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### iii 

## Table of Contents
Connecticut PM 2.5 

## Redesignation Request and Maintenance Plan

Executive Summary

CHAPTER 1 INTRODUCTION AND BACKGROUND 1

1.1 Particulate Matter Formation and Health Effects 1 1.2 Particulate Matter NAAQS History 2
1.2.1 1997 PM 2.5 NAAQS 2 1.2.2 2006 PM 2.5 NAAQS 5 1.3 Required Elements for PM 2.5 Redesignation 5

CHAPTER 2 DEMONSTRATION OF ATTAINMENT OF THE PM 2.5 STANDARDS 7

2.1 Monitoring Network 7
2.2 Data Handling and Quality Assurance 7
2.3 PM 2.5 Monitoring Data Analysis 10

CHAPTER 3 APPLICABLE REQUIREMENTS UNDER CAA SECTION 110 AND TITLE 1 PART D 21

3.1 Satisfying Section 110 General SIP Requirements 21 3.2 Satisfying Part D Requirements 22
3.3 Fully Approved SIP Under Section 110(k) 24

CHAPTER 4 PERMANENT AND ENFORCEABLE EMISSION REDUCTIONS 25

4.1 Federal Control Measures 25
4.1.1 Tier 2 Vehicle Standards and Gasoline Sulfur Standards 25 4.1.2 Heavy-Duty Diesel and Gasoline Highway Vehicle Standards 27
4.1.3 Motorcycle Exhaust Standards 27
4.1.4 Large Non-road Diesel Engine Standards 27 4.1.5 Non-road Spark-Ignition Engines and Recreational Engine Standards 28
4.1.6 NO
x SIP Call, CAIR and CSAPR Programs 28 4.2 Connecticut Control Measures 29
4.2.1 Control of SO 2 and NO

x Emissions from Power Plants and Other Large Stationary Sources 31
4.2.2 The Post-2002 Nitrogen Oxides (NOx) Budget Program 31 4.2.3 CAIR and Connecticut’s CAIR Replacement Rule 31
4.2.4 Outdoor Wood Burning Furnace (OWBF) Restrictions 32
4.2.5 Improvements in the Control of Particulate Matter and Visible Emissions 32 4.2.6 Connecticut Enhanced I/M (ASM 2525 final standards) and OBD-II Enhanced I/M 33
4.2.7 California Low Emission Vehicle 2 (CALEV2) 33
4.2.8 Reducing NO

x Emissions from Municipal Waste Combustors 33 4.2.9 Conclusions 34

### iv CHAPTER 5 MAINTENANCE PLAN 35

5.1 Attainment Inventory and Demonstration of Continued Maintenance 35
5.1.1 Pollutants 37 5.1.2 Source Categories 37
5.1.3 Geographic and Temporal Resolution 37
5.1.4 Point Source Inventory Procedures 38 5.1.5 Area Source Inventory Procedures 41
5.1.6 Non-Road Source Inventory Procedures 44 5.1.6.1 NMIM/NONROAD Modeling Methodology 44 5.1.6.2 MAR Methodology 45
5.1.7 On-Road Mobile Source Inventory Procedures 48 5.1.8 Comparison of Attainment Year and Projected Future Year Emissions 56 5.1.9 Motor Vehicle Emission Budgets 59
5.2 Ambient Monitoring Network Commitment 61 5.3 Verification of Continued Attainment 61
5.4 Contingency Plan 62
5.4.1 Warning Level Response 62 5.4.2 Action Level Response 63
5.5 Commitment to Revise Plan 63

CHAPTER 6 SUMMARY AND CONCLUSIONS 644

6.1 Area Has Attained the NAAQS 644
6.2 Applicable CAA Section 110 and Title 1 Part D Requirements are Satisfied 644 6.3 Attainment is Due to Permanent and Enforceable Emission Reductions 655
6.4 Maintenance Plan Ensures Continued Attainment 66
6.5 Withdrawal of the Attainment Demonstration 66

### v 

## List of Tables

Table 2.1 Connecticut PM 2.5 Monitors: Data Completeness by Qu arter 2008 – 2010 (Percent) ....................... 9

Table 2.2 Annual PM 2.5 Design Values 1 in Connecticut’s Portion of the NY-NJ-CT Nonattainment Area 2

( μ g/m 3 ) ............................................................................................................................. ............... 13

Table 2.3 24-hour PM 2.5 Design Values 1 in Connecticut’s Portion of the NY-NJ-CT Nonattainment Area 2

( μ g/m 3 ) ............................................................................................................................. ............... 13

Table 4.1 Post-2002 Cont rol Measures ................................................................................................... ........ 26

Table 4.2 Comparison of Actual EGU Emissi ons from States Impacting Connecticut’s PM 2.5 Air Quality .. 30

