Connecticut Department of 

ENERGY & 

ENVIRONMENTAL 

PROTECTION 

August 19, 2011 

David Conroy, Chief, Air Programs Branch 

US EPA - New England 

5 Post Office Square- Suite 100 (Mail Code OEP05-2) 

Boston, MA 02109-3912 

Re: Addendum to the CAA §110(a)(2)(D)(i)(I) Portion of Connecticut's Infrastructure 

Submittal for the 2006 PM2,5 NAAQS 

Dear Mr. Conroy: 

On September 18, 2009, the Connecticut Department of Environmental Protection (now the 

Connecticut Department of Energy and Environmental Protection) submitted a determination 

that Connecticut's State Implementation Plan (SIP) adequately addressed the requirements of 

§§110(a)(1) and (2) of the Clean Air Act (CAA) for the 2006 fine particulate matter (PMZ,5) 

national ambient air quality standards (NAAQS), demonstrating that Connecticut's resources 

and authorities are adequate to implement, maintain, and enforce the NAAQS. Considering 

EPA's recent release of the Cross-State Air Pollution Rule (CSAPR), Connecticut is submitting this 

addendum to our September 2009 submittal to clarify how Connecticut complies with 

§110(a)(2)(D)(i)(I) requirements, as described below . 

The §110(a)(2)(D)(i)(I) portion of the September 2009 submittal addresses the requirement that 

Connecticut prohibit any source or other type of emissions activity in the state from 

contributing significantly to nonattainment, or interfering with maintenance, of the NAAQS in 

another state . This portion of Connecticut's September 2009 submittal indirectly referenced 

EPA's 2005 Clean Air Interstate Rule (CAIR) and the associated State program. However, a 

December 2008 court decision vacated CAIR, but kept CAIR requirements in place temporarily 

while directing EPA to issue a replacement rule. On August 2, 2010, EPA proposed the courtrequired replacement rule, which EPA called the Transport Rule.' EPA's modeling analysis 

conducted for the proposed Transport Rule supported EPA's conclusion at the time that 

Connecticut significantly contributed to nonattainment or interfered with maintenance of the 

1996 24-hour PM2.5 NAAQS. After discussions with EPA Region 1 staff regarding the impact of 

the 2008 court decision upon the approvability of our September 2009 infrastructure submittal 

and the conclusions in the proposed Transport Rule, on January 7, 2011, Connecticut withdrew 

the §110(a)(2)(D)(i)(I) portion of the infrastructure submittal, as requested by EPA. 

I See, Federal Implementation Plans To Reduce Interstate Transport of Fine particulate Matter and Ozone (75 FR 

45210. 

79 Elm Street " Hartford, CT 06106-5127 

www.ct.gov/deep 

Affirmative ActionlEqual Opportunity Employer 
Mr. David Conroy 

Page 2 

August 19, 2011 

On July 6, 2011, EPA finalized CSAPR, which replaces CAIR. The results of EPA's analysis 

conducted for CSAPR differ from the results of the proposed Transport Rule.2 CSAPR 

requirements do not apply to Connecticut because the final rule's updated air quality modeling 

led EPA to conclude that Connecticut does not contribute significantly to nonattainment, or 

interfere with maintenance, of the 2006 PM2,5 NAAQS in another state.3 Therefore, based on 

EPA's modeling analysis and conclusions, we are resubmitting the section of our September 18, 

2009 infrastructure submittal that addresses interstate transport provisions of 

§110(a)(2)(D)(i)(I), certifying that Connecticut does not contribute significantly to 

nonattainment, or interfere with maintenance, of the 2006 PM2,5 NAAQS in any other state. 

Thank you for your consideration of this clarification of the Connecticut's infrastructure 

certification for the 2006 PM2,5 NAAQS. If you have any questions or comments concerning this 

matter, please contact me. 

Sincerely, 

Anne Gobin 

Chief, Bureau of Air Management 

2 EPA updated its modeling platforms and modeling inputs in response to public comments received on the proposed 

Transport Rule and subsequent NODAs and performed other standard updates. 

3 EPA's modeling also concludes that Connecticut does not significantly contribute significantly to nonattainment or 

maintenance issues in other states for the 1997 ozone and PM2.5 NAAQS. Information about EPA's modeling for 

CSAPR is available on their CSAPR website on the technical information and support documents page: 

http ://www.eva .pov/_crossstaterule/techinfo .html.