Air Quality Conformity

Draft for Public Comment Transportation Conformity Determination Report for the 1997 Ozone NAAQS Flint Orphan Maintenance Area (Genesee and Lapeer Counties) Thirty-Day Public Comment Period is from March 9, 2020 to April 7, 2020

Prepared by: Genesee County Metropolitan Planning Commission

Draft for Public Comment

TABLE OF CONTENTS Executive Summary ................................................................................................................................. 3 1.0 Background ......................................................................................................................................... 5 1.1 Transportation Conformity Process ................................................................................................ 5 1.2 Conformity Area ................................................................................................................................ 6 1.3 Attainment Status .............................................................................................................................. 6 2.0 Long-Range Transportation Plan or Metropolitan Transportation Plan ................................ 7 3.0 Transportation Improvement Program .......................................................................................... 8 4.0 Transportation Conformity Determination: General Process ................................................... 8 5.0 Transportation Conformity Requirements ................................................................................... 9 5.1 Overview ............................................................................................................................................. 9 5.2 Latest Planning Assumptions ........................................................................................................ 10 5.3 Consultation Requirements ............................................................................................................ 10 5.4 Timely Implementation of Transportation Control Measures .................................................. 11 5.5 Fiscal Constraint ............................................................................................................................... 11 6.0 Conclusion ......................................................................................................................................... 12 Appendix A: Meeting Summary of Interagency Workgroup........................................................ 13 Appendix B: Public Comments and Responses ............................................................................... 14 Appendix C: Financial Constraint ...................................................................................................... 15 Appendix D: Projects Evaluated for Conformity ............................................................................. 18

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EXECUTIVE SUMMARY As part of its transportation planning process, Genesee County Metropolitan Alliance (GCMA) completed the transportation conformity process for the Genesee County 2045 Long-Range Transportation Plan (LRTP) and FY 2020-2023 Transportation Improvement Program (TIP). This report documents that the Genesee County 2045 LRTP and Genesee County FY 2020-2023 TIP, as well as the State Transportation Improvement Plan (STIP) in Lapeer County meet the federal transportation conformity requirements in 40 CFR Part 93.

Clean Air Act (CAA) section 176(c) (42 U.S.C. 7506(c)) requires 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 national ambient air quality standard (NAAQS) or any interim milestones. 42 U.S.C. 7506(c)(1).

United States Environmental Protection Agency’s (EPA) transportation conformity rules establish the criteria and procedures for determining whether MTPs, TIPs, and federally supported highway and transit projects conform to the SIP, 40 CFR Parts 51.390 and 93.

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 NAAQS and attainment for the 2008 ozone NAAQS when the 1997 ozone NAAQS was revoked. These conformity determinations were required in these areas after February 16, 2019. The Flint area (Genesee and Lapeer counties) was in 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.

It was also designated attainment for the 2015 ozone NAAQS on August 3, 2018. Therefore, per the South Coast II decision, this 3

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conformity determination is being made for the 1997 ozone NAAQS on the LRTP and TIP. 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 Court Decision issued on November 29, 2018.

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1.0 BACKGROUND 1.1 TRANSPORTATION CONFORMITY PROCESS The concept of transportation conformity was introduced in the CAA of 1977, which included a provision to ensure that transportation investments conform to a 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 LRTPs, TIPs, 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 of the relevant air quality standard, or any interim milestone.

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1.2 CONFORMITY AREA The conformity area consists of two counties: Genesee and Lapeer.

Within the boundary is the Metropolitan Planning Organization (MPO) of GCMA (core city Flint), as well as the rural projects contained in the STIP in Lapeer County.

Findings of the transportation conformity report are for transportation activities contained within the conformity area.

1.3 ATTAINMENT STATUS On April 15, 2004, the EPA issued final designations of areas not attaining the 1997 ozone NAAQS. Genesee and Lapeer counties were designated a nonattainment area.

