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Final PM2.5 Project-Level Conformity Analysis for the Ohio River Bridges Project in Louisville, Kentucky

VI. PM2.5 Hot-Spot Analysis

The ORB project meets the criteria set forth in 40 CFR 93. 123(b)(1) for projects of air quality concern primarily because it is a new highway facility with a significant level of diesel vehicles; thereby requiring a hot-spot analysis. The ORB downtown 2020 (open to traffic date) AADT and total daily truck traffic are forecasted to be 291,412 and 45,700 (15.7 percent), respectively. These AADT and total daily truck traffic are over 125,000 AADT and 10,000 trucks per day - the values cited in the preamble to the conformity rule by EPA as examples of projects of air quality concern.

Construction emissions and re-entrained road dust

40 CFR 93.123(c)(5) states "CO, PM10, and PM2.5 hot-spot analyses are not required to consider construction-related activities which cause temporary increases in emissions. Each site which is affected by construction-related activities shall be considered separately, using established "Guideline" methods. Temporary increases are defined as those which occur only during the construction phase and last five years or less at any individual site." As shown in Exhibit 2, page 7, the ORB project is comprised of several individual sub-projects. At a high level, the sub-projects are:
Downtown:
1) Kennedy Interchange Reconstruction,
2) Downtown Bridge,
3) Downtown Indiana Approach, and
East End
4) East End Kentucky Approach,
5) East End Bridge, and
6) East End Indiana Approach.

An approximate schedule is shown in Exhibit 6.

Exhibit 6.
Louisville Southern Indiana Ohio River Bridges Project Construction Schedule Overview
State Fiscal Year 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020
Section 1 - Kennedy Interchange                          
Phase 1 X X                      
Phase 2       X X                
Phase 3           X X X          
Phase 4             X X X X      
Phase 5                 X X X    
Phase 6                     X X  
Phase 7                     X X X
Phase 8                     X X X
Section 2 - I-65 Downtown Bridge               X X X X    
Section 3 - I-65 Indiana Approach                          
Phase 1             X X X        
Phase 2                 X X X    
Phase 3                     X X  
Section 4 - East End Kentucky Approach                          
Phase 1 X X X X X                
Phase 2   X X X X                
Phase 3       X X X              
Section 5 - East End Bridge     X X X X              
Section 6 - East End Indiana Approach     X X X X              

It is anticipated that the construction of these sub-projects will be further divided into different individual construction sites. As such, localized construction emissions can be considered separately and temporary as construction-related emissions at each individual construction site is anticipated to be less than 5 years. Per 40 CFR 93.123(c)(5), temporary construction-related emissions are not required to be included in the hot-spot analysis.

The Conformity Rule requires PM2.5 hot-spot analyses to include road dust emissions only if such emissions have been found significant by EPA or the state air agency prior to the PM2.5 SIP or as part of an adequate PM2.5 SIP motor vehicle emissions budget (40 CFR §93.102(b)(3)). EPA has not approved a PM2.5 SIP for the Louisville KY-IN PM2.5 nonattainment area, nor has EPA or the state air agency made any significance findings related to re-entrained road dust for the PM2.5 nonattainment area. Therefore re-entrained road dust is not considered in the analysis, per the Conformity Rule. In addition, as there is not an applicable PM2.5 SIP for this area, there are no PM2.5 control measures and the project is in compliance with 40 CFR 93.117.According to 40 CFR 93.123(b)(2) and (4), a quantitative analysis for applicable projects is not required until EPA releases modeling guidance in the Federal Register. However, a qualitative hot-spot analysis is required. For the ORB project, a qualitative, project-level, hot-spot assessment was conducted in order to assess whether the project will cause or contribute to any new localized PM2.5 violations, increase the frequency or severity of any existing violations, or delay timely attainment of the PM2.5 NAAQS.

Existing Conditions

The affected area for the purposes of this analysis is the ORB study area, as discussed in Section III of this report and further elaborated in the FEIS and associated documentation. This section includes a discussion of currently available information on existing conditions related to air quality and traffic conditions in the project area.