Table 5.1 CT DEEP Banked Em ission Reduction Credits .............................................................................. 39

Table 5.2 MOVES Run Specifications ................................................................................................... ........ 50

Table 5.3 MOVES County Data Manager (CDM) .......................................................................................... 5 2

Table 5.4 References Cited in Table 5.2 and 5.3 ....................................................................................... ..... 55

Table 5.5 Comparison of MOVES Em issions for 200 7 and 200 9 .................................................................. 56

Table 5.6 Connecticut PM 2.5 Emissions Inventory Pr ojections 20 07-2025 .................................................... 57

Table 5.7 Connecticut NO

x Emissions Inventory Pr ojections 20 07- 2025 ..................................................... 57

Table 5.8 Connecticut SO 2 Emissions Inventory Pr ojections 20 07-2025 ....................................................... 58

Table 5.9 New York Preliminary Emissi ons Projections 2007-2025 .............................................................. 59

Table 5.10 New Jersey Preliminary Emissi on Projections 2007-2025 ............................................................. 59

Table 5.11 Transportation Conformity Budgets for Connecticut’s Portion of the NY-NJ-CT Area ................ 61

### vi 

## List of Figures

Figure 1.1 The NY-NJ-CT Annual and 24-hour PM 2.5 Nonattainment Areas .................................................... 4

Figure 2.1 Connecticut’s PM 2.5 Monitoring Network ....................................................................................... 8

Figure 2.2 2010 Annual De sign Values...................................................................................................... ...... 11

Figure 2.3 2010 24-hour Design Values .................................................................................................... ....... 12

Figure 2.4 Annual Design Value Trends for Monitors in Connecticut’s Portion of the NY-NJ-CT Area ....... 15

Figure 2.5 Annual Design Value Trends for Monitors in New York’s Portion of the NY-NJ-CT Area .......... 16

Figure 2.6 Annual Design Value Trends for Monitors in New Jersey’s portion of the NY-NJ-CT Area ........ 17

Figure 2.7 24-hour Design Value Trends for Monitors in Connecticut’s portion of the NY-NJ-CT Area ....... 18

Figure 2.8 24-hour Design Value Trends for Monitors in New York’s portion of the NY-NJ-CT Area ......... 19

Figure 2.9 24-hour Design Value Trends for Monitors in New Jersey’s portion of the NY-NJ-CT Area ....... 20

### vii 

## Appendices

Appendix A Version 3.3 Technical Support Document for the Development of the 2007 Emission INventory
for Regional Air Quality Modeling in the Northeast/Mid-Atlantic Region; Prepared for
MARAMA by AMEC Environment & Infrastructure and SRA International, Inc.; January 23,

2012.

Appendix B Version 3.3 Technical Support Document for the Development of the 2025 Emission Inventory
for PM Nonattainment Counties in the MANE-VU Region; Prepared for MARAMA by AMEC
Environment & Infrastructure and SRA International, Inc.; January 23, 2012

Appendix C Version 3.3 Technical Support Document for the Development of the 2017 / 2020 Emission
Inventories for Regional Air Quality Modeling in the NOrtheast / Mid-Atlantic Region; January

23, 2012

Appendix D File Locations for Additional Documentation on Inventory Development Process

Appendix E Connecticut Department of energy and Environmental Protection's Review of the Seasonality of
High PM 2.5 Days.
Appendix F Excerpts from Connecticut's 2005 Draft Periodic Emission Inventory (PEI) for Ozone and Carbon

Monoxide

Appendix G Connecticut 2007 Airport Related Emissions Provided to MARAMA for Inclusion in the 2007

MANE-VU Inventory

Appendix H Connecticut 2007 Locomotive Emissions Provided to MARAMA for Inclusion in the 2007

MANE-VU Inventory

Appendix I Connecticut MOVES On-Road Modeling Documentation

### E-1 

## Executive Summary

This document presents the Connecticut Department of Energy and Environmental Protection’s (CT DEEP) request to redesignate Conn ecticut’s portion of the New York-N ew Jersey-Connecticut (NY-NJCT) nonattainment area to attainment for the fede ral 1997 annual and 2006 24-hour National Ambient Air Quality Standards (NAAQS) for fine particulate matter less than a nominal 2.5 micrometers in diameter (PM 2.5 ). Evidence is provided satisfying Clean Air Ac t (CAA) sections 107(d)(3)(E) and 175A, which specify the requirements that must be met for th e U.S. Environmental Protection Agency (EPA) to redesignate a nonattainment area to attainment status . These requirements include demonstrations that:

• The area has attained the NAAQS;

• The applicable implementation plan is fully approved under CAA section 110(k) and the area has met all applicable requirements of CAA section 110 and part D;

• The air quality improvements are due to perm anent and enforceable emission reductions;

• The area has a fully approved a maintenance plan satisfying CAA section 175A.



