FHWA Resource Center
RC Success Stories
VOLUME 1, ISSUE 5
Your Link To Successful Solutions For Today's Transportation
JANUARY, 2002
INTERAGENCY - A Fresh Breath Of Air Quality
In 1995, The Commonwealth of Kentucky submitted their motor vehicle emissions budgets (MVEBs) for Marshall and a portion of Livingston Counties (i.e., the Paducah area). Because of underestimation of the region's travel activity and lack of an interagency consultative process, the State air quality Implementation Plan (SIP) under the Environmental Protection Agency (EPA) air quality guidelines did not provide adequate provisions for the growth necessary on motor vehicle emission to allow for future highway projects. The result was an unfortunate transportation conformity lapse that lasted for more than five years. This issue had to be resolved, and it would take multiple agencies coming together for a successful resolution.
The State submitted the SIP in 1992 when EPA classified the area as a ''marginal'' non-attainment area for Ozone under the Clean Air Act Amendments of 1990. The maintenance SIP projections were from 1990 through 2004. Since the 1990 data had been grossly underestimated, demonstrating transportation conformity was extremely difficult for subsequent years. As a result, several of the region's highway projects were stopped or eliminated because they could not conform to the emission budgets contained in the maintenance SIP.
In March, 2000, the Federal Highway (FHWA) Kentucky Division coordinated a rapid response team led by Sarah Siwek, a consultant to FHWA Headquarters. Additionally, this team included FHWA Headquarters specialist Cecilia Ho, FHWA Eastern Resource Center (ERC) specialist Joon Byun, FHWA Southern Resource Center (SRC) specialist Andrew Edwards, members of Kentucky Transportation Cabinet (KYTC), and members of Kentucky's Division for Air Quality (DAQ). While this team investigated the impact of varying parameters in the emission model as well as the potential for taking off model credits, a solution was not found that allowed conformity to be demonstrated. The conclusion of the rapid response team was that a SIP revision was required. However, at the time, the 8-hour standard implementation appeared imminent and Kentucky's DAQ would not initiate a SIP revision.
Not succumbing to obstacles, KYTC again contacted the FHWA Kentucky Division. FHWA Kentucky Division Environment team's Brent Sweger and Bernadette Dupont accessed the issue and involved the FHWA Southern Resource Center (SRC) specialists Mike Roberts and Andrew Edwards. At the same time, high-level officials from Kentucky state government, KYTC, FHWA and U.S. Environmental Protection Agency (USEPA) collaborated to resolve the problem. At the heart of the issue was getting all the affected parties involved in an open and frank discussion of the technical issues. The specialists knew they had a strong justification to warrant a revision of the original SIP done in 1995. All parties agreed that a SIP revision request was in order. KYTC Transportation Engineer Specialist, Barry House, worked to quantify the original problem and to provide justification for a SIP revision. Through collaboration with Mike and Andy, the justification was provided to the satisfaction of USEPA and the SIP revision was approved.
INTERAGENCY WORKS
- The states ability to do conformity is only as good as their interagency consultative process.
- The lack of a thorough interagency process will lead to a break down in your ability to get transportation projects done in a non-attainment area.
- Methodologies included in the SIP document and the conformity analyses should be coordinated through the IAC process.
The "Interagency Consultation Process" is prescribed by EPA regulations to help avoid such a situation, yet it is often overlooked by many State and local agencies because it involves new working relationships. Mike and Andy had to jump start Kentucky's interagency consultation process by assembling all agencies that are involved to discuss the issues. This included the FHWA Division office, KYTC, the State Air Quality Agency and Region 4 EPA. Several meetings later, and employing new methodologies for estimating previous years travel activities for the maintenance area, an agreed upon justification for the revised SIP was produced.
FHWA's Air Quality Specialists were successful helping Kentucky in submitting a revised SIP--which EPA later signed and the KYTC is now preceding with the conformity demonstration for the Paducah area. A quality interagency process brought a fresh breath of air to the KYTC's highway program.
For more information, please contact:
Bernadette S. Dupont, KY FHWA-Planning & Environment at (502) 223-6729 or Michael Roberts, SRC-Air Quality Specialist (404) 562-3928
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