On May 16, 2007, the EPA redesignated the area attainment, approving and finding adequate motor vehicle emissions budgets for volatile organic compounds (VOC) and nitrogen oxides (NOx) for the year 2018. The area was placed into maintenance; this requires conformity emissions to be compared to the motor vehicle emission budgets contained in the SIP. On July 20, 2012, the EPA designated all of Michigan as attainment for the strengthened 2008 ozone NAAQS. On July 20, 2013, the EPA partially revoked the 1997 ozone NAAQS, revoking the requirement to do transportation conformity for areas that were in maintenance.

On April 6, 2015, the EPA completely revoked the 1997 ozone NAAQS, which resulted in removal of all transportation conformity requirements.

On April 23, 2018, FHWA began requiring areas in the country to conduct conformity if they were a maintenance area for the 1997 ozone NAAQS and attainment for the 2008 ozone NAAQS when 6

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the 1997 ozone NAAQS was revoked. This was to comply with the court’s decision in South Coast II. The Flint conformity area was one of these areas. Later, this was amended to require MPOs to have a conformity in place on February 16, 2019, and conduct conformity going forward.

On August 3, 2018, the EPA designated both Genesee and Lapeer counties as attainment for the strengthened 2015 ozone NAAQS. On December 4, 2019, the EPA proposed a rule that the Flint 1997 ozone maintenance area be considered for a limited maintenance plan for the area's second maintenance period. To be considered for a limited maintenance plan, the area must show the design value to be well below the NAAQS and the area's levels of air quality are unlikely to violate the NAAQS in the future. Areas with limited maintenance plans are not required to conduct emission modeling for conformity.

2.0 LONG-RANGE TRANSPORTATION PLAN OR METROPOLITAN TRANSPORTATION PLAN The LRTP, also referred to as an MTP, is developed by the MPO to establish a long-term transportation plan. An LRTP is federally required for MPOs to receive federal funding and must provide a 20-year (or longer) horizon. Plans are required to be updated every four to five years. The purpose of an LRTP is to assess future needs of the area’s transportation system and set goals to meet those needs. The planning process can enhance quality of life by fostering the mobility of people and freight in an effective and safe method.

Findings of the transportation conformity report are for transportation activities contained within the conformity area. The GCMA is developing a new 2045 LRTP. This conformity report is to ensure that GCMA satisfies its obligation to the CAA. This analysis also includes the GCMA TIP and STIP and its latest amendments. This report evaluates transportation activities contained in: •

Genesee County 2045 LRTP, 7

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•

Genesee County FY 2020-2023 TIP, and

•

STIP projects in Lapeer County.

3.0 TRANSPORTATION IMPROVEMENT PROGRAM The TIP is a financially constrained four-year program covering the most immediate implementation priorities for transportation projects and strategies from the LRTP. The TIP identifies proposed projects developed by local agencies in accordance with the joint regulations of the FHWA and the FTA. These regulations establish the TIP as the programming phase of the overall continuing, comprehensive, and cooperative planning process. This planning process includes local jurisdictions, transit agencies, and state and federal transportation officials.

All areas in Michigan are operating under FY 2020-2023 TIPs that were approved for use by FHWA and FTA on October 1, 2019.

Conformity for the Flint maintenance area was conducted on the FY 2020-2023 TIP and associated LTRP, and received a letter supporting the conformity findings from FHWA/FTA on September 17, 2019.

4.0 TRANSPORTATION CONFORMITY DETERMINATION: GENERAL PROCESS 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 ozone NAAQS nonattainment and maintenance areas identified by EPA 1 for certain transportation activities, including updated or amended MTPs and TIPs. FHWA/FTA made its 1997 ozone NAAQS conformity determination for the 2040 LRTPs and FY 2020-2023 TIPs on September 17, 2019. Conformity will now be required no less frequently than every four years. This conformity determination The areas identified can be found in EPA’s “Transportation Conformity Guidance for the South Coast II Court Decision," EPA-420-B-18-050, available on the web at www.epa.gov/state-and-local-transportation/policy-andtechnical-guidance-state-and-local-transportation.

