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PM2.5 CONFORMITY DETERMINATION

I-695: I-70 to MD 170

BALTIMORE COUNTY, MARYLAND

ANNE ARUNDEL COUNTY, MARYLAND



MARYLAND DEPARTMENT OF TRANSPORTATION

STATE HIGHWAY ADMINISTRATION

April 2008

Project Description


General

The purpose of this project is to accommodate projected increases in traffic volumes along both I-695 and MD 295, and to enhance traffic operations and safety. This purpose is to be achieved by widening 9.0 miles of the Baltimore Beltway (I-695) and 4.1 miles of the Baltimore-Washington Expressway (MD 295), and modifying three existing interchanges. These improvements are designed to improve traffic congestion, improve safety conditions and enhance traffic operations


Build Alternative


The Selected Alternative involves adding one lane in each direction to I-695 and MD 295. Along I-695, this would generally involve adding a fourth lane to the outside of the existing three lanes except in two locations. Along I-695 between I-95 and U.S. Route 40, the existing northbound roadway (Inner Loop) is four lanes. Therefore, the additional lane of the Selected Action would provide a fifth lane. In the section between I-95 and Wilkens Avenue, the Selected Action involves adding two lanes to the outside of the existing roadway in order to improve the I-95 interchange operation. Along MD 295, the additional lane would be a third lane, added in the median to the existing two lanes. The Selected Action also involves the modification of ramps within the I-695 interchanges at 1-70, Hollins Ferry Road and MD 295. Bridge widening and/or reconstruction and the provision of retaining walls to minimize right-of-way acquisition would be required. This alternate would require ramp adjustments at each interchange along I-695 to tie into the additional mainline lane. Major reconfiguration of the existing interchanges is not proposed. Interchange Options are proposed at the following I-695 interchanges: I-70, U.S. Route 40, Edmondson Avenue, Frederick Road, Wilkens Avenue, Leeds Avenue, I-95, Washington Blvd., Hollins Ferry Road, I-895, Nursery Road, and MD 295.

As shown on Table 1 below, construction of a portion of the proposed improvements considered in the 1991 FEIS are complete. The area that has not been constructed and is the focus of this PM2.5 analysis is, in general, I-695 from I-70 to MD 170. The ADT on I-695 varies from one location to another within this area.



TABLE 1

I-695: Baltimore Beltway

Security Boulevard to Crosby Road: Inner / Outer Loop

Not constructed -Concept design in progress

Crosby Road to Ingleside Avenue: Outer Loop (SWOL III)

Not constructed -Concept design in progress

Ingleside Avenue to Frederick Road: Outer Loop (SWOL II)

Not constructed -Final design in progress

Frederick Road to I-95: Outer Loop (SWOL I)

Constructed

Crosby Road to I-95: Inner Loop (SWIL)

Design On-hold

I-95 to MD 170

Design On-hold







MD 295: Baltimore–Washington Expressway

I-195 to I-695

Conformity Determination Completed1 Determined to not be a project of air quality concern.

I-695 to Baltimore City Line

Constructed

This project is located in the Baltimore, MD PM2.5 nonattainment area. The area was designated as nonattainment for PM2.5 on January 5, 2005 by the US Environmental Protection Agency. This designation became effective on April 5, 2005, 90 days after EPA's published action in the Federal Register. Transportation conformity for the PM2.5 standards applied on April 5, 2006, after the one-year grace period provided by the Clean Air Act. Because the previous environmental document for this project area (FEIS, 1991) was completed prior to this effective date in June 2004, a project level PM2.5 conformity determination is now required prior to FHWA providing any further approval or authorization of this project.

On March 10, 2006, EPA issued amendments to the Transportation Conformity Rule to address localized impacts of particulate matter: "PM2.5 and PM10 Hot-Spot Analyses in Project-level Transportation Conformity Determinations for the New PM2.5 and Existing PM10 National Ambient Air Quality Standards" (71 FR 12468). These rule amendments require the assessment of localized air quality impacts of Federally-funded or approved transportation projects in PM10 and PM2.5 nonattainment and maintenance areas deemed to be projects of air quality concern2. Projects that require hotspot analysis for PM2.5 are those projects that are Projects of Air Quality Concern as enumerated in 40 CFR 93.123(b)(1):

(i) New or expanded highway projects that have a significant number of or significant increase in diesel vehicles;

(ii) Projects affecting intersections that are at Level-of-Service D, E, or F with a significant number of diesel vehicles, or those that will change to Level-of-Service D, E, or F because of increased traffic volumes from a significant number of diesel vehicles related to the project;

(iii) New bus and rail terminals and transfer points that have a significant number of diesel vehicles congregating at a single location;

(iv) Expanded bus and rail terminals and transfer points that significantly increase the number of diesel vehicles congregating at a single location; and

