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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Memo: Conformity and Nitrogen Oxides (Nox)

FHWA Policy Memorandums - Office of Environment and Planning

This order was canceled on July 27, 2004


INFORMATION: Conformity and Nitrogen Oxides (Nox)  
Director, FTA Office of Planning < td=""> <>
Directors, FHWA Office of Program Development (Regions 8 and 9)
Directors, FTA Office of Program Development (Regions 1-10)

On March 10, 1994, we provided you with information and guidance on NOx emissions because of the difficulty that some State and metropolitan areas are experiencing with the new NOx requirements in the EPA's transportation conformity regulation. Attached is further information on efforts being made to understand and evaluate the NOx impacts of transportation plans and programs, The material summarizes what we have learned from Ohio's NOx modeling experiences, and suggestions we provided to further refine their NOx modeling capabilities.

Some key observations and conclusions from the Ohio analyses are as follows:

  • The TRB Highway Capacity and Quality of Service Committee is currently updating the curves which reflect the speed versus volume/capacity ratio relationships. These new curves show a much flatter speed curve when compared to volume to capacity ratios than those included in the 1985 HCM. This tends to reduce the differences in the modeled NOx emissions between the build and no-build alternatives. It is permissible to use the new speed curves in current conformity analyses.
  • On the other hand, the new curves tend to generate higher total NOx emissions estimates for both the build and no-build alternatives because the new curves reflect higher and more consistent speeds even as the volume to capacity ratios increase. This may create some problems in meeting the modeled hydrocarbon emissions budgets, and future NOx emission budgets. This is particularly true if the budgets are established using the speed versus volume/capacity curves in the 1985 HCM and the conformity analyses are completed using the newer curves. If this is the case, the SIP emissions budgets may need to be revised to reflect the new speed curves, since speed is an important factor in MOBILE5A for estimating emissions.
  • Speed enforcement on the freeway system can reduce NOx emissions. The Ohio NOx model analysis demonstrated that enforcing the speed limit on freeways between 11 p.m. and 1 a.m. could eliminate the NOx problem in the city of Cincinnati, because of the high percentage of truck traffic during this period. Truck traffic contributes a disproportionate amount of the total mobile source NOx emissions--approximately 40-50 percent of NOx from highway vehicles. Speed enforcement, however, can only be used in the conformity analysis if it is a specific mitigation measure which is directly linked to the build alternative.
  • The Ohio DOT estimated their traffic volumes and speeds on an hourly basis for individual links. The link level focus of the emissions calculation is both valid and necessary. Improvements to individual, low speed, congested links can generate NOx reductions because the speeds for the no-build alternative are typically below the minimum point on the "U" shaped NOx curve in MOBILE5A. These emission reductions might not show up with a higher average speed calculated over a widespread area. However, it may not be necessary to calculate speeds and emissions on an hourly basis. Four or five aggregate time periods over the course of the day may suffice (e.g. a.m. peak, off-peak day, p.m. peak, evening off-peak, late night off-peak).

Another potential source of NOx reductions is from traffic flow improvements and demand management on highly congested arterial and local roadways. Typically, under the no-build alternative, these facilities operate at speeds below the NOx minimum point for significant time periods of the day. Any NOx increases from freeway improvements can often be offset by NOx reductions on arterials and local streets. This occurs on facilities parallel to the freeway because of traffic diversions, but this can also be aggressively pursued by including transportation demand management strategies and/or traffic flow improvement projects in the TIP for small congested facilities throughout the region as an offset for any emissions increases for the freeway or other high speed facility.

The best way to estimate emissions reductions from small facility improvements is to incorporate them into the simulation model network. This procedure directly estimates the effect of these improvements on operating speed and VMT. If the highway network of a given region is inadequate to support this level of detail, reasonable professional methodologies may be developed.

Also attached for your information is a copy of a memorandum dated April 5, 1994, from David J. Brzezinski, Chief of EPA's Model Development Section in Ann Arbor, Michigan, regarding the effect of VMT growth on MOBILE5A NOx estimates. The FHWA is currently reviewing this material and intends to discuss the methodology and conclusions with EPA. The EPA conducted an analysis on the effect of VMT growth rates because of the concern that even moderate growth rates would cause mobile source NOx emissions to exceed the 1990 base-year levels. Not surprisingly, the results show that as VMT growth rates increase, the 1990 base year emission levels will be exceeded sooner. For example, for an area that has a basic I/M program and a 2 percent annual growth rate, the 1990 levels would not be exceeded until 2020. However, the same area with a 4 percent annual VMT growth rate would exceed 1990 levels by 1992 and beyond. The analysis also shows that technology will also increase the time period before the 1990 levels are exceeded. For example, an area with an enhanced I/M program and the introduction of Low Emitting Vehicles will not exceed the 1990 base-year levels by 2020 for either a 2 percent or 4 percent annual VMT growth rate. Consequently, areas that are projecting their NOx emissions to exceed 1990 base-year levels will need to more aggressively pursue transportation demand management strategies and/or "opt" into additional technological programs.

As additional information on this important subject becomes available, we will continue to provide national distribution. We would also appreciate learning of other State and local methodologies and insights for possible distribution.

Samuel L. Zimmerman  

9 Attachments

cc: Jane Garvey
Tony Kane
Ed Kussy
Reid Alsop
Abbe Marner, FTA
Camille Mittelholtz, OST
Phil Lorang, EPA
Paula Van Lare, EPA
Jon Kessler, EPA
Dave Clawson, AASHTO
Nancy Krueger, STAPPA/ALAPCO
Rich Weaver, APTA
Becky Brady, NCSL
Lydia Conrad, NGA
Joan Glickman, ICMA
Janet Oakley, NARC
Robert Fogel, NACO
Cara Woodsen, NLC
Kevin McCarthy, USCM
Leo Penne, Nevada Office
Mike McGarry, Ohio Office