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3.4 Air 

3.4.1 Introduction 

General NEPA significance criteria (as listed in 40 CFR 1508.27) identify impacts and their 

significance caused by emissions of criteria air pollutants. The federal Clean Air Act, which 

was last amended in 1990, requires the USEPA to set National Ambient Air Quality Standards 

(NAAQS) for criteria pollutants. The significance of potential air quality impacts of the 

Proposed Action includes conformance determinations with the NAAQS as applicable under 

Section 309 of the federal Clean Air Act. These ambient air quality standards are presented in 

this section along with discussions on climate, ambient air quality, emission sources on nation 

lands, regulatory compliance, and a mobile source analysis. 

3.4.2 Climate 

The climate of Oneida and Madison Counties, the location of the Proposed Action, is typical 

of the Great Lakes Plain of western New York State. The waters of Lakes Erie and Ontario 

warm slowly in the spring, the effect of which is to reduce the warming of the atmosphere 

over adjacent land areas. In the fall season, the lake waters cool more slowly than the land 

areas and thus serve as a heat source (National Oceanographic and Atmospheric 

Administration, 1982). As cold air moves across the water in Lakes Erie and Ontario, the air 

is warmed in the lower layers, picks up moisture, and reaches the land in an unstable 

condition. Precipitation in the form of snow is released as the air stream moves inland over 

the gradually sloping terrain. Snow produced in part from air masses moving across Lakes 

Erie and Ontario is an important and central aspect of New York State’s climate. Heavy snow 

squalls frequently occur, generating from one to two feet of snow and occasionally four feet or 

more. In the heavy Snow Belt near Lakes Erie and Ontario, monthly snowfall amounts in 

excess of 24 inches are experienced in most winters and accumulations of more than 50 inches 

within two consecutive months are not uncommon (National Oceanographic and Atmospheric 

Administration, 1982). In general, winters are usually cold and are sometimes severe. 

There are several climatic elements that have an impact on air quality. These elements include 

winds, temperature, precipitation, and visibility. These four elements are discussed in detail 

below. 

The prevailing wind is generally from the west in New York State. A southwest component 

becomes evident in winds during the warmer months, while a northwest component is 

characteristic of the colder half of the year. Occasionally, well-developed storm systems 

moving across the continent or along the Atlantic Coast are accompanied by very strong 

winds (National Oceanographic and Atmospheric Administration, 1982). 

There is significant variability in the average seasonal temperatures in Oneida and Madison 

Counties. Table 3.4-1 presents the maximum and minimum average normal temperatures that 

are representative of Oneida County on a seasonal basis; temperature ranges for Madison 
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County, which is adjacent to Oneida County, are in a similar range. The temperature data 

presented in this table were taken at the Utica meteorological station located in Oneida 

County, New York; a meteorological station is a location where meteorological observations 

such as surface, upper air, and climatological observations are recorded. These normal 

temperatures were based on five decades of climate data, from 1950 to 2002. During the 

winter months of December through February, the minimum average normal temperature is 

16.3 degrees Fahrenheit (o

 F). Temperatures drop below 0o F on an average of approximately 

ten times each winter in Oneida County. During the summer months of June through August, 

the maximum average normal temperature is 78.2o

 F. Typically, this region experiences only a 

few days of 90o

 F or higher each summer. 

Table 3.4-1 

Average Temperature Data for Oneida County

Winter 

(December-February) 

(

o

 F) 

Spring 

(March-May) 

(

o

 F) 

Summer 

(June-August) 

(

o

 F) 

Fall 

(SeptemberNovember) 

(

o

 F) 

Average Maximum 

Seasonal Temperature 31.2 54.2 78.2 57.6 

Average Minimum 

Seasonal Temperature 16.3 35.5 57.9 40.8 

Source: New York State Climatologist, 2005 

Precipitation data for Oneida County is also collected at the Utica meteorological station. The 

annual normal precipitation for Oneida County is approximately 45.3 inches. The average 

normal monthly total precipitation is 3.54 inches during the winter months, 3.67 inches 

during the spring months, 3.83 inches during the summer months, and 4.04 inches during the 

fall months. Based on this data, there is not a high degree of seasonal variability in the 

distribution of precipitation in Oneida County. 

Visibility is a measure of the opacity of the atmosphere, which is a measure of the distance 

that can be seen clearly at any given time. Visibility conditions in Oneida and Madison 

Counties are generally good. The climate of central New York State features a lot of cloudy 

weather during the months of November, December, and January. From June through 

September, however, approximately 60 to 70 percent of the possible sunshine hours are 

received in Oneida and Madison Counties. The occurrence of heavy, dense fog is variable 

over New York State. The influence of Lakes Erie and Ontario in the Great Lakes Plain and 

the northern valleys contribute to the formation of fog, with occurrences averaging about 10 

to 20 days annually. 