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report will address transportation conformity for the new Genesee County 2045 LRTP, the FY 2020-2023 TIP and the existing STIP in Lapeer County.

5.0 TRANSPORTATION CONFORMITY REQUIREMENTS 5.1 OVERVIEW On November 29, 2018, EPA issued the Transportation Conformity Guidance for the South Coast II Court Decision 2 (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 NAAQS in EPA’s original designations for this NAAQS (May 21, 2012). The area was designated attainment for the 2008 ozone NAAQS on May 21, 2012, and August 3, 2018, for the 2015 ozone NAAQS. The transportation conformity regulation at 40 CFR 93.109 sets forth the criteria and procedures for determining conformity. The conformity criteria for MTPs and TIPs includes: 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 MTPs and TIPs 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 an 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 2

Available from https://www.epa.gov/sites/production/files/2018-11/documents/420b18050.pdf

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to use the latest emissions model, or budget or interim emissions tests.

Therefore, transportation conformity for the 1997 ozone NAAQS for the Genesee County 2045 LRTP, FY 2020-2023 TIP, and the rural STIP in Lapeer County can be demonstrated by showing the remaining requirements in Table 1 in 40 CFR 93.109 have been met.

These requirements, which are laid out in Section 2.4 of EPA’s guidance and addressed below, include: •

Latest planning assumptions (93.110),

•

Consultation (93.112),

•

Transportation Control Measures (93.113), and

•

Fiscal constraint (93.108).

5.2 LATEST PLANNING ASSUMPTIONS The use of latest planning assumptions in 40 CFR 93.110 of the conformity rule generally apply to regional emissions analysis. In the 1997 ozone NAAQS areas, the use of the latest planning assumptions requirement applies to assumptions about transportation control measures (TCMs) in an approved SIP. The Michigan SIP does not include any TCMs (see also Section 5.4).

5.3 CONSULTATION REQUIREMENTS The consultation requirements in 40 CFR 93.112 were addressed both for interagency consultation and public consultation.

Interagency consultation was conducted with GCMA, the Michigan Department of Transportation (MDOT), the Michigan Department of Environment, Great Lakes, and Energy (EGLE), FHWA, FTA, and EPA. A summary of the Michigan Transportation Interagency Workgroup (MITC-IAWG) meeting on September. 4, 2019, and relevant interagency consultation correspondence related to this conformity is in Appendix A. Interagency consultation was conducted consistent with Michigan’s conformity SIP. 10

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Public consultation will be conducted consistent with planning rule requirements in 23 CFR 450. The Public Participation Plan adopted by the MPO Policy Committee establishes the procedures by which the MPOs reach affected public agencies and the public. The same procedures were followed for this document, ensuring the public has an opportunity to review and comment before the MPOs make a determination.

A formal public comment period for this draft conformity report will be held from March 9, 2020 to April 7, 2020, for the GCMA. Public comments received and responses to those comments will be in Appendix B. The GCMA policy committee will make a formal conformity determination through a resolution on July 15, 2020.

5.4 TIMELY IMPLEMENTATION OF TRANSPORTATION CONTROL MEASURES The Michigan SIP does not include any TCMs. 5.5 FISCAL CONSTRAINT Transportation conformity requirements in 40 CFR 93.108 state that transportation plans and TIPs must be fiscally constrained consistent with the metropolitan planning regulations at 23 CFR part 450. The LRTPs and FY 2020-2023 TIPs are fiscally constrained, as demonstrated in: •

Genesee County 2045 LRTP, by going to: http://ourfuturegenesee.org/wp-content/uploads/2019/08/TransFinancial-New-Format-Final.pdf

•

Genesee County 2023-2023 TIP, by going to: http://gcmpc.org/wp-content/uploads/2019/10/sgallLocallyApproved-TIP-Document_IncludesAppendix-Fed-Approved-withDocumentation.pdf then go to Section 2: Financial Plan.

