What is attainment? How Chicagoland may lose $90 million in federal funding annually


Transit and road improvement projects that increase efficiency and reduce emissions are at risk. Photo of Red Line and Dan Ryan traffic, looking north to the Chicago Loop. 

Chicago is currently a non-attainment area.

That means we don’t meet National Ambient Air Quality Standards (NAAQS) “for pollutants considered harmful to public health and the environment” (read more), standards which are regulated by the United States Environmental Protection Agency (EPA). Six pollutants are measured across the country (note 1).  We currently don’t attain standards for particle pollution, specifically Particulate Matter 2.5; they’re particles smaller than 2.5 micrometers and “referred to as ‘fine’ particles and are believed to pose the greatest health risks”. Additionally, we’re a maintenance area for the 8-hour ozone standard. It is this designation that puts a large portion of the region’s transportation funding risk.

The Chicago Metropolitan Agency for Planning (CMAP), the region’s official regional planning organization, reported last week that the EPA may remove our designation of “non attainment”, putting at risk about $90 million per year in federal grants from the Congestion Mitigation and Air Quality (CMAQ) program. This designation would be based on revised air quality standards (note 2) and 2008-2010 data, even though 2011 data has been gathered and certified by the Illinois EPA. Our attainment level would be lowered to maintenance for the 8-hour ozone standard.

CMAQ funds a lot of projects that we’ve written about: bike sharing, bike lanes, train stations, etc. (read all of our articles about the program). My three-year job at the Chicago Department of Transportation was paid for my CMAQ funding, as are many of the positions at the Bicycle Program. The region can still receive funding as a maintenance area, but at a reduced level.

The policy update on the CMAP website explains (A) why the new ozone standard is wrong:

An updated ozone standard of 75 parts per billion (ppb) promulgated in 2008 has been controversial and generated several lawsuits.  A scientific advisory panel, charged with reviewing health impact studies and recommending the level of the standard to U.S. EPA, later suggested a more stringent level of between 60 and 70 ppb.  Implementation of the standard has therefore been delayed until now. [See note 2 for more information]

(B) that the Chicago region (note 3) will likely again become non-attainment in a 2013 review, possibly restarting eligibility for 2015:

First of all, with exceedances in 2011 and an update of the standard scheduled for 2013, it is inevitable that the region will revert to a non-attainment status.  There is little to be gained by declaring attainment for a relatively short period of time.

and (C), that we breached the 2008 standards numerous times in 2011:

Complicating the issue is the fact that our region experienced numerous exceedances of the 2008 air quality standard in 2011.  If that year’s data is included in making the determination, then the region would not be in attainment of the 2008 standard and would continue to receive CMAQ funding.  The IEPA has already certified the 2011 monitoring data and forwarded it to U.S. EPA, requesting that it be considered when making their initial designation.  However, after replying to IEPA in a December 9 letter, U.S. EPA has now announced its preliminary designations that assert northeastern Illinois to be in attainment based on the 2008 standard.

The policy update notes that while the region may become an attainment area for the 8-hour ozone standard, it doesn’t note that we are a non-attainment area for PM2.5, as I explained in the beginning. I’m looking into this, specifically whether or not the EPA will also make the region an attainment or maintenance area for PM2.5 as well as ozone.


Pace buses can use the shoulder on the Stevenson, I-55, for specific segments, to bypass traffic going slower than 35 MPH. This project was funded in part by CMAQ. Photo by Ann Fisher. 


(1) List of measured pollutants

  • Carbon Monoxide
  • Lead
  • Nitrogen Dioxide
  • Ozone
  • Particle Pollution
  • Sulfur Dioxide

(2) From the New York Times, September 2, 2011:

The E.P.A., following the recommendation of its scientific advisers, had proposed lowering the so-called ozone standard of 75 parts per billion, set at the end of the Bush administration, to a stricter standard of 60 to 70 parts per billion. The change would have thrown hundreds of American counties out of compliance with the Clean Air Act and required a major enforcement effort by state and local officials, as well as new emissions controls at industries across the country.

