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Introduction

The Commonwealth of Massachusetts is classified as serious non-attainment for ozone, and is divided into two non-attainment areas. The Eastern Massachusetts Ozone Non-attainment Area includes Barnstable, Bristol, Dukes, Essex, Middlesex, Nantucket, Norfolk, Suffolk, and Worcester counties. Berkshire, Franklin, Hampden, and Hampshire counties comprise the Western Massachusetts Ozone Non-attainment Area. With these classifications, the 1990 Clean Air Act Amendments (CAAA) required the Commonwealth to reduce its emissions of volatile organic compounds (VOCs) and nitrogen oxides (NOx), the two major precursors to ozone formation to achieve attainment of the ozone standard.

In 2002, the cities of Lowell, Waltham, Worcester and Springfield were re-designated to attainment for carbon monoxide with EPA-approved limited maintenance plans. In April 1996, the communities of Boston, Cambridge, Chelsea, Everett, Malden, Medford, Quincy, Revere, and Somerville were classified as attainment for carbon monoxide (CO). Air quality conformity analysis must still be completed in these communities, as they have a carbon monoxide maintenance plan approved into the state implementation plan (SIP). The year 2010 carbon monoxide motor vehicle emission budget established for the Boston CO attainment area with a maintenance plan is 228.33 tons of carbon monoxide per winter day.

The CAAA also required Metropolitan Planning Organizations (MPOs) within non-attainment areas to perform conformity determinations prior to the approval of their Regional Transportation Plans (RTPs) and Transportation Improvement Programs (TIPs). Periodically, air quality analyses are conducted on all the RTPs, the purposes of which are to evaluate the RTPs’ air quality impacts on the SIP. Conformity determinations are then performed to ensure that all regionally significant projects are included in the RTPs and the TIPs, and that they meet the air quality goals of the SIP. The Federal Highway Administration (FHWA) – in consultation with the Environmental Protection Agency (EPA New England) and the Massachusetts Department of Environmental Protection (DEP) – confirm and approve these conformity determinations (more details and background of major conformity milestones in recent years are provided in the each MPO’s 2012 Regional Transportation Plan).

Previously, the Massachusetts Department of Transportation found the emission levels from the 2012 Regional Transportation Plans – as well as from the 2012-2015 TIPs – to be in conformance with the SIP. Each MPO had certified (and continues to certify) that all activities outlined in its RTP and its TIP:

  • will not cause or contribute to any new violation of any standard in any area;
  • will not increase the frequency or severity of any existing violation of any standard in any area;
  • will not delay the timely attainment of any standard or any required interim emission reductions or other milestones in any area.

Key elements of this FY 2013–2016 STIP related to air quality conformity are as follows:

  • This STIP is financially constrained, and all projects in the STIP come from the conforming 2012 Regional Transportation Plan of each MPO.
  • All regionally significant RTP projects for 2013 through 2016 (both Federal and Non-Federal Aid) are programmed in the STIP.
  • All regionally significant projects included in the STIP have been included in the air quality analysis for the conforming Plan. These projects are of the same design and concept as presented in the 2012 conforming RTPs (projects in the STIP come from the conforming Plans).
  • In the Eastern Massachusetts Ozone Non-Attainment Area, a new conformity analysis was performed because certain regionally significant transportation project(s) programmed in the 2013-2016 TIPs (and included in the transportation models) changed their projected completion timeframe by crossing one or more milestone years used (2016, 2020, 2025, 2035), compared to the mix and timelines of projects assumed for the previously performed and approved conformity analyses done in 2011.
  • Specifically, the new conformity analysis (for Eastern Mass.) continued to demonstrate that emissions levels for all build scenarios remain below established emission budgets for all pollutants and all milestone years, meeting the federal conformity criteria (see emission tables).
  • All other of the latest planning assumptions (for both Eastern and Western Mass.) relative to conformity analyses (latest emission rates, latest socio-economic projections, etc.) remain unchanged from the previously completed and approved conformity analyses on each 2012-2015 TIP.
  • In the Western Massachusetts Ozone Non-Attainment Area, all regionally significant transportation projects programmed in each regional 2013-2016 TIP (and included in the transportation models) do not substantially change their projected completion timeframe by crossing any milestone years used (2016, 2020, 2025, 2035) for the most recently performed and approved conformity analyses done in 2011.
  • Therefore, for Western Massachusetts, with no changes to any of the assumptions, project timelines, or model inputs, the same conformity analysis performed and approved for last year’s STIP can be used once again with the 2013-2016 STIP for the determination of air quality conformity.
  • Therefore, this STIP, as a product of the TIPs from all MPOs in both Massachusetts’ nonattainment areas, demonstrates air quality conformity.