After each amendment, staff posts the most current list of projects which includes the most current fiscal constraint at: www.gcmpc.org/transportation-improvement-program/ then go to the “TIP Projects” icon.

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•

FY 2020-2023 STIP, including latest amendments for Lapeer County, by going to https://www.michigan.gov/documents/mdot/20202023_STIP_Draft_660694_7.pdf

Excerpts of the financial constraint information from these documents is presented in Appendix C.

6.0 CONCLUSION The conformity determination process completed for the Genesee County 2045 LRTP and FY 2020-2023 TIP, and the FY 2020-2023 STIP for Lapeer County demonstrates that these planning documents meet the CAA and Transportation Conformity rule requirements for the 1997 ozone NAAQS.

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Appendix A: Meeting Summary of Interagency Workgroup Summary of Meeting

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Summary of September 2019 Meeting

On September 4, 2019, GCMPC staff participated in a conference call with MDOT, the Federal Highway Administration (FHWA), the U.S. Environmental Protection Agency (EPA), and the Michigan Department of Environment, Great Lakes, and Energy (EGLE) to get consensus on Genesee County projects for the new 2045 Long Range Transportation Plan (LRTP) and Lapeer County rural projects in the October STIP amendment. The FY 20202023 Transportation Improvement Program (TIP) projects were reviewed by IAWG at a previous meeting and have not changed and will be included in the 2045 LRTP and corresponding analysis with the new transportation travel demand model. One new 2045 Long Range Transportation Plan project was presented for review. The MPO staff recommended that this project is non-exempt because it is a widening project over two miles long. Three Lapeer County projects were then presented, and all three had a recommendation of exempt as they were only preliminary engineering and pavement preservation projects. All IAWG members concurred with staff’s recommendations for the 2045 LRTP project and the three Lapeer County projects. Meeting summary and handouts begin on next page.

Meeting Summary Michigan Transportation Conformity Interagency Workgroup (MITC‐ IAWG) Flint Conformity Area 2045 Long Range Transportation Plan/Lapeer County Projects September 4, 2019 9:00 a.m. Conference Call Members on Call:

Breanna Bukowski, Michigan Department of Environment, Great Lakes, and Energy Aaron Dawson, Federal Highway Administration Michael Leslie, Environmental Protection Agency Don Mayle, Michigan Department of Transportation (MDOT) Jay Reithel, MDOT John Roberts, MDOT Donna Wittl, MDOT Sharon Gregory, Genesee County Metropolitan Planning Commission (GCMPC) Jacob Maurer, GCMPC Jason Nordberg, GCMPC Christine Pobocik, GCMPC

Mr. Nordberg opened the meeting with introductions, and explained that the purpose of the conference call was to get consensus on Genesee County projects for the new 2045 Long Range Transportation Plan (LRTP) and Lapeer County rural projects in the October STIP amendment. He noted that the FY 2020‐2023 Transportation Improvement Program (TIP) projects were reviewed

by IAWG at a previous meeting and will be included in the 2045 LRTP and corresponding analysis with the new transportation model. One new 2045 Long Range Transportation Plan project was presented for review. The MPO staff recommended that this project is non‐exempt because it is a widening project over two miles long. Three Lapeer County projects were then presented, and all three had a recommendation of exempt as they were only preliminary engineering and pavement preservation projects. All IAWG members concurred with staff’s recommendations for the 2045 LRTP project and the three Lapeer County projects. Copies of the projects are attached.

Mr. Nordberg noted that the transportation model for the 2045 plan has modeling years of 2014 (the base year), 2020, 2025, 2035, and 2045 that will be used for air quality analysis. The LRTP project will be represented in the 2045 modeling year. Ms. Wittl verified with GCMPC staff that they would update the Air Quality document to reflect these changes.

