1­
1
DATE:
3/
24/
05
MEMORANDUM
SUBJECT:
Note
to
the
docket
related
to
a
replacement
document
for
Region
I's
Response
to
Comments
Document
for
docket
no.
OAR­
2003­
0061
FROM:
Larry
D.
Wallace,
Air
Quality
Strategies
and
Standards
Division,
Office
of
Air
Quality
Planning
and
Standards
TO:
U.
S.
EPA
Office
of
Air
Docket
Per
a
note
from
Geoffrey
Wilcox,
of
the
Office
of
General
Counsel
(
OGC),
I
request
that
the
Response
to
Comments
document
for
Region
I
that
is
currently
in
docket
"
OAR­
2003­
0061"
be
removed
and
replaced
with
a
revised
version
of
the
document.
As
stated
in
the
note
from
Mr.
Wilcox's,
dated
March
22,
2005,
the
revised
document
that
is
to
be
inserted
into
the
docket
was
submitted
on
December
16th,
2004,
prior
to
the
December
17th
signature
date
of
the
Federal
Register
notice
designating
PM2.5
areas.
The
revised
document
was
intended
to
replace
the
version
of
the
document
that
is
currently
in
the
docket
and
was
omitted
by
mistake.
In
the
interest
of
full
and
fair
disclosure,
we
request
that
the
revised
document
replace
the
current
version
in
the
docket
and
that
this
note
be
added
to
the
docket
along
with
the
document
so
that
the
public
may
be
advised
of
this
change.

.

1.
Responses
to
Comments
EPA
Region
1
(
Connecticut,
Maine,
Massachusetts,
New
Hampshire,
Rhode
Island
and
Vermont)
1­
2
Comment:
1011­
1
Region:
1
State:
CT
Area:
New
York­
N.
New
Jersey­
Long
Island,
CT­
NJ­
NY
Comment:
Commenter
requests
that
EPA
support
Governor
Rell's
recommendation
of
attainment
for
the
entire
state
of
Connecticut.
The
comment
letter
transmits
additional
information
as
requested
by
EPA.
These
comments
are
as
follows:

1.
Recently
acquired
monitoring
data
demonstrate
that
the
community
in
New
Haven
is
not
being
exposed
to
PM2.5
concentrations
above
the
NAAQS
levels.
Thus
the
city
of
New
Haven
should
be
designated
attainment
for
PM2.5
.

2.
Atmospheric
transport
and
dispersion
modeling
conducted
by
EPA
and
DEP
confirm
that
emissions
from
Connecticut
are
not
contributing
significantly
to
measured
PM2.5
nonattainment
in
New
York
City
and
northern
New
Jersey.
The
Clean
Air
Interstate
Rule
(
CAIR)
specifically
excludes
Connecticut
from
the
program
because
EPA
concluded
that
Connecticut's
emissions
do
not
significantly
contribute
to
the
PM2.5
nonattainment
measured
in
New
York
and
New
Jersey.

If
EPA
believes
the
data
do
not
support
an
attainment
designation,
the
commenter
requests
EPA
to
consider
designating
parts
of
southwest
Connecticut
as
unclassifiable
as
provided
under
Section
107(
d)(
1)(
A)(
iii).

EPA
Response:
Comment
1:
We
have
reviewed
information
provided
to
us
by
Connecticut
supporting
an
argument
that
data
from
the
Stiles
Street
PM2.5
monitor
in
New
Haven
County
is
not
representative
of
area­
wide
population
exposure
in
the
New
Haven
area,
and
that
this
monitor
should
be
considered
a
"
hot
spot."
We
have
concluded
that
Connecticut
presents
a
good
case
that
the
diesel
truck
traffic
on
the
on­
ramp
within
30
feet
of
the
Stiles
Street
monitor
is
contributing
an
added
2
to
4
µ
g/
m3,
which,
when
combined
with
regional
and
urban
levels
of
fine
particles,
is
enough
to
cause
the
monitor
to
violate
the
NAAQS.
Based
on
information
provided
to
us
by
Connecticut
and
our
own
review
of
all
available
data
and
information,
we
have
concluded
that
it
is
appropriate
to
consider
the
Stiles
Street
PM2.5
monitor
a
unique
hot
spot
monitor,
which
is
not
appropriate
for
comparison
with
the
annual
PM2.5
NAAQS
standard.
This
is
consistent
with
section
2.8.1.2.3
of
40
CFR
Part
58,
Appendix
D
which
reads:

