6­
1
6.0
NINE­
FACTOR
ANALYSES
OF
INDIVIDUAL
NONATTAINMENT
AREAS
Chapter
6
contains
the
rationale
for
EPA's
PM2.5
designations
sorted
by
EPA
Region.
The
first
section
under
each
Region
contains
the
9­
Factor
Analyses
for
any
nonattainment
areas
that
was
sent
in
the
120
day
letters
from
EPA
to
the
states
and
tribes.
These
letters,
sent
on
June
28
and
29,
2004
responded
to
the
states
and
tribes
recommendations
for
areas
meeting
and
not
meeting
the
PM2.5
NAAQS.
The
second
section
contains
justifications
for
any
modifications
made
to
the
intended
designations
found
in
the
120
day
letters.

6.1
Region
1
Nonattainment
Areas
6.1.1
EPA
9­
Factor
Analyses
for
Southern
New
England
for
the
Designation
of
PM2.5
Nonattainment
Areas
The
following
is
a
9­
factor
analysis
for
New
England
counties
that
are
candidates
for
nonattainment
status
for
the
PM2.5
air­
quality
standard.
EPA
guidance
establishes
the
metropolitan
area
(
i.
e.,
MSA
or
C/
MSA
where
one
exists)
as
the
presumptive
boundary
for
PM2.5
nonattainment
areas.
(
See
memo
from
Jeffrey
R.
Holmstead
to
EPA
Regional
Administrators,
April
1,
2003).
OMB
issued
revised
urban­
area
definitions
on
June
6,
2003.
Although
states
were
not
asked
to
use
the
2003
urban­
area
definitions
when
recommending
PM2.5
nonattainment
areas
to
EPA,
EPA
is
using
the
2003
definitions
in
its
review
of
state
recommendations.
Therefore,
this
9­
factor
analysis
considers
all
counties
in
New
England
that
are
in
the
2003
New
York­
Newark­
Bridgeport,
NY­
NJ­
CT
CSA,
and
any
counties
in
New
England
that
are
adjacent
to
this
CSA.
(
A
list
of
the
2003
metropolitan
area
definitions
is
available
at:
www.
census.
gov/
population/
www/
estimates/
metroarea.
html).

In
New
England,
the
New
York­
Newark­
Bridgeport,
NY­
NJ­
CT­
PA
CSA
counties
include
Fairfield,
New
Haven,
and
Litchfield
counties
in
CT.
Adjacent
counties
to
the
CSA
include
Middlesex
and
Hartford
counties
in
CT,
and
Berkshire
and
Hampden
counties
in
MA.
The
only
monitor
in
the
New
England
portion
of
this
CSA
that
violated
the
annual
PM2.5
standard
based
on
2001­
2003
data
is
located
in
New
Haven,
CT.
Additionally,
there
are
no
monitors
in
the
adjacent
counties
that
violated
the
annual
PM2.5
standard.
However,
the
absence
of
a
violating
monitor
does
not
automatically
disqualify
a
county
from
a
PM2.5
nonattainment
designation.

Connecticut
recommended
that
the
entire
state
be
designated
as
attainment
based
on
an
argument
that
the
violating
monitor
is
a
"
hot
spot"
(
letter
from
CT
DEP
to
EPA,
February
10,
2004).
As
an
alternative,
if
EPA
does
not
accept
the
"
hot
spot"
analysis,
CT
recommended
a
nonattainment
designation
for
a
limited
geographic
area,
such
as
the
City
of
New
Haven
or
New
Haven
County.
In
addition,
CT
recommended
that
all
CT
counties
should
be
excluded
from
the
nonattainment
area
associated
with
the
New
York­
Northern
New
Jersey­
Long
Island,
NY­
NJ­
CT­
PA
CMSA
based
on
an
argument
that
6­
2
Connecticut
does
not
significantly
contribute
to
PM2.5
violations
in
the
New
York
City
metropolitan
area.

The
Massachusetts
Department
of
Environmental
Protection
(
MA
DEP)
recommended
that
all
of
Massachusetts
be
designated
as
attainment/
unclassifiable
for
PM2.5
based
on
air
quality
data
measured
at
the
monitors
within
the
state
(
letter
from
MA
DEP
to
EPA,
February
13,
2004).
This
designation
is
appropriate
for
areas
where
monitors
have
insufficient
data,
but
where
available
data
support
attainment
of
standards.