3.4.3 Ambient Air Quality Standards and Criteria 

The Proposed Action is the transfer of Nation lands into trust with the BIA. Once these lands 

are transferred into trust, they would not be subject to New York State, local and municipal 

zoning and land use laws and regulations. However, federal air quality laws and regulations 

would apply to all lands accepted into trust for the Nation. 

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The Clean Air Act is the primary federal legislation controlling air quality standards. Within 

the New York State tribal communities, including the Oneida Nation, the Clean Air Act 

program is administered by the USEPA. Federal regulations also require that individual states 

have plans, known as State Implementation Plans (SIPs) in place which provide for the 

implementation, maintenance, and enforcement of the ambient air quality standards 

promulgated under the Clean Air Act. The State of New York’s regulatory scheme for air 

quality consists of the Clean Air Act and its implementing regulations, the federallyenforceable SIP and New York State’s own air quality laws and regulations. 

As required by the federal Clean Air Act and its amendments, the USEPA has established 

primary and secondary NAAQS for six air pollutants, which are called criteria pollutants. 

These criteria pollutants include carbon monoxide (CO), sulfur dioxide (SO2), nitrogen 

dioxide (NO2), ozone (O3), lead (Pb), and particulates (PM10 and PM2.5, particulate matter with 

aerodynamic diameters less than or equal to 10 micrometers (μm) and 2.5 μm, respectively). 

Nitrogen oxides (NOx) are of principal concern because of their role as precursors in the 

formation of ozone. Ozone is formed when volatile organic compounds (VOCs) and NOx 

undergo slow photochemical reactions in the presence of sunlight. 

As identified above, primary and secondary standards were developed for the NAAQS. 

Primary standards set limits to protect public health including the health of sensitive 

populations such as asthmatics, children, and the elderly. The primary standards represent 

levels at which there are no known significant effects on human health. Secondary standards 

are intended to protect public welfare including protection against visibility impairment and 

damage to animals, crops, vegetation, and buildings. 

New York State has adopted these primary standards as the New York State Ambient Air 

Quality Standards (NYSAAQS). In addition, New York State regulates ambient air 

concentrations of hydrogen sulfide (H2S), beryllium (Be), fluorides, and total suspended 

particulates (TSP). The NAAQS and NYSAAQS for each pollutant and the averaging time 

period utilized to obtain these values are presented in Table 3.4-2. The NYSAAQS are 

prescribed a numerical contaminant level that will not be exceeded in a specified area of New 

York State. Under 6 NYCRR Part 257, the parts of contaminant per million (ppm) of air by 

volume for SO2, CO, O3, Non-Methane Hydrocarbons, and NO2 corresponds to the NAAQS 

in micrograms of contaminant per cubic meter (μg/m3

) of air at a temperature of 25 degrees 

Celsius and a pressure of 760 millimeters of mercury. 

For non-criteria pollutants such as air toxics, there are no established regulatory standards. 

However, New York State seeks to regulate the ambient levels of air toxics under 6 NYCRR 

Part 212. The NYSDEC publishes maximum allowable guideline concentrations for these 

compounds; these one-hour and annual guideline concentrations are called Short-Term 

Guideline Concentrations and Annual Guideline Concentrations, respectively. The 

methodology for assessing the impact due to air toxic emissions is found in Air Guide 1: 
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Guidelines for the Control of Toxic Air Contaminants (New York State Department of 

Environmental Conservation, 1997). While not yet a promulgated regulation, Air Guide 1 is 

utilized to evaluate sources of air contaminants for permitting purposes. 
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Table 3.4-2 

National and New York State Ambient Air Quality Standards 

NAAQS NYSAAQS 

Primary Standard Secondary Standard 

Pollutant1 Averaging 

Period 

Conc. Units Statistic2 Conc. Units3 Statistic5 Conc. Units Statistic

12 

consecutive 

months 

0.03 ppm A.M. 80 μg/m3 A.M. 

24-hour 0.14 ppm Max. 365 μg/m3 Max. 

Sulfur Dioxide 

3-hour 0.50 ppm Max. 1300 μg/m3 Max. 

8-hour 9 ppm Max. 10,000 μg/m3 Max. 10,000 μg/m3 Max. 

Carbon Monoxide 

1-hour 35 ppm Max. 40,000 μg/m3 Max. 40,000 μg/m3 Max. 

1-hour 0.12 ppm Max. 235 μg/m3 Max. 235 μg/m3 Max. 

Ozone4

8-hour 0.08 ppm Max. 157 μg/m3 Max. 157 μg/m3 Max. 

Hydrocarbons 

(non-methane) 

3-hour 

(6-9 am) 0.24 ppm Max.

