Air Quality Conformity

Air Quality Conformity Task Force

The Air Quality Conformity Task Force (AQCTF) is an interagency working group which MTC consults prior to making either regional transportation conformity determinations on the Regional Transportation Plan (RTP) or Transportation Improvement Program (TIP) or project-level conformity determinations.

The Task Force carries out a number of activities, including reviews the assumptions, approach, and methodology for the regional conformity analysis, reviews the draft and proposed final conformity analysis for the RTP and TIP, facilitates interagency consultation and reviews projects to determine project-level conformity requirements, reviews various elements of state and federal air quality plans, and discusses relevant regional and statewide conformity issues.

Membership of the AQCTF includes representatives from federal (US Environmental Protection Agency Region 9, Federal Highway Administration, Federal Transit Administration), state (Air Resources Board, Caltrans), regional (MTC, Bay Area Air Quality Management District, and Association of Bay Area Governments), and sub-regional (Congestion Management Agencies, transit operators, local jurisdictions, etc.) agencies.

The AQCTF meets on the fourth Thursday of each month with the exception of when that Thursday lands on a holiday. Meetings are held at the MetroCenter in Oakland and start at 9:30am. Task Force meetings are open to the public. For more information about the Task Force or transportation conformity in the Bay Area region, please contact Brenda Dix (bdix@mtc.ca.gov) or Stefanie Hom (shom@mtc.ca.gov).

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Project Level Conformity

The nine-county San Francisco Bay Area region was designated by EPA as a non-attainment area for the 24-hour fine particulate matter (PM2.5) standard. As of December 14, 2010, certain transportation projects which use any federal funds or seek federal action are subject to project level conformity requirements.

To complete the project level conformity requirements, please begin with Step 1 of the  Air Quality module in the Fund Management System (FMS). A step-by-step guide to completing this process can be found in the download box below.

Some projects which do not have air quality implications, such as a bicycle and pedestrian projects, are considered exempt from project level conformity requirements. A listing of exempt projects can be found in the Federal Transportation Conformity Rules (PDF). For projects which are not exempt, a project level review and an interagency consultation with members of EPA, FHWA, FTA, Caltrans, MTC and other agency members is completed to determine if the construction of the project will result in adverse air quality impacts of fine particulate matter in the project area. Procedures for project level review and interagency consultation in the Bay Area region can be found in MTC Resolution 3946 (PDF). Additionally, a project assessment form and sample form can be found below. If a project is deemed to have localized impacts, the project will be labeled as a “project of air quality concern” or POAQC. Projects of air quality concern must complete a localized emissions impact analysis known as hot-spot analysis.

Procedures for completing a hot-spot analysis are currently in transition from a qualitative analytical method to a quantitative analytical method. Sponsors of projects requiring a hot-spot analysis may prepare a qualitative hot-spot analysis up until December 20, 2012. However, effective December 20, 2012, sponsors are required to prepare a rigorous quantitative hot-spot analysis which involves significant data collection and emissions modeling using the California Air Resources Board’s EMFAC emissions model. EPA and US DOT are offering a 3-day training course on preparing PM2.5 quantitative hot-spot analysis.  Information regarding the procedures of conducting a qualitative or quantitative hot-spot analysis as well as participating in training courses can be found below.

For more information about the PM2.5 project level conformity process, please see the reference materials below.

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Regional Transportation Conformity

Pursuant to the Environmental Protection Agency (EPA) Transportation Conformity Rule Parts 51 and 93 as well as the United States Department of Transportation’s Metropolitan Planning Rule 23 CFR Part 450, federal transportation plans, programs and projects must conform to the State Implementation Plan (SIP). This means that transportation activities will not cause new air quality violations, worsen existing violations, or delay timely attainment of the relevant national ambient air quality standards.

A conformity finding demonstrates that the total emissions projected for the RTP or TIP are within the emissions limits ("budgets") established by the SIP, and that transportation control measures (TCMs) are implemented in a timely fashion.

Conformity requirements apply in all nonattainment and maintenance areas for transportation-related criteria pollutants and precursor pollutants for which the area is designated nonattainment or maintenance area. For the Bay Area, the criteria pollutant to be addressed is ground-level ozone (i.e., reactive organic compounds and oxides of nitrogen), carbon monoxide, and PM2.5 and the precursor pollutants to be addressed include volatile organic compounds (VOC) and oxides of nitrogen (NOx) for ozone and NOx for PM2.5. The latest EPA published transportation conformity regulations to implement the 1990 California Clean Air Act section 175A is dated March 2010.

For more information regarding regional conformity status of the Bay Area or general information, please see the reference materials below.