### E.1 Background

Fine particles in the atmosphere are comprised of a complex mixture of components, including sulfate (SO 4 ), nitrate (NO 3 ), ammonium, elemental carbon, organic co mpounds and inorganic material (e.g., metals, dust, sea salt) generally referred to as ‘crustal material.’ Primary particles are emitted directly into the air as solid or liquid particles (e.g., elem ental carbon from diesel engines). Secondary particles form in the atmosphere over time because of various chemical reactions (e.g., gaseous sulfur dioxide and ammonia reacting to form ammonium su lfate particles). Consequently, PM 2.5 experienced at one location can have origins both nearby and distant.

The annual average and 24-hour average PM 2.5 NAAQS were initially established by EPA in 1997 and revised in 2006, based on evidence demonstrating that serious health effects are associated with exposure
to elevated levels of PM 2.5 , mainly because particles of this size can easily reach into the deepest regions of the lungs. Significant health effects associated with PM 2.5 exposure include premature mortality, aggravation of respiratory and cardiovascular disease, decreased lung function and difficulty breathing, asthma attacks, as well as cardiovascular problems such as heart attacks and cardiac arrhythmia. Particularly sensitive individuals include older adu lts, people with heart and lung disease, and children.

Connecticut’s Fairfield and New Haven Counties ar e currently designated by EPA as nonattainment for
both the 1997 annual and 2006 24-hour PM 2.5 NAAQS and are grouped with several counties in New York and northern New Jersey in a multi-stat e (NY-NJ-CT) nonattainment area that encompasses metropolitan New York City, as shown in Figure E-1. EPA established these nonattainment areas in 2005 for the annual NAAQS and in 2009 for the 24-hour NAAQS based on PM 2.5 air quality measured prior to those years.E-2Figure E-1. New York-New Jersey-Connecticut (NY-NJ-CT) Annual/24-hour PM2.5Nonattainment Area

### E-3 

### E.2 Monitoring Show s Compliance with PM 2.5 

### NAAQS

As shown in Figures E-2 and E-3, PM 2.5 air quality has improved significantly over the last decade in the Connecticut portion of the NY-NJ-CT area. Simila r improvements have occurred in the New York and New Jersey portions of the area as well. Conn ecticut’s portion of the nonattainment area measures compliance with the 15 μg/m 3 annual NAAQS, with a maximum 2010 design value of 10.3 μg/m 3 . As a whole, the area first reached compliance with the annual NAAQS in 2008, with a most recent (2010) maximum design value of 12.5 μg/m 3 , measured in New York City.

Connecticut’s portion of the area first measured compliance with the 35 μg/m 3 24-hour NAAQS in 2008, with a maximum 2010 design value of 29 μg/m 3 . As a whole, the NY-NJ-CT area first complied with the 24-hour NAAQS in 2009 and has a most recent (2010) maximum design value of 30 μg/m 3 , measured in New Jersey. Therefore, the entire NY-NJ-CT area has complied with both NAAQS since 2009.



### E.3 Applicable CAA Section 110 and Titl e 1 Part D Requirements are Satisfied

Connecticut has submitted “infrastructure SIPs” addr essing CAA section 110(a) requirements, for both
the 1997 annual and 2006 24-hour PM 2.5 NAAQS. EPA has found Connecticut’s infrastructure SIP submittal for the 1997 annual NAAQS to be complete, but has not yet issued rulemakings to approve the infrastructure SIPs for either of the NAAQS. Noneth eless, previous redesignation rulemakings issued by
EPA for other areas conclude that section 110 elements that are not connected with nonattainment plan
submissions and are not linked with an area’s attain ment status are not applicable requirements for purposes of redesignation, because a state remains s ubject to these requirements after redesignation.

CAA Subpart 1 of part D sets forth the basic nonattain ment requirements applicable to all nonattainment areas. All areas that were designated nonattain ment for the 1997 annual or the 2006 24-hour PM 2.5 NAAQS were designated under this subpart of the C AA, and the requirements applicable to them are contained in sections 172 and 176. For purposes of ev aluating redesignation requests, the applicable part D, subpart 1 SIP requirements are contained in sections 172(c)(1)–(9 ) and in section 176.

States with nonattainment areas are required to submit a plan to reach attainment. Connecticut submitted an attainment demonstration for its portion of the annual nonattainment area in November 2008, meeting CAA sections 172 and 176 requirements. See Section E.6 for further discussion regarding that attainment
demonstration. Attainment demonstrations for the 24-hour NAAQS are due in December 2012.