"
The
health­
effects
data
base
that
served
as
the
basis
for
selecting
the
new
PM2.5
standards
relied
on
a
spatial
average
approach
that
reflects
average
community­
oriented
area­
wide
PM
exposure
levels.
Under
this
approach,
the
most
effective
way
to
reduce
total
population
risk
is
by
lowering
the
annual
distributions
of
ambient
24­
hour
PM2.5
concentrations,
as
opposed
to
controlling
peak
24­
hour
concentrations
on
individual
days.
The
annual
standard
selected
by
EPA
will
generally
be
the
controlling
standard
for
lowering
both
short­
and
long­
term
PM2.5
concentrations
on
an
area­
wide
basis
and
will
achieve
this
result.
In
order
to
be
consistent
with
this
rationale,
therefore,
PM2.5
data
collected
from
SLAMS
and
special
purpose
monitors
that
are
representative,
not
of
area­
wide
but
rather,
of
relatively
unique
population­
oriented
micro­
scale,
or
localized
hot
1­
3
spot,
or
unique
population­
oriented
middle­
scale
impact
sites
are
only
eligible
for
comparison
only
to
the
24­
hour
PM2.5
NAAQS.
However,
in
instances
where
certain
population­
oriented
micro­
or
middle­
scale
PM2.5
monitoring
sites
are
determined
by
the
EPA
Regional
Administrator
to
collectively
identify
a
larger
region
of
localized
high
ambient
PM2.5
concentrations,
data
from
these
population­
oriented
sites
would
be
eligible
for
comparison
to
the
annual
NAAQS."

Comment
2:
We
have
reviewed
information
provided
to
us
by
Connecticut
supporting
an
argument
that
Connecticut
should
be
separated
from
any
PM2.5
nonattainment
area
that
encompasses
the
violating
monitors
in
NYC
and
northern
New
Jersey,
and
that
the
entire
state
of
Connecticut
should
be
designated
in
attainment
with
the
PM2.5
NAAQS.
While
Connecticut
makes
some
good
arguments,
we
have
decided
to
include
New
Haven
and
Fairfield
Counties
in
the
New
York­
N.
New
Jersey­
Long
Island,
CT­
NJ­
NY
PM2.5
nonattainment
area.
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),
which
was
delineated
by
the
Office
of
Management
and
Budget
(
OMB)
on
June
6,
2003.
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.

Traffic
count
data
from
the
New
York
State
Department
of
Transportation
indicate
that
average
annual
daily
traffic
crossing
the
NY­
CT
border
in
both
directions
on
Route
1
was
10,017
vehicles
(
2001),
on
Interstate
95
was
121,214
vehicles
(
1998),
and
on
the
Hutchinson/
Merritt
Parkway
was
41,177
vehicles
(
2001).
Furthermore,
there
are
66,476
vehicles
(
2003)
entering
and
leaving
Connecticut
daily
via
Interstate
84
north
of
Westchester
County.
(
See
www.
dot.
state.
ny.
us/
tech_
serv/
high/
countfiles/
westchestertvbk.
pdf
and
www.
dot.
state.
ny.
us/
tech_
serv/
high/
countfiles/
putnamtvbk.
pdf.)