Nitrogen Dioxide 

12 

consecutive 

months 

0.05 ppm Max. 100 μg/m3 A.M 100 μg/m3 A.M. 

Lead 

3 

consecutive 

months 

1.5 μg/m3 Max. 

12 

consecutive 

months 

Fine Particulate 15 μg/m3 A.M. 15 μg/m3 A.M. 

Matter (PM2.5) 

24-hour 65 μg/m3 Max. 65 μg/m3 Max. 

12 

consecutive 

months 

Inhalable 50 μg/m3 A.M. 50 μg/m3 A.M. 

Particulates (PM10) 

24-hour 150 μg/m3 Max. 150 μg/m3 Max. 

12 

consecutive 

months Total Suspended 75 μg/m3 G.M. 

Particulates (TSP) 

24-hours 250 μg/m3 Max. 

Notes: 1 New York State also has standards for beryllium, fluorides, hydrogen sulfide, and settleable particulates (dustfall). 

 Ambient monitoring for these pollutants is not currently conducted. 

 2 All maximum values are concentrations not to be exceeded more than once per calendar year. (Federal Ozone Standard 

 not to be exceeded more than three days in three calendar years). 3

 Gaseous concentrations for Federal standards are corrected to a reference temperature of 25°C and to a reference 

 pressure of 760 millimeters of mercury. 

4 Former NYS Standard for ozone of 0.08 ppm was not officially revised via regulatory process to coincide with the 

 Federal standard of 0.12 PPM which is currently being applied by NYS to determine compliance status. 5

 A.M. is arithmetic mean, Max. is maximum, and G.M. is geometric mean. 

Source: New York State Department of Environmental Conservation, 2005 
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3.4.4 Ambient Air Quality 

The fundamental mechanism by which the USEPA and the NYSDEC track compliance with 

the ambient air quality standards is by monitoring and designating areas as either in 

attainment or non-attainment for a particular pollutant. This designation is assigned to 

describe the air quality in a given area for any of the seven criteria pollutants. Other 

pollutants, such as Be, H2S, fluorides and TSP, although regulated by the state, are not 

currently monitored and therefore are not considered for the determination of an area’s 

attainment status. For each of the monitored pollutants, areas that meet primary or secondary 

NAAQS are considered to be in attainment. Areas that do not meet or that contribute to 

ambient air quality in a nearby area that does not meet the primary or secondary NAAQS for 

a pollutant is designated as non-attainment. Oneida and Madison Counties, which are located 

in the Central Air Quality Control Region (AQCR) are currently in attainment for all of the 

NAAQS with the exception of O3 (United States Environmental Protection Agency, 2005). 

New York and other northeastern states are designated as part of the Northeast Ozone 

Transport Region (OTR); an OTR is defined by the U.S. Congress as a non-attainment area 

for ozone precursors. As a result, the Central AQCR is also designated as non-attainment for 

ozone. 

The NYSDEC operates over 80 air quality monitoring stations located throughout New York 

State to measure ambient levels of criteria and other regulated pollutants. Each of these air 

quality monitoring stations takes measurements of one or more regulated air pollutants. 

There are several air quality monitoring stations located within the Central AQCR from which 

ambient concentration data was obtained for this EIS including Nick’s Lake in Herkimer 

County, Utica in Oneida County, and Camp Georgetown in Madison County (Figure 3.4-1); 

data for CO and NO2 was obtained from air quality monitoring stations located in Buffalo 

and Syracuse because these stations were located the closest to Oneida and Madison Counties 

that measures these pollutants. The last three years (2003 – 2005) of available monitoring 

data was obtained for each of the six air quality monitoring stations. Table 3.4-3 presents a 

summary of the ambient air concentrations for each of the monitored pollutants. A 

comparison of the ambient concentrations of SO2, CO, NO2, PM10, PM2.5, and O3 in this table 

with the corresponding NAAQS and NYSAAQS indicates that there were no violations of any 

federal or New York State standards during the four-year monitoring period. 
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Table 3.4-3 

