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NAAQS. As a result, special intersection analysis should be performed to determine the
likelihood of a violation occurring as a result of the airport or air base project. For an intersection
assessment, the pollutant concentrations would be analyzed at each applicable intersection. For
EPA guidance on a methodology for evaluating air quality impacts at one or more roadway
intersections where vehicle traffic will cause or contribute to increased emissions of carbon
monoxide (CO) see EPA’s Guideline For Modeling Carbon Monoxide From Roadway
Intersections. For an intersection assessment, state or regional air quality regulatory staff or the
regional transportation planning staff should be consulted.
Once dispersion modeling has been performed, pollutant concentrations are combined with
background pollutant concentrations and compared to the NAAQS. If concentrations do not
exceed the NAAQS, an air quality certificate is obtained from the Governor (if applicable) and
the assessment is complete. If pollutant concentrations do exceed the NAAQS, emissions must
be mitigated or offset, or the action redesigned to reduce emissions.
2.2 Assessment Process Participants
Many different agencies and individuals must be involved when assessing the air quality impact
of a project, since Federal, State, and local requirements all must be considered. This
coordination, and subsequent analysis, are time consuming and need to be addressed early in the
assessment process. Common participants include the airport sponsor or USAF, the FAA, the
EPA, the State, the local air quality management district (AQMD), the local metropolitan
planning organization (MPO), contractors, and the public. These participants contribute to
various stages of the assessment process such as information gathering, scoping meetings,
developing modeling consensus, and obtaining consensus on air quality analysis and conformity
determination. The airport sponsor’s or USAF’s responsibilities include defining the project and
alternatives and preparing environmental documents. The FAA, as well as the USAF, have the
responsibility to analyze the environmental impacts associated with the proposed Federal airport
action. Agency documents previously referenced also contain guidance on agency
offices/personnel to contact during this process.
2.3 Screening Thresholds
Many projects at airports and air bases are too small to require a detailed air quality analysis and
only a few projects are both broad enough in scope and located in nonattainment areas such that
the full complement of analyses described in this document would be required. To determine
which of the steps identified in section 2.1 will be required, applicable screening threshold levels
are reviewed. The performance an Emissions Inventory is dependent on how the analysis is to be
used to fulfill Indirect Source Review, Conformity, NAAQS or other requirements.
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The following sub-sections define the threshold levels for Indirect Source Review,
Transportation Conformity, General Conformity and NAAQS. In addition to summarizing air
quality analyses that often are required for different projects, Figure 2 also addresses the specific
threshold levels.
2.3.1 Indirect Source Review
Indirect source review requirements are state-specific and at this writing are required only for
projects in certain parts of California, Connecticut, Minnesota, New York, North Carolina,
Oregon, Utah, Vermont, and Wisconsin. Typically, thresholds are set for secondary measures of
emissions rather than calculated emissions. Common thresholds are: number of added parking
spaces, total parking spaces, increased highway trips, total highway trips, increased aircraft
LTOs, and total aircraft LTOs. Appendix J, State Indirect Source Review Regulations,
summarizes the threshold values for the states having indirect source review requirements as of
this writing.
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Figure 3. Air Quality Analysis Guidelines and Thresholds
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2.3.2 Transportation Conformity
Transportation conformity determinations are required for all nonattainment and maintenance
area highway or transit projects that are developed, funded or approved by the Federal Highway
Administration or Federal Transit Administration for some aspect of the project. Transportation
conformity also applies to projects that are “regionally significant”. A “regionally significant”
project is a transportation project that is on a facility serving regional transportation needs and
would normally be included in the modeling of a metropolitan areas transportation network. In
the case of an airport or air base in a nonattainment or maintenance area, almost any roadway or
transit project off the airport or air base boundary will require transportation conformity analysis
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