Hampton Roads Regional Transportation Conformity

Understanding Transportation Conformity

Transportation Conformity is a critical process mandated by the Clean Air Act to ensure that our regional transportation plans and programs align with federal and state air quality goals.  It helps make sure transportation activities do not worsen air quality or delay the attainment of National Ambient Air Quality Standards (NAAQS), which are set by the Environmental Protection Agency (EPA) to protect public health and the environment. 

The transportation conformity rule only applies in areas that do not currently meet or have not met the NAAQS in the past.  The EPA designates these areas as nonattainment or maintenance areas, respectively.  While the Hampton Roads region currently meets all NAAQS, it was previously in maintenance for the 1997 eight-hour ozone NAAQS.  Although this standard was revoked by the EPA in 2015, the South Coast Air Quality Management District v. EPA court decision reinstated the requirement for conformity determinations in areas like Hampton Roads, which are now classified as “orphan maintenance areas.” 

Regional Conformity Assessments

Due to the region’s status as an orphan maintenance area, the Hampton Roads region is subject to streamlined transportation conformity requirements for updates and amendments to the Long-Range Transportation Plan (LRTP) and Transportation Improvement Program (TIP).  These requirements involve conducting a Regional Conformity Assessment (RCA) that focuses on consultation, fiscal constraint, and proper documentation to maintain compliance with air quality standards. 

Key Components of the RCA for Hampton Roads

The streamlined conformity requirements for orphan maintenance areas require the Hampton Roads region to: 

• Conduct Consultation:  Engage with federal, state, and local agencies to ensure comprehensive and coordinated planning. 
• Ensure Fiscal Constraint:  Demonstrate that proposed transportation projects are financially feasible with sufficient funding.
• Document:  Provide necessary documentation to confirm that conformity requirements are met.   

Inter-Agency Consultation for Conformity Procedures

To reflect the streamlined transportation conformity requirements, Inter-Agency Consultation for Conformity (IACC) Procedures were developed and approved by the HRTPO Board in April 2023.  These procedures ensure that updates and amendments to the LRTP and TIP align with applicable conformity requirements.  They outline steps for collaboration and consultation among key stakeholders and formalize programmatic approaches for demonstrating fiscal constraint and processing non-regionally significant amendments.   

There are two types of RCAs:  full RCAs and RCA letters.  Full RCAs provide comprehensive documentation and are conducted for full updates of the LRTP or TIP.  RCA letters are used for amendments and offer streamlined assessments while still meeting all conformity requirements. 

Latest RCA and Conformity Project List

For detailed information, please refer to the latest RCA, the conformity project list, and the latest Joint FHWA/FTA Finding of Conformity linked below.   

• Latest Full Regional Conformity Assessment (RCA)
• Latest RCA Letter
• Current Conformity Project List
• Latest Joint FHWA/FTA Finding of Conformity

By maintaining a structured conformity process, we ensure that our transportation plans not only meet mobility needs but also contribute to cleaner air and a healthier region.