The possibility of the Wichita area violating the federal air quality standard for ozone has been a topic of discussion for many years. The Environmental Protection Agency (EPA) recently revised the National Ambient Air Quality Standard (NAAQS) for ozone, lowering the standard from 75 parts per billion (ppb) to 70 ppb. They will be evaluating the air quality of metropolitan areas around the country against this new standard, including the Wichita area.
After the rule is finalized the Kansas Department of Health and Environment (KDHE) will have up to a year to recommend to EPA new non-attainment areas in Kansas. If they recommend a non-attainment area in the Wichita region it will probably include Sedgwick, Butler, and Sumner Counties, possibly including other adjoining counties as well.
Once KDHE makes their recommendation the EPA will have one year to act on it, meaning that the final decision would be made in late 2017. The EPA can accept KDHE’s recommendation or make changes to it before making a final designation.
The EPA will make their decision using ozone data from 2014, 2015, and 2016. Based on ozone levels in 2014 and preliminary ozone numbers for 2015, it appears that this decision could go either way, depending on what our ozone levels are in 2016. This makes 2016 is the critical year for a non-attainment area designation in the Wichita area.
October 2015 – New ozone rule finalized
1 year later – KDHE recommends new non-attainment areas
2 years later – EPA designates new non-attainment areas
3 years later – WAMPO must demonstrate “conformity”
Being designated a non-attainment area would mean some significant changes for the Wichita area. The KDHE must develop a State Implementation Plan (SIP) describing the steps that must be taken to lower our ozone levels. These regulations will impact all types of emission sources – small and large businesses, construction, transportation, etc.
The emissions that concern WAMPO directly are “on-road mobile sources”: cars and trucks on public highways in the WAMPO region. In non-attainment areas metropolitan planning organizations are responsible for demonstrating that transportation planning and programming decisions are in conformity with federal air quality regulations.
Transportation conformity is a process required by the CAA to ensure that federal transportation funding is given to highway and transit activities that are consistent with air quality goals. Within one year of being designated, WAMPO will have to produce a document called a conformity determination showing our current transportation plans are in compliance with federal air quality regulations. After this first conformity determination we will have to make a new conformity determination any time we approve a new Long Range Transportation Plan (LRTP) or Transportation Improvement Program (TIP), or amend an existing LRTP or TIP with a major project. If we fail to produce a conformity determination report, we risk losing most federal transportation funding in the region. One additional effect of being designated a non-attainment area is that we will have to produce a new LRTP every four years, rather than every five.
In order to show the impact our proposed transportation projects have on emissions, we will need a computer-based regional emissions model. This model will allow us to forecast the effect new transportation projects will collectively have on ozone levels in the Wichita area.
The regional emissions model uses our existing Travel Demand Model (TDM) to predict the amount of travel in the region. The model takes into account a variety of factors, including the mix of different types of vehicles, the age of the vehicle fleet, predicted travel speeds, and many other factors.
The model itself, called MOVES, was developed by the EPA and is available for free. However, providing the appropriate local data and calibrating it to our region is a complex and time-consuming task. In order to have the emissions model ready for our first conformity determination, we will have to begin this process long before we are formally designated. WAMPO staff is proposing to start development when the new EPA rule is finalized in 2015.
Initially, demonstrating conformity requires that the slate of transportation projects planned in the Wichita area will not make the air quality problem worse. There are two different tests for demonstrating this: Will building the projects in the plan reduce emissions compared to not building them? Will building the projects in the plan reduce emissions compared to a baseline year? (the baseline year will probably be 2016). WAMPO must use its emissions model to show that the proposed transportation projects collectively pass these tests. Passing these tests may require revisions to the slate of projects in MOVE 2040 or the TIP. However, the MOVE 2040 investment strategy’s focus on “preserve and maintain” should help minimize the impact on planned transportation projects in the Wichita area.
Within three years of being designated a non-attainment area, KDHE will produce a State Implementation Plan (SIP) describing how the Wichita area will get back into compliance with the ozone standard. The SIP will include measures for dealing with emissions from all sorts of sources, including an emissions budget for motor vehicle emissions. WAMPO will use that emissions budget in future conformity determinations.