The adoption of our county’s latest long-range transportation plan comes at a time of
tremendous change.
The passage of the Infrastructure Investment
and Jobs Act (IIJA), also known as the
Bipartisan Infrastructure Law, or BIL, in
November 2021 injected an additional
$13 billion over the law’s five-year life into
Pennsylvania transportation. Of that amount,
$14.59 million was dedicated to Franklin
County, which allowed us to add 15 previously
deferred projects to our transportation
construction program.
Nevertheless, challenges remain. Although
there are millions available in new federal
dollars through formula and discretionary
programs, local governments are struggling
to raise the local match required to secure
new federal funds. Soaring inflation is
diminishing our buying power. Franklin
County’s population continues to surge—
numbers from the 2020 U.S. Census reveal
that the county registered its 23rd consecutive
decennial population increase since its
founding in 1784. This translates to growing
demand for transportation infrastructure and
services, and is reflected in changes to our
landscape, as warehousing, distribution, and
intermodal centers consume our farms and
open spaces.
As we look ahead, we can expect to grapple
with the economic and transportation changes
that were wrought by the COVID-19 pandemic
and its aftermath. The following influences
are expected to change how we plan for the
county’s future:
This document, our latest long-range transportation plan, provides us with a framework for addressing these challenges to ensure that our transportation system remains a strategic asset for our county’s continued mobility and economic vitality. I invite your review of the plan and ask you to join us as we work together to ensure we maintain a dependable and sustainable transportation system for Franklin County.
Figure 1: Franklin County's Geographic Position
1831
Cumberland Valley Railroad (CVRR) incorporated
1837
CVRR reaches Chambersburg
1924
First segments constructed of US 30/Lincoln Highway—the first transcontinental highway in the U.S.
1940
PA Turnpike opens
1960
First segments of I-81 constructed
1969
Franklin County’s population exceeds 100,000
1995
Conrail donates former rail corridor to Cumberland Valley Rails-to-Trails Council
2000
BicyclePA Route S designated
2003
Daily vehicle-miles traveled (DVMT) exceeds 4 million for the first time
2005
I-81 Exit 17 constructed
2007
CSX opens intermodal yard in Chambersburg
2013
Franklin County Metropolitan Planning Organization designated
2013
Norfolk Southern opens intermodal yard in Greencastle
2025
I-81 Exit 12 interchange slated to open
The long-range transportation plan (LRTP)
establishes goals and potential projects to
improve the transportation system in Franklin
County, consistent with the county’s overall
vision. The LRTP considers a 25-year planning
horizon and provides a framework for making
transportation decisions that will support the
county’s desired future.
Specifically, the LRTP inventories and
assesses the county’s current land use,
transportation patterns, and the operations of
all transportation modes. The LRTP identifies
needed improvements to the multimodal
transportation system—highway/bridge, rail,
air, transit, bicycle, and pedestrian facilities—to
facilitate a desired long-term outcome.
The LRTP is guided by the Franklin County
Metropolitan Planning Organization (MPO)
and serves several key functions, including:
A metropolitan planning organization (MPO) is a transportation policy-making body comprised of representatives of local government and transportation agencies that own, operate, and fund transportation infrastructure. Federal law requires the formation of an MPO in any urbanized area with a population greater than 50,000; Franklin County became an MPO due to population growth reflected in the 2010 U.S. Census. MPOs ensure that decisions and spending on transportation projects and programs are based on a “continuing, comprehensive, and cooperative” (3C) planning process that reflects the needs and priorities of the county. MPOs administer federal and state funding for transportation projects and programs, consistent with the approved LRTP.
Developing and regularly updating an LRTP is a prerequisite to receiving federal transportation funding. Further, it helps ensure that transportation investment decisions are made strategically and considered in light of their long-term effect on the county.
Transportation decisions profoundly shape the county’s direction and growth. An LRTP helps determine what improvements are needed to guide the county in a cohesive, agreed-upon direction for the future. Without this solid direction, growth would occur in an unplanned and incremental manner, likely to the detriment of what makes Franklin County a great place in which to live, work, or visit.
The Metropolitan Planning Organization (MPO) is the official transportation planning organization for Franklin County recognized by the Pennsylvania Department of Transportation (PennDOT) and the Federal Highway Administration (FHWA). Federal law and regulations establish five core functions of an MPO. The Secretary of Transportation on behalf of the Governor of Pennsylvania designated Franklin County as an MPO on March 27, 2013. The MPO succeeded the Franklin County Rural Planning Organization (RPO), which was established in May 2009.
Figure 7: Transportation and Warehousing: Share of Total Employment by Pennsylvania County, 2019
Figure 33: Percentage of State-Owned Bridges Rated “Poor,” Franklin County and Statewide, 2017-21
The implementation of the Franklin County Long-Range Transportation Plan will be guided by several overarching principles that provide a framework for plan implementation. The topic areas are listed below and directly mirror the policy ideas that were used to gauge public opinion through the MPO’s surveys:
The strategies presented within this section are consistent with and build upon policies previously adopted in other county plans. The implementation of the long-range transportation plan will guide the activities of the MPO; its partners at the local, county, state, and federal levels; and the public. Public responses to the MPO’s LRTP survey support the strategic directions of the plan by placing the most emphasis on safety, economic development, and maintenance and development. When prioritizing program spending, the public’s choices reflected the same three policy areas as priorities, but in a slightly different order: fixing the existing infrastructure (system maintenance), traffic management (reliable travel), and safety. Interestingly, the public’s survey responses recognized the difficult choices the MPO faces in providing a balanced program, because no potential implementation strategy received less than three stars out of five. As a result, plan implementation addresses some needs in all the policy areas, while focusing more significant efforts on strategies to affect safety, reliable travel, and system maintenance, consistent with public sentiment. The MPO will continue to work with stakeholders at the local, state, and federal levels and the public to make the plan’s vision a reality.