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.
Information
from
the
Federal
Highway
Administration
illustrates
that
Interstate
95
is
the
major
thoroughfare
for
truck
traffic
entering
and
exiting
Connecticut.
Moreover,
this
truck
traffic
is
expected
to
increase
significantly
over
the
next
20
years.
(
See
ops.
fhwa.
dot.
gov/
freight/
freight_
analysis/
state_
info/
connecticut/
profile_
ct.
htm).

This
large
volume
of
vehicular
traffic
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
the
above
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.
1­
4
Comment:
1013a­
7
Region:
1
State:
CT
Area:
New
York­
N.
New
Jersey­
Long
Island,
CT­
NJ­
NY
Comment:
The
entire
New
York­
Newark­
Bridgeport,
NY­
NJ­
CT­
PA
Combined
Statistical
Area,
including
Litchfield
County
must
be
designated
nonattainment.
EPA
recommended
the
exclusion
of
Litchfield
County
from
the
nonattainment
area
partially
due
to
a
lack
of
monitored
violations;
however,
there
is
no
PM2.5
monitor
in
the
county,
so
it
is
impossible
to
conclude
that
this
county
does
not
violate
the
standard.

EPA
Response:
The
boundaries
of
the
New
York­
Northern
New
Jersey­
Long
Island,
NY­
NJ­
CT­
PA
Consolidated
Metropolitan
Statistical
Area
(
CMSA),
which
was
delineated
by
OMB
in
1999,
includes
only
a
very
small
portion
of
Litchfield
County,
Connecticut
(
i.
e.,
only
the
towns
of
Bethlehem,
Bridgewater,
New
Milford,
Roxbury,
Thomaston,
Washington,
Watertown
and
Woodbury).
In
2003,
however,
OMB
did
include
Litchfield
County
in
the
New
York­
Newark­
Bridgeport,
NY­
NJ­
CT­
PA
Combined
Statistical
Area
(
CSA).

To
identify
candidate
counties
for
a
PM2.5
nonattainment
designation,
EPA
considered
nine
factors,
including
emissions,
air
quality
(
as
determined
by
PM2.5
monitors),
population
density,
traffic
and
commuting
patterns,
expected
growth,
meteorology,
geography/
topography,
jurisdictional
boundaries,
and
level
of
control
of
emission
sources.
Based
on
these
factors,
Litchfield
County
did
not
qualify
as
a
candidate
for
a
PM2.5
nonattainment
designation.
In
particular,
emissions
levels
from
sources
in
Litchfield
County
are
low
compared
to
other
counties
in
the
New
York­
Newark­
Bridgeport,
NY­
NJ­
CT­
PA
CSA.
Moreover,
although
Litchfield
County
has
no
PM2.5
monitors
with
3
years
of
complete
data,
there
are
nearby
monitors
in
the
adjacent
counties
of
Fairfield,
Hartford
and
New
Haven
that
meet
the
PM2.5
NAAQS
standards.

Furthermore,
EPA
and
CT
DEP
assessed
the
contribution
of
commuters
from
Litchfield
County
to
traffic
levels
in
the
New
York
portion
of
the
CSA
and
concluded
that
vehicle
emissions
from
Litchfield
County
do
not
contribute
significantly
to
violating
monitors
in
NYC
and
northern
New
Jersey.
Based
primarily
on
these
considerations,
EPA
concludes
that
Litchfield
County
does
not
violate
or
contribute
to
violations
of
the
PM2.5
NAAQS
standard.
1­
5
Comment:
1094­
1
Region:
1
State:
CT
Area:
New
York­
N.
New
Jersey­
Long
Island,
CT­
NJ­
NY
Comment:
Commenter
is
concerned
about
the
use
by
EPA
of
the
New
Haven
Stiles
Street
PM2.5
monitor
as
a
basis
for
designations
of
nonattainment
in
New
York
State.
NY
DEC
believes
that
the
Stiles
Street
monitor
is
a
microscale
monitor
that
is
unrepresentative
of
community
exposure
and,
therefore,
should
not
be
used
for
comparison
with
the
annual
NAAQS.