(v) Projects in or affecting locations, areas, or categories of sites which are identified in the PM10 or PM2.5 applicable implementation plan or implementation plan submission, as appropriate, as sites of violation or possible violation.
As discussed in the examples to the preamble to the March 10, 2006 Final Rule for PM2.5 and PM10 Hot-Spot Analyses in Project-Level Transportation Conformity Determinations (71FR12491), for projects involving the expansion of an existing highway, 40 CFR 93.123(b)(1)(i) has been interpreted as applying only to projects that would involve a significant increase in the number of diesel transit buses and diesel trucks on the existing facility. This has been further clarified in a proposed rule amendment as ''EPA is proposing to clarify this provision as ``New highway projects that have a significant number of diesel vehicles, and expanded projects that have a significant increase in the number of diesel vehicles.”3

SHA has prepared the following analysis of the proposed improvements:



  • The projected 2025 No-Build and Build ADT for I-695 as shown in Tables 2 and 3 both represent the unconstrained user demand. Based upon SHA staff interpretation of refined output from the BMC regional travel demand model, travel demand forecasts were determined for No-Build and Build conditions along I-695; both of which were shown to be similar. With the lack of functionally comparable, parallel facilities to draw traffic from (I-695 is an existing, circumferential interstate), and with the unimproved sections of I-695 at either study limits metering traffic on the Build section; ADT is expected to remain unchanged. The capacity improvements along this section of I-695 are designed to accommodate future peak period demand on the study segment solely; they are not anticipated to induce traffic in the uncongested off-peak periods. A review of the data in Table 2 and 3 below demonstrates that there will not be a “significant increase” in the number of trucks nor Average Daily Traffic (ADT) from the No-build condition to the Build for the following reasons:

  • Users will take the shortest origin-destination path. In addition, user unfamiliarity with alternative routes and conditions encourages drivers to remain on I-695 despite the level of congestion and delay. .

  • During peak traffic periods, diversion from what is the shortest path of travel between origin/destination points to alternate routes would not be attractive to the majority of users. Traffic conditions on these alternative routes are generally as bad as or worse than I-695 during these peak travel periods, with significant congestion, slower speeds and numerous traffic lights, all factors translating into longer travel times. During off-peak periods, an uncongested I-695 will be equally attractive to users for either the No-build or Build condition.

  • Shown on the graph below is a diurnal curve for I-695 south of I-70; which compares existing, future no-build and future build hourly distributions. The graph shows how the demand is and will be accommodated on I-695, given constrained  (peak spreading) and unconstrained (a more definitive peak hour) roadway conditions.  The 3:00 p.m. to 8:00 p.m. period illustrates the peak hour spreading phenomena. Essentially, what would be a 7% peak hour for a manageable 1-2 hours under existing and future Build conditions, flattens out into a consistent 6% peak hour for a 5 hour duration under the no-build condition.

  • Trucks, which are the primary emitter of mobile source PM2.5, will tend to stay on I-695 since the alternative routes would require frequent stop/start conditions due to traffic signals, and may not have lane widths, roadway grades, and curves that suit these types of vehicles. Similarly, other users primarily traveling alternative routes under the No-build condition will tend to remain on these alternative routes for local trip use due to non-congestion-related reasons such as route familiarity, and aggressive driving associated with higher speeds on I-695.

  • With the proposed I-695 improvements roadway safety will improve; however, the roadway will continue to be congested during peak periods; although the length and time of this congestion will be reduced.

  • Depicted truck percentages represent the amount of light, medium and heavy truck activity along a given roadway segment in accordance with FHWA's 13 vehicle classification guidelines. Existing percentages are derived from 48-hour portable classified count data. Without the addition of significant truck land use generators to the traffic influence area (sizable increases in industrial- employment projections in surrounding BMC model TAZs would show this), truck percentages would remain relatively unchanged between the No-Build and Build conditions for this section of I-695. As previously mentioned, Build improvements will add capacity to mainline I-695, relieving peak period system congestion. A heavy portion of I-695 truck travel occurs during the uncongested off-peak periods, where the addition of capacity would have no bearing on truck travel decision-making. Current truck origin-destination patterns will dictate future patterns, unless changes are made in policy or there is a significant influx in truck generators to the traffic influence area - neither of which has been assumed by the approved Regional Transportation model. The most recent version of the Baltimore Regional Transportation model does include a truck model component, which can be used as a tool to analyze existing and future truck conditions throughout the network. The Baltimore Regional transportation model (which is land use driven), as applied by SHA staff, shows consistent truck percentages along I-695 between the No-Build and Build conditions, which supports this assertion. This analysis is based on assumptions of SHA staff as well as their refinement of model results.

