PM 2.5 Quantitative Hot‐spot Analysis Page 1 Air Quality Technical Report PM 2.5 Quantitative Hot‐spot Analysis I‐65, SR44 to Southport Road (Segmented from SR44 to Main Street and Main Street to Southport Road) A. Introduction This technical report outlines the methodology, inputs and results of the PM 2.5 quantitative hot‐spot analysis for the I‐65, SR44 to Southport Road (segmented from SR44 to Main Street and Main Street to Southport Road) project in Indiana. The environmental document for this project is being developed as a Categorical Exclusion (CE). This report will be included as a technical appendix to the CE document when it is completed. The project is within the Central Indiana nonattainment area for the 1997 annual fine particles (PM 2.5 ) National Ambient Air Quality Standard (NAAQS). On March 10, 2006, the U.S. Environmental Protection Agency (EPA) published a Final Rule (71 FR 12468) that establishes transportation conformity criteria and procedures for determining which transportation projects must be analyzed for local air quality impacts in PM 2.5 and PM 10 nonattainment and maintenance areas. A quantitative PM hot‐spot analysis using EPA’s MOVES emission model is required for those projects that are identified as projects of local air quality concern. Quantitative PM hot‐spot analyses are not required for other projects. The interagency consultation process plays an important role in evaluating which projects require quantitative hot‐spot analyses and determining the methods and procedures for such analyses. The air quality analysis for the I‐65, SR44 to Southport Road project included modeling techniques to estimate project‐specific emission factors from vehicle exhaust and local PM 2.5 concentrations due to project operation. Emissions and dispersion modeling techniques were consistent with EPA’s latest quantitative PM hot‐spot analysis guidance, “Transportation Conformity Guidance for Quantitative Hot‐spot Analysis in PM 2.5 and PM 10 Nonattainment and Maintenance Areas“ (USEPA, 2013) 1 that was updated in November, 2013. B. Interagency Consultation The conformity rule requires that federal, state and local transportation and air quality agencies establish formal procedures for interagency coordination. This analysis included participation from the following agencies: FHWA Indiana Division and Resource Center Indiana Department of Environmental Management (IDEM) Indiana Department of Transportation (INDOT) Indianapolis Metropolitan Planning Organization (MPO) EPA Region 5 1 US EPA. 2013. Transportation Conformity Guidance for Quantitative Hot‐spot Analyses in PM2.5 and PM10 Nonattainment and Maintenance Areas” (EPA‐420‐B‐13‐053) located online at: http://www.epa.gov/oms/stateresources/transconf/policy/420b13053‐sec.pdf
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This technical report outlines the methodology, inputs and results of the PM2.5 quantitative hot‐spot
analysis for the I‐65, SR44 to Southport Road (segmented from SR44 to Main Street and Main Street to
Southport Road) project in Indiana. The environmental document for this project is being developed as a
Categorical Exclusion (CE). This report will be included as a technical appendix to the CE document when
it is completed. The project is within the Central Indiana nonattainment area for the 1997 annual fine
particles (PM2.5) National Ambient Air Quality Standard (NAAQS).
On March 10, 2006, the U.S. Environmental Protection Agency (EPA) published a Final Rule (71 FR
12468) that establishes transportation conformity criteria and procedures for determining which
transportation projects must be analyzed for local air quality impacts in PM2.5 and PM10 nonattainment
and maintenance areas. A quantitative PM hot‐spot analysis using EPA’s MOVES emission model is
required for those projects that are identified as projects of local air quality concern. Quantitative PM
hot‐spot analyses are not required for other projects. The interagency consultation process plays an
important role in evaluating which projects require quantitative hot‐spot analyses and determining the
methods and procedures for such analyses.
The air quality analysis for the I‐65, SR44 to Southport Road project included modeling techniques to
estimate project‐specific emission factors from vehicle exhaust and local PM2.5 concentrations due to
project operation. Emissions and dispersion modeling techniques were consistent with EPA’s latest
quantitative PM hot‐spot analysis guidance, “Transportation Conformity Guidance for Quantitative
Hot‐spot Analysis in PM2.5 and PM10 Nonattainment and Maintenance Areas“ (USEPA, 2013)1 that was
updated in November, 2013.