Safety across all transportation modes is the MPO’s highest priority. The annual number of traffic fatalities has averaged 18 in recent years. Total roadway crashes continue to trend upward, even as the demand for travel has remained relatively constant (and even declined during the COVID-19 pandemic). Addressing safety will entail an array of strategies that include education, improved traffic operations, needed countermeasures, and strategic additions to network capacity. The MPO also continues to work with PennDOT to monitor safety performance targets in support of attaining statewide and national highway safety goals.
The Franklin County MPO will also coordinate with PennDOT District 8-0 to identify locations for conducting roadway safety audits as part of its TIP development process. Additionally, the Safe Streets and Roads for All Grant Program (SS4A) funding aims to prevent roadways deaths and serious injuries. The Franklin County MPO will apply for this funding to conduct planning, design, and development activities in support of the Action Plan, in addition to carrying out projects and strategies identified in the plan.
The MPO will seek to improve conditions for non-motorized users by working with PennDOT to implement low-cost opportunities to improve non-motorized safety and connectivity. The MPO will ensure that safety measures for non-motorized users are incorporated into programmed projects, when feasible.
Work zones are characterized by traffic pattern changes, the presence of construction workers, and work vehicles frequently entering and leaving construction areas. These factors create increased risk for crashes in work zones. The Franklin County MPO will continue to work with PennDOT to implement best practices to improve the predictability of work zones.
Franklin County has a sizeable Plain Sect population and agricultural communities with distinct and unique transportation needs. Truck traffic has increased on county roads that are also heavily frequented by Plain Sect travelers using buggies and bicycles, and walking. The MPO will continue to work with the Plain Sect and agricultural communities to provide wider shoulders and safer intersection crossings on roads identified as priorities.
Roadway closures impact emergency response time and the reliability of the county’s roadways. Franklin County will seek to improve the emergency response capabilities of those who are responding to and clearing incidents from the county’s roadways. Other efforts include improving Intelligent Transportation Systems (ITS) infrastructure, including weather information systems and dynamic messaging signs. New data and tools have provided valuable insight into incident management by helping identify the causes of non-recurring congestion. These include crashes, weather, and road construction.
According to FHWA, 94 percent of all rail-related injuries occur at railroad crossings or due to trespassing, and most of them are preventable. Working with federal, state, and local agencies, the MPO will collaborate with PennDOT to address and increase safety at railroad crossings.
The role of planning for improved traffic operations in transportation planning has increased in recent years in response to several related factors: the increased demand for travel in general, the lack of state and federal funding for major capital-intensive projects, and technological advances. The MPO continues to partner with PennDOT in these areas through such initiatives as the update and maintenance of a Regional Operations Plan (ROP), and planning for Transportation Systems Management and Operations (TSMO).
The LRTP planning team used RITIS data to identify the county’s top bottlenecks, based on the extent and duration of congestion. This data provides the MPO with a starting point for addressing the most critical locations where congestion relief is needed. The MPO should further explore PennDOT’s data on estimated causes of congestion after it has been refined and released to better understand how it can be used for making decisions on reducing recurring and non-recurring congestion.
Recommendations from the Eastern Regional Operations Plan (ROP) detailed elsewhere within this plan should be explored.
Interstate 81 accommodates approximately 43 percent of all travel demand within Franklin County, making it the county’s most strategic roadway. It connects the county and its shippers and receivers to the broader state and national economies, with overland access to origins and destinations in other market areas. Planning and programming functions for the interstate are centralized within PennDOT; the MPO must continue its efforts to maintain proper connections and access to the interstate through the TIP process.
Incidents on Interstate 81 often have a deleterious effect on the county’s mobility, causing delays on the mainline and congestion and safety concerns on parallel roadways. A Traffic Incident Management Strategy (TIMS) is needed for the length of Interstate 81 in Franklin County. Within these limits there are 10 full-access interchanges and nearly 26 miles of mainline from the Mason-Dixon Line to the Cumberland County border. Franklin County’s neighboring MPO regions in Harrisburg and Lebanon have established TIMS teams to coordinate incident management strategies and enhance response times, including along the I-81 corridor. The Franklin County MPO could coordinate with those MPOs to discuss best practices.
An ideal TIMS program relies on efficient data collection, analysis, and reporting to measure performance and identify gaps that can be addressed. Other options to consider include Computer-Aided Dispatch, electronic crash reporting, traffic management center software, and smart devices that simplify data collection.
Traffic signals are typically installed by PennDOT and then owned and maintained by the host municipality. Signal equipment that is properly timed and maintained helps improve travel efficiency and reduces the cost of signal operation/ maintenance over time. There are 121 signalized intersections county-wide, and of prime concern are the signals along commercial corridors that traverse multiple municipalities. Prime examples are the signalized corridors of US 11, US 30, and PA 316. New Traffic Signal Technologies grants passed by the General Assembly in July 2022 provide an additional $5 million statewide for municipalities to install and maintain traffic signal technologies such as adaptive signal control, detection, and communication technology.
