Revised
Draft
­
June
29,
2004
June
29,
2004
Arthur
J.
Rocque,
Commissioner
Department
of
Environmental
Protection
79
Elm
Street
Hartford,
CT
06106
Dear
Commissioner
Rocque:

Today
we
sent
your
Governor
a
letter
responding
his
February
10,
2004
letter
with
Connecticut's
recommendations
on
air
quality
designations
for
the
PM2.5
standard.
In
that
letter,
we
noted
that
we
intended
to
modify
Connecticut's
recommendations
for
certain
portions
of
the
State.

Under
the
Clean
Air
Act
(
CAA),
EPA
is
required
to
promulgate
designations
for
new
or
revised
standards,
such
as
the
PM2.5
standard.
EPA
is
required
by
the
Omnibus
Bill
to
promulgate
PM2.5
designations
by
December
15,
2004.
It
is
our
goal,
however,
to
have
final
designations
promulgated
by
November
17,
2004.
These
designations
will
be
based
on
2001­
2003
monitoring
data.

The
CAA
defines
a
nonattainment
area
as
any
area
that
does
not
meet
(
or
that
contributes
to
ambient
air
quality
in
a
nearby
area
that
does
not
meet)
the
national
primary
or
secondary
ambient
air
quality
standard
for
the
pollutant.
EPA
guidance
indicates
that
an
entire
Consolidated
Metropolitan
Statistical
Area
(
C/
MSA)
or
the
Metropolitan
Statistical
Area
(
MSA)
is
the
presumptive
boundary
for
a
PM2.5
nonattainment
area
if
any
monitor
in
the
metropolitan
area
violates
the
annual
PM2.5
standard.
States
can
recommend
a
modified
area
that
is
larger
or
smaller
than
the
presumptive
boundaries
based
on
nine
factors
provided
in
the
guidance.

EPA
carefully
reviewed
Connecticut's
February
10,
2004
letter
and
the
information
submitted
to
support
Connecticut's
recommendations
for
areas
that
differed
from
the
presumptive
boundaries.
We
appreciate
the
effort
the
State
has
made
to
develop
this
supporting
information.
EPA
has
carefully
considered
Connecticut's
proposal
to
classify
the
violating
monitor
in
New
Haven
County
as
a
"
microscale"
site,
and
to
designate
the
entire
State
as
attainment.
Connecticut
also
offered
the
opinion
that
it
is
not
contributing
to
violations
in
New
York
or
New
Jersey
and,
therefore,
should
not
be
part
of
the
New
York
City
nonattainment
area.

Based
on
an
EPA
analysis
of
nine
factors
(
see
enclosure),
EPA
is
considering
designating
Fairfield
and
New
Haven
Counties
in
Connecticut
as
part
of
the
New
York
City
nonattainment
area.
Therefore,
consistent
with
section
107(
d)(
1)
of
the
CAA,
we
informed
your
Governor
that,
based
upon
the
information
available
to
EPA
at
this
stage
in
the
review
process,
EPA
intends
to
make
modifications
to
Connecticut's
recommended
designations
and
boundaries.
Before
doing
so,
however,
we
want
to
share
our
analysis
with
the
State
and
fully
consider
the
State's
comments.

We
recognize
that
the
Stiles
Street
monitor
is
adjacent
to
an
on­
ramp
to
Interstate
95,
which
carries
significant
truck
traffic.
However,
EPA
is
not
convinced
that
this
monitor
is
not
representative
of
the
area,
and
that
there
are
not
other
high­
traffic
areas
near
Interstates
95
or
91
with
elevated
PM2.5
levels.
In
addition,
it
is
difficult
for
EPA
to
conclude,
based
on
available
information,
that
these
two
counties,
which
are
part
of
the
New
York­
New
Jersey­
Connecticut
C/
MSA,
should
not
be
included
in
the
New
York
City
nonattainment
area.

We
recognize
that
Connecticut
considered
the
nine
factors
identified
in
EPA's
national
designation
guidance
when
developing
recommendations.
However,
EPA
believes
the
information
provided
to
date
is
not
sufficient
to
justify
the
conclusion
that
the
entire
State
of
Connecticut
should
be
designated
attainment
and
excluded
from
the
applicable
nonattainment
area.
As
we
informed
your
Governor,
we
invite
the
State
to
submit
more
information
by
September
1,
2004,
supporting
its
claim
that
the
violating
monitor
is
not
representative
of
a
larger
area,
and
that
Fairfield
and
New
Haven
counties
do
not
contribute
to
violations
in
the
New
York
metropolitan
area.

We
will
carefully
review
any
further
information
Connecticut
provides,
and
will
work
closely
with
you
in
reaching
a
decision
on
final
designations.
If
you
have
any
questions,
please
do
not
hesitate
to
call
me
or
David
Conroy,
Acting
Manager
of
the
Air
Programs
Branch,
at
617­
918­
1661.

Sincerely,

Robert
W.
Varney
Regional
Administrator
Enclosure
cc:
Anne
Gobin,
CT
DEP