Summary of Selected Ambient Air Quality Monitoring Data1

Pollutant Monitoring 

Station NYSAAQS NAAQS 2003 2004 2005 

3-hour 0.50 ppm 0.0112 ppm 0.0143 ppm 0.0115 

ppm 0.0108 ppm 

24-hour 0.14 ppm 0.0084 ppm 0.0061 ppm 0.0064 

ppm 0.0063 ppm SO2

Annual 

Nick’s Lake 

0.03 ppm 0.001 ppm 0.001 ppm 0.0009 

ppm 0.0009 ppm 

3-hour 0.50 ppm 0.019 ppm 0.020 ppm 0.020 ppm 0.024 ppm 

24-hour 0.14 ppm 0.013 ppm 0.013 ppm 0.011 ppm 0.012 ppm SO2

Annual 

Camp 

Georgetown 

0.03 ppm 0.002 ppm 0.002 ppm 0.002 ppm 0.002 ppm 

NO2 Annual Buffalo 0.05 ppm 0.020 ppm 0.020 ppm 0.018 ppm 0.019 ppm 

1-hour 35 ppm 3.4 ppm 3.2 ppm 3.0 ppm 2.8 ppm CO 

8-hour Syracuse 9 ppm 2.1 ppm 1.7 ppm 1.4 ppm 1.9 ppm 

24-hour NA 54 μg/m3 32 μg/m3 40 μg/m3 NA 

PM10 Annual Nick’s Lake 

NA 12 μg/m3 11 μg/m3 13 μg/m3 NA 

24-hour NA 40.1 μg/m3 30.8 μg/m3 40.6 

μg/m3 38 μg/m3

PM2.5 Annual 

Utica 

NA 12.2 μg/m3 11.5 μg/m3 11.2 

μg/m3 11.4 μg/m3

1-hour 0.12 ppm 0.094 ppm 0.093 ppm 0.075 ppm 0.078 ppm 

O3 8-hour 

Nick’s Lake 

0.08 ppm 0.079 ppm 0.075 ppm 0.064 ppm 0.068 ppm 

1-hour 0.12 ppm 0.095 ppm 0.103 ppm 0.080 ppm 0.081 ppm 

O3 8-hour 

Camp 

Georgetown 0.08 ppm 0.085 ppm 0.080 ppm 0.067 ppm 0.074 ppm 

Notes: 1Maximum concentrations over the years 2003-2005 are reported for annual averages; maximum second 

highest concentrations over the years 2003-2005 are reported for all other averaging periods, except for 8-hour O3

where the 4th highest maximum concentration is reported. 

Source: New York State Department of Environmental Conservation, Division of Air Resources, 2003, 2004, and 2005 

New York State Air Quality Reports Ambient Air Monitoring System. 

3.4.5 Emission Sources on Nation Lands 

Group 1 Lands 

Group 1 lands are comprised of 3,428 acres proposed for conveyance into trust. These Group 

1 lands contain the Nation’s gaming and resort properties, which are identified in Section 

2.2.1.2 Existing Use of Alternative A Lands Entering Trust. The Turning Stone Resort & 

Casino, which is located on Group 1 lands, is the Nation’s largest air emission source. The 

Turning Stone Resort & Casino operates two natural gas-fired boilers that are each 20.4 

million (MM) British Thermal Units (BTU) per hour (hr) in size and six diesel-fired emergency 

generators that range in size from approximately two MMBtu/hr to 15 MMBtu/hr. The 

recently constructed co-generation electric station at the Turning Stone Resort & Casino 

facility operates the following sources of combustion:

• One natural gas-fired turbine generator with a heat recovery steam generator that is 

59.86 MMBtu/hr in size; 
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• One natural gas-fired package boiler that is 33.48 MMBtu/hr in size;

• One natural gas/distillate oil-fired package boiler that is 33.48 MMBtu/hr in size; and 

• One diesel-fired emergency generator that is 3.62 MMBtu/hr in size. 

The three natural gas-fired boilers and one gas/distillate oil-fired boiler produce steam/hot 

water at the Turning Stone Resort & Casino. The new natural gas-fired electricity generating 

turbine also produces steam. The seven emergency generators, ranging from approximately 

two MMBtu/hr to 15 MMBtu/hr in size, produce power during periods of electricity outages; 

each emergency generator is limited to operate less than 1,000 hours in a year due to permit 

restrictions, which are discussed in Section 3.4.6 Regulatory Compliance. These combustion 

sources (boilers, gas turbines, and emergency generators) emit criteria pollutants, VOCs and 

air toxics. 

Mobile sources can also contribute to air pollution. Mobile sources include both on-road 

vehicles such as cars, trucks, and buses and off-road equipment such as boats, airplanes, and 

agricultural and construction equipment. Emissions of NOx, VOCs and CO from motor 

vehicles have the potential to impact local air quality. An analysis of the contribution of 

mobile source emissions at the Turning Stone Resort & Casino is discussed in Section 3.4.7 

Mobile Source Analysis. 

Refueling emissions or evaporative emissions can emanate from motor vehicle fuel tank(s) 

during refueling operations. The USEPA has estimated that vehicle refueling emissions 

account for as much as two percent of the overall VOC emissions in urban areas. Spillage 

emissions result when fuel is spilled during the refueling process. Some or all of the spilled 

fuel can subsequently vaporize, adding hydrocarbon compounds to the atmosphere. 