There is a need to compile traffic operations infrastructure assets and planned “colored” detour routes and present it in both spreadsheet and GIS output formats. Moreover, incident management needs (gaps and issues) need to be identified to improve the traffic operations environment.
The COVID-19 pandemic was an historic, disruptive event that changed much of the way we live, work, and travel. The health crisis fueled a greater public desire for active transportation and facilities. Interest in bicycle and pedestrian forms of travel as a mode of transportation and form of recreation has increased. Moreover, the MPO seeks to plan for facilities that encourage mode choice and reduce the county’s dependence on the private automobile.
Bicycle and pedestrian facilities are critical infrastructure for accessibility and mobility. Developing this infrastructure also improves quality of life, connecting people while also improving their health and wellness. The MPO will seek to implement plans that encourage bicycle and pedestrian activity.
A key component of improving bicycle and pedestrian safety and increasing micromobility is to connect gaps in sidewalk and trail networks. The MPO should make it a priority to address these concerns with the appropriate stakeholders. A key action item will include the designation of US Bicycle Route 11 through the county, in collaboration with PennDOT, the American Association of State Highway and Transportation Officials (AASHTO), and Adventure Cycling.
Greater separation of bicyclists and pedestrians from vehicular traffic can reduce fatalities and serious injuries for all users, while also encouraging greater use of non-motorized modes of transportation. Shared-use paths connect people to jobs, schools, parks, and other transportation routes. In addition to their transportation function, they offer opportunities for improving community health and wellness.
Countdown signals help pedestrians judge whether there is sufficient time to cross, which can be especially helpful to mobility-challenged and elderly pedestrians. The MPO will work to identify appropriate crosswalks at which to install these signals.
IIJA/BIL includes a new Vulnerable Roadway Users (VRU) Special Rule. For Pennsylvania, at least 15 percent of the state’s Highway Safety Improvement Program (HSIP) allocation must be spent on VRU-related projects. In Franklin County, the investment will be used to implement a system-wide safety improvement for VRUs by installing pedestrian countdown timers (PCTs). It will require several tiered projects based on the level of effort to install PCTs, which varies for each location. PennDOT District 8-0 took the lead for this effort in 2022.
Expanded and improved bicycle and pedestrian infrastructure ensures that a network is in place to make biking and walking viable modes of travel that are safe and convenient. Strategies can support Safe Routes to School, Complete Streets, and Encourage Bicycling and Walking programs.
An Active Transportation Advisory Committee, comprising bicyclists, pedestrians, and other active movers, can advise the MPO based on their own personal experiences and related work backgrounds with the goal of implementing an active transportation plan. Such a committee could help guide bicycle and pedestrian planning efforts at a local level and form a consortium for regional dialog and planning as it relates to active transportation.
Transportation’s impact on the environment remains a critical policy issue for the MPO. County planning staff will continue to work with all agencies to avoid, minimize, and mitigate impacts from transportation projects on the environment. The MPO’s ongoing involvement in the PennDOT Connects process will further facilitate the identification of potential impacts of projects early in the preliminary design process so that agencies can be contacted to review and comment on strategies to reduce negative impacts.
Consideration should be given to incorporating resiliency into the MPO’s project prioritization process. Ongoing coordination with federal, state, and local environmental agencies is critical in prioritizing these vulnerable locations. Franklin County should partner with its municipalities and PennDOT to identify where stormwater infrastructure is lacking or could be improved on roadways with high levels of vulnerability in extreme rain and snow events. This reduces the need for emergency roadwork on critical highways and bridges and the need for emergency funds due to flood damage.
The MPO continues to work toward improving the resiliency of its transportation network in the face of both natural and man-made disruptions. Part of this effort includes identifying high-volume roadways that are prone to flooding, which affects network reliability.
The MPO will work with municipalities to help advance MS4 or municipal separate storm sewer systems, countywide. These systems help protect water quality and manage runoff and flooding during storms. Helping to develop these programs throughout the county can help protect transportation infrastructure during severe weather events.
Many states (including Pennsylvania) are currently in the process of developing National Electric Vehicle Infrastructure (NEVI) plans for developing essential charging corridors to help spur electric vehicle adoption. While PennDOT implements its NEVI plan for implementing electric-vehicle infrastructure, the MPO can prepare and identify which corridors will become electrified and prepare for this new infrastructure.
The MPO recognizes transportation’s role in not only providing mobility and access, but also in maintaining and improving the county’s economic competitiveness. In fact, this is one of the federal planning factors for transportation and one of the guiding principles in the county’s planning and programming activity. The LRTP recognizes transportation’s impact in connecting workers to jobs, consumers to commercial outlets, and the county’s businesses and industries in general to consumer market areas both near and far. Within Franklin County, transportation is a major employment sector in its own right, constituting 11.6 percent of the county’s total employment—more than double the state rate of 4.8 percent.
A safe and efficient transportation system is a key component of an area’s quality of life. It has direct bearing on mobility and the access of people and goods to employment, shopping, and recreation. Access management strategies help improve the safety and efficiency of traffic by reducing congestion and decreasing accidents while also preserving community character through site design and land use planning.
In conjunction with the PennDOT District 8-0 office, the MPO can hold regular outreach and information sessions with municipal governments and developers countywide to keep them up to date on transportation developments and inform them of the procedures that are required as part of the transportation planning process.
