Transportation Conformity and the MPO
Transportation conformity is required by the Clean Air Act section 176(c) (42 U.S.C. 7506(c)) to ensure that federal funding and approval are given to highway and transit projects that are consistent with, or conform to, the air quality goals established by a state air quality implementation plan (SIP).
Transportation Conformity means that transportation activities will not cause new air quality violations, worsen existing violations, or delay timely attainment of the national ambient air quality standards. Conformity applies to Metropolitan Transportation Plans (MTP), Transportation Improvement Programs (TIP) and highway and transit projects funded or approved by the Federal Highway Administration (FHWA) and the Federal Transit Authority (FTA).
Transportation Conformity requirements ensure that federal funds go to transportation activities that are consistent with an area's air quality goals.
During a “Conformity Determination” the MPO estimates emissions that will result from an area’s transportation system through Transportation Demand Modeling (TDM) and demonstrates that those emissions are within the air quality goals, or “budget” established by the state air quality implementation plan, known as the State Implementation Plan (SIP).
The portion of the SIP we are interested in addresses the on-road mobile sources emitted in our region also known as the Motor Vehicle Emission Budget (MVEB). To be found in conformity with the SIP, an area’s MTP and TIP must be found to result in emissions that are within the SIP’s MVEB, or if no MVEB is available by the state, the MPO must use a “Test”. These “tests” include either an “action vs. baseline” or “less than baseline”. For these “tests”, emissions are estimated for travel demand modeling network scenarios that include the proposed roadway and transit improvements and for scenarios that do not include the proposed improvements. The resulting emissions are compared against each other and conformity is demonstrated is the scenario with the proposed improvements results in less emissions that that without the proposed improvements.
The following describes the entities involved and basic organizational obligations throughout the transportation conformity process:
- The MPO and Texas Commission on Environmental Quality (TCEQ) are responsible to meet legal public consultation requirements.
- The MPO has principal responsibility for demonstrating Transportation Conformity.
- FHWA and FTA are responsible for issuing a final conformity determination.
Additional Transportation Impacts
- The long-range plan, known as the Metropolitan Transportation Plan (MTP) update cycle is every 4 years instead of every 5 years
- Eligible for Congestion Mitigation Air Quality (CMAQ) improvement program funding for transportation projects that reduce air pollutants.
- Less flexibility in transportation project planning and implementation Project mix becomes more critical and is partially determined by emissions estimates.
- Transportation Conformity requirements apply for 20 years after the area is in compliance with federal standards.
- Federal funding and approvals can be delayed for State Implementation Plan (SIP) or conformity failures.
For more information, please visit the MPO’s website at www.sametroplan.org or, contact Nick Page at (210) 230-6901
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