Air Quality Conformity Analysis

On April 2, 2008, EPA found that the 2008 and 2009 motor vehicle emissions budgets (MVEBs) in the January 31, 2008 Massachusetts 8-hour ozone State Implementation Plan revision were adequate for transportation conformity purposes. The submittal included 2008 and 2009 MVEBs for the Boston-Lawrence-Worcester (Eastern Massachusetts) and Springfield (Western Massachusetts) 8-hour ozone non-attainment areas. Massachusetts submitted these budgets as part of the 8-hour ozone attainment demonstration and reasonable further progress plan for both non-attainment areas, and as a result of EPA’s adequacy finding, these budgets were required to be used for conformity determinations. EPA later determined (in 2010) that only the most recent MVEBs - 2009 - be used for future conformity determinations.

In 2011, air quality analyses were conducted on behalf of all the 2012-2015 Regional Transportation Improvement Programs (TIPs), the purposes of which were to evaluate the TIPs’ air quality impacts on the SIP. Conformity determinations were performed to ensure that all regionally significant projects were included in the TIPs. The Massachusetts Department of Transportation found the emission levels from the 2012-2015 TIPs to be in conformance with the SIP. On November 8, 2011, EPA confirmed that both the Eastern and Western Massachusetts Non-Attainment areas collectively demonstrated transportation conformity, with concurrence on the conformity analyses from Massachusetts DEP on 11/2/11. On November 30, 2011, FHWA and FTA determined that the TIPs were in conformity with the Clean Air Act and the EPA conformity regulations (40 CFR Part 51).

Conformity Test

The conformity test is to show consistency with the emissions budgets set forth in the SIP, and to contribute to reductions in CO non-attainment areas. In addition, the format of the conformity test is determined by evolving regulations. These regulations set specific requirements for different time periods depending on the timeframe of the Commonwealth’s SIP submittals to EPA. These periods are defined below:

Control Strategy Period:
Once a control strategy SIP has been submitted to EPA, EPA has to make a positive adequacy determination of the mobile source emission budget before such budget can be used for conformity purposes. The conformity test in this period is consistent with the mobile source emissions budget.
Maintenance Period:
is the period of time beginning when the Commonwealth submits and EPA approves a request for redesignation to an attainment area, and lasting for 20 years. The conformity test in this period is consistent with the mobile source emissions budget.

Horizon years for regional and state model analyses have been established following 40 CFR 93.106(a) of the Federal Conformity Regulations. The years for which the regional and state transportation models were run for ozone precursor emission estimates are shown below:

2010:
Milestone Year – This year is now being used by the statewide travel demand model as the new base year for calculation of emission reductions of VOCs and NOx.

2016:
Milestone Year and Analysis Year: This year is used to show conformity with the existing emission budgets for ozone precursors in Eastern and Western Massachusetts.

2020:
Analysis Year

2025:
Analysis Year

2035:
Horizon Year – last forecast year of the regional transportation plans

The milestone and analysis year transportation model networks are composed of projects proposed in this 2013-2016 STIP. Projects in these networks consist of all in-place “regionally significant” projects that can reasonably be expected to be completed by a given analysis/horizon year with consideration of available funding commitments. This project group would include, but not be limited to, regionally significant projects where at least one of the following steps has occurred within the past three years:

  • Comes from the first year of a previously conforming TIP,
  • Completed the NEPA process, or
  • Currently under construction or are undergoing right-of-way acquisition

Based on these definitions – for the following three regions – there are no regionally significant projects included in each referenced 2012 regional transportation plan for the corresponding 2013-2016 regional transportation improvement program, and there have been no changes in project design since the last conformity determination:

  • Martha’s Vineyard Commission1 (Eastern Massachusetts)
  • Nantucket Planning and Economic Development Commission1 (Eastern Massachusetts)
  • Franklin Regional Council of Governments1 (Western Massachusetts)