B.InteragencyConsultation
The conformity rule requires that federal, state and local transportation and air quality agencies
establish formal procedures for interagency coordination. This analysis included participation from the
following agencies:
FHWA Indiana Division and Resource Center
Indiana Department of Environmental Management (IDEM)
Indiana Department of Transportation (INDOT)
Indianapolis Metropolitan Planning Organization (MPO)
EPA Region 5
1 US EPA. 2013. Transportation Conformity Guidance for Quantitative Hot‐spot Analyses in PM2.5 and PM10
Nonattainment and Maintenance Areas” (EPA‐420‐B‐13‐053) located online at: http://www.epa.gov/oms/stateresources/transconf/policy/420b13053‐sec.pdf
PM2.5 Quantitative Hot‐spot Analysis Page 2
Interagency consultation provides an opportunity to reach agreements on key assumptions to be used in
conformity analyses, strategies to reduce mobile source emissions, specific impacts of major projects,
and issues associated with travel demand and emissions modeling for hot‐spot analyses. 40 CFR
93.105(c)(1)(i) requires interagency consultation to “evaluate and choose models and associated
methods and assumptions.” Per Section 2.3 of EPA’s hot‐spot guidance, “for many aspects of PM
hot‐spot analyses, the general requirement of interagency consultation can be satisfied without
consulting separately on each and every specific decision that arises. In general, as long as the
consultation requirements are met, agencies have discretion as to how they consult on hot‐spot
analyses.”
For this project, an interagency consultation conference call was held on May 20, 2014. As a result of
the meeting, a decision was made to proceed with a quantitative PM2.5 hot‐spot analysis, even though a
formal determination was not made with respect to whether this project was determined to be a
project of local air quality concern. Subsequent input from the ICG was provided via email consultation
between May 29 and May 30, 2014. The meeting and review process were used to obtain feedback on
the document text and technical analysis assumptions. Exhibit 1 provides a summary of the meeting
topics and the key decisions by the interagency consultation group (ICG). Additional consultation via
email was conducted between June 26 and June 27 to review the preliminary version of the technical
report, offer feedback, and to advance the document for public comment.
Exhibit 1: Key ICG Decisions on Quantitative Methods and Data
Topic Key Decisions/Considerations
Analysis Approach • Compare results of the Build analyses to the NAAQS.
Study Area • Focus on the I-65 / Southport Road Interchange. It was determined this location was
the location with highest emissions.
Analysis Years • 2017
Type of PM Emissions Analyzed
• Direct PM2.5 mobile source running emissions (exhaust, crankcase, brake/tire wear) • Construction emissions are not considered (< 5 years in duration) • No major non-road sources near the project location • Road dust is not considered a significant source
Emission and Air Quality Models
• MOVES2010b • AERMOD (run using “Area” method)
Background Concentrations
• Based on an average of three monitor locations • Average monitor reading 2011-2013 = 11.27
Receptor Locations • Placed according to EPA guidance
Other Input Parameters • MOVES inputs consistent with SIP/Conformity analysis by Indianapolis MPO • Recommendations from hot-spot training • AERMOD meteorology from IDEM
C.OverviewoftheAnalysisApproach
EPA released updated guidance for quantifying the local air quality impacts of certain transportation
projects for the PM2.5 and PM10 NAAQS in November 2013. This guidance must be used by state and
local agencies to conduct quantitative hot‐spot analyses for new or expanded highway or transit
PM2.5 Quantitative Hot‐spot Analysis Page 3
projects with significant increases in diesel traffic in nonattainment or maintenance areas.
The steps required to complete a quantitative PM hot‐spot analysis are summarized in Exhibit 2. The
hot‐spot analysis compares the air quality concentrations with the proposed project (the build scenario)
to the 1997 annual PM2.5 NAAQS. These air quality concentrations are determined by calculating a future
design value, which is a statistic that describes a future air quality concentration in the project area that
can be compared to a particular NAAQS. This report serves as documentation of the PM hot‐spot
analysis (Step 9) and includes a description of all steps.
Exhibit 2: EPA’s PM Hot‐spot Analysis Process
D.(Step1)DetermineNeedforPMHot‐spotAnalysis
Section 93.109(b) of the conformity rule outlines the requirements for project‐level conformity
determinations. A PM2.5 hot‐spot analysis is required for projects of local air quality concern, per Section
93.123(b)(1). The need for a quantitative PM2.5 analysis for I‐65, SR44 to Southport Road was discussed
by the ICG. The project’s environmental document is being developed as a CE, and it was noted that
the project is located in a PM2.5 nonattainment area with an increase in the number of diesel vehicles
expected in future years. The ICG agreed that a project level hot‐spot analysis would be conducted for
I‐65, SR44 to Southport Road. However, the group did not formally conclude that the project was a
Project of Air Quality Concern.