Ms. Wittl indicated that starting on October 1, 2019, IAWG meetings will not be required for TIP or LRTP amendments. Instead, staff will attach a document to the amendment. MDOT is currently working on creating the document. Ms. Wittl also explained that GCMPC is now considered a Limited Orphan Maintenance Area (LOMA), a special area which does not have to run the emissions model. This is because the area is 85% below the 1997 ozone National Ambient Air Quality Standard. The emission budget is considered to be unconstrained. However, there 1

must be an air quality conformity determination every four years. In order to accomplish this, conformity will be done on new TIPs and LRTPs. Ms. Wittl also indicated that the LOMA maintenance plan is scheduled to be approved by EPA in January 2020. GCMPC will also need to sign what is commonly referred to as the “conformity SIP”. It is a Memorandum of Agreement (MOA) that provides the rules, roles, and procedures of the MITC‐IAWG. This agreement was shared with MITC‐IAWG in October 2018 and June 2019 to participants of the conformity training. The MPO, it appears at this time, will need to sign this agreement sometime during the coming year. The agreement is part of the SIP so the signing will be facilitated by the Michigan Department of Environment, Great Lakes, and Energy. The Environmental Protection Agency will then pass the MOA through their process.

Mr. Nordberg adjourned the meeting at approximately 9:25 a.m.

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Appendix B: Public Comments and Responses

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Appendix C: Financial Constraint Below are excerpts of financial constraint for the TIP, STIP, and LRTP. STIP Financial Constraint for FY 2020 - 2023 Michigan Department of Transportation. (2018, October 24). Financial Chapter. State Transportation Improvement Program (pp. 32). Retrieved https://www.michigan.gov/documents/mdot/20202023_STIP_Draft_660694_7.pdf Demonstration of Financial Constraint, FY 2020-2023 After determination of resources available for federal-aid highway and transit capital needs for FY 2020-2023, and matching those available resources to specific needs, a four-year program of projects is created within the context of the region’s transportation policies as contained in the 2020-2023 STIP. The list must be adjusted to each year’s YOE factor and then fiscally constrained to available revenues. Table 11 contains a summary of the cost of highway and transit projects programmed over the four-year TIP period, matched to revenues available in that same period. This table shows that the FY 2020- 2023 TIP is fiscally constrained.

Note: Operations and maintenance (O&M) costs of the federal- aid highway system is included in the text of this chapter; however, these costs are not included in the TIP itself, as nearly all highway O&M costs are ineligible for federal-aid funding.

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Table 11: Demonstration of Fiscal Constraint FY 2020-2023 STIP dollars)

(millions of

Excerpt of Genesee County TIP Financial Constraint for FY 2020 - 2023 Genesee County Metropolitan Planning Commission. FY 2020-2023 Transportation Improvement Program. (approved September 26, 2019). Section 2. (pp. 15). www.gcmpc.org/tip-document-and-public-notices/ Demonstration of Financial Constraint, FY 2020-2023 After determination of resources available for federal-aid highway and transit capital needs for FY 2020-2023, and matching those available resources to specific needs, a four-year program of projects is created within the context of the region’s transportation policies as contained in the 2020-2023 STIP. The list must be adjusted to each year’s Year of Expenditure (YOE) factor and then fiscally constrained to available revenues. Table 11 contains a summary of the cost of highway and transit projects programmed over the four-year TIP period, matched to revenues available in that same period. This table shows that the FY 2020- 2023 TIP is fiscally constrained.

Note: O&M costs of the federal- aid highway system are included in the text of this chapter; however, these costs are not included in the TIP itself, as nearly all highway O&M costs are ineligible for federal-aid funding.