Changes in Project Design since the Last Conformity Determination Analyses

The Commonwealth requires that any change in project design from the previous conformity determination for the region is identified. Changes that have occurred since the last conformity determination in 2011 are as follows:

  • In the Eastern Massachusetts Ozone Non-Attainment Area only, a new conformity analysis was performed because certain regionally significant transportation project(s) programmed in the 2013-2016 TIPs (and included in the transportation models) changed their projected completion timeframe by crossing one or more milestone years used (2016, 2020, 2025, 2035), compared to the mix and timelines of projects assumed for the previously performed and approved conformity analyses done in 2011. Note: In terms of anticipated completion timelines, only a single project necessitated a change across milestone years. While the new analysis did result in a non-zero change, the emissions difference from previous results was insignificant out to multiple decimal places – hence the final numbers in Tables AQ-3 and AQ-4 appear identical to the last conformity results from 2011.

Latest Listings of Regionally Significant Projects used in the Conformity Analyses

A complete listing of future regionally significant projects for the entire Eastern (Table AQ-1) and Western (Table AQ-2) Massachusetts Ozone Non-Attainment Area follows:

Table AQ-1

Regionally Significant Projects Included in the Regional Transportation Models for the Eastern Massachusetts Ozone Non-Attainment Area
Analysis Year Community Description of Projects Under Construction – Boston Region
2016 Bedford, Burlington Middlesex Turnpike Improvements Phases 1and 2
2016 Bellingham Pulaski Boulevard
2016 Boston Fairmount Line Improvements, including new stations
2016 Boston East Boston Haul Road/Chelsea Truck Route (new grade separated roadway)
2016 Concord, Lincoln Route 2/Crosby's Corner (grade separation)
2016 Danvers Route 128/Route 35 and Route 62
2016 Hudson Route 85 (capacity improvements from Marlborough TL to Rt 62)
2016 Marshfield Route 139 Widening (to 4 lanes between School St. and Furnace St.)
2016 Quincy Quincy Center Concourse, Phase 2 (new roadway: Parking Way to Hancock St.)
2016 Randolph to Wellesley Route 128 Additional Lanes
2016 Somerville Assembly Square Orange Line Station
2016 Somerville Assembly Square Roadways (new and reconfigured)
2016 Weymouth, Hingham, Rockland South Weymouth Naval Air Station Access Improvements
2016 Regionwide 1000 Additional Park and Ride Spaces
Analysis Year Community Description of Recommended Plan Projects– Boston Region
2016 Beverly Beverly Station Commuter Rail Parking Garage
2016 Boston Conley Haul Road
2016 Hanover Route 53 Final Phase (widening to 4 lanes between Rt 3 and Rt 123)
2016 Salem Salem Station Commuter Rail Parking Garage Expansion
2016 Somerville, Cambridge, Medford Green Line Extension to Medford Hillside/Union Square
2016 Weymouth Route 18 Capacity Improvements
2020 Bedford, Burlington, Billerica Middlesex Turnpike Improvements Phase 3 – widening Plank St. to Manning Rd.
2020 Boston Sullivan Square/Rutherford Avenue Improvements
2020 Salem Bridge Street (widening to 4 lanes between Flint and Washington St.)
2020 Somerville, Medford Green Line Extension to Mystic Valley Parkway (Route 16)
2025 Canton I-95 (NB)/Dedham Street Ramp/Dedham Street Corridor (new ramp with widening on Dedham St. from I-95 to University Ave.)
2025 Canton I-95/I-93 Interchange (new direct connect ramps)
2025 Newton, Needham Needham Street/Highland Avenue (includes widening Charles River Bridge)
2025 Woburn Montvale Avenue (widening between Central St. to east of Washington St.)
2025 Woburn New Boston Street Bridge (reestablish connection over MBTA Lowell line)
2035 Braintree Braintree Split - I-93/Route 3 Interchange
2035 Framingham Route 126/135 Grade Separation
2035 Reading, Woburn, Stoneham I-93/I-95 Interchange (new direct connect ramps)
2035 Revere, Malden, Saugus Route 1 (widening from 4 to 6 lanes between Copeland Circle and Rt. 99)
2035 Wilmington Tri-Town Interchange (new “Lowell Junction” interchange on I-93 between Route 125 and Dascomb Rd.)
Analysis Year Community Project Description - Cape Cod Region
2020 Barnstable Yarmouth Rd. /Rt 28 (widening to 4 lanes) with Hyannis Access Improvements
2025 Bourne Route 6 Exit 1 WB on-ramp changes and interchange improvements
2035 Bourne Route 25 Access Ramp widening / Belmont Circle two-way travel
