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EPA Home > Region 5 > Air > Correspondence


John Baxter, Division Administrator
Federal Highway Administration
575 North Pennsylvania Street, Room 254
Indianapolis, Indiana 46204

Dear Mr. Baxter:

This letter provides the Region 5 United States Environmental Protection Agency's (USEPA) comments regarding the September 23, 1999, Louisville Area updated 2020 transportation plan (Plan). The Plan was received from the Kentuckiana Regional Planning and Development Agency (KIPDA) on
October 1, 1999. USEPA received supplemental materials on November 4, 1999. The USEPA received a request for review of the Plan amendment from the Federal Highway Administration on September 30, 1999. The Indiana Department of Environmental Management issued a letter supporting a positive conformity finding of the Plan on October 26, 1999.

The Louisville area, which consists of Clark and Floyd County in Indiana and, Jefferson and portions of Oldham and Bullitt Counties in Kentucky, is a moderate nonattainment area for ozone. This area is currently required to show consistency with the motor vehicle emissions budget for volatile organic compounds (VOC) and, to demonstrate that future nitrogen oxide (NOx) emissions are less than 1990 baseline emissions. The area must also show for selected future years that NOx emissions under a build scenario will be less than those emissions under a no build scenario. The conformity analysis prepared by KIPDA for the Plan update demonstrates conformity to the emission budget for VOC and meets the relevant tests for NOx.

However, the plan update received October 1, 1999, did not contain a demonstration that the Plan is consistent with the Transportation Improvement Program (TIP). KIPDA submitted materials to USEPA stating the two documents are consistent on November 4, 1999.

The Federal Highway Administration (FHWA) did not request comments on the TIP amendments. However, the TIP amendments do contain changes to regionally significant projects. If amendments contain projects other than those specifically listed as exempt in 60 Code of Federal Regulations 93.126 and 93.127, a new conformity finding is required. In this case, none of the changes affect the modeling, and a new modeling analysis is not required. However, since some of the projects in the amendment are not exempted, a conformity finding is required. USEPA Region 5 will comment fully on the conformity of the TIP when FHWA requests comments starting the formal conformity comment period.

In summary, USEPA Region 5 recommends that the 2020 Plan adopted September 23, 1999, be found to conform to the SIP.

The TIP amendments made to the Fiscal Year 2000 - 2002 TIP need to be submitted to the conformity consultation agencies. USEPA is providing some general comments as guidance in this letter. USEPA will formally comment on the TIP amendments when we receive a request to do so.

If you have any questions regarding these comments, please contact
Ryan Bahr, Environmental Engineer, of my staff, at (312) 353-4366.

Sincerely yours,


J. Elmer Bortzer, Chief
Regulation Development Section

cc: Kathryn Watson, Chief
Air Programs Branch
Indiana Department of Environmental Management

Doug Gerleman, Transportation Representative
Federal Transit Administration

Janice Osadczuk, Division Chief
Division of Preliminary Engineering and Environment
Indiana Department of Transportation

Randy Simon, Transportation Planner
Kentuckiana Regional Planning and Development Agency

cc by E-mail:

Phyllis Hockett, Manager
Environmental Services Section
Indiana Department of Transportation

Dan Buck, Transportation Planner
Environmental Services Section
Indiana Department of Transportation

Larry Heil, Planning and Program Development Manager
Federal Highway Administration - Indiana Division

Joyce Newland, Transportation Planner
Federal Highway Administration - Indiana Division

For further information, contact:
This Information Last Modified On: 09/18/2008 04:03 PM