Based
on
EPA's
9­
factor
analysis,
EPA
proposes
that
Fairfield
and
New
Haven
Counties
in
Connecticut
be
considered
for
a
designation
of
nonattainment
of
PM2.5
air­
quality
standard
as
part
of
the
New
York
City
nonattainment
area.

NY­
NJ­
CT­
PA
CMSA
Area
State
Recommended
Nonattainment
Counties
EPA
Proposed
Nonattainment
Counties
Connecticut
None
New
Haven
County
Fairfield
County
Massachusetts
None
None
The
following
is
a
brief
summary
of
the
9­
factor
analysis
for
the
New
England
portion
of
the
New
York­
N.
New
Jersey­
Long
Island,
NY­
NJ­
CT­
PA
Area.

Factor
1:
Emissions
For
this
factor,
EPA
looked
at
primary
PM2.5,
SO2,
NOx,
carbon,
and
crustal
PM2.5
emissions.
The
weighted
emissions
score
serves
as
an
indicator
of
the
local
PM2.5
contribution.
The
emissions
score
(
also
called
"
composite"
or
"
cumulative"
emissions
score)
was
derived
as
follows:

Emissions
score
=
[(
county
SO2
tons/
CSA
SO2
tons)
*
(%
sulfate
of
urban
excess
PM2.5)]
+
[(
county
NOx
tons/
CSA
NOx
tons)
*
(%
nitrate
of
urban
excess
PM2.5)]
+
[(
county
carbon
tons/
CSA
carbon
tons)
*
(%
carbon
of
urban
excess
PM2.5)]
+
[(
county
crustal
PM
tons/
CSA
crustal
PM
tons)
*
(%
crustal
of
urban
excess
PM2.5)]

For
the
NY­
NJ­
CT­
PA
CSA,
"
urban
excess"
was
estimated
using
data
from
speciation
monitors
in
Newark,
NJ
(
urban
site)
and
in
Brigantine
National
Wildlife
Refuge,
NJ
(
regional
site)
for
the
period
from
April
2002
to
March
2003.
For
the
Newark
speciation
monitor,
the
total
PM
mass
for
this
period
was
17.5
µ
g/
m3;
for
the
Brigantine
IMPROVE
monitor,
the
total
PM
mass
was
10.9
µ
g/
m3.
Therefore,
the
urban
excess
was
estimated
to
be
6.6
µ
g/
m3,
composed
of
6%
SO2,
25%
NOx,
67%
carbon,
and
3%
crustal
material.

The
table
below
shows
total
emissions
(
in
tons)
and
emissions
scores
for
counties
that
are
included
in
the
NY­
NJ­
CT­
PA
CSA
and
for
those
that
are
adjacent
to
the
CSA.
The
counties
that
are
in
the
2003­
defined
CSA
are
in
bold;
other
counties
are
adjacent
to
the
CSA
counties.
(
Data
source:
2001
NEI).
Following
this
table
is
a
histogram
showing
6­
3
total
2001
emissions
of
NOx
and
carbon,
the
major
"
local"
PM2.5
components
for
the
CSA
counties
and
adjacent
counties.