Lisa P. Jackson, the E.P.A. administrator, has pushed hard for a tougher ozone standard, telling associates that it was one of the most important regulatory initiatives she would handle during her tenure. But she found herself on the losing end of a fight with top White House economic and political advisers, who were persuaded by industry arguments that the 2008 ozone rule was due to be reviewed in two years anyway and who were concerned about the impact on state, local and tribal governments that would bear much of the burden of compliance.”

(3) The Chicago Metropolitan Area includes:

  • Lake County Sector –  Lake County only
  • North and West Suburbs Sector – Parts of Cook, Du Page, and Mc Henry Counties north of I-290 (the Eisenhower Expressway) and outside of Chicago city limits.
  • Chicago Sector – All areas within the city limits of Chicago
  • South and West Suburbs Sector – Parts of Cook and DuPage Counties south of I-290 and outside of Chicago city limits
  • Will County/Joliet Sector – Will County only
  • Aurora-Elgin Sector – The eastern part of Kane County

5 thoughts on “What is attainment? How Chicagoland may lose $90 million in federal funding annually”

    1. Not just bike lanes, new CTA stations, bus priority lanes, hybrid buses, bike sharing, etc…

      That’s not what CMAP is saying. They are saying that

      1. the EPA is ignoring 2011 data that showed us having worse air quality than in 2010; and
      2. without this funding for projects that improve air quality (by sustaining modes that contribute less to air quality degradation than SOVs), then the area will go right back into non-attainment in a couple years. 

  1. Its complicated.  You aren’t a maintenance area until US EPA says you are in attainment with air quality standards and certifies you; the maintenance designation just means EPA wants to keep existing local/state clean air programs in locked in place to prevent backsliding into dirty air stauts again.  But the worry is that EPA could designate metro Chicago as ‘attainment’ with the brand new 2011 ozone standard and completely erase any other label of attainment, nonattainment or maintenance with the ‘old’ ozone standard set way back in 1997. i.e the old standard could just disappear, along with any labels attached to it.  Areas get CMAQ money if you are ozone nonattainment; you still get some money but less if you are ozone attainment maintenance – idea here is you need some money to prevent backsliding.  But if EPA erasese the old standard and says we meet the new ozone standards, then the logic is we don’t need $$ to clean the air more. 

    There will be an opportunity for the public to comment to EPA in a few weeks, and that will be the perfect time to point out that metro Chicago DIDN’T meet ozone smog health standards if you include data from the summer of 2011.  Once released I plan to put details up on how to comment at http://www.lungchicago.org/e-advocacy/

    Right now PM2.5 status doesn’t affect CMAQ funding.  Its only tied to ozone.  But that could change in future federal multi-year transportation funding bills, which are needed, but have not been finshed yet; they need to find the money to fund them.  That being said, the Chicago metro area will likely be moved to attainment maintenance sometime in the next 6 months or so.  The Illlinois EPA has applied to US EPA saying the air monitoring shows the standards are met for PM2.5.

    Another thing to keep in mind is that the Bush Administration approved inadequate PM2.5 standard in 2006 and an inadequate ozone standard in 2008, ignoring the EPA’s own medical experts who said tighter standards were needed to protect public health.  Unfortunately, Pres Obama just rubber stamped the bad ozone standard and kicked the can to 2013 for possibly setting a responsible and legally defensible ozone standard.  on the PM2.5 front, a newer tighter standard could be proposed as early as late 2012.

  2. This is so damn disheartening. I live in Chicago and rely on public transit. For years it’s nothing but cuts, cuts, and more cuts. It’s now every difficult to get most places, and highly time consuming. L trains that aren’t 24 hours? Most lines aren’t. Buses with sporadic schedules that stop at obscenely early hours? Everywhere. The federal gov’t seems more and more determined to make people poor and then punish us for being poor. Go ahead, make the cuts necessary to cope with the lack of funding and see just how easy it is for us poor people without cars to get jobs without reliable transit.

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