Other potential sources of air emissions are generated from golf course operations. The 

Nation owns three 18-hole golf courses, which are the Atunyote, Kaluhyat, and Shenendoah 

Golf Courses. The Kaluhyat and Shenendoah Golf Courses are located in the Town of Verona 

while the Atunyote Golf Course is located in the Town of Vernon. The Nation also owns two 

nine-hole golf courses (Pleasant Knolls and Sandstone Hollow Golf Courses) located in the 

Town of Verona. Air emissions generated from the daily operation and maintenance activities 

associated with these golf courses were not accounted for since these emissions are considered 

minimal in comparison to the contribution of air emissions to local and regional air quality 

which were considered from the Turning Stone Resort & Casino operations. 

The smallest percentage of Nation lands that are categorized as being utilized for agricultural 

purposes are located in Group 1. Some of these agricultural Group 1 lands are utilized to 

grow crops, the Nation’s traditional crops (Three Sisters - white corn, beans, and squash), and 

some land is vacant. Professional products such as herbicides, insecticides, and fungicides are 

commonly used in commercial agriculture. Air emissions could be generated from the 

agricultural equipment used to apply these professional products and from the volatilization of 
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utilizing these professional products. However, the Nation’s land is less than 1% of the total 

land area of Oneida and Madison counties, therefore the air emissions associated with these 

agricultural activities would be considered minimal and these air emissions were not 

considered for further analysis. 

Group 2 Lands 

Group 2 lands are comprised of 6,475 acres proposed for conveyance into trust. These Group 

2 lands contain the Nation’s non-gaming properties, which are identified in Section 2.2.1.2 

Existing Use of Alternative A Lands Entering Trust. Air emissions are generated from the 

operation of agricultural properties and marinas; other Group 2 land uses do not contribute to 

or do not include significant sources of air emissions. The generation of air emissions from 

these agricultural properties and marinas is discussed below. 

Some of the Group 2 lands that are categorized as agricultural are being utilized to grow 

crops, for livestock operations, and some are vacant. As identified under the discussion for 

Group 1 lands, professional products such as herbicides, insecticides, and fungicides are 

commonly used in commercial agriculture. Overall, air emissions associated with the 

utilization of these products are expected to be low. Primary sources of odors, gases, and dust 

from production agriculture could include livestock operations (poultry and pig shelters, open 

cattle feedlots), manure storage facilities; and land application of manure. 

The Nation owns three marina facilities located on Oneida Lake. During marina operations, 

emissions of criteria air pollutants emissions can be generated from motorboats powered by 

diesel or gasoline fuel. The contribution of air emissions from these marina motorboats to 

local and regional air quality is considered insignificant since these boats normally use small 

engines and operate over short travel distances with limited hours per day, as compared to 

cars. Therefore, these emissions were not considered for further analysis. 

Group 3 Lands 

Group 3 lands are comprised of 7,467 acres proposed for conveyance into trust. These Group 

3 lands contain the Nation’s non-gaming other properties, which are identified in Section 

2.2.1.2 Existing Use of Alternative A Lands Entering Trust. Air emissions are generated from 

agricultural operations. Some of the Group 3 lands that are categorized as agricultural are 

being utilized for pasture, to grow crops, and for livestock operations. As identified under the 

discussion for Group 1 lands, professional products such as herbicides, insecticides, and 

fungicides are commonly used in commercial agriculture. Overall, air emissions associated 

with the utilization of these products are expected to be low. As identified under the 

discussion for Group 2 lands, livestock operations generate odors, gases, and dust. 

3.4.6 Regulatory Compliance 

The Clean Air Act provided the USEPA with the authority to issue a Part 71 permit for the 

Nation under 40 CFR Part 71.4. This permit was issued to ensure compliance with all 

applicable federal regulations. Currently, the Turning Stone Resort & Casino operates two 
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natural gas-fired boilers and six diesel-fired emergency generators at its facility and has 

recently constructed a new co-generation electric station consisting of a natural gas-fired 

turbine generator, two boilers (one natural gas-fired and the other natural gas/distillate oilfired) and a diesel-fired emergency generator. Prior to the construction of the co-generation 

electric station, the Turning Stone Resort & Casino was an existing non-major facility for 

NOx with a potential to emit of approximately 90 tons per year. With the construction of the 

co-generation electric station, the Turning Stone Resort & Casino added 60 tons per year to 

its NOx emission potential and, therefore, qualified as a major source; a designation that 

required the Turning Stone Resort & Casino to obtain a major source operating permit. 

Accordingly, the Nation applied for an operating permit from USEPA Region 2 under Title V 

of the Clean Air Act. USEPA Region 2 issued the Title V air permit pursuant to 40 CFR Part 

71 to the Turning Stone Resort & Casino (Permit Number: ONEIDA001) on February 22, 

2006. The Title V Permit includes the one turbine generator, four boilers, and seven 

emergency generators at the Turning Stone Resort & Casino. A summary of these emission 

sources and their corresponding emissions is presented in Table 3.4-4. 

