Conformity Analysis

Aug 7, 2013

Conformity Analysis


Northeastern Illinois does not attain national ambient air quality standards (NAAQS) for Ozone. Depending on the Standard it is classified either as marginal or Serious non-attainment area for the 8-hour ozone standard. The region must implement a transportation program which will help to reduce levels of these pollutants to national standards.

Nonattainment areas are designated by the US Environmental Protection Agency (US EPA) based, in part, on recommendations from the Illinois Environmental Protection Agency (IEPA). IEPA's recommendation follows US EPA guidelines for identifying nonattainment areas. This includes not just monitor data, but also emissions data, urbanization patterns, meteorology, and so on. Technical information on this process can be found on the IEPA website.

The IL-IN-WI Nonattainment area does not have the same geographic boundaries as MPO as they are established through a different process than then MPO boundaries are.  With each standard a nonattainment area is established by the US EPA.   The the nonattainment boundaries and the MPO boundaries are similar but not identical.  The nonattainment area in northeast Illinois under the 1997 and 2008 Ozone standards are the same and include: Cook, DuPage, Kane, Lake, McHenry, and Will Counties and portions of Grundy (Aux Sable and Goose Lake Townships) and Kendall (Oswego Township) Counties.  Under the 2015 Ozone standard the nonattainment area no longer includes McHenry County.   

The nonattainment area under all 3 Ozone standards also includes portions that are outside of Illinois.  The 1997 Ozone standard also included a portion of NW Indiana and the 2008 and 2015 Ozone standards also included portions of NW Indiana and SE Wisconsin.  The Northwestern Indiana Regional Planning Commission and Southeastern Wisconsin Regional Planning Commission handle conformity requirements for those portions of the nonattainment area that are in there respective states while CMAP is responsible for transportation conformity in Northeast Illinois portion of the nonattainment area for each Ozone standard.

The Chicago region (including the entire CMAP region) was redesignated as being in attainment of the 1997 PM2.5 NAAQS.  As a result transportation conformity no longer applies on the effective date of the final PM2.5 SIP requirements rule, October 24, 2016. After that date, conformity determinations for the 1997 annual PM2.5 NAAQS for metropolitan transportation plans, metropolitan transportation improvement programs (TIPs), or transportation projects are no longer required in these areas for this NAAQS.

For more information regarding PM 2.5 and conformity see Transportation Conformity Guidance, specifically question 5 from the EPA.

As part of the transportation planning and programming process, CMAP staff evaluates the impact of proposed transportation activities on the region's air quality. This evaluation, called a conformity analysis, must demonstrate that the a long-range regional transportation plan or Transportation Improvement Program (TIP) conforms before it is approved by the MPO or accepted by DOT.

The conformity analysis must demonstrate that the emissions resulting from the long-range regional transportation plan or TIP meet the requirements of (i.e., "conform to") the regulations governing air quality.

Interagency consultation is required under the transportation conformity rule, as described in 40 CFR 51.402. In the northeastern Illinois region, these procedures are addressed through the Tier II Consultation process. Decisions made through this interagency consultation process guide the MPO in making conformity determinations.

Current Conformity Analysis

The current conformity analysis, covering ON TO 2050 and FY 2019 – 2024 Transportation Improvement Program, consists of these documents:

Conformity Amendments

The conformity analysis is updated semi-annually. Updates are initiated with the submittal of TIP changes by project sponsors. The staff analysis of the required changes is reviewed by the Transportation Committee and released for a 30-day public comment period. Comments are addressed and reviewed by the Transportation Committee and approved by the MPO Policy Committee. USDOT and IDOT provide final approval of the amendments.

For More Information

To learn more about the effects of air pollution, please see the following documents on the United States Environmental Protection Agency's web site:

To learn more about conformity requirements, please see the following documents on the Federal Highway Administration's web site:

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