Emissions
scores
for
all
counties
in
the
NY­
NJ­
CT­
PA
CSA
add
to
100
(
see
"
Cumulative
Emissions
Score"
on
table).
Counties
adjacent
to
the
CSA
are
assigned
an
emissions
score
based
on
the
emissions
scores
of
counties
in
the
CSA
so
that
emissions
from
those
counties
can
be
compared
to
the
CSA
counties.
County
State
Recommended
Nonattainment
Design
Values
2001­
2003
(
µ
g/
m3)
Direct
PM2.5
(
tons)
SO2
(
tons)
NOx
(
tons)
Carbon
PM2.5
(
tons)
Crustal
PM2.5
(
tons)
Emissions
Score
Cumulative
Emissions
Score
Suffolk,
NY
No
12.3
9,834
45,379
42,938
5,894
3,455
10.8
10.8
Nassau,
NY
No
12.4
7,289
12,587
30,695
4,665
2,370
7.9
18.7
Queens,
NY
Yes
13.6
5,443
21,315
57,013
3,203
1,539
7.0
25.7
New
York,
NY
Yes
17.7
4,531
29,811
45,611
2,701
1,269
6.1
31.8
Orange,
NY
No
11.6
4,410
30,875
22,978
2,091
2,058
4.5
36.3
Kings,
NY
Yes
14.9
3,039
14,163
42,392
1,800
973
4.4
40.7
Fairfield,
CT
No
13.3
3,154
20,031
36,762
1,779
1,008
4.3
45.0
New
Haven,
CT
No1
16.7
3,170
17,771
31,345
1,903
1,009
4.2
49.2
Middlesex,
NJ
Yes
12.7
3,430
5,663
26,425
1,960
1,269
3.9
53.1
Westchester,
NY
No
12.5
3,229
9,680
20,815
1,923
1,154
3.7
56.8
Bergen,
NJ
Yes
13.8
2,691
7,945
27,835
1,451
1,726
3.6
60.4
Monmouth,
NJ
Yes
3,143
3,028
18,971
1,820
1,226
3.4
63.8
Essex,
NJ
Yes
14.5
2,435
8,114
27,325
1,466
808
3.2
67.0
Ocean,
NJ
No
11.7
3,291
1,500
13,754
1,802
1,404
3.1
70.1
Mercer,
NJ
Yes
14.0
2,950
16,426
27,098
1,113
1,608
3.0
73.1
Hudson,
NJ
Yes
14.8
2,529
22,745
25,572
1,004
1,241
2.9
76.0
Union,
NJ
Yes
15.7
2,092
5,393
21,149
1,263
688
2.7
78.7
Morris,
NJ
Yes
12.6
2,038
3,753
16,208
1,301
648
2.5
81.2
Dutchess,
NY
No
11.0
2,804
4,786
11,471
1,387
1,330
2.5
83.7
Bronx,
NY
Yes
15.8
1,460
6,723
20,299
849
503
2.1
85.8
Rockland,
NY
No
1,762
9,541
10,621
928
625
1.9
87.7
Somerset,
NJ
Yes
1,523
2,490
9,743
816
610
1.6
89.3
6­
4
Passaic,
NJ
Yes
13.3
994
4,349
13,645
658
260
1.5
92.3
Litchfield,
CT
No
1,574
934
5,062
852
670
1.4
93.7
Richmond,
NY
Yes
12.2
1,776
1,079
8,399
708
1,009
1.4
95.1
Hunterdon,
NJ
No
1,490
1,158
8,494
628
809
1.3
96.4
Sussex,
NJ
No
1,225
872
5,191
612
574
1.1
97.5
Warren,
NJ
No
13.5
1,204
975
6,358
600
530
1.1
98.6
Putnam,
NY
No
1,040
548
3,083
505
512
0.9
99.5
Pike,
PA
No
739
355
2,997
402
317
0.7
100.2
Hartford,
CT
No
13.1
3,145
4,326
29,590
1,947
1,058
3.9
Northampton,
PA
No
14.8
5,646
55,105
24,051
1,212
3,374
3.9
Bucks,
PA
Yes2
14.6
3,100
6,870
16,852
1,443
1,444
2.8
Burlington,
NJ
No
2,298
2,330
15,113
1,326
836
2.5
Hampden,
MA
No
13.5
1,965
16,077
19,050
994
781
2.4
Ulster,
NY
No
2,328
3,818
8,417
1,025
1,235
1.9
Middlesex,
CT
No
1,417
4,751
9,520
731
563
1.5
Berkshire,
MA
No
12.2
1,641
3,702
6,382
826
711
1.5
Monroe,
PA
No
1,758
1,367
6,222
881
811
1.5
Sullivan,
NY
No
1,200
612
2,875
625
544
1.0
Greene,
NY
No
936
3,836
7,511
375
503
0.9
Columbia,
NY
No
1,018
585
3,497
420
574
0.8
Delaware,
NY
No
996
879
2,705
496
475
0.8
Wayne,
PA
No
765
746
1,786
374
365
0.6
1.
Only
recommended
NA
under
scenario
that
EPA
disagrees
with
"
hotspot"
argument.