Table 3.4-4 

Total Stationary Source Emissions from the Turning Stone Resort & Casino 

Source NOx CO PM10 SO2 VOC 

(2) 20.4 MMBtu/hr Boilers 17.52 14.72 1.33 0.11 0.96 

(2) 33.48 MMBtu/hr Boilers 32.99 31.97 4.99 75.67 6.75 

(7) Emergency Diesel Generators 81.73 20.78 3.28 11.19 3.25 

(1) Turbine Generator 21.46 21.46 12.88 1.04 3.37 

Total 153.71 88.93 22.47 88.00 14.33 

All lands accepted into trust will be subject to the provisions of Title 40 CFR Part 60 New 

Source Performance Standards (NSPS). A summary of the applicable requirements listed in 

the permit for each of the combustion units is provided below. The new natural gas-fired 

turbine generator is subject to the monitoring, record-keeping and reporting provisions of 40 

CFR Part 60 Subpart GG – Standards of Performance for Stationary Gas Turbines. 40 CFR 

Part 60 Subpart GG requires monitoring of the nitrogen content and sulfur content of the fuel 

being fired in this turbine. The permit also requires NOx emissions testing every five years. 

The three natural gas-fired and one natural gas/distillate oil-fired boiler are subject to 40 CFR 

Part 60 Subpart Dc – Standards of Performance for Small Industrial – Commercial – 

Institutional Steam Generating Units. 40 CFR Part 60 Subpart Dc requires that fuel use be 

monitored and recorded. An opacity limit is required when a boiler is firing distillate fuel oil. 

The provisions of the Air Pollution Control Title V Permit to Operate requires the Nation to 

monitor and record the number of hours each emergency generator at the Turning Stone 

Resort & Casino is operated. In general, fuel use is measured and recorded and emissions are 
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estimated by multiplying fuel use amount with its heat content and appropriate emission 

factor. This permit does not address any New York State air quality policies. 

3.4.7 Mobile Source Analysis 

There are a number of passenger vehicle trips generated each day to and from the Turning 

Stone Resort & Casino. The emissions from these trips are primarily associated with patron 

and employee motor vehicles traversing the roadways and potentially congregating in the 

Turning Stone Resort & Casino parking areas. There are also vendor, contractor, and 

construction worker vehicle trips resulting from ongoing daily service, management, and 

facility improvement activities. 

Since the large majority of traffic is associated with patrons and employees, an estimation of 

emissions for the on-road mobile source activities associated with the Turning Stone Resort & 

Casino was performed. Emission factors were developed based upon specific emission factor 

tables for Oneida County provided by the New York State Department of Transportation 

(NYSDOT, 2004). These emission factors were developed using the USEPA’s emissions 

model, MOBILE6.2 (USEPA, 2003), and the latest model input parameters provided by the 

NYSDEC. 

The MOBILE6.2 model was designed by the USEPA to calculate average in-use fleet emission 

factors. The model calculates emission rates under various conditions affecting in-use 

emission levels, such as average traffic speeds. The MOBILE6.2 model also accounts for the 

impact of factors such as changes in vehicle emission standards, changes in vehicle populations 

and activity, and variation in local conditions such as temperature, humidity, and fuel quality 

on emissions. The model allows site-specific inputs in order to adapt the emission factors to 

local conditions, and to model special situations that are not reflected in the model’s default 

parameters. MOBILE6.2 provides emission factors for CO, hydrocarbons (expressed as 

VOCs), and NOx. This model also has the ability to estimate particulate matter emissions 

(PM10 and PM2.5) including particulate emissions from the exhaust and from brake and tire 

wear. 

The MOBILE 6.2 emission factors for on-road vehicles provided by New York State 

Department of Transportation were expressed in terms of grams per vehicle mile traveled 

(g/mi). These emission factors were then multiplied by the distance each vehicle was assumed 

to travel in order to determine the emissions. Additionally, idle emissions, expressed in units 

of grams per hour (g/hr) were determined from the MOBILE6.2 emission factor tables. The 

idling emissions were conservatively calculated using emission factors at 2.5 miles per hour 

(MPH) and multiplying this emission factor by the 2.5 MPH speed to get an idling emission 

factor in g/hr, then multiplying this by the idling time (three minutes) to determine idling 

emissions. 
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The emissions estimation provided annual average emission rates for each pollutant of concern 

due to operations at the Turning Stone Resort & Casino. Emission estimates were obtained 

for the year 2006. Total emissions in terms of tons per year (tpy) were calculated considering 

both the free flow and idling emission components for the employee and patron vehicles. The 

analysis included the emissions of CO, VOCs, NOx, PM10, and PM2.5 and consisted of both a 

regional emissions component for vehicles traveling from various origins to the Turning Stone 

Resort & Casino and emissions associated with travel within the Turning Stone Resort & 

Casino site for vehicles traveling from the Turning Stone Resort & Casino entrance to their 

respective parking areas. 