The Franklin County MPO should be involved in any comprehensive planning efforts spearheaded by municipal governments to help advise on local land use planning and the strategic placement and development of economic centers and design as it relates to transportation infrastructure.
Franklin County’s share of FHWA’s priority freight designations includes portions of US 11 in Antrim Township (between Greencastle and I-81), PA 16 in Antrim Township (between I-81 and the Village of Shady Grove), and portions of PA 997, US 11, and PA 433 between I-81 and Letterkenny Army Depot. Even as these segments have been certified by FHWA and are eligible for National Highway Freight Program (NHFP) funding, the MPO may also consider elevating these and other priority freight segments for suballocating available TIP funding for these corridors.
Increased access to low-cost multimodal transportation options expands economic opportunity by giving non-drivers access to jobs, businesses, and other locations that are otherwise out of reach without a car. Multimodal transportation options also expand the labor force available to some businesses.
The passage of MAP-21 and its successor legislation, the FAST Act, placed a greater emphasis on planning for goods movement. MPOs and DOTs alike have put forth plans and initiatives to address the growth of freight and its impact on public infrastructure. Surrounding MPO regions in Harrisburg and Hagerstown have already developed and adopted regional freight plans. The availability of additional federal funding through formula and new discretionary programs from IIJA/ BIL, coupled with the explosive growth of warehousing and distribution centers in Franklin County, make this a critical action item for the future.
With more than 1,700 linear miles of roadway and approximately 320 state-owned bridges (and more than 100 locally owned bridges), Franklin County has an extensive and mature transportation system. While there are a few major capacity-adding projects planned (a new Exit 12 on Interstate 81 being a prime example), the MPO will use new tools and techniques to invest in system maintenance and preservation. New approaches such as Lowest LifeCycle Cost will provide needed attention to the system to extend the life of its transportation assets and provide the MPO with the greatest benefit for its limited transportation funding.
The MPO will continue to work with PennDOT District 8-0 to fund and plan for resurfacing and pavement preservation activities. A regular investment in maintaining roadway pavements will reduce the need for large investments in roadway reconstruction projects. It will also reduce the need for road closures and lengthy detours. PennDOT’s forthcoming asset management planning tool will include the county’s unconstrained needs by each highway category on PennDOT’s Business Plan Networks.
The Franklin County MPO will continue to work with PennDOT District 8-0 to fund and plan for routine bridge maintenance activities. A regular investment in maintenance will reduce the need for large, one-time investments in necessary rehabilitation or replacement projects. The goal is to extend the useful life of an asset and prevent costly emergency repair situations. A source of sustainable funding for bridge maintenance should be identified and programmed on future TIPs. PennDOT is developing a Web-based asset management planning tool that will be accessible by the MPO. It will include the county’s unconstrained needs by each highway category on PennDOT’s Business Plan Networks, consistent with asset management principles in the Pennsylvania Transportation Asset Management Plan (TAMP).
Local bridges are often ineligible for federal transportation funds, with the exception of the Off-System Bridge program. It establishes criteria for funding improvements to bridges that are not on the Federal-Aid System. PennDOT is required to apply 15 percent of its annual funding allocation to these bridges. The Franklin County MPO will assist its municipal partners in addressing local bridge needs by maintaining a list of priority off-system bridges to refer to when federal funding is available. The MPO in August 2022 moved to waive the 5 percent local match for federal dollars for off-system bridges. This will give the MPO more flexibility with its TIP, and will assist municipalities that are still recovering from the impact of the COVID-19 pandemic.
The MPO remains committed to planning for public transportation services for its residents. This included the adoption of a Local Coordinated Plan in July 2021, and the launch of a pilot program for microtransit (rabbittransit’s “Stop Hopper” program) in August 2022. Public transportation is crucial to the county’s transportation system, as it provides accessible and affordable transportation for people with limited mobility options. Planning for this mode should assess transportation needs for seniors, persons with disabilities, and low-income individuals; strategies and/or projects to address any gaps between current services and future needs; and priorities for implementation based on resources, time, and feasibility.
Fixed-route bus service is an important element of the regional economy, providing people with mobility and access to employment, community resources, medical care, and recreational opportunities. The Franklin County MPO and regional partners will investigate possibilities for instituting fixed-route service.
The implementation of the new microtransit service (“Stop Hopper”) serves as a two- to three-year pilot for the Greater Chambersburg area. The MPO will monitor the pilot’s effectiveness and coordinate with rabbittransit, PennDOT, and the Franklin County Commissioners on its evolution.
PennDOT and Franklin County MPO have worked together for many years to improve transportation infrastructure in the region. Moving forward, the MPO will continue to work with PennDOT to improve connections with adjacent transit agencies (e.g., Capital Area Transit) to create a region with more connected commercial and recreation hubs.
Analysis of travel patterns in the county indicates several places that could serve as parking lots for ridesharing programs. The county should work with municipalities where appropriate to implement park-and-ride lots through the land development process and through partnerships with rabbittransit and Commuter Services.
Since 2007, Coordinated Plans have been a crucial tool for regional multimodal transit planning. Coordinated Plan requirements place a large emphasis on stakeholder engagement and public involvement to ensure that the plan is designed by, and benefits, those who need and use public transportation. The MPO acknowledges the need to improve mobility throughout the county, including the interconnectedness of the county and the inter- and intra-county travel of residents. While the current plan serves as an administrative update of its predecessor, the next update should engage the public and transit stakeholders.
