Planning for Clean Air and Conformity:

Connecting the SIP to the Transportation System

Jeff RileyHouston, TX

May 30, 2007

The Many Sources of Air Pollution

Source: When Smoke Ran Like Water, Devra Davis, Perseus Books

Donora, Pennsylvania

"Night at Noon." London's Piccadilly Circus at midday, during another deadly smog episode, this time in the winter of 1955.Source: When Smoke Ran Like Water, Devra Davis, Perseus Books

Central London during the killer smog, December 1952. At this point, visibility is less than 30 feet. During the height of the smog, people could not see their own hands or feet, and buses had to be led by policemen walking with flares.Source: When Smoke Ran Like Water, Devra Davis, Perseus Books

London “Smog Episode”December 1952

Source:Why the Great Smog of London Was Anything but Great By ERIC NAGOURNEY

Houston Air Quality

HGB NOx Emissions - 2009

Nonroad(32%) Point

(21%)

Area(9%)

On-road(38%)

Source: TCEQ, May 2007Total: 444 tpd NOx

Trends in Region 6

Houston and DFW 8-hour OzoneExceedance Day Numbers Compared toPrevious Years Through September 21

8-hr O3 days 2006 average 01-05Houston 36 41DFW 31 32

Our two moderate areas (DFW, Houston) face significant challenges in implementing control strategies in time to show attainment by 2009

'88

'90

'92

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'96

'98

'00

'02

'04

'06

'08

'10

Years

70

90

110

130

150

170

190

210

230

pp

b

1-hour ozone concentration1-hour standard

8-hour ozone concentration8-hour standard

1-HR SIP

8-HR SIP

84

124

Houston Ozone Trends

1990 - Clean Air Act Amended to its

Present Form

There have been many iterations of federal clean air legislation, beginning in 1955.

What is a State Implementation Plan (SIP)?

• A specific plan required by the CAA to achieve the NAAQS in all nonattainment areas

• Required by federal law

• SIPs are developed by States (with local input) and submitted to US EPA for approval through federal rulemaking

• After US EPA approval, these SIPs and associated control measures are enforceable at both the state and national levels

SIP Development Process

These components form the state’s plan, or SIP

The State Plan to meet the NAAQS

1-Hr / 8-Hr Transition

• 8-Hr ozone designations effective June 15, 2004.

• The 1-Hr ozone standard was revoked on June 15, 2005.

• HGB area classified as “moderate” under the 8-Hr.

• Attainment year 2009

Houston 8-Hour Timeline

Base case modeling complete

2009 inventory complete

2009 modeling

Control strategy development

Rule development complete

SIP proposal in Dec. 2006

SIP Adoption in May 2007

SIP submittal to EPA no later than June 15, 2007

2006 2007

Comment period closed Feb 12, 2006

TCEQ Houston 8-HR SIP Proposal

• Proposed on December 13, 2006; comment period closed February 12, 2007

• Illustrates a need for ~250 tpd of NOx reductions– Proposes 4 tpd (transportation measures, TxLED for marine fuels)– Some reductions will come from implementation of Federal measures

• Does not demonstrate attainment for any year (current attainment year is 2009)

• EPA is encouraging TCEQ to request a reclassification to a later year and to work with us to identify additional control measures

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4

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1990 1995 2000 2005 2010 2015 2020 2025 2030

highway gasoline

highwaydiesel

nonroad diesel

other mobile sources

Impact of Federal Mobile Source Programs on NOx Emissions

million tons / year

NOx

Status of 8-hr Litigation

• Court ruled on Dec 22, 2006 for vacature of EPA’s rule. At issue:– Revocation of 1-hr NAAQS– Subpart 1 vs Subpart 2 classification– Anti-backsliding measures

• 1-hr NSR threshold• Section 185 fees• Contingency measures• Conformity in 1-hr areas

• EPA has requested rehearing or clarification, but the court has not indicated whether or not this request will be granted

Challenges

• Attainment Deadlines are short for moderate areas where the plan needs to show attainment by 2009; TCEQ has not been able to demonstrate this for HGB area

• Federal Mobile Source Reduction Benefits are not fully achieved until ~2020

• Reclassification decisions – hard choices

• Current litigation adds a great deal of regulatory uncertainty

How Does this Affect Transportation Planning?

Title 23 USC Section 134(a)(1)

It is in the national interest to encourage and promote the safe and efficient management, operation and development of surface transportation systems that will serve the mobility needs of people and freight and foster economic growth and development within and through urbanized areas, while minimizing transportation-related fuel consumption and air pollution.

Transportation Planning Factors

1. Support economic vitality

2. Increase safety and security

3. Increase accessibility & mobility options

4. Protect environment & improve quality of life

5. Enhance system integration & connectivity

6. Promote efficient system management and operation

7. Emphasize system preservation

Transportation Conformity: Keeping the Process Connected

The SIP

(State AirQualityPlan)

TransportationPlan, and TransportationImprovementProgram (TIP)

Questions or Comments

Please contact your EPA Regional Office

Peggy Wade: Texas (except El Paso), Oklahoma, Louisiana

wade.peggy@epa.gov

214-665-7247

Jeff Riley: El Paso, Arkansas, New Mexico

Riley.jeffrey@epa.gov

214-665-8542