Air Quality - Monitors

There are currently seven PM2.5 monitors in the Louisville KY-IN PM2.5 nonattainment area: five in the Commonwealth of Kentucky and two in the State of Indiana. The location of the Kentucky and Indiana monitors are shown in Exhibit 7, and Exhibit 8, respectively. Based on 2003-2005 air quality monitoring data, there are four monitors that exceed the annual mean PM2.5 standard (three year average of annual means) of 15.0 ug/m3. The exceeding monitors are the Jeffersonville, Indiana monitor and three of the monitors in Kentucky, including the Barret Avenue monitor. Based on 2003-2005 air quality monitoring data, none of the monitors in the PM2.5 nonattainment area are exceeding the 24-hour PM2.5 standard (3-year average of the annual 98th percentile) of 65 ug/m3 and none have exceeded this standard in past years. Appendix B provides a summary of the 2003-2005 annual averages as well as the 2003-2005 design values.

The Barret Avenue monitor (AIRS-ID number 211110048) and the Jeffersonville, Indiana monitor (180190006) are the only monitors in reasonably close proximity to the ORB project; both monitors are about 1.3 miles from the center of the downtown project site. The Barret Avenue monitor annual design values have dropped by 8 percent since 2002; however, it is still slightly exceeding the annual standard with a 2003-2005 annual design value of 15.3 ug/m3. The Jeffersonville, Indiana monitor is exceeding the annual standard with a 2003-2005 annual design value of 16.5 ug/m3. With the prevailing winds in the area from the southwest, the Jeffersonville monitor may be picking up river barge traffic emissions, industrial park emissions, and downtown Louisville area mobile source emissions leading to the high design value. Exhibit 9 shows a more detailed map of the downtown project areas with the Barret Avenue and Jeffersonville monitor locations depicted.

The Kentucky Division for Air Quality 2004 Kentucky Ambient Air Quality Annual Report and Air Quality Surveillance Network showed a downward trend in annual average PM2.5 design values between 2000 and 2004 for Louisville area.6.

Exhibit 7. PM2.5 Monitor Sites in the LMA in Kentucky
General map showing locations of Kentucky's PM2.5 monitors in the vicinity of Louisville, Kentucky.


Exhibit 8. PM2.5 Monitor Sites in the LMA in Indiana
General map showing locations of Indiana's two PM2.5 monitors in the vicinity of Louisville, Kentucky.  The Jeffersonville site is just north of downtown, and the New Albany site is just inside I-264 northwest of the city.


Exhibit 9. More Detailed Map of the Barret Avenue and Jeffersonville PM2.5 Monitor Sites
Detailed street-level map showing the downtown area around the Kennedy Bridge. Locations of the Barret Avenue and Jeffersonville PM2.5 monitors are marked on the map. The Barret Avenue site is roughly 1.5 miles south of the bridge, and the Jeffersonville site is roughly 1.5 miles north of the bridge.

Transportation and Traffic Conditions

Currently, mobility in the LMA is limited, in part, due to inadequate capacity to cross the Ohio River. Based on 2006 KYTC traffic counts, I-64 is carrying 134,500 vehicles per day; I-65 is carrying 139,500 vehicles per day; and US 31 is carrying 19,200 vehicles per day in the downtown area. Therefore, the total current traffic volume in this area is 293,200 vehicles per day. Current (2006) AADT for the ORB project area is depicted in Appendix A. Level of Service is poor. The 1999 LOS is depicted in Exhibit 3 previously seen in this report. With increased AADT and increased congestion, the LOS will continue to worsen. Based on current and future forecasted congested conditions, the existing and planned (excluding the ORB project) network will not carry the forecasted traffic without a severe increase in delay time resulting in an increase in travel time and a decrease in LOS on the interchanges (see Exhibit 3). The existing downtown bridges will be forced to carry the additional cross-river traffic generated by the east end, increasing the travel and safety problems of the downtown area. Please refer to the FEIS at the ORB website http://www.kyinbridges.com/ for a complete presentation of the traffic data.