“When individuals have increased mobility options, they have increased possibilities to improve their quality of life. We’re proud to offer the Stop Hopper as an affordable way to help riders in smaller, rural communities access the benefits of public transit.”
– Rich Farr, Executive Director, SRTA
The passage of the FAST Act in 2015 added new provisions for long-range transportation planning, including the enhancement of travel and tourism. The MPO recognizes the role that travel and tourism have on the transportation system, and the need for the system to be intuitive and easy to navigate for the county’s visitors, as well as serving the county’s many tourist destinations. Tourism continues to be a major industry, and especially so as the Baby Boomer generation transitions out of the workforce with more disposable income and a greater degree of mobility compared to previous generations.
Not only do trails, parks, and cultural attractions provide an opportunity for outdoor recreation, they can also provide a means of transportation or a commuting connection. By promoting the PA Department of Conservation and Natural Resources’ (DCNR’s) grant programs, the MPO can assist the county and local municipalities in securing funding for trail gap closures and enhancing local tourism and travel destinations.
In improving access and connectivity to tourism destinations and visitor centers, efforts can be made to improve the signage and resources at these facilities countywide.
Data related to tourism should be part of the planning and programming process to ensure that future projects and programs are supportive of the county’s tourism industry. Ensuring the proactive involvement of tourism groups—such as the Franklin County Visitors Bureau—in the county’s transportation planning process will help ensure tourism interests are being considered.
In lieu of specific projects, line-item amounts were determined for the plan’s “out years” (2035-2047) in consultation with PennDOT District 8-0 and Central Office. The MPO used PennDOT’s 2023 Financial Guidance documentation for the 2023 program to determine the shares of funding to go toward three project types: Highway, Bridge, and Safety.
The MPO determined shares based on funding available for specific funding programs, i.e., “Highway” amounts based on funding allocations from NHPP, STP, and State Highway; “Bridge” amounts based on State Bridge and Off-System Bridges; and “Safety” from HSIP. The shares resulted in a 66/23/11 split, respectively, as shown in the following table.
Appendix A Countywide Line Items Table
Note that the following projects are unfunded, and illustrative only. The MPO will consider the candidates from this project listing as future programs are being developed.
As part of its transportation planning process, the Franklin County Metropolitan Planning Organization (FCMPO) completed the transportation conformity process for the updated 2045Long Range Transportation Plan (LRTP) and the FY 2023-2026 Transportation Improvement Program (TIP).This report documents that theTIP and LRTP meets the federal transportation conformity requirements in 40 CFR Part 93. Note the TIP has not changed from previous conformitydeterminations.
Clean Air Act (CAA) section 176(c) (42 U.S.C. 7506(c)) requires that federally funded or approved highway and transit activities are consistent with (“conform to”) the purpose of the State Implementation Plan (SIP). Conformity to the purpose of the SIP means that transportation activities will not cause or contribute to new air quality violations, worsen existing violations, or delay timely attainment of the relevant NAAQS or any interim milestones. EPA’s transportation conformity rules establish the criteria and procedures for determining whether metropolitan transportation plans, TIPs, and federally supported highway and transit projects conform to the SIP.
On February 16, 2018, the United States Court of Appeals for the District of Columbia Circuit in South Coast Air Quality Mgmt. District v. EPA(“South Coast II,” 882 F.3d 1138) held that transportation conformity determinations must be made in areas that were either nonattainment or maintenance for the 1997 ozone national ambient air quality standard (NAAQS) and attainment for the 2008 ozone NAAQS when the 1997 ozone NAAQS was revoked. These conformity determinations are required in these areas after February 16, 2019.Franklin Countywas maintenance at the time of the 1997 ozone NAAQS revocation on April 6, 2015 and was also designated attainment for the 2008 ozone NAAQS on May 21, 2012. Therefore, per the South Coast II decision, this conformity determination is being made for the 1997 ozone NAAQS.
This conformity determination was completed consistent with CAA requirements, existing associated regulations at 40 CFR Parts 51.390 and 93, and the South Coast II decision, according to EPA’s Transportation Conformity Guidance for the South Coast II CourtDecisionissued on November 29, 2018.
The concept of transportation conformity was introduced in the CAA of 1977, which included a provision to ensure that transportation investments conform to a State Implementation Plan (SIP) for meeting the Federal air quality standards. Conformity requirements were made substantially more rigorous in the CAA Amendments of 1990. The transportation conformity regulations that detail implementation of the CAA requirements were first issued in November 1993, and have been amended several times. The regulations establish the criteria and procedures for transportation agencies to demonstrate that air pollutant emissions from metropolitan transportation plans, transportation improvement programs and projects are consistent with (“conform to”) the State’s air quality goals in the SIP. This document has been prepared for State and local officials who are involved in decision making on transportation investments.
Transportation conformity is required under CAA Section 176(c) to ensure that Federally-supported transportation activities are consistent with (“conform to”) the purpose of a State’s SIP. Transportation conformity establishes the framework for improving air quality to protect public health and the environment. Conformity to the purpose of the SIP means Federal Highway Administration (FHWA) and Federal Transit Administration (FTA) funding and approvals are given to highway and transit activities that will not cause new air quality violations, worsen existing air quality violations, or delay timely attainment ofthe relevant air quality standard, or any interim milestone.
