of Technical Services and their consultants. Definitions Consulting Parties a group of agencies comprised of ODOT, FHWA, EPA and OEPA meeting for the purpose of facilitating project level conformity determinations for transportation projects in PM2.5 non-attainment areas. Particulate Matter Aerosol sized, airborne particles either 2.5 microns or smaller and particles that are 10 microns or smaller in size. Average Daily Traffic (ADT) the average daily traffic of a given roadway Areas of Air Quality Concern - counties that have been designated non-attainment status for PM2.5 and PM10 by the USEPA Residential Area land developed for residential use Sensitive Area developed land comprised of residential areas (schools, hospitals, nursing homes and other similar uses). Vulnerable Population - children, the elderly and other populations with particular sensitivity to particulate matter Training The procedure will be incorporated in Environmental training modules of the Office of Environmental Services. 3
Fiscal Analysis Implementation of this procedure will result in minor cost increases during Preliminary Design. The impact is expected to be limited to personnel involved in report preparation and modeling by the responsible party 4
Table 1: Ohio Department of Transportation PM 2.5 Screening Process Project Type Highway Capacity Expansion Screening Evaluation Criteria Are the forecasted total Build condition traffic volume 87,500 annual average daily traffic (AADT) and truck volume 7000 heavy trucks per day in the project vicinity? Does the project result in a 4375 and 350 increases in total truck volume respectively between Build and No Build conditions? Not a project of air quality Not a project of AQ Qualitative PM2.5 Analysis Required Intersection (Channelization, Circles, Roundabout, Signalization) or Interchange Reconfiguration New Highway, Expressway or Interchange Construction Expanded Intermodal or Transit Facility for Rail, Bus or Truck New Intermodal or Transit Facility for Rail, Bus or Truck Other Project Types Do the above criteria for the Highway Capacity Expansion project type identify this project as Not a project of AQ? Is the project expected to improve (or not further degrade) LOS and delay for the roadway with the highest number of diesel vehicles in the project vicinity? Not a project of AQ Qualitative PM2.5 Analysis Required Are the forecasted total Build condition traffic volume 87,500 AADT and truck volume 7000 heavy trucks per day in the project vicinity? Does the project include new ramps or other improvements to connect a highway to a major freight, bus or intermodal terminal? Qualitative PM2.5 Not a project of AQ Analysis Required Is the existing facility not regionally significant under 40CFR93.101 or does the expanded facility have 10 buses/trucks in peak hour of the facility? Will the facility involve an increase in peak diesel bus/truck arrivals 25% between Build and No Build conditions? Will the facility expansion primarily ( 80%) involve nondiesel Not a project of AQ vehicles (CNG, Hybrid, etc.)? Not a project of AQ Not a project of AQ Qualitative PM2.5 Analysis Required Is the existing facility not regionally significant under 40CFR93.101? Not a project of AQ 5