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Mr. Conrad Simon Director 

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February 14, 1994

Air and Waste Management Division United States Environmental Protection Agency, Region II Jacob K. Javits Federal Building New York, New York 10278-0012
Dear Mr.

**Simon:~~~~** ThomasC.Jorllng Commissioner

Thank you for notifying us of the designation of Manhattan

as moderate non attainment for particular matter (PM10) in the December 21, 1993 Federal Register. Your offer of assistance in developing the PM10 State Implementation Plan (S

. IP) is welcomed and

**~ppreciated.** To address your immediate concern, we have come to the conclusion that PM10 problems and the control strategies to solve them cannot be limited to an area smaller than the borough of Manhattan. The steps you outlined in the January 20, 1994 correspondence are helpful, and I will relate to you where we stand in those matters and how your office can be of help.

In regards to air quality information, the six-phase PM10 Saturation Air QualityMonitoring study is in final analysis, and completion is expected by the end of March. All of the data, past and present, indicate that the Madison Avenue site contains the highest levels of PM10, and there is nothing which would lead

us to any other conclusion. Therefore, we expect to report the Madison Avenue site as the most probable location for an exceedance of the PM10 standard.
A recent NYS DEC study has characterizedthe PM10 sample at the Madison Avenue site, on average, as 52.8% diesel exhaust particulate, 22.9% due to long range transport (principally ammonium sulfate, and ammonium nitrate) 8.5% Road Dust, 5.9% marine aerosol (sea salt) transported from the Atlantic Ocean, 5.9% gasoline exhaust particulate, and 5.0% residual carbon from fossil fuel combustion and iron particulate, all of which are based upon the total weight of PM10• These percentages change significantlywith the time of day, although those associated with diesel emissions did not drop below a four hour average of

()printedonleey(;ledpepe< l2.
30% during the 48 hour test period. This constitutes our impetus in designating heavy duty diesel vehicles as the primary contributors to the PM10problem inMidtown Manhattan.
At this juncture, we must advise against limiting the nonattainment status to only a certain portion of Manhattan, as the main controllable source of PM10 has been identified as the heavy duty diesel traffic in midtownManhattan (tentative numbers suggest that motor vehicle emissions constitute on the order of 70% of the total annual PM10 sample weight). Since these emitters of PM10 are mobile, they would have the abilityto move freely in and out of the nonattainment area. This could decrease the effectiveness of any implemented PM10 control strategies and shift the site of highest PM10 to another area within the Borough.
We expect, that upon completion of analysis the 1993 particulate mattermonitoring results for 1993 will yield an annual mean that is below the PM10 standard. If this be the case, and the three year average upon which compliance is determined results in a value below the PM10 standard, NYS will seek to petition EPA to redesignate New York County back to attainment status. On the same note, one correction, the Madison Avenue monitor failed to meet the 75% data acquisition criteria in 1990, not 1992. Since we have identified diesel vehicles as the largest controllable population of the PM10 emitters, the diesel vehicle emissions model has become the center point of our PM10 SIP development. We must thank you for expediting its development and availability. The need for accurate traffic data was stressed in your January 20, 1994 correspondence, a consideration with which we agree wholeheartedly. Sinceyour letter John Walsh of your staff has helped us acquire the parameters which need to be collected. We are now coordinating with the New York City Departments of Transportation (NYCDOT) and Environmental Protection to obtain that data while the diesel vehicle emissions model undergoes final development.
The July 20, 1995 submittal date for the PM10 SIP is acknowledged and confirmed. Currently we are establishing a protocol and consultation process among the various relevant government agencies. James Ralston has been designated as our lead contact person and will work with Ray Werner in the development of the PM10 SIP

. Thank you for understanding the other pressing clean-air demands placed upon our state. I am certain that through a cooperative effort between the Environmental ProtectionAgency, New York state Department of Environmental Conservation, and all other agencies involved, the PM10 SIP will be developed in a timely fashion.cc: R

. Werner R. Kapichak wfencl. G

. Cioffiwfencl.

**~** Nudelman, NYCDEP wfencl. G. Soffian, NYCDOT wjencl. D. Park Sincerely,



# ~ Thomas M. Allen, P.E. Director Division ofAir Resources 3.