2035 Capewide Daily Passenger Rail Service: Hyannis to Buzzard’s Bay, Middleborough
2035 Mashpee Mashpee Rotary Ring Roads (connectors, Great Neck Rd, Routes 28 and151)
Analysis Year Community Project Description - Central Massachusetts Region
2016 Northborough Rt 20 Church to South, signal coordination in corridor
2016 Shrewsbury/Worcester Rt 9 Bridge over Lake Quinsigamond: widening, additional lane each direction
2016 Auburn Rt 12/20 to Auburn TL capacity improvements and raised median
2016 Worcester Lincoln/Highland/Pleasant Streets intersection corridor improvements, minor widening, select signal coordination
2016 Worcester Route 20 Widening to a consistent 4 lanes
2020 Charlton, Oxford Route 20 Widening to a consistent 4 lanes
2025 Westborough, Hopkinton I-90/I-495 and I-495/Rt 9 Interchange Improvements (CD or frontage roads)
2035 Worcester Route 122/122A Madison St/Chandler St. Kelley Square to Pleasant St: various improvements and signal coordination
2035 Worcester I-290 Hope Ave. (to full interchange and roundabout at Webster and Hope)
2035 Millbury, Sutton Route 146 Improvements: Route 122A to Central Turnpike
Analysis Year Community Project Description – Martha’s Vineyard Region
n/a n/a none
Analysis Year Community Project Description – Merrimack Valley Region
2016 Amesbury Route 110 from I-495 to I-95 (widen from 2 lanes to 4)
2020 Newburyport, Amesbury I-95 over Merrimack River (Whittier Bridge widening from 6 to 8 lanes)
2020 Methuen Route 110/113 (Methuen Rotary – new interchange ramps at I-93)
2025 Lawrence, North Andover Route 114 (widening from I-495 to Waverly Road)
2035 Andover Tri-Town Interchange (new “Lowell Junction” interchange on I-93 between Route 125 and Dascomb Rd.) and I-93 widening to 4 lanes in each direction from new interchange/current “lane drop” area to I-495.
Analysis Year Community Project Description – Montachusett Region
2016 Fitchburg/Westminster New Wachusett Commuter Rail Station
2016 Ayer to South Acton Fitchburg Line Commuter Rail Improvements (double track)
2020 Leominster Route 13 Hawes St. to Prospect St. (some widening, new signals, etc)
2025 Athol New Interchange on Route 2 at South Athol Road
Analysis Year Community Project Description – Nantucket Region
n/a n/a none
Analysis Year Community Project Description – Northern Middlesex Region
2016 Westford Route 110 Minot’s Corner to Nixon widen to 4 lanes
2020 Billerica Middlesex Turnpike Improvements Phase 3 – widening Plank St. to Manning Rd.
2035 Tewksbury Tri-Town Interchange (new “Lowell Junction” interchange on I-93 between Route 125 and Dascomb Rd.) and I-93 widening to 4 lanes in each direction from new interchange/current “lane drop” area to I-495.
2035 Westford I-495 at Boston Road (Exit 32) widening of on and off ramps
2035 Lowell, Tewksbury, Chelmsford, and Westford I-495 Additional travel lane each direction between Exits 32 and 35 and between Exits 37 and 40
2035 Lowell Wood Street, Rourke Bridge: new bridge, widening and corridor improvements
Analysis Year Community Project Description – Old Colony Region
2016 Abington Route 18 - Widening to 4 Lanes from Route 139 to Highland Rd.
2020 Brockton Route 123 - Widen from Route 24 to Angus Beaton Drive
2020 Bridgewater Route 24 - Add Northbound Slip Ramp from Route 104 WB to Route 24 NB Northbound
2020 Plymouth Route 3 - Add Northbound on-Ramp at Long Pond Road (Exit 5)
2020 Plymouth Long Pond Road Bridge widening (Exit 5)
2025 Brockton Main Street, Warren Avenue, Spring Street, West Elm Street, Belmont Street - Reestablish Two-Way Circulation
2025 West Bridgewater Route 106 - Widening from 2 to 4 Lanes between Route 24 and Route 28
2035 Plymouth Route 3 – Add NB Off-ramp to Plimouth Plantation Hwy (Exit 4)
2035 Plymouth Route 25 - Add New Interchange Before Exit 1 and connect to Bourne Road
2035 West Bridgewater Route 28, Route 106, Central Square Signal and intersection coordination
Analysis Year Community Project Description – Southeastern Massachusetts Region
2016 Fall River, Somerset New Brightman Street Bridge - capacity improvements to 4 lane divided facility
2016 Fall River Route 79/Davol Street (interchange improvements and new traffic circulation)
2016 Freetown Route 24 - New Interchange (Exit 8 ½)
2016 Mansfield Route 140 / I-495 New Southbound On-Ramp
2020 Dartmouth Route 6 (Faunce Corner Rd) / I-195 Interchange - Bridge Widening to 5 Lanes
2035 Taunton Route 24 / 140 - Interchange Reconstruction