2.
Recommended
to
be
part
of
Philadelphia
nonattainment
area.

6­
5
6­
6
NYC
CMSA
­
NOx
and
Carbon
by
County
0
10,000
20,000
30,000
40,000
50,000
60,000
Suffol
k,
NY
N
assau,
N
Y
Queens,
NY
New
Y
or
k,
NY
Oran
ge,
NY
King
s,
NY
Fairfield,
CT
New
Haven,
CT
Mi
dd
lesex,
NJ
Westcheste
r,
NY
Ber
gen,
NJ
Mo
nmouth,
NJ
Essex,
NJ
Ocea
n,
NJ
Mercer,
NJ
Hudson,
NJ
Union,
NJ
Morris,
NJ
Dutche
ss,
NY
Bronx,
NY
Roc
kla
nd,
NY
Somerset,
NJ
Pa
ss
aic,
NJ
Lit
chfield,
CT
Ric
hm
ond,
NY
Hunterdon,
NJ
S
u
ssex,
NJ
Warr
e
n,
NJ
Putnam
,
NY
Pike,
PA
H
artford,
CT
Northam
p
ton,
PA
Bucks,
PA
N
ew
Lond
on
,
CT
Bu
rlington,
NJ
Hampden
,
MA
Uls
ter
,
N
Y
Middlesex,
CT
Ber
kshire,
MA
Monroe
,
PA
Sullivan
,
NY
Gree
ne,
NY
C
olumbia
,
NY
Delaware,
NY
Wayn
e,
PA
NOx
(
tons)

0
1,000
2,000
3,000
4,000
5,000
6,000
7,000
Carbon
(
tons)
NOx
Carbon
Counties
in
NYC
CMSA
Adjacent
Counties
CT
Counties
State
recommended
counties
EPA
developed
a
national
process
for
assessing
emissions
based
on
emissions
scores
to
identify
candidate
counties
for
a
PM2.5
nonattainment
designation.
This
process
flags
CSA
and
adjacent
counties
with
relatively
high
cumulative
emissions
scores.
For
the
NY­
NJ­
CT­
PA
CSA,
counties
with
cumulative
emissions
scores
of
 
80%
(
as
well
as
adjacent
counties
that
have
emissions
scores
that
are
 
the
emissions
score
of
the
80%
CSA
county)
were
considered
to
be
counties
with
relatively
high
emissions.
The
80%
CSA
cutoff
counties
are
Morris,
NJ
and
Dutchess,
NY
(
cum
emissions
scores
=
81.2
and
83.7,
respectively;
emissions
scores
=
2.5).

This
process
applied
to
the
New
England
counties
identifies
Fairfield,
New
Haven,
and
Hartford
Counties
in
Connecticut
as
candidates
for
a
PM2.5
nonattainment
designation
(
i.
e.,
counties
with
emissions
scores
 
2.5),
and,
therefore,
requiring
further
analysis.

Litchfield
and
Middlesex
Counties
in
Connecticut,
and
Hampden
and
Berkshire
Counties
in
Massachusetts
are
dropped
from
further
analysis
because
(
1)
none
of
these
counties
contain
violating
PM2.5
monitors,
(
2)
none
were
recommended
for
a
nonattainment
designation
by
the
state,
and
(
3)
all
have
emissions
scores
 
2.5.

Factor
2:
Air
quality
PM2.5
Design
Values
(
in
µ
g/
m3)
for
the
three­
year
period
from
2001
to
2003
are
given
in
the
table
above
for
all
counties
in
and
adjacent
to
the
NY­
NJ­
CT­
PA
CSA.
In
New
England,
only
one
county,
New
Haven,
shows
a
violation
of
the
annual
PM2.5
standard.
However,
this
factor
alone
is
not
sufficient
to
eliminate
the
other
New
England
counties
as
candidates
for
nonattainment
status.
6­
7
Factors
3
(
Population
Density
and
Urbanization)
and
4
(
Traffic
and
commuting
patterns)

The
table
below
shows
population,
VMT
and
commuting
data
for
counties
that
are
included
in
the
NY­
NJ­
CT­
PA
CSA
and
for
those
that
are
adjacent
to
the
CSA.
The
ranking
of
the
counties
is
based
on
the
number
of
people
commuting
to
other
counties
from
highest
to
lowest.
The
counties
that
are
in
the
2003­
defined
CSA
are
in
bold;
other
counties
are
adjacent
to
the
CSA
counties.