Public transportation is provided across the Ohio River in the LMA by the Transit Authority of River City (TARC). Currently TARC operates six bus routes across the Ohio River. Three routes use the Sherman Minton Bridge (I-64) with 243 weekday boardings (unlinked passenger trips) on 48 one-way trips. Three routes use the Clark Memorial Bridge (US 31) with 1037 weekday boardings on 93 one-way trips. Pedestrian access is provided on two narrow walkways on the Clark Memorial Bridge (US 31). Bicycle travel is accommodated in the driving lanes on the Clark Memorial Bridge. Pedestrian and bicycle travel are prohibited on both the Kennedy (I-65) and Sherman Minton (I-64) bridges.

No other cross-river transportation access is provided in the LMA other than on the three existing roadway bridges and the two railroad bridges.

Built and Natural Environment

The LMA has developed effective planning and growth management systems. The existing land use throughout the LMA includes parks and open space, residential areas, commercial and industrial areas as well as agricultural areas. Exhibit 10 depicts the existing land use within the area from the FEIS. The downtown area is currently the economic heart of the area; however, locally-approved land use plans call for additional commercial, industrial, and residential development, with attendant population and employment growth, in eastern Jefferson and southeastern Clark counties in the coming years.

For a more detailed discussion of the study area land use, please refer to the FEIS (http://www.kyinbridges.com/).

Exhibit 10. Existing Land Use
Detailed map showing existing land use in the vicinity of Louisville, Kentucky.

Emissions Trends

EPA's December 2004 particle pollution trend report7 findings indicate that PM2.5 emissions have dropped nationwide by 10% from 1999-2003. During that time, in the Industrial Midwest states, including Kentucky, PM2.5 emissions have dropped by 9%. Per the KIPDA August 2006, PM2.5 preliminary conformity assessment using EPA's approved mobile source emissions estimation tool, MOBILE6.2, direct on-road mobile sources PM2.5 annual mobile source emissions for the entire nonattainment area are expected to decrease by over 50 percent in 2014 (the anticipated open to traffic date for the east end bridge) from a 2002 baseline and by 61 percent in 2020 (the anticipated complete ORB project opening year), even though the vehicles miles traveled are expected to increase by 32 percent from 2002 to 2020 (see Exhibit 11.). Although the estimates of direct PM2.5 from on-road mobile sources show a slight increase in 2030 from 2020, these estimates are still 58% less than the 2002 baseline and 50% less than 2006 emission estimates.

Exhibit 11. PM2.5 Mobile Source EmissionsTrends Analysis for Louisville Nonattainment Area

KIPDA August, 2006 PM2.5 Preliminary Conformity Assessment 8

Bar graph showing PM2.5 and NOx estimates from MOBILE6.2 modeling.  PM2.5 values are reported in kg/day and NOx values are reported in 1000 kg/day.  The 2002 values are 1333 and 92 for PM2.5 and NOx, respectively.  The 2009 values are 852 and 52 for PM2.5 and NOx, respectively.  The 2012 values are 664 and 36 for PM2.5 and NOx, respectively.  The 2020 values are 520 and 15 for PM2.5 and NOx, respectively.  The 2030 values are 562 and 14 for PM2.5 and NOx, respectively.

According to EPA, the 2007 Heavy-duty engine standards will result in the introduction of new, highly effective control technologies for heavy-duty engines, beginning in 2007. Particulate matter emission levels are expected to be 90 percent lower on a per vehicle basis than 2000 standards levels due to the 2007 diesel engine and fuel program.9

The ORB project is intended to provide additional roadway capacity in the study area to accommodate the future traffic growth and demand for through traffic travel on both I-64 and I-65. The additional capacity in the region will help to reduce stop and go traffic, extended idling, and improve traffic flow in the area. Additionally, the new east end bridge will relieve traffic in the downtown area by allowing cross-river travel between the high growth areas of eastern Jefferson County, Kentucky and southeastern Clark County, Indiana. Please refer to the FEIS, Alternatives for a complete presentation of the traffic data.

Analytical Considerations

A comparison approach was used for the PM2.5 hot-spot consideration. A surrogate analysis was used. A "surrogate" (or substitute) site is a site for which the current levels of AADT and truck traffic are comparable to or greater than those of the future worst-case build scenario. If, additionally, the surrogate site has a monitor in the vicinity with current PM2.5 design values
less than the standards, then one can logically conclude that the worst-case build scenario will not cause or add to an existing PM2.5 violation.