E.(Step2)DetermineApproach,ModelsandData
GeographicAreaandEmissionSourcesPM hot‐spot analyses must examine the air quality impacts for the relevant PM NAAQS in the area
substantially affected by the project (40 CFR 93.123(c)(1)). It is appropriate in some cases to focus the
PM hot‐spot analysis only on the locations of highest air quality concentrations. For large projects, it
may be necessary to analyze multiple locations that are expected to have the highest air quality
concentrations and, consequently, the most likely new or worsened NAAQS violations.
The length of the project study area falls within the Indianapolis PM2.5 non‐attainment area. To assist
Step 2 Determine Approach, Models and Data
Step 4Estimate Emissions from Road Dust, Construction and Additional Sources
Step 5Select Air Quality Model, Data Inputs, and Receptors
Step 1 Determine the need for
Analysis
Step 7 Determine Design Values and Determine Conformity
Step 8 Consider Mitigation or Control Measures
Step 3 Estimate On‐Road Motor
Vehicle Emissions
Step 6Determine Background
Concentrations
Step 9 Document Analysis
PM2.5 Quantitative Hot‐spot Analysis Page 4
in identifying the location of potential highest emissions, the ICG reviewed available traffic data
including INDOT 2010 traffic counts and forecast (2035) no‐build and build volumes from the INDOT
Statewide Travel Demand Model (ISTDM). The average annual daily traffic (AADT) and truck
percentages are summarized in Exhibit 3. Results from Indianapolis MPO regional traffic modeling were
also evaluated to determine how local traffic patterns would likely be affected by the project.
Exhibit 3: Current and Projected Traffic Volumes in Study Area
2010 Traffic* 2035 Traffic**
I-65 Segment AADT Truck
Volume % Truck AADT
Truck Volume
% Truck
County Line Rd to Southport Rd 98,921 16,670 17% 125,695 19,806 16%
Main St to County Line Rd 77,910 18,400 24% 97,182 22,442 23%
Whiteland Rd to Main St 63,150 15,870 25% 83,383 22,025 26%
SR-44 to Whiteland Rd 56,220 14,850 26% 68,559 18,457 27% *Count Data (http://dotmaps.indot.in.gov/apps/trafficcounts/) **Generated by ISTDM
The interchange of I‐65 with Southport Road, illustrated in Exhibit 4, was determined to be the location
with the highest traffic and emissions. This interchange has the highest truck and AADT volumes in the
project study area, is the closest segment to the more urbanized area to the north, has the most traffic
congestion in the corridor, and has residential development abutting the freeway. Based on the above
characteristics, the ICG agreed that the geographic area for the analysis should focus on the Southport
Road interchange including the signalized intersections at the ramps to I‐65 and the segments of
Southport Road immediately to the east and west.
Exhibit 4: Study Area for Quantitative Hot‐spot Analysis
Maps from Google
Project Study
PM2.5 Quantitative Hot‐spot Analysis Page 5
A review of the selected project area (Southport Road interchange) did not identify any new or
worsening point sources or facilities with significant numbers of idling diesel vehicles that would require
individual consideration
AnalysisApproachandYear(s)Per ICG consultation and agreement, the 2017 project opening year was determined to be the year for
the analysis. This decision was based on several key factors. PM2.5 vehicle emissions are predominately
generated by truck traffic. Average truck emissions are dropping rapidly as older vehicles are retired and
replaced with vehicles meeting more stringent emission requirements. Previous analysis completed for
INDOT confirmed this trend in truck emissions at the project level2 and found it offset traffic growth by
a sizable margin. Based on available ISTDM and MPO modeling, truck volumes within the study area are
not increasing at a significant rate that would offset newer engine technology. As a result, the ICG
agreed to model only 2017.
According to EPA guidance and per ICG concurrence, the hot‐spot analysis focused on the project’s build
alternative. A hot‐spot evaluation of the no‐build analysis is not required to demonstrate conformity
when the build alternative does not show a new or worsened violation of the NAAQS.
PMNAAQSEvaluatedThe project is located in an area designated as nonattainment for the 1997 annual PM2.5 NAAQS (15
micrograms per cubic meter µg/m3). The area is currently attaining the 24‐hour PM2.5 NAAQS and
24‐hour PM10 NAAQS.