County
State
Recommended
NA
2002
Population
2002
Pop
Density
(
pop/
sq
mi)
2002
VMT
(
1000
mi)
Commuting
to
Other
Metro
Counties
(%)
Commuting
to
Other
Metro
Counties
(#)
Queens,
NY
Yes
2,237,815
20,530
10,441
60
557,383
Kings,
NY
Yes
2,488,194
35,045
12,313
51
463,551
Nassau,
NY
No
1,344,892
4,686
6,875
41
256,588
Bronx,
NY
Yes
1,354,068
32,240
6,440
59
243,970
Bergen,
NJ
Yes
895,091
3,825
6,732
42
178,468
Suffolk,
NY
No
1,458,655
1,601
7,414
26
175,244
Middlesex,
NJ
Yes
775,549
2,494
5,794
43
157,177
Westchester,
NY
No
937,279
2,165
4,964
36
154,322
Essex,
NJ
Yes
798,301
6,336
6,356
46
150,496
Hudson,
NJ
Yes
611,439
13,009
4,518
53
141,386
Union,
NJ
Yes
530,763
5,153
4,034
52
123,905
Passaic,
NJ
Yes
496,646
2,685
3,568
54
113,164
Monmouth,
NJ
Yes
629,836
1,334
5,146
39
112,634
New
York
NY
Yes
1,546,856
55,245
7,961
15
111,765
Richmond,
NY
Yes
457,383
7,752
2,030
54
104,042
Morris,
NJ
Yes
478,730
1,021
3,939
41
98,930
Somerset,
NJ
Yes
309,886
1,016
2,209
55
82,696
Fairfield,
CT
No
896,202
1,432
7,889
19
78,180
Ocean,
NJ
No
537,065
844
3,641
37
76,620
New
Haven,
CT
No1
835,657
1,379
6,989
19
72,261
6­
8
Rockland,
NJ
No
291,835
1,677
1,413
45
59,116
Orange,
NY
No
356,773
437
3,628
32
48,241
Sussex,
NJ
No
148,680
285
1,323
58
42,375
Mercer,
NJ
Yes
359,463
1,591
3,869
24
38,571
Hartford,
CT
No
867,332
1,178
8,105
9
35,469
Bucks,
PA
Yes2
610,440
1,004
3,830
11
34,474
Putnam,
NY
No
98,257
424
781
71
34,078
Dutchess,
NJ
No
287,752
359
2,905
27
34,054
Hunterdon,
NJ
No
125,795
293
1,893
54
33,861
Burlington,
NJ
No
437,871
544
3,748
14
29,263
Litchfield,
CT
No
186,515
203
1,170
30
27,825
Warren,
NJ
No
107,537
300
1,473
52
26,228
Ulster,
NY
No
179,986
160
1,850
30
24,275
Northampton,
PA
No
273,324
731
2,132
15
18,557
Middlesex,
CT
No
159,679
433
1,560
18
14,700
Monroe,
PA
No
148,839
245
1,434
22
13,830
Pike,
PA
No
50,095
92
722
46
8,820
Sullivan,
NY
No
74,273
77
683
27
7,999
Columbia,
NY
No
63,532
100
754
12
3,532
Greene,
NY
No
48,538
75
643
7
1,487
Berkshire,
MA
No
133,462
143
1,850
2
1,291
Wayne,
PA
No
48,889
67
334
6
1,269
Hampden,
MA
No
459,116
742
3,708
1
1,016
Delaware,
NY
No
47,302
33
508
4
846
1.
Only
recommended
NA
under
scenario
that
EPA
disagrees
with
"
hotspot"
argument.
2.
Recommended
to
be
part
of
Philadelphia
nonattainment
area.

The
three
candidate
counties
in
CT
(
i.
e.
Fairfield,
New
Haven,
and
Hartford
Counties)
have
moderately
sized
populations
and
population
densities
relative
to
other
counties
in
the
NY­
NJ­
CT­
PA
CSA
and
adjacent
counties.

Although
there
is
a
much
smaller
number
of
commuters
in
the
three
Connecticut
counties
than
in
some
NY
counties
in
the
NY­
NJ­
CT­
PA
CSA,
the
numbers
of
commuters
in
6­
9
Fairfield
and
New
Haven
Counties
are
moderately
high,
each
with
more
than
twice
as
many
commuters
as
Hartford
County.

CT
DEP
used
2000
Census
Bureau
data
on
work­
trip
origins
and
destinations
to
assess
Connecticut
contribution
(
i.
e.,
from
Fairfield,
New
Haven,
and
Litchfield
counties)
to
traffic
levels
in
the
New
York
portion
of
the
CMSA.
CT
DEP
concluded
that
the
Connecticut
contribution
is
0.7%
overall,
with
0.1%
in
the
NJ
portion
and
1.0%
in
the
New
York
portion
of
the
CMSA.
However,
heavy­
duty
truck
traffic
from
Connecticut
to
both
New
York
and
New
Jersey
may
not
have
been
adequately
taken
into
account
in
this
analysis.

All
three
counties
score
relatively
high
for
VMT
when
compared
to
the
rest
of
the
CSA
and
adjacent
counties.