The east end build scenario open to traffic date of 2014 is considered the worst-case scenario for the east end. This worst-case sencario was compared to the example of "a project of air quality concern" from the preamble to the March 10, 2006 rule (71 FR 12491) which cited as "significant" a project on a new highway or expressway with 125,000 AADT and 8 percent trucks. Further, the east end 2014 worst-case scenario was compared to two "surrogate" sites.

The downtown area build scenario 2020 worst-case (i.e., assuming completion and open to traffic of a new east end bridge and a new downtown bridge, as well as completion of the downtown Kennedy interchange reconstruction) was compared to the two chosen "surrogate" sites as well.

The KYTC reviewed the current traffic and monitoring data in Kentucky and neighboring states in search of a site that might possibly have similar traffic counts and truck percentages as the ORB project. Two surrogate sites were selected and are discussed below.

Worst-Case Scenarios

As clarified in the preamble to the July 1, 2004, revision to the transportation conformity rule (69 Federal Register 40004), the conformity rule requires that project-level analyses consider the year (or years) of expected peak mobile source emissions from the project. For PM2.5, this is expected to be a near-term year, such as the first year of operation of the project, because emission rates from vehicles are predicted to decline with time due in part to improvements in tailpipe emissions and national vehicle emissions control programs. As indicated in the KIPDA trend analysis shown in Exhibit 11, the regional PM2.5 mobile source emissions are much lower in 2020 (the open to traffic year for the final phases of the ORB project) than in the 2002 baseline year. It should be noted that the KIPDA trend analysis predicts 2030 mobile source emissions slightly higher than for 2020; however, the 2030 predicted mobile source emissions are still 58 percent less than those for 2002 and 15 percent less than those predicted for 2012.

In addition, over the last few years, EPA has finalized a series of national vehicle control programs expected to reduce mobile source emissions substantially over the next several years. These programs include the Tier II vehicle and fuel sulfur standards for light-duty vehicles, the 2007 Highway Rule for heavy-duty diesel vehicles, and other related programs10

Regional mobile source emissions are a good indicator of the overall emissions trends in the region, therefore it is expected that the open to traffic date would represent the year of peak emissions from the project and other emissions sources that affect the project area. As discussed below, the open to traffic date for the east end bridge is 2014 and the open to traffic date for the downtown bridge and interchange reconstruction is 2020. Since these two areas are the only concentrations of traffic resulting from this project, it is logical to identify these two areas and their respective open to traffic dates as worst-case locations.

Currently, without an east end bridge, traffic desiring to cross the Ohio River in the east end must do so by crossing one of the downtown bridges. As a part of the ORB project, the east end bridge will be completed and open to traffic by 2014. Hence, the east end area build scenario in 2014 can be selected as a worst-case. Based on FEIS forecasted traffic for 2025, the 2014 AADT for the east end bridge can be estimated to be 53,20011. Based on forecasts for I-265 in the east end area, the 2014 truck percentage for the east end bridge is forecasted to be 11.7 percent; resulting in an estimated daily truck volume of 6,200 in 2014. This information is displayed in Appendix A.

The downtown area 2020 traffic analysis, includes the impact of traffic on I-64 (after I-71 has merged with I-64), on I-65, and on the Clark Bridge (US 31). In 2020, the downtown AADT has been estimated assuming completed construction of the new east end bridge and has been determined from forecasts detailed in the FEIS12. Hence, since 2020 is the open to traffic date for the downtown construction, 2020 can be selected as a worst-case scenario for downtown. In 2020, with completion of both the new east end bridge and the new downtown bridge, as well as the completion of the Kennedy interchange reconstruction and the reconfiguration of the existing I-65 bridge, I-64 is projected to carry 133,700 vehicles per day; I-65 is expected to carry 138,600 vehicles per day; and US 31 is projected to carry 19,100 vehicles per day in this vicinity. Therefore, the total overall 2020 traffic volume in the downtown area for the ORB project is estimated to be 291,000 vehicles per day. (It should be noted that in 2020 the east end bridge will be carrying 42,000 AADT of cross-river traffic that would otherwise have traveled across the downtown bridges under the no-action scenario). I-64 is projected to have a truck percentage of 19.2 percent; I-65 to have a truck percentage of 13.3 percent; and US 31 to have a truck percentage of 8.2 percent. The weighted average truck percentage for these three roadways is approximately 15.7 percent or 45,700 trucks per day. The east end bridge 2020 AADT has been estimated as 61,400 including 19,400 AADT generated by the building of the new bridge. Based on forecasts for I-265 in the east end area, the forecasted 2020 truck percentage for the east end bridge is forecasted to be 13.6 percent; resulting in an estimated daily truck volume of 8,300 in 2020. This information is displayed in Appendix A.