The transportation air quality conformity analyses prepared for the 2013 – 2016 Regional Transportation Improvement Programs (and collectively, this State TIP) also serve to demonstrate transportation air quality conformity to the Regional Transportation Plans in Massachusetts. All regionally significant transportation projects in the FFY 2013 – 2016 transportation improvement programs are contained in the 2012 transportation plans (with any amendments). Furthermore, all regionally significant projects in the 2016 to 2035 timeframe of all the transportation plans are modeled in the FFY 2013 – 2016 Transportation Improvement Programs’ transportation air quality conformity analyses.

Table AQ-2

Regionally Significant Projects Included in the Regional Transportation Models for the Western Massachusetts Ozone Non-Attainment Area
Analysis Year Community Project Description – Pioneer Valley Region
2016 Chicopee Deady Bridge signal coordination: Broadway/Montgomery, Main, and Belcher Streets
2016 Hadley Route 9 widening Home Depot to Lowes.
2016 Holyoke, W.Springfield Route 5 signal coordination from Ashley Ave. to Main St.
2016 Springfield,Wilbraham Boston Rd. signal coordination Pasco Rd. to Stony Hill Rd.
2016 Westfield Route 10/202 Great River Bridge - two bridges acting as one-way pairs.
2016 West Springfield Improve the Union Street Railroad Underpass. Construct a truck bypass road.
2016 Through Region Additional “Vermonter” passenger rail service
2020 Chicopee/South Hadley Route 33 signal coordination and upgrades from Abbey St. to Fuller Rd.
2020 Hadley Route 9 widening Middle Street to Lowes.
2020 Ludlow Route 21 Center Street reconstruction and widening with center turn lane
2020 Northampton Damon Rd. widening, improvements from Rte 9 to King St.
2020 Through Region New Commuter Rail Service: Hartford, CT to Greenfield, MA
2025 Agawam Connector, Route 5 to Route 57, eliminate rotary.
2025 Holyoke Linden St. signal coordination and improvements at 5 intersections.
2025 Longmeadow Route 5 signal coordination, improvements Converse St to Springfield city line.
2025 Westfield Route 10/202 Elm Street, North Elm Street signal coordination.
2035 Agawam, Longmeadow, Springfield South End Bridge improvements, including related work on I-91 between Exits 1-3.
2035 Agawam, West Springfield Improvement to Route 5 access ramps for truck routing, route into CSX rail yard.
Analysis Year Community Project Description – Berkshire Region
2016 Great Barrington Main St .intersection improvements, signalization upgrades and add turning lanes
2020 Pittsfield Intersection widening, turning lane improvements First/Tyler & Tyler/Stoddard Ave
2025 Great Barrington Realign & widen State Rd., including new bridge to replace the current Brown Bridge
2025 Lanesboro/Cheshire Construct passing lanes on Route 8 between Mall Road and truck weighing station
2025 Pittsfield Safety and capacity improvements on East St. between Elm St. and Merrill Road
2035 Pittsfield Construct connector street from W. Housatonic St. to West St. near CSX yard
Analysis Year Community Project Description - Franklin Region
2016 Through Region Additional “Vermonter” passenger rail service
2020 Greenfield, Deerfield, Whately New Commuter Rail Service: Hartford, CT to Greenfield, MA