Factor
5:
Expected
growth
The
table
below
shows
population,
population
growth,
VMT
and
VMT
growth
for
counties
that
are
included
in
the
NY­
NJ­
CT­
PA
CSA.
The
ranking
of
the
counties
is
based
on
the
VMT
growth
in
thousand
of
miles
between
1996
and
2002
from
highest
to
lowest.

County
2002
Population
Population
Growth
(
90­
00)
%
growth
(
90­
00)
2002
VMT
(
1000
mi)
VMT
Growth
(
1000
mi)
(
96­
02)
VMT
%
chng
(
96­
02)

Kings,
NY
2,488,194
164,662
7
12,313
1,011
39
Westchester,
NY
937,279
48,593
6
4,964
755
13
Monmouth,
NJ
629,836
62,177
11
5,146
739
17
Middlesex,
NJ
775,549
78,382
12
5,794
721
14
New
Haven,
CT
835,657
19,789
2
6,989
714
11
Essex,
NJ
798,301
15,427
2
6,356
713
13
Fairfield,
CT
896,202
54,922
7
7,889
656
9
Suffolk,
NY
1,458,655
97,505
7
7,414
595
9
Warren,
NJ
107,537
10,830
12
1,473
578
65
Bergen,
NJ
895,091
58,738
7
6,732
540
12
Mercer,
NJ
359,463
24,937
8
3,869
526
16
Hudson,
NJ
611,439
55,876
10
4,518
506
13
Hunterdon,
NJ
125,795
14,213
13
1,893
481
34
6­
10
Passaic,
NJ
496,646
35,989
8
3,568
466
15
Ocean,
NJ
537,065
77,713
18
3,641
464
15
Union,
NJ
530,763
28,722
6
4,034
452
13
Dutchess,
NY
287,752
20,688
8
2,905
408
12
Pike,
PA
50,095
18,336
66
722
406
128
Somerset,
NJ
309,886
57,211
24
2,209
336
18
Litchfield,
CT
186,515
8,101
5
1,170
232
25
Orange,
NY
356,773
33,720
11
3,628
213
2
Queens,
NY
2,237,815
277,781
14
10,441
180
2
New
York,
NY
1,546,856
49,659
3
7,961
137
2
Putnam,
NY
98,257
11,804
14
781
134
21
Nassau,
NY
1,344,892
47,196
4
6,875
117
2
Bronx,
NY
1,354,068
128,861
11
6,440
111
2
Morris,
NJ
478,730
48,859
12
3,939
97
3
Sussex,
NJ
148,680
13,223
10
1,323
74
6
Richmond,
NY
457,383
64,751
17
2,030
35
2
Rockland,
NY
291,835
21,278
8
1,413
24
2
Based
on
analysis
of
this
factor,
Fairfield
and
New
Haven
counties
had
low
population
growth
between
1990
and
2000.
However,
they
both
had
a
sizable
increase
in
vehicle
miles
traveled
from
1996­
2002,
an
increase
above
most
other
counties
in
the
NY­
NJ­
CTPA
CSA.

Factor
6:
Meteorology
County
Prevailing
Wind
Direction
%

NW
SW
SE
NE
Fairfield,
CT
34
30
12
24
New
Haven,
CT
34
30
13
24
Hartford,
CT
35
29
13
23
6­
11
Individual
24­
hour
FRM
data
(
2001­
2003)
paired
with
daily
resultant
WS/
WD
(
includes
event­
flagged
data)
"
Bubble
Rose"
of
Wind
and
PM2.5
data
for
New
York
Urban
Area
DV
=
15.8
PM
Station:
Bronx,
New
York
MET
Station:
Central
Park,
NY
PM
Station:
Roosevelt
School
Park
Ave,
Bridgeport,
CT
MET
Station:
Sikorsky
Memorial
Airport,
Bridgeport
DV
=
13.3
6­
12
DV
=
16.7
PM
Station:
Stiles
Street,
New
Haven,
CT
MET
Station:
Sikorsky
Memorial
Airport,
Bridgeport
PM
Station:
715
State
Street,
New
Haven,
CT
MET
Station:
Sikorsky
Memorial
Airport,
Bridgeport
DV
=
14.1
6­
13
Connecticut
did
studies
to
assess
whether
emissions
from
Connecticut
sources
are
contributing
significantly
to
violations
in
other
parts
of
the
New
York
City
metropolitan
area.
These
studies
included
use
of
the
ISCST3
(
Industrial
Source
Complex
Simple
Terrain)
area
source
model
and
HYSPLIT4
(
HYbrid
Single­
Particle
Lagrangian
Integrated
Trajectory)
model.