3.4.7.1 Regional Emissions Estimate 

For patrons, estimates of the vehicle miles traveled were based upon trip data generated from 

the socio-economic analysis performed by the Louis Berger Group for fiscal year 2005. This 

trip data provided the total number of trips per year for patrons traveling to the Turning Stone 

Resort & Casino and the percentage of total trips from various regional origins. The majority 

of patrons (approximately 74 percent) traveling to and from the Turning Stone Resort & 

Casino are from the Cities of Utica and Syracuse and travel an average distance of 29 miles 

each way. The average driving distance traveled was determined using a commercial mapping 

program and was set as the driving distance from the center of each respective originating city 

to the entrance of the Turning Stone Resort & Casino at Patrick Road. The regional 

emissions estimates extended to travel originating approximately 400 miles from the Turning 

Stone Resort & Casino, where the socio-economic data indicated that approximately eight 

percent of patrons originated (e.g., from out of state areas such as Pennsylvania, Vermont, 

Maryland, and Ohio). Table 3.4-5 provides a summary of the patron trip information that 

was utilized for the determination of mobile source emissions. 

Table 3.4-5 

Regional Patron Trip Information 

Region Total Number of 

Trips per Year 

Total 

Percentage of 

Trips 

Average Distance 

Traveled 

(miles) 

Utica and Syracuse 1,781,127 74.4 29.1 

Albany, Binghamton, Rochester, and 

Watertown 395,720 16.5 107.3 

Kingston and Buffalo 33,713 1.4 171.7 

Connecticut, Massachusetts, New Jersey, 

New York City, Pennsylvania, and 

Vermont 

66,125 2.8 257.4 

Glen Falls, Ohio, and Other 116,174 4.9 409.6 

Source: Personal Communication, David Aimen of the Louis Berger Group, July 31, 2006; average distance traveled 

determined via MapQuest © 2006. 

It was assumed that patrons would largely use privately owned vehicles (classified as lightduty gasoline vehicles (LDGV) in MOBILE6.2) to transport themselves to and from the 
Section 3 

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3-83

Turning Stone Resort & Casino. The patrons were assumed to travel along interstate routes 

to and from the Turning Stone Resort & Casino at a posted speed limit of 55 MPH. 

For employees, estimates of the vehicle miles traveled were based upon employment statistics 

obtained as part of the socio-economic analysis as well. According to this information, 3,779 

people were employed at the Turning Stone Resort & Casino during fiscal year 2005. Of the 

total employees, 60.2 percent live in Oneida County, 26.6 percent live in Madison County, 

and 13.2 percent live in central New York counties (with the majority of these 13.2 percent of 

employees living in Onondaga County). The average distance traveled for employees was 

determined using a commercial mapping program and was calculated as approximately half 

the distance from the entrance of the Turning Stone Resort & Casino at Patrick Road to the 

furthest town within each respective county. Table 3.4-6 provides a summary of the employee 

trip information that was utilized for the determination of emissions. 

Table 3.4-6 

Regional Employee Trip Information 

Road Assignment 

Percentage of 

Employees Assigned 

to Road 

Annual Volume of 

Employee Trips per 

Year 

Average Distance 

Traveled 

(miles) 

Oneida County 60.2 2,275 18.8 

Madison County 26.6 1,005 20.2 

Onondaga County 13.2 499 30.7 

Source: Calculated from data presented in Section 3.7 of this document; average distance traveled determined via 

MapQuest © 2006. 

It was assumed that employees would largely use LDGV to transport themselves to and from 

the Turning Stone Resort & Casino. The employees were assumed to travel on the arterial 

and local roads surrounding the Turning Stone Resort & Casino at an average speed of 40 

MPH. This speed was based on a traffic study conducted by C&S Engineers during January 

2006 along Route 365 between the Turning Stone Resort & Casino and I-90. 

The emission factors used in the analysis for the patrons and employees traveling to the 

Turning Stone Resort & Casino are presented in Table 3.4-7. 

Using the emission factors in Table 3.4-7 and the trip information from Tables 3.4-5 and 3.4-

6, an estimate of the annual average emissions for each pollutant of concern was calculated. 

These total regional emissions are presented in Table 3.4-8. 
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Table 3.4-7 

Emission Factors for Regional Patrons and Employees 

Emission Factors (g/mi) Pollutant 40 MPH 55 MPH 

CO 20.27 22.03 

NOx 0.68 0.71 

VOCs 0.87 0.78 

PM10 0.03 0.03 

PM2.5 0.01 0.01 

Source: NYSDOT (2004). 