  • Section 176(c) of the Clean Air Act and the federal conformity rule requires that transportation plans and programs conform to the intent of the state air quality implementation plan (SIP) through a regional emissions analysis in PM2.5 nonattainment areas. The I-695: I-70 to MD 170 project is located in the Baltimore, MD PM2.5 nonattainment area and is under the jurisdiction of the Baltimore Regional Transportation Board (BRTB). The Baltimore Regional Transportation Board is the federally recognized Metropolitan Planning Organization (MPO) for transportation planning in the Baltimore region. The Transportation Outlook 2035 and the FY 2008-2012 Transportation Improvement Program have been determined to conform to the intent of the SIP4. The US Department of Transportation made a Conformity Determination on the CLRP and the TIP on February 4, 2008, and thus there is a currently conforming transportation plan and TIP in accordance with 40 CFR 93.114. The current conformity determination is consistent with the final conformity rule found in 40 CFR Parts 51 and 93. The I-695: I-70 to MD 170 project was included in the regional emissions analysis and there have been no significant changes in the project's design concept or scope, as used in the conformity analyses. Therefore, this project comes from a conforming plan and program in accordance with 40 CFR 93.115. Conformity to the purpose of the SIP means that the transportation activity will not cause new air quality violations, worsen existing violations, or delay timely attainment of the relevant national ambient air quality standards (NAAQS or "standards").

  • Based on review and analysis as discussed above, it is determined that I-695: I-70 to MD 170 meets the Clean Air Act and 40 CFR 93.109 requirements. These requirements are met for particulate matter without a project-level hot-spot analysis, since the project has not been found to be a project of air quality concern as defined under 40 CFR 93.123(b)(1). Since the project meets the Clean Air Act and 40 CFR 93.109 requirements, the project will not cause or contribute to a new violation of the PM2.5 NAAQS, or increase the frequency or severity of a violation.

  • By email dated December 19, 2007 the above analysis was approved by FHWA and forwarded to EPA, MDE and BRTB for Interagency Consultation. On December 26, 2007 approval was received from EPA. On January 7, 2008 response was received from MDE with comments. The comments received from MDE concerned the assumption that there would be 0% change in ADT between the build and No-Build conditions. This was also a concern of the BRTB’s air quality subcommittee. On February 25, 2008, after discussions with FHWA, a revised determination was submitted; and on March 5, 2008 the analysis was presented to the BRTB’s air quality subcommittee. Additional clarifications have been made to satisfy the concerns of BRTB’s air quality subcommittee, and address additional FHWA comments received on February 25, 2008. FHWA, EPA, and MDE agreed with the conclusion that the I-695: I-70 to MD 170 Project is not a project of air quality concern under 40 CFR 93.123(b)(1). As no other comments were received from Interagency Consultation, this Conformity Determination will be placed on SHA’s website for a 15 day pubic review and comment period. Refer to the Appendix for emails concerning comments and approvals.



TABLE 2
I-695 South of I-70



















 

Ex. 2005

2025 No-Build

2025 Build

% Change: No-Build vs. Build.

Remarks

SHA Project ADT volumes

172050

228500

228500













0%










 

 

 

 

 

 

 

 

Percent of Trucks - ADT

Truck % is 10% based upon July 2007 count data




Assumption would be made that truck percentage would be 10%

for future No-Build/Build conditions. Actual truck volumes would increase proportional

to increase in overall traffic.
















 

 

 

 

 

 

 

 

SHA Project Daily Truck Volumes

24087

31990

31990

0%

 









TABLE 3
I-695 North of I-95






















 

Ex. 2005

2025 No-Build

2025 Build

% Change: No-Build vs. Build.

Remarks




SHA Project ADT volumes

172050

228500

228500

 




 







0%













 

 

 

 

 

 

 

 




Percent of Trucks - ADT

Truck % is 13% based upon July 2007 count data and 14% based upon







SHA study data. Assumption would be made that truck percentage would be 14%




for future No-Build/Build conditions. Actual truck volumes would increase proportional




to increase in overall traffic.



















 

 

 

 

 

 

 

 




SHA Project Daily Truck Volumes

24087

31990

31990

0%

 




 




Notes:

1. SHA project volumes consider both directions of travel along I-695







2. The approved BMC Regional transportation model (Round 7) shows truck percentages







consistent with the table assertion that truck percentages would remain 10% and 14% as shown above for all conditions



1 See Conformity Determination entitled “ PM2.5 Conformity Determination MD 295: I-695 to I-195, September 2006

2 Criteria for identifying projects of air quality concern is described in 40 CFR 93.123(b)(1), as amended.

3 Transportation Conformity Rule Amendments to Implement Provisions Contained in the 2005 Safe, Accountable, Flexible, Efficient Transportation Equity Act: A Legacy for Users (SAFETEA-LU) [Federal Register: May 2, 2007 (Volume 72, Number 84)] [Proposed Rules] [Page 24489]


4 Transportation Outlook 2035 and the FY 2008-2012 Transportation Improvement Program, Baltimore Regional Transportation Board (BRTB), November 2007.


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