Results
from
the
ISCST3
model
show
that
primary
PM2.5
emissions
have
low
impact
on
New
York
City
and
Hudson
Co,
NJ.
The
model
estimates
the
Connecticut
source
contribution
to
New
York
City
to
be
between
1.7
and
2.3%.
For
receptors
in
the
cities
of
Bridgeport
and
New
Haven;
Connecticut
sources
contributed
>
50%
primary
PM2.5
totals.

For
the
HYSPLIT4
model,
Connecticut
obtained
maximum
daily
PM2.5
concentrations
from
January
1999
to
September
2003
from
a
monitor
in
New
York
City,
rank­
ordered
them
from
high
to
low,
and
recorded
dates
of
the
top
and
bottom
10
percentiles.
They
then
ran
back­
trajectory
winds
once
a
day
for
each
of
those
days
at
three
height
levels
(
10m,
500m,
and
1000m).
Results
of
this
modeling
show
that
air
mass
during
highest
PM2.5
days
originated
from
and
passed
through
locations
in
a
sector
from
SSW
and
SW
through
W
and
WNW
from
New
York
City,
and
not
from
directions
that
pass
over
Connecticut.

Although
the
meteorological
data
make
a
strong
case
that
CT
is
not
frequently
a
significant
contributor
to
elevated
PM2.5
levels
in
the
New
York
City
urban
area,
EPA
notes
that
PM2.5
is
a
year­
round
standard
with
some
contributions
during
all
seasons
from
many
directions,
as
shown
in
the
"
bubble
roses"
above
for
monitors
in
the
Bronx,
Fairfield
and
New
Haven
counties.
These
roses
show
that,
although
not
a
frequent
occurrence,
some
component
of
elevated
PM2.5
measured
at
the
monitor
in
the
Bronx
does
originate
from
a
northeastern
direction
(
i.
e.,
direction
of
CT).
The
roses
also
show
the
need
to
consider
the
contribution
of
NJ
and
NY
to
the
violating
monitor
in
Connecticut.
This
is
also
supported
by
modeling
done
for
the
CAIR
(
seeEPA's
January
30,
2004
(
69
FR
4566)
notice
of
proposed
rulemaking
(
NPR)),
which
showed
that
both
NJ
and
NY
"
contribute
significantly"
to
New
Haven
County.

Based
on
analysis
of
this
factor,
EPA
is
not
convinced
that
Fairfield
and
New
Haven
counties
should
be
excluded
from
the
New
York
City
nonattainment
area.
However,
Hartford
County,
which
is
an
adjacent
county
to
the
NY­
NJ­
CT­
PA
CSA,
is
further
removed
geographically
and
meteorologically
from
the
NYC
area.
Based
on
this
fact,
plus
the
absence
of
a
violating
PM2.5
monitor
in
Hartford
County,
EPA
concludes
that
Hartford
County
can
drop
from
further
consideration
as
a
nonattainment
county.

Factor
7:
Geography/
topography
The
New
England
portion
of
the
NY­
NJ­
CT­
PA
CSA
and
adjacent
counties
do
not
have
any
geographical
or
topographical
boundaries
limiting
its
airshed.

This
factor
did
not
play
a
significant
role
in
the
decision
making
process.
6­
14
Factor
8:
Jurisdictional
boundaries
From
a
New
England
perspective,
the
major
jurisdictional
boundary
in
the
NY­
NJ­
CTPA
CSA
(
and
adjacent
counties)
is
the
state
line
between
New
York
and
Connecticut.
Violating
counties
in
the
NY­
NJ­
CT­
PA
CSA
include
New
York
County
(
Manhattan),
Bronx
County,
and
Union
County,
NJ.
The
State
of
Connecticut
has
no
jurisdictional
say
in
the
air
quality
regulations
and
policies
developed
by
either
New
York
or
New
Jersey
to
address
PM2.5
emissions
in
the
areas
with
the
violating
monitors.
In
addition,
State
of
Connecticut
has
very
limited
influence
in
the
transportation
policies
developed
to
address
traffic
and
vehicle
miles
traveled
in
the
New
York
City
metropolitan
area.