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Table 4: Demonstration of Genesee County Fiscal Constraint FY 2020-2023 TIP (millions of dollars) Highway Funding Highway Programmed Transit Funding Transit Programmed Total Funding Total Programmed Difference

2020 $44.8 $44.8 $15.7 $15.7 $60.5 $60.5 $0.4

2021 $28.9 $28.9 $17.2 $17.2 $46.1 $46.1 $0

2022 $99.9 $99.9 $17.5 $17.5 $117.4 $117.4 $0

2023 $35.7 $35.7 $17.4 $17.4 $53.1 $53.1 $0

Excerpt of Genesee County LRTP Financial Constraint for FY 2020 – 2045 Genesee County Metropolitan Planning Commission. Genesee: Our County, Our Future.

Technical Reports. Transportation, CD, and Solid Waste Financial Reports. (pp. 2-6). www.ourfuturegenesee.org/transportation-financial-plan-report/ Projects programmed in the LRTP are known as commitments. Commitments cannot exceed funds reasonably expected to be available. Projects must also be programmed in year of expenditure dollars, meaning that they must be adjusted for inflation to reflect the estimated purchasing power of a dollar in the year the project is expected to be built. The MTPA/Financial Work Group has decided on an annual inflation rate of 4 % for projects over the plan period. This means that a project costing $100,000 in FY 2020 is expected to cost $104,000 in FY 2021, $108,160 in FY 2022, and $112,486 in FY 2023, and so on. Since the amount of growth in available funding is forecasted to be less than the rate of inflation, less work can be done each year with available funding.

Table 12: Summary of Highway Fiscal Constraint Demonstration for the FY 2020 through FY 2045 Plan Period (Millions of Dollars) Amount Available $4,648.13

Amount Programmed $4,648.13

Net Balance $0

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Appendix D: Projects Evaluated for Conformity Attached are all the projects evaluated at the September 4, 2019, MITC-IAWG.

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FY 2045 Long Range Transportation Plan Proposed Capacity Project for IAWG Review

Year

2045

MDOT Job Number

n/a

MPO

GCMPC

County

Genesee

Responsible Agency

Project Name

Genesee County Road Grand Blanc Road Commissoin

Length

2.6

Limits

Job Type

Fenton Rd. to Grand Blanc Local City Limits

Project Description

Primary Work Type

Widen to 5 Lanes, including Reconstruct new bridge over I-75

Phase

CON

GPA Type

n/a

AC Year

n/a

Fund Type

EDC

Federal

$25,825,500

State

$0

Local

$6,456,375

Total Cost

$32,281,875

Comments

Capacity Project; Included as part of Genesee County's 2045 LRTP

Air Quality

Non-Exempt

Air Quality Comments

Fiscal Job Type Year

Job#

MPO

County Responsible Project Name Limits Agency

Length Primary Work Type

Project Description

Air Quality Air Quality comment

Phase Fed Estimated State Estimated Local Amount Amount Estimated Amount

exempt

PE

2021

Trunkline

208831

Rural

Lapeer MDOT

I-69 E

Lake George Rd to Newark Rd

1.887 Reconstruction

Reconstruction

2022

Local

208972

Rural

Lapeer Lapeer

E Oregon St

Oregon Street between Saginaw and bridge

0.19

Street improvement: new exempt asphalt driveway approaches, sub-base improvements, storm system including drain tile under the curb the length of the project, curb and gutter throughout.

2021

Trunkline

204355

Rural

Lapeer MDOT

M-53

Newark Road to Capac Road

1.746 Road Rehabilitation

Milling and Two Course HMA Overlay

Reconstruction

exempt

Total Estimated Amount

$1,891,656

$210,184

$0

CON

$211,800

$0

$363,200

CON

$1,098,258

$243,536

$0

Fund Source

Action Type Federal Amendment Type

$2,101,840 IM $575,000 STUL

$1,341,794 NH

Admin Modification

S/TIP Status

Phase Added

Pending

Phase Added

Pending

Approved