The CAA requires the EPA to set NAAQS for pollutants considered harmful to public health and the environment. A nonattainment area is any area that does not meet the primary or secondary NAAQS. Once a nonattainment area meets the standards and additionalredesignation requirements in the CAA [Section 107(d)(3)(E)], EPA will designate the area as a maintenance area.
Franklin Countyis currently designated as a maintenance area under the 1997 8-hour ozone NAAQS. The countyis in attainment of the 2008 and 2015 8-hour ozone, 2006 24-hour PM2.5 and 2012 annual PM2.5 NAAQS. Transportation conformity requires nonattainment and maintenance areas to demonstrate that all future transportation projects will not prevent an area from reaching its air quality attainment goals.
1997 8-hour Ozone NAAQS
The EPA published the 1997 8-hour ozone NAAQS on July 18, 1997 (62 FR 38856), with an effective date of September 16, 1997. An area was in nonattainment of the 1997 8-hour ozone NAAQS if the 3-year average of the individual fourth highest air quality monitor readings, averaged over 8 hours throughout the day, exceeded the NAAQS of 0.08 parts per million (ppm). On May 21, 2013, the EPA published a rule revoking the 1997 8-hour ozone NAAQS, for the purposes of transportation conformity, effective one year after the effective date of the 2008 8-hour ozone NAAQS area designations (77 FR 30160).
On February 16, 2018 the D.C. Circuit reached a decision in South Coast Air Quality Management District v. EPA, Case No. 15-1115. In that decision, the court vacated major portions of the final rule that established procedures for transitioning from the 1997 ozone NAAQS to the stricter 2008 ozone NAAQS. By court decision, Franklin Countywas designated asan “orphan” maintenance area since the area was maintenance for the 1997 ozone NAAQS at the time of its revocation (80 FR 12264, March 6, 2015) and was designated attainment for the 2008 NAAQS in EPA’s original designations for this NAAQS (77 FR 30160, May 21, 2012).
2008 and2015 8-hour Ozone NAAQS
The EPA published the 2008 8-hour ozone NAAQS on March 27, 2008 (73 FR 16436), with an effective date of May 27, 2008. EPA revised the ozone NAAQS by strengthening the standard to 0.075 ppm. Thus, an area is in nonattainment of the 2008 8-hour ozone NAAQS if the 3-year average of the individual fourth highest air quality monitor readings, averaged over 8 hours throughout the day, exceeds the NAAQS of 0.075 ppm. FranklinCounty was designated as an attainment area under the 2008 8-hour ozone NAAQS, effective July 20, 2012 (77 FR 30088).
In October 2015, based on its review of the air quality criteria for ozone and related photochemical oxidants, the EPA revised the primary and secondary NAAQS for ozone to provide requisite protection of public health and welfare, respectively (80 FR 65292). The EPA revised the levels of both standards to 0.070 ppm, and retained their indicators, forms (fourth-highest daily maximum, averaged across three consecutive years) and averaging times (eight hours). Under the Clean Air Act, the EPA administrator is required to make all attainment designations within two years after a final rule revising the NAAQS is published. Franklin County is in attainment of the 2015 8-hour ozone NAAQS.
The Long-Range Transportation Plan (LRTP) serves as the official transportationplan for a metropolitan area.TheLRTP documents the current and future transportation demand and identifies long-term improvements and projects to meet those needs. TheLRTP was recently updated by the FCMPOto guide decision-making about transportationimprovements in the county. The planning factors specified in federal regulations provide the framework for developing theLRTP. In addition,PennDOT provides guidance to help MPOs prepare LRTPs, and local policies and plans play a role in LRTP development to ensure transportation investments address current and future needs.The Franklin County LRTP includes projects from the Pennsylvania Department of Transportation (PennDOT) Twelve Year Program (TYP).
In addition, MPOs and Rural Planning Organizations (RPOs) each develop a TIP at the local level, which reflects the first four years of the PennDOT TYP.The Statewide Transportation Improvement Program (STIP) covers the entire state and includes the individual TIPs representing each Planning Partner. Federal Law requires TIPs to be updated at least every four years. Pennsylvania’s MPOs and RPOs update their TIPs every two years during the TYP update process.
The February 16, 2018, South Coast vs. EPA Court decision did not vacate EPA’s revocation of the 1997 ozone standard and the decision does not change the area’s attainment status. Therefore, while such areas might be required to meet conformity requirements as part of anti-backsliding controls, such areas are not considered nonattainment or maintenance areas under the Transportation Planning Rule (23 CFR 450.104). Such areas continue to complete 5-year plan update cycles as described in 23 CFR 450.324(c). The 5-year metropolitan transportation plan update cycle continues to apply from the date of the most recent MPO metropolitan transportation plan adoption (not the most recent FHWA/FTA conformity determination). While these areas have a 5-year plan cycle for transportation planning purposes, as a result of the court decision they must still meet the 4-year frequency requirements for conformity determinations on TIPs and LRTPsas required by 40 CFR 93.104.
Appendix A provides a listing of the regional significant projects that are funded in the TIP and LRTP within FranklinCounty. Regionally significant projects include transportation projects (other than exempt projects as defined under 40 CFR 93.126- 127) that areon a facility which serves regional transportation needs.
Per the court’s decision in South Coast II, beginning February 16, 2019, a transportation conformity determination for the 1997 ozone NAAQS will be needed in 1997 ozoneNAAQS nonattainment and maintenance areas identified by EPA for certain transportation activities, including updated or amended TIPs and LRTPs. Once US DOT makes its 1997 ozone NAAQS conformity determination, conformity will be required no less frequently than every four years. This conformity determination report addresses transportation conformity for the FCMPO 2023-2026 TIP and 2045LRTP.