On
the
other
hand,
areas
designated
as
8­
hour
ozone
nonattainment
areas
are
also
important
boundaries
for
state
air­
quality
planning.
Fairfield,
New
Haven,
and
Middlesex
counties
in
Connecticut
were
included
in
the
ozone
nonattainment
area
associated
with
the
New
York
City
metropolitan
area.
Other
counties
included
in
this
9­
factor
analysis
are
also
designated
as
8­
hour
ozone
nonattainment
areas,
but
are
not
associated
with
the
New
York
City
area.
A
goal
in
designating
PM2.5
nonattainment
areas
is
to
achieve
a
degree
of
consistency
with
ozone
nonattainment
areas.
Comparison
of
ozone
areas
with
potential
PM2.5
nonattainment
areas,
therefore,
gives
added
weight
to
designation
of
Fairfield
and
New
Haven
counties,
but
not
to
the
other
CSA
and
adjacent
counties
considered
herein.

Factor
9:
Level
of
control
of
emission
sources
The
emissions
used
to
prepare
the
composite
emissions
scores
are
for
2001.
These
emission
estimates
include
any
control
strategies
implemented
by
the
states
in
the
CSA
prior
to
2001
that
may
influence
emissions
of
primary
PM2.5,
SO2,
NOx,
carbon,
and
crustal
PM2.5
emissions.

In
CT,
however,
there
may
be
some
emission
reductions
of
SO2
subsequent
to
2001
that
are
not
accounted
for
pursuant
to
the
SO2
rule
Connecticut
adopted
pursuant
to
state
legislation
(
see
http://
dep.
state.
ct.
us/
air2/
regs/
mainregs/
sec19a.
pdf).
This
rule
basically
requires
compliance
with
0.55
lbs/
mm
BTU
by
January
1,
2002
and
0.33
lbs/
mm
BTU
by
January
1,
2003.
To
date,
this
rule
has
resulted
in
a
significant
reduction
is
statewide
SO2
emissions.
However,
in
the
New
York
City
metropolitan
area,
only
a
small
percentage
of
the
urban
increment
is
from
SO2
(
i.
e.,
about
6%).
Thus,
incorporating
the
additional
SO2
emission
reductions
from
Connecticut
sources
in
the
composite
emissions
score
analysis
for
the
CSA
is
not
expected
to
change
the
outcome
significantly.
Furthermore,
the
Connecticut
SO2
rule
is
currently
not
part
of
the
federally­
approved
State
Implementation
Plan,
and
thus
is
not
federally
enforceable.
Thus,
this
factor
analysis
generally
considered
the
emissions
controls
currently
in
place.
6­
15
6.1.2
Justifications
for
Changes
to
EPA
Recommendations
Contained
in
the
June
29,
2004
Letters
to
States
Connecticut
EPA
does
not
intend
to
modify
its
recommendations
concerning
nonattainment
designations
and
boundaries
that
were
listed
in
the
June
29,
2004
letter
to
Connecticut.

New
Haven
and
Fairfield
EPA
is
recommending
that
New
Haven
and
Fairfield
Counties
be
designated
nonattainment.
This
decision
is
based
on
consideration
of
nine
factors,
including
emissions,
air
quality,
population
density,
traffic
and
commuting
patterns,
expected
growth,
meteorology,
geography/
topography,
jurisdictional
boundaries,
and
level
of
control
of
emission
sources.
EPA
compared
emissions,
population,
and
traffic
levels
in
all
counties
within
and
adjacent
to
the
New
York­
Newark­
Bridgeport,
NY­
NJ­
CT­
PA
Combined
Statistical
Area
(
CSA).
New
Haven
and
Fairfield
Counties
had
similar,
or
sometimes
greater
levels
for
all
these
factors
than
other
New
York
counties
(
e.
g.,
Westchester,
Nassau,
Suffolk,
and
Orange)
and
New
Jersey
counties
(
e.
g.,
Middlesex,
Bergen,
and
Monmouth)
for
which
EPA
is
designating
nonattainment.
In
addition,
EPA
notes
that
Fairfield
and
New
Haven
Counties
are
a
conduit
for
a
large
percentage
of
the
truck
traffic
that
flows
throughout
New
England.
As
such,
this
presents
an
opportunity
for
Connecticut
to
work
with
New
York
and
New
Jersey
to
identify
measures
to
help
reduce
diesel
emissions
and,
thus,
help
monitors
in
the
New
York
urban
area
to
meet
PM2.5
standards.
Based
on
these
considerations,
EPA
is
including
New
Haven
and
Fairfield
Counties
in
the
New
York­
N.
New
Jersey­
Long
Island,
CT­
NJ­
NY
PM2.5
nonattainment
area.
