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Ask the Experts

How can communities use outreach and education programs to tap funding and conformity credit?

Many transportation projects and programs that contribute to compliance with the 1990 Clean Air Act Amendments (CAAA) likely qualify for transportation conformity credit and Congestion Mitigation and Air Quality (CMAQ) Improvement Program funding. Understanding some of the requirements may help Community Partners in their hunt for conformity credits and budget support.

The 1990 CAAA set limits on outdoor air pollution in the United States. Areas whose air is cleaner than the federal health-based outdoor air quality standards are called attainment areas; areas that don't meet the standards are called non-attainment areas; and areas that were nonattainment and have been redesignated as attainment are called maintenance areas.

States prepare State Implementation Plans (SIPs) to provide for implementation and enforcement of control measures to attain and maintain the National Ambient Air Quality Standards (NAAQS). SIPs are collections of regulations and measures used by States to reduce emissions from all sources, and demonstrate attainment and maintenance of air quality standards.

SIPs can include a wide variety of measures -- from the use of new technology to reduce vehicle fleet emissions to public awareness efforts (such as air quality health alerts) and initiatives (such as It All Adds Up to Cleaner Air) -- on which Federal funds may be spent.

The CAAA require that, in non-attainment and maintenance areas, metropolitan transportation plans (plans), transportation improvement programs (TIPs), and projects funded or approved by the Federal Highway Administration (FHWA) or the Federal Transit Administration (FTA) are consistent with air quality goals. In other words, transportation programs, plans, and projects must "conform" to the purpose of the SIP.

Every metropolitan area must adopt a plan and TIP. The plan is a 20-year multi-modal list of projects that is updated every 4 years in nonattainment and maintenance areas. The TIP is a prioritized list of transportation projects the region plans to undertake over the next four years. In nonattainment and maintenance areas a conformity determination is also required to demonstrate that the total emissions projected for a plan or TIP are within the emissions limits established by the SIP.

John Zamurs, Head, Air Quality Section, Environmental Analysis Bureau, New York State Department of Transportation, explains how his state taps federal funds to implement outreach programs, including It All Adds Up, to reduce congestion, improve air quality, and earn those conformity credits.

Q. Some transportation projects help reduce emissions, while others don't, isn't that right?

A. Yes, some projects and programs in a plan and TIP may increase emissions, and it's incumbent on regions to find ways to balance projects that increase emissions with those that reduce emissions so that, overall, air quality is improved.

Q. Is that how "credit" comes into play?

A. Yes. Credits help regions stay in conformity or achieve conformity. If you have a program that can help reduce emissions, you could use it as a "credit" to offset projects that may increase emissions. The other benefit is that often there are federal funds to support some of these "creditable" programs—usually CMAQ funds.

To be approved for credits, regions have to demonstrate that the program will result in a reduction in emissions and that they are committed to the program.

Q. What happened in your state?

A. We were concerned we might have difficulty passing the conformity budget test, so we worked with agencies and organizations in the New York metropolitan region to develop programs to reduce emissions. One of them was an existing Ozone Action Day program. We enhanced the program, made it more visible, and with CMAQ funds, expanded it. By working with the regional offices of the U.S. Environmental Protection Agency (EPA) and the FHWA, we were able to design an action day program that qualified for emissions credit in our conformity determination.

Q. What made you think your air quality outreach and education program might earn conformity credit?

A. Well, we knew EPA's guidelines for the voluntary mobile source emissions program say you can take credit in a SIP for these types of programs. We worked with our EPA regional office to verify that the emissions benefits could, instead, be credited in a conformity determination. But for regions that are just starting to explore this idea, consulting with their Metropolitan Planning Organization (MPO) and their EPA regional office is a good first step.

Q. But you still had to enhance your Ozone Action Day program to make it "credit-worthy," right?

A. Yes, we did step it up. Our Ozone Action Day program is now a year-round outreach and education program where we collaborate with our transportation management associations, and others who work with employees, to get the message out about the connections among transportation choices, congestion, and air quality. We also display Ozone Action Day alerts and information on our highway signage and run radio spots and TV spots—much of the content coming directly from the It All Adds Up to Cleaner Air initiative.

Q. How did you get the ball rolling toward achieving conformity credit?

A. We worked through the Interagency Consultation Process, which includes the other agencies involved in governing air quality conformity in our region. In addition to collaborating with our MPO to increase funding for the Ozone Action Days program, we listed it as a separate project in the plan and TIP, which indicates the region's commitment to the program. The next step was calculating the emissions benefits. In our case, we didn't have any survey data that could serve as a baseline, so we worked through the Interagency Consultation Process to determine how we might estimate the emissions benefits of the program.

Q. Without any survey data or other quantitative information, how did you argue your program's effectiveness in order to calculate the credit?

A. Working with our partners in the Interagency Consultation Process, we agreed on an initial estimate of how effective the program might be in reducing Vehicle Miles Traveled (VMT) and emissions. Those assumptions, along with data we collected from studies on similar programs around the country, served as a baseline. We estimated that our program would reduce VMT by one percent in both a.m. peak and p.m. peak travel periods. We will be evaluating the effectiveness of the program, comparing the results to our assumptions, and adjusting our projected emissions benefits, as needed.

Q. It sounds as if connecting in the Interagency Consultation Process is the first step.

A. Yes, the first and most important steps are working with your partners in the Interagency Consultation Process to see if they are willing to work with you to "credit" your public education and outreach program for conformity or SIP purposes, and if so, to determine a reasonable estimate for that credit.

It's also important for me to mention that, although we were able to generate credit for the expanded program without having an evaluation component in place, we committed to evaluating the program. It would be tough to get interagency agreement to allow credit for a public education program that doesn't monitor its effectiveness and adjust its projected benefits based on that information, without a clear commitment to do so in the near future.

Q. Could our MPO fund our air quality program and then take the credit?

A. The first thing you should do is approach your MPO, state agency, or regional EPA office to see what kind of interest there is in pursuing conformity credit for public awareness efforts. Ask if you could partner with them to try to generate funding and conformity credit for their public education activities. Right now, I think New York is one of the few states—if not the only—taking conformity credit for an air quality awareness program. That may be because our program is run by the State Department of Transportation, so we are very aware of air quality conformity issues and the crediting process.

There are a lot of good, effective public education and outreach programs out there and they ought to get as much support and credit as they can.