EPA
Response:
We
have
reviewed
information
provided
to
us
by
Connecticut
supporting
an
argument
that
data
from
the
Stiles
Street
PM2.5
monitor
in
New
Haven
County
is
not
representative
of
area­
wide
population
exposure
in
the
New
Haven
area,
and
that
this
monitor
should
be
considered
a
"
hot
spot."
We
have
concluded
that
Connecticut
presents
a
good
case
that
the
diesel
truck
traffic
on
the
on­
ramp
within
30
feet
of
the
Stiles
Street
monitor
is
contributing
an
added
2
to
4
µ
g/
m3,
which,
when
combined
with
regional
and
urban
levels
of
fine
particles,
is
enough
to
cause
the
monitor
to
violate
the
NAAQS.
Based
on
information
provided
to
us
by
Connecticut
and
our
own
review
of
all
available
data
and
information,
we
have
concluded
that,
consistent
with
section
2.8.1.2.3
of
40
CFR
Part
58,
Appendix
D,
it
is
not
appropriate
to
compare
the
data
from
the
Stiles
Street
PM2.5
monitor
to
the
annual
PM2.5
NAAQS
standard.
1­
6
Comment:
?
Region:
1
State:
CT
Area:
New
York­
N.
New
Jersey­
Long
Island,
CT­
NJ­
NY
(
Letter
from
CT
Fund
for
the
Environment)

Comment:
Commenter
supports
EPA's
preliminary
determination
that
New
Haven
and
Fairfield
Counties
should
be
included
in
the
New
York­
N.
New
Jersey­
Long
Island,
CTNJ
NY
PM2.5
nonattainment
area,
and
encourages
EPA
to
include
these
counties
in
the
nonattainment
area
in
the
agency's
final
designation
decisions.

EPA
Response:
We
have
reviewed
information
provided
to
us
by
Connecticut
supporting
an
argument
that
Connecticut
should
be
designated
in
attainment
with
the
PM2.5
NAAQS.
While
Connecticut
makes
some
good
arguments,
we
have
decided
to
include
New
Haven
and
Fairfield
Counties
in
the
New
York­
N.
New
Jersey­
Long
Island,
CT­
NJ­
NY
PM2.5
nonattainment
area.
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,
and
on
national
consistency
in
the
designation
process.

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),
which
was
delineated
by
the
Office
of
Management
and
Budget
(
OMB)
on
June
6,
2003.
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.

Traffic
count
data
from
the
New
York
State
Department
of
Transportation
indicate
that
average
annual
daily
traffic
crossing
the
NY­
CT
border
in
both
directions
on
Route
1
was
10,017
vehicles
(
2001),
on
Interstate
95
was
121,214
vehicles
(
1998),
and
on
the
Hutchinson/
Merritt
Parkway
was
41,177
vehicles
(
2001).
Furthermore,
there
are
66,476
vehicles
(
2003)
entering
and
leaving
Connecticut
daily
via
Interstate
84
north
of
Westchester
County.
(
See
www.
dot.
state.
ny.
us/
tech_
serv/
high/
countfiles/
westchestertvbk.
pdf
and
www.
dot.
state.
ny.
us/
tech_
serv/
high/
countfiles/
putnamtvbk.
pdf.)

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.
Information
from
the
Federal
Highway
Administration
illustrates
that
Interstate
95
is
the
major
thoroughfare
for
truck
traffic
entering
and
exiting
Connecticut.
Moreover,
this
truck
traffic
is
expected
to
increase
significantly
over
the
next
20
years.
(
See
ops.
fhwa.
dot.
gov/
freight/
freight_
analysis/
state_
info/
connecticut/
profile_
ct.
htm).

This
large
volume
of
vehicular
traffic
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.
1­
7
Based
on
the
above
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.