ORB Project Downtown Build 2020 (Worst-Case) vs. No-Action

As discussed above, the ORB project downtown area open to traffic date of 2020 represents the downtown area build worst-case scenario. As can be seen in Appendix A, the build 2020 worst-case forecasts are for considerably lower AADT and fewer trucks for the downtown area than the forecasts for the 2020 no-action scenario. Further, as can be seen (by interpolation) from the LOS data displayed in Exhibit 3, the 2020 build scenario will lead to a better LOS for the downtown area than that predicted by the no-action scenario. This is due to the relief in the downtown AADT provided by the availability of the new east end bridge, with additional congestion relief and LOS improvement coming from the reconstruction of the Kennedy interchange and the additional cross-river lanes on the new downtown bridge in the downtown area. As compared to the no-action scenario, the 2020 build scenario will result in improved speeds, less delay, and reduced idling in the downtown area; thus leading to reduced mobile source emissions.

Surrogate Site Search

A search was made in Kentucky and surrounding states for sites (surrogate sites) having similar, or greater, AADT and truck traffic as one or both the ORB worst-case locations as detailed in Appendix A. Two potential surrogate sites, current downtown Louisville I-64/I-65 Interchange and the Northern Kentucky I-75(I-71)/I-275 Interchange, were selected and are discussed below:

Surrogate Site 1 - Current Downtown Louisville I-64/I-65 Interchange13

Currently, in the Louisville downtown area, near the I-64/I-65 Interchange, I-64 is carrying 134,500 vehicles per day; I-65 is carrying 139,500 vehicles per day; and US 31 is carrying 19,200 vehicles per day, resulting in a total current AADT in this area of 293,200 vehicles per day. Truck traffic makes up 11.1 percent or 32,500 trucks per day. The level of service (LOS) is poor. The Barret Avenue monitor (AIRS-ID number 211110048) and the Jeffersonville, Indiana monitor (180190006) are the only monitors in reasonably close proximity to the ORB project; both monitors are about 1.3 miles from the center of the downtown project site. Although the Barret Avenue monitor annual design value is still slightly exceeding the annual standard with a 2003-2005 annual design value of 15.3 ug/m3, the design values have dropped by 8 percent since 2002. The Jeffersonville, Indiana monitor is exceeding the annual standard with a 2003-2005 annual design value of 16.5 ug/m3. With the prevailing winds in the area from the southwest, the Jeffersonville monitor may be picking up river barge traffic emissions, industrial park emissions, and downtown Louisville area mobile source emissions leading to the high design value. As stated earlier, none of the monitors in the area are exceeding the current 24-hour PM2.5 standard of 65 ug/m3. National, state, and local PM2.5 emissions are expected to decrease dramatically
over the next 15 years due to the implementation of various programs as explained above; the trend in PM2.5 mobile source emissions for the LMA is demonstrated in the KIPDA trend analysis shown in Exhibit 11.

Downtown Area Build 2020 Worst-Case Comparison - The current downtown Louisville AADT is more than the ORB downtown area 2020 worst-case. The growth in truck percentage with time results in a downtown area build 2020 worst-case truck percentage of 15.7 percent (or 45,700 trucks per day) verses the current downtown truck percentage of 11.1 percent (or 32,500 trucks per day). Since the Barret Avenue monitor in the vicinity of the site is reading barely over the standard, it is reasonable to conclude that the monitor readings in 2020 will not be increased, and, in fact, due to the area downward trend in emissions as discussed above, will be meeting the standard. Thus, the current downtown Louisville area could act as a surrogate for the downtown Louisville area 2020 build scenario. Hence, the ORB downtown area build scenario 2020 worst-case emissions will not cause or add to an existing PM2.5 violation.