TypeofPMEmissionsModeledThe PM hot‐spot analyses include only directly emitted PM2.5 emissions. These include vehicle running
and crankcase exhaust, brake wear, and tire wear emissions from on‐road vehicles. Start and
evaporative emissions are not a significant portion of the roadway emissions in the study area. Any
non‐running emissions are assumed to be included in the background concentrations. PM2.5 precursors
are not considered in PM hot‐spot analyses, since precursors take time at the regional level to form into
secondary PM.
Re‐entrained road dust was not included because the State Implementation Plan does not identify that
such emissions are a significant contributor to the PM2.5 air quality in the nonattainment area. In
addition, emissions from construction‐related activities were not included because they are considered
temporary as defined in 40 CFR 93.123(c)(5) (i.e. emissions that occur only during the construction
phase and last five years or less at any individual site).
ModelsandMethods The latest approved emissions model must be used in quantitative PM hot‐spot analyses. The latest
approved emission factor model is EPA’s MOVES2010b. Ground‐level air concentrations of PM2.5 were
estimated using AERMOD which is listed as one of the recommended air quality models for highway and
intersection projects in the EPA quantitative PM hot‐spot guidance. Based on previous EPA OTAQ
recommendations, the roadway emissions were treated as an area source within the AERMOD model.
2 Air Quality Technical Report. PM2.5 Quantitative Hot‐spot Analysis I‐69 Evansville to Indianapolis, Indiana: Section 5 Bloomington to Martinsville. Indiana Department of Transportation.
PM2.5 Quantitative Hot‐spot Analysis Page 6
Project‐SpecificDataThe conformity rule requires that the latest planning assumptions (available at the time that the analysis
begins) must be used in conformity determinations (40 CFR 93.110). In addition, the regulation states
that hot‐spot analysis assumptions must be consistent with those assumptions used in the regional
emissions analysis for any inputs that are required for both analyses (40 CFR 93.123(c)(3)).
Traffic Data In the absence of readily available traffic projections within the study corridor, a simple traffic
forecasting effort was undertaken to support the air quality analysis. The forecasted 2017 traffic
volumes were developed using runs of the Indianapolis MPO regional travel demand model (as
conducted by the MPO) and traffic count/vehicle classification data from INDOT’s Average Daily Traffic
and Commercial Vehicles Interactive Map website3. Methods consistent with NCHRP Report 765:
Analytical Travel Forecasting Approaches for Project‐Level Planning and Design4 were used to develop
the forecasted volumes. Note that NCHRP Report 765 is an update to the long‐standing NCHRP Report
255 which served as the definitive guidebook to the application of travel demand models for project
evaluation analysis purposes. Where possible, conservative traffic assumptions were used to ensure
the resulting air quality analysis would be conservative.
A traffic signal analysis of the intersections of the I‐65 ramps at Southport Road was completed using the
Synchro analysis tool and available 2010 traffic count data. The signal analysis was used to identify
potential queue lengths and used for defining link types within the MOVES emission model. The
percentage of trucks within the total traffic volume was based on INDOT traffic volume classification
count data and was developed for each time period. Classification counts were not available on
Southport Road, and in these cases the truck percentage was obtained from the travel demand model.
The forecasted 2017 traffic volumes for the 3‐hour AM, 3‐Hour PM, and remaining off‐peak periods are
provided in Attachment A.
Roadway Elevation Data To support the MOVES modeling of specific roadway links, geographic digital elevation files, obtained
from the Indianapolis Mapping and Geographic Infrastructure System (imagis), and available Google
Earth elevations were used to estimate a link‐specific grade that impacted the resulting emission factors
from MOVES. Attachment B summarizes the MOVES input data for each roadway link.
Emissions and Air Quality Data This quantitative analysis uses local‐specific data for both emissions and air quality modeling whenever
possible, though default inputs may be appropriate in some cases. The Indianapolis MPO provided
MOVES input files that were used for regional emissions analyses, including vehicle/fleet
characterization data (age, fleet mix etc.), meteorological data, fuel, and control strategy parameters.
Hourly meteorological data is used for dispersion modeling and must be representative of the project
area. The most recent available years (2006‐2010) of off‐site meteorological data prepared by IDEM was
downloaded from the IDEM website (http://www.in.gov/idem/airquality/2376.htm). Surface