Regional Components

Specific information regarding the analysis methods, latest planning assumptions, and consultation procedures are all detailed in the 2012 RTPs. The emissions from the following MPOs have been combined to show conformity with the SIP for the Eastern Massachusetts Nonattainment Area:

  • Cape Cod MPO
  • Central Massachusetts MPO
  • Merrimack Valley MPO
  • Boston MPO
  • Montachusett Region MPO
  • Northern Middlesex MPO
  • Old Colony MPO
  • Southeastern Region MPO
  • Martha's Vineyard Commission1
  • Nantucket Planning and Economic Development Commission1

The emissions from the following MPOs have been combined to show conformity with the SIP for the Western Massachusetts Non-attainment Area:

  • Berkshire Region MPO
  • Franklin Regional Council of Governments1
  • Pioneer Valley MPO

Using the latest planning assumptions, MassDOT’s Office of Transportation Planning estimated the emissions for VOC and NOx from all MPOs through a combination of the statewide and selected regional travel demand models (and with assistance from MPO staff). The VOC mobile source emission budget for 2009 (and beyond) for the Eastern Massachusetts Non-attainment Area has been set at 63.50 tons per summer day (TPSD) and the 2009 (and beyond) mobile source emission budget for NOx is 174.96 TPSD (Tables AQ-3 and AQ-4). For the Western Massachusetts Non-attainment Area (Tables AQ-5 and AQ-6), the 2009 (and beyond) VOC mobile source emission budget has been set at 10.73 TPSD, while the 2009 (and beyond) mobile source emission budget for NOx is 27.73 TPSD. As shown in the tables, the results of the air quality analyses demonstrate that the VOC and NOx emissions from all action scenarios are less that the VOC and NOx emissions budgets for both non-attainment areas.

TABLE AQ-3

VOC Emissions Estimates for the Eastern Massachusetts Ozone Non-attainment Area
all emissions in tons per summer day
Year Eastern MA Action Emissions Budget Difference (Action – Budget)
2010 64.974 n/a n/a
2016 36.232 63.5 -27.268
2020 32.386 63.5 -31.114
2025 30.988 63.5 -32.512
2035 31.063 63.5 -32.437

TABLE AQ-4

NOx Emissions Estimates for the Eastern Massachusetts Ozone Non-attainment Area
all emissions in tons per summer day
Year Eastern MA Action Emissions Budget Difference (Action – Budget)
2010 234.85 n/a n/a
2016 66.219 174.96 -108.741
2020 45.188 174.96 -129.772
2025 36.521 174.96 -138.439
2035 29.038 174.96 -145.922

TABLE AQ-5

VOC Emissions Estimates for the Western Massachusetts Ozone Non-attainment Area
all emissions in tons per summer day
Year Western MA Action Emissions Budget Difference (Action – Budget)
2010 10.947 n/a n/a
2016 6.832 10.73 -3.898
2020 5.979 10.73 -4.751
2025 5.534 10.73 -5.196
2035 5.602 10.73 -5.128

TABLE AQ-6

NOx Emissions Estimates for the Western Massachusetts Ozone Non-attainment Area
all emissions in tons per summer day
Year Western MA Action Emissions Budget Difference (Action – Budget)
2010 27.736 n/a n/a
2016 11.751 27.73 -15.979
2020 7.732 27.73 -19.998
2025 5.774 27.73 -21.956
2035 5.018 27.73 -22.712

In summary, each Eastern Massachusetts MPO and each Western Massachusetts MPO has found that the emission levels from its FY 2013-2016 TIP, in combination with the emission levels from the other MPOs in its non-attainment area, demonstrate conformity with the SIP, the Clean Air Act, and the EPA conformity regulations (40 CFR part 51) as required.

All the regional TIPs are derived from regional transportation plans that meet the conformity requirements. The applicable MPO conformity determinations have been prepared in accordance with EPA’s and Massachusetts’ final conformity regulations. These conformity determinations show that the 2013-2016 Statewide TIP – as a product of all the regional TIPs – has been prepared following all the guidelines and requirements of these rules during this time period.

Therefore, the implementation of the FFY 2013-2016 Statewide Transportation Improvement Program is consistent with the air quality goals, and in conformity with, the Massachusetts State Implementation Plan.

1These regions do not contain any official urbanized areas, but are considered to be MPOs for planning purposes.
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