East End Area 2014 Worst-Case Comparison - The current downtown Louisville (surrogate site 1) AADT and number of trucks is more than triple the forecasted ORB east end area 2014 worst-case. Thus, this site (surrogate site 1) would adequately represent the ORB east end area build 2014 worst-case scenario. Further, as explained above, since the Barret Avenue monitor in the vicinity of the site is reading barely over the annual standard, it is reasonable to conclude that the monitor readings in 2020 will not be increased, and, in fact, due to the area downward trend in emissions, will be below the annual standard. Further, as discussed above, the monitor readings are well below the 24-hour standard. Therefore, it is reasonable to conclude that the ORB east end area build scenario 2014 worst-case emissions will not cause or add to an existing PM2.5 violation.

Surrogate Site 2 - Northern Kentucky I-75(I-71)/I-275 Interchange

Near the northern Kentucky I-75(I-71)/I-275 interchange area, I-75(I-71) is carrying 164,900 vehicles per day with 30 percent (49,500) trucks and I-275 is carrying 95,000 vehicles per day with 10 percent (9,500) trucks. Thus, the total current AADT in this area is 259,900 vehicles per day with an average percentage of 22.7 percent (59,000) trucks. The LOS is not available for this interchange, however, the volume to surface flow ratio (V/SF) values14 are over or near 1.0, indicating that the LOS for at least some legs of the interchange are at a level E or worse. The 1401 Dixie Highway, Covington monitor AIRS-ID number 211170007 is the only monitor within reasonable proximity (about six miles away) of this interchange. The 2003-2005 annual design value for this monitor is below the annual standard with a value of 14.5 ug/m3. Monitor readings for 2002-2005 have been well below the 24-hour standard5. A map of this area, marking the monitor site, is shown in Appendix C.

Downtown Area Build 2020 Worst-Case Comparison - While the surrogate site 2 AADT is less than the ORB downtown area 2020 worst-case, the truck percentage and number of trucks (22.7 percent trucks or 59,000 total trucks) are considerable higher that of the ORB downtown area 2020 worst-case forecasts (15.7 percent trucks or 45,700 total trucks). Thus, because of the excessive diesel traffic this site would likely generate more PM2.5 than would the ORB downtown area build 2020 worst-case scenario from a diesel emissions perspective. Therefore, since the monitor in the vicinity of this area has design values under the standards, it is reasonable to conclude that the downtown area build 2020 area worst-case emissions will not cause or add to an existing PM2.5 violation.

East End Area 2014 Worst-Case Comparison - The AADT and number of trucks is more than triple the ORB east end area 2014 worst-case. Thus, this site would adequately represent the ORB east end area 2014 worst-case scenario. Therefore, since the monitor in the vicinity of this area has design values under the standards, it is reasonable to conclude that the ORB east end area 2014 worst-case emissions will not cause or add to an existing PM2.5 violation.



5 Criteria for identifying projects of air quality concern is described in 40 CFR 93.123(b)(1).
6 2004 Kentucky Ambient Air Quality Annual Report and Air Qualilty Surveillance, Kentucky Division for Air Quality, 2005
7 The Particle Pollution Report, EPA 454-R-04-002
8 KIPDA Fall 2006 Conformity Analysis
9 Heavy-duty Engine and Vehicle Standards and Highway Diesel Fuel Sulfur Control Requirements - Final Rule ("2007 Heavy-Duty Highway Final Rule") (Signed December 21, 2000)
10 For more information on EPA's national vehicle control programs, please refer to EPA's Office of Transportation and Air Quality program information available at http://www.epa.gov/otaq/.
11 2014 traffic was interpolated based 1990 and 2025 estimates from the FEIS. All values are rounded to the nearest hundred.
12 By definition, data for a surrogate site is current data; however, the redundant word "current" is used here to emphasis the distinction between the current (2006) downtown conditions and the downtown area build scenario 2020 "worst-case" conditions, i.e., locations are the same, years are different.
13 See FHWA's Highway Capacity Manual 2000 http://www.fhwa.dot.gov/ohim/hpmsmanl/appn.htm
Updated: 07/06/2011
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