On November 29, 2018, EPA issued Transportation Conformity Guidance for the South Coast II Court Decision (EPA-420-B-18-050, November 2018) that addresses how transportation conformity determinations can be made in areas that were nonattainment or maintenance for the 1997 ozone NAAQS when the 1997 ozone NAAQS was revoked, but were designated attainment for the 2008 ozone NAAQSin EPA’s original designations for this NAAQS (May 21, 2012).
The transportation conformity regulation at 40 CFR 93.109 sets forth the criteria and procedures for determining conformity. The conformity criteria forTIPs and LRTPs include: latest planning assumptions (93.110), latest emissions model (93.111), consultation (93.112), transportation control measures (93.113(b) and (c), and emissions budget and/or interim emissions (93.118 and/or 93.119). For the 1997 ozone NAAQS areas, transportation conformity for TIPs and LRTPs for the 1997 ozone NAAQS can be demonstrated without a regional emissions analysis, per 40 CFR 93.109(c). This provision states that the regional emissions analysis requirement applies one year after the effective date of EPA’s nonattainment designation for a NAAQS and until the effective date of revocation of such NAAQS for an area. The 1997 ozone NAAQS revocation was effective on April 6, 2015, and the South Coast II court upheld the revocation. As no regional emission analysis is required for this conformity determination, there is no requirement to use the latest emissions model, or budget or interim emissions tests.
Therefore, transportation conformityfor the 1997 ozone NAAQS can be demonstrated by showing the remaining requirements in Table 1 in 40 CFR 93.109 have been met. These requirements, whichare laid out in Section 2.4 of EPA’s guidance and addressed below, include:
The use of latest planning assumptions in 40 CFR 93.110 of the conformity rule generally applies to a regional emissions analysis. In the 1997 ozone NAAQS areas, the use of latest planning assumptions requirement applies to assumptions about transportation control measures (TCMs) in an approved SIP. However, the Franklin County SIP maintenance plan does not include any TCMs.
The consultation requirements in 40 CFR 93.112 were addressed both for interagency consultation and public consultation.
As required by the federal transportation conformity rule, the conformity process includes a significant level of cooperative interaction among federal, state, and local agencies. For this air quality conformity analysis, interagency consultation was conducted as required by the Pennsylvania Conformity SIP. This included conference call(s) or meeting(s) of the Pennsylvania Transportation-Air Quality Work Group (including the Pennsylvania Department of Transportation (PennDOT), DEP, EPA, FHWA, FTA and representatives from larger MPOs within the state).
Meeting and conference calls were conducted quarterly in 2022 to review all planning assumptions and to discuss the template and content for transportation conformity analyses in 1997 ozone orphan areas.
TheTIP, LRTP and associated conformity determination hasundergone the public participation requirements as well as the comment and response requirements according to the procedures established in compliance with 23 CFR part 450, FCMPO’s Public Participation Plan, and Pennsylvania's Conformity SIP. The draft document was made available for a 30-day public review and comment period, which included a public meeting.
The planning regulations, Sections 450.324(f)(11) and 450.326(j), require the transportation plan to be financially constrained while the existing transportation system is being adequately operated and maintained. Only projects for which construction and operating funds are reasonably expected to be available are included. The FCMPO, in conjunction with PennDOT, FHWA and FTA, has developed an estimate of the cost to maintain and operate existing roads, bridges and transit systems in the region and have compared the cost with the estimated revenues and maintenance needs of the new roads over the same period. The FCMPOTIP and LRTP has been determined to be financially constrained.
The conformity determination process completed for the FCMPOTIP and LRTP demonstrates that these planning documents meet the Clean Air Act and Transportation Conformity rule requirements for the 1997 ozone NAAQS.
The public involvement efforts for MPO/RPOs are guided by several federal mandates to ensure nondiscrimination in federally funded activities. These mandates are designed so that planning and public involvement activities are conducted equitably and in consideration of all citizens, regardless of race, nationality, sex, age, ability, language spoken, or economic status. These mandates include:
FHWA recently introduced the Environmental Justice Core Elements Methodology to ensure an MPO/RPO can meaningfully assess the benefits and burdens of plans and programs. Franklin County is committed to following the Core Elements approach, which includes efforts to:
By integrating the Core Elements into the planning process, state and local agencies are better equipped to carry out the investment strategy and project selection. The EJ process should be comprehensive and continuous with each task informing and cycling back to influence the next step.
In developing its 2045 Long Range Transportation Plan (LRTP), Franklin County conducted an Environmental Justice Benefits and Burdens analysis. A distributive geographic analysis was conducted to identify the locations and concentrations of minority, low-income and other Traditionally Underserved Populations (TUP). The identification of these populations is essential to establishing effective strategies for engaging them in the transportation planning process. When meaningful opportunities for interaction are established, the transportation planning process can effectively draw upon the perspectives of communities to identify existing transportation needs, localized deficiencies, and the demand for transportation services. Mapping of these populations not only provides a baseline for assessing impacts of the transportation investment program, but also aids in the development of an effective public involvement program. Minority population is defined as any readily identifiable group of Black, Hispanic, Asian American, American Indian, and Alaskan Native who live in geographic proximity and who would be similarly affected by a proposed FHWA program, policy, or activity.