Table 3.4-8 

Annual Average Emission Rates for Regional Patrons and Employees 

Annual Average Emission Rates (tpy) Region CO NOx VOCs PM10 PM2.5

Patron Regional Emissions 

Utica and Syracuse 2,520 81 89 3.4 1.1 

Albany, Binghamton, Rochester, and 

Watertown 2,062 66 73 2.8 0.9 

Kingston and Buffalo 281 9.1 10 0.4 0.1 

Connecticut, Massachusetts, New 

Jersey, New York City, 

Pennsylvania, and Vermont 827 27 29 1.1 0.4 

Glen Falls, Ohio, and Other 2,311 75 82 3.1 1.0 

Total Patron Regional 8,001 258 283 11 3.5 

Employee Regional Emissions 

Oneida County 1.9 0.06 0.08 <0.01 <0.01 

Madison County 0.9 0.03 0.04 <0.01 <0.01 

Onondaga County 0.7 0.02 0.03 <0.01 <0.01 

Total Employee Regional 3.5 0.11 0.15 <0.01 <0.01 

Total Regional Emissions (Patrons 

and Employees) 8,004.5 258.1 283.2 11.0 3.5 
Section 3 

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3.4.7.2 On-site Travel Emissions Estimate 

For travel within the Turning Stone Resort & Casino site, the emissions estimates accounted 

for vehicles (both patrons and employees) entering the parking lots to park and those vehicles 

exiting the parking lot. The emissions estimates included the idling emissions from a warm-up 

period prior to each vehicle leaving its parking spot. Emission rates per vehicle for travel 

within the parking lot were conservatively determined assuming a vehicle speed of 10 MPH. 

The travel distance within the parking lot was determined from a scaled site plan and was 

estimated as the approximate distance from the Turning Stone Resort & Casino entrance at 

Patrick Road to the center of the patron/employee parking lots (the Main Parking Lot for 

patrons and the Employee Lot for the employees). The three-minute warm-up period per trip 

was assumed for vehicles exiting the parking lot. 

The emission factors used in the analysis for the patrons and employees traveling within the 

Turning Stone Resort & Casino are presented in Table 3.4-9. 

Table 3.4-9 

Emission Factors for On-Site Travel of Patrons and Employees 

Pollutant Emission Factor (g/mi) 

at 10 MPH Idle Emission Factor (g/hr) 

CO 24.13 133.23 

NOx 1.07 4.10 

VOCs 1.89 27.98 

PM10 0.03 N/A 

PM2.5 0.01 N/A 

Source: NYSDOT (2004). 

Using the emission factors in Table 3.4-9 and the trip information from Tables 3.4-5 and 3.4-

6, an estimate of the annual average emissions for each pollutant of concern due to on-site 

travel was calculated. These total on-site travel emissions are presented in Table 3.4-10. 

Total mobile source emissions due to the Turning Stone Resort & Casino, considering 

regional and on-site travel from patrons and employees are summarized in Table 3.4-11.
Section 3 

Affected Environment

Bureau of Indian Affairs 

Draft EIS 

Oneida Nation of New York Conveyance of Lands Into Trust

3-86

Table 3.4-10 

Annual Average Emission Rates for On-Site Travel of Patrons and Employees 

Annual Average Emission Rates (tons per year) Road Assignment CO NOx VOCs PM10 PM2.5

Patrons: Patrick Road to Main Parking Lot 

At 10 MPH 39.1 1.7 3.1 0.05 0.02 

Idle 17.6 0.5 3.7 N/A N/A 

Total Patron On-Site Travel 56.7 2.2 6.8 0.05 0.02 

Employees: Patrick Road to Employee Lot 

At 10 MPH 1.3 0.04 0.3 <0.01 <0.01 

Idle 0.03 <0.01 0.01 N/A N/A 

Total Employee On-Site Travel 1.3 0.04 0.3 <0.01 <0.01 

Total On-Site Travel Emissions 

(Patrons and Employees) 58 2.2 7.1 0.05 0.02 

Table 3.4-11 

Total Mobile Source Emissions from the Turning Stone Resort & Casino 

(Patrons and Employees) 

Pollutant Total Annual Emissions (tpy) 

CO 8,058 

NOx 260 

VOCs 290 

PM10 11 

PM2.5 4 

Additional emissions of VOCs may result from vehicle refueling. These refueling or 

evaporative emissions emanate from a motor vehicle fuel tank during a refueling operation. 

The USEPA has estimated that vehicle refueling emissions can account for as much as two 

percent of the overall VOC emissions inventory in urban areas. In addition, some spillage 

emissions may result when fuel is spilled on the ground during the refueling process. Some or 

all of the spilled fuel can subsequently vaporize, adding hydrocarbon compounds to the 

atmosphere. These secondary emissions were not accounted for in calculations since they 

were considered small in comparison to the tailpipe emissions from the patron and employee 

vehicles.