Low-income population is defined as any readily identifiable group of persons at or below the Department of Health and Human Services poverty guidelines who live in a geographic proximity who would be similarly affected by a proposed FHWA program, policy, or activity. As shown in Table EJ-1, based on the 2015-2019 American Community Survey (ACS) data, minority persons in Franklin County make up nearly 14 percent of the total population. The number of persons in poverty is just above 9 percent of the total regional population. Table EJ-2 identifies the total population by race and low-Income category. The White, Non-Hispanic category has the highest population in the county and most individuals that are low-Income, however, the category’s overall low-income percentage is about 9 percent, which is about the same as the county average of 9.25 percent. In contrast, nearly 25 percent of the Hispanic population and nearly 72 percent of the Native Hawaiian category is considered low income.
In order to meaningfully analyze benefits and adverse effects of the transportation program, Franklin County has examined the existing conditions of transportation assets throughout the county and safety performance measures among the minority and low-income populations. These data assessments allow the county to track changes in crashes, poor condition bridges, and poor pavement mileage in the region and identify safety gaps and distribution disparities between minority and low-income populations.
Tables EJ-3 and EJ-4 provide the number and percentage of bridges by condition and by the concentration of minority and low-income population. Comparing the distribution of total bridges and poor condition bridges between low and high minority and low-income areas helps provide insights on potential equity issues. For areas with higher minority population shares, the percentage of total bridges and poor bridges is 27.2% and 28.5%, respectively. For areas with higher shares of low-income population, the percentage of total bridges and poor bridges is 26.2% and 34.4%, respectively. In both cases the share of poor condition bridges is near the percentage of total bridges in minority and low-income areas. The data does not indicate any disproportionate impacts to those communities related to bridge asset conditions.
Tables EJ-5 through EJ-8 show the number and percentage of crashes in Franklin County from 2015-2019 in areas of varying minority and low-income shares. This data is reviewed to identify if any disproportionate numbers of crashes occur in areas with high shares of minority or low-income population. As shown in Table EJ-5, about 42 percent of the total crashes occur within block groups that have higher shares of minority population, while nearly 58 percent of crashes occur
in block groups with lower shares of minority population. Similarly, nearly 36 percent of crashes occur within block groups that have higher shares of low-income populations, while 64 percent of crashes occur in block groups with lower shares, as shown in Table EJ-6. This data does not indicate disproportionate impacts for minority or low-income populations related to total crashes, fatalities or serious injuries.
However, the bicycle and pedestrian crashes shown in Tables EJ-7 and EJ-8 show much higher numbers and percentages in areas with a higher share of minority populations. This may be a result of higher
levels of pedestrian and bicycle activity and usage in those areas. Franklin County will continue to review and evaluate safety needs for these populations in its planning process.
Tables EJ-9 and EJ-10 identify the number and percentage of roadways with poor International Roughness Index (IRI) and with poor Overall Pavement Index (OPI) within minority and low-income population block group intervals. Poor pavement condition data in Franklin County may indicate a need for increased roadway resurfacing
and reconstruction. The data indicates that poor rated IRI and OPI pavement occurs at nearly equal amounts between areas with and without high shares of low-income and minority populations. The data does not indicate any disproportionate impacts to those communities related to pavement conditions.
Franklin County reviewed transportation projects located in areas that were determined to have higher than average minority and lowincome levels. When evaluating the potential benefit or burden of a project, it should be noted that each type of project has a unique set of impacts and will affect individual populations differently. For example, maintenance projects tend to cause the least amount of impact on the population since they typically involve highway resurfacing or repaving work on existing roadways. Although these projects can cause delayed travel time and transit service, traffic detours, and work zone noise and debris, the projects are typically shorter in duration and result in improvements to the functionality of the roadway network by providing smoother driving surfaces and new roadway markings. While most bridge projects are identified as either a rehabilitation or replacement, both types of projects can lend itself to significant traffic detours, traffic delay, and noise. However, the benefits of these types of improvements result in safer bridge structures, improved roadway conditions and updated signage.
Capacity projects, which can involve the addition of new lanes to existing roadways, new roadways to the existing network, or at times the realignment of intersections or interchanges, in an effort to provide for more traffic mobility. Special attention needs to be made when planning capacity projects, especially to low-income
and minority populations. Not only can these projects result in right-of-way acquisitions to account for the additional capacity, but also construction impacts are normally more severe due to longer construction periods, travel pattern shifts, and delayed travel times among others. The consequences of the completion of capacity projects can involve the loss of property, increased traffic volumes, and decreased air quality, while other benefits can include improved transit service time, decreased travel delay, and safer roadway conditions which will result in improved quality of life for all residents and users of the roadway system.
Of all locatable projects on Franklin County’s 2045 LRTP, the number of projects in minority or low-income areas is lower than the number of projects located in non-minority and non-low-income areas. Tables EJ-11 and EJ-12 depict the types of projects and funding investments in each minority/income interval. Figures EJ-1 and EJ-2 illustrate the geographic proximity between different LRTP projects and the concentrations of minority and low-income populations by Census block groups based on 2015-2019 ACS data. Franklin County will continue to evaluate needs and investment opportunities in these areas to ensure all communities share in transportation investment benefits.
Figure EJ-1: Concentrations of Minority Populations by Census Block Groups & LRTP Project Locations
Figure EJ-2: Concentrations of Low-Income Populations by Census Block Groups & LRTP Project Locations