As discussed earlier, all monitors in the NY-NJ-C T area show compliance with both the annual and 24- hour NAAQS. EPA has already recognized that the mu lti-state area has “clean data” in accordance with 40 CFR 51.1004(c), for the annual NAAQS. Connecticut has requested a similar “clean data” finding for the 24-hour NAAQS and is awaiting EPA action. The requirement to submit the 24-hour NAAQS
attainment demonstration would no longer apply if EPA issues a “clean data” finding for that NAAQS, or if EPA approves this redesignation request for th e 24-hour NAAQS before the December 2012 due date.

CAA section 172(c)(3) requires an inventory of actual emissions. The maintenance plan portion of this submittal includes a 2007 base year emissions inventory that meets the requirement.

### E-4 Figure E-2 Annual Design Value Trends in Connecticut’s Portion of the NY-NJ-CT Area

Figure E-3 24-Hour Design Value Trends in Connecticut’s Portion of the NY-NJ-CT Area 0 2 4 6 8 10 12 14 16 18

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010μg/m3 

### Connecticut Annual PM2.5 Design Values 2001

‐ 2010

Bridgeport (09

‐ 001

‐ 0010) Danbury (09

‐ 001

‐ 1123)

Stamford HS (09

‐ 001

‐ 2124) Norwalk (09

‐ 001

‐ 3005)

Westport (09

‐ 001

‐ 9003) New Haven Fire House (09

‐ 009

‐ 0026)

New Haven Criscuolo (09

‐ 009

‐ 0027) New Haven State St (09

‐ 009

‐ 1123)

New Haven Ag Station (09

‐ 009

‐ 2008) Waterbury (09

‐ 009

‐ 2123)

Hamden Millrock (09

‐ 009

‐ 9005) Annual NAAQS

0 5 10 15 20 25 30 35 40 45

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010μg/m3 

### Connecticut 24

‐ hr PM2.5 Design Values 2001

‐ 2010

Bridgeport (09

‐ 001

‐ 0010) Danbury (09

‐ 001

‐ 1123)

Stamford HS (09

‐ 001

‐ 2124) Norwalk (09

‐ 001

‐ 3005)
Westport (09

‐ 001

‐ 9003) New Haven Fire House (09

‐ 009

‐ 0026)

New Haven Criscuolo (09

‐ 009

‐ 0027) New Haven State St (09

‐ 009

‐ 1123)

New Haven Ag Station (09

‐ 009

‐ 2008) Waterbury (09

‐ 009

‐ 2123)

Hamden Millrock (09

‐ 009

‐ 9005) 24

‐ hr NAAQS

### E-5 EPA’s PM 2.5 implementation rules require states to adopt specified new source review (NSR) permitting revisions by July 20, 2012. CT DEEP held a public hearing in November 2011 to consider revisions to Sections 22a-174-1 and 22a-174-3a of the Regulations of Connecticut State Agencies (RCSA) to include significant impact levels, significant emissions rates and increments for PM 2.5 , consistent with EPA’s requirements. CT DEEP anticipates that the revised regulations will be submitted as a SIP revision by the end of summer 2012, at which point Connecticut will have in place all applicable CAA Section 110 and Title 1 Part D requirements necessary for PM 2.5 redesignation.



### E.4 Attainment Results fr om Permanent and Enforcea ble Emission Reductions

Numerous federal and state emission control programs have been adopted and implemented over the last decade, providing permanent and enforceable reductions in direct PM 2.5 and PM 2.5 precursor emissions (e.g.,

SO 2 and NO
x ) in Connecticut and some upwind areas. Table E-1 lists post-2002 NO
x , SO 2 and PM 2.5 control measures that are largely responsible for the si gnificant improvements realized in measured PM 2.5 air quality. Some of these control programs (e.g., on-road vehicle and non-road engine standards) will provide additional emission reductions during the maintenance period , ensuring continued compliance with the NAAQS. Connecticut requests withdrawal of one control measure cited in the attainment demonstration for the 1997
annual PM 2.5 NAAQS (submitted November 18, 2008). No app lications were ever received for a general permit issued for distributed generation sources (authorized under CGS 22a-174(k) and section 102 of Public Act 07-242). The general permit has since expired, with no plans for renewal. Therefore, there is no need to include the general permit in the SIP.



### E.5 Maintenance Plan Provides for Continuing Attainment

CAA section 175A establishes the required elements of a maintenance plan for areas seeking redesignation from nonattainment to attainment. Plans must include: an inventory sufficient to ensure attainment; a demonstration that the plan provides for continued NAAQS compliance through the first 10-year maintenance period; a commitment to maintain an appropriate monitoring network; methods to track the progress of the maintenance plan and contingency measures to be implemented if NAAQS violations occur during the maintenance period.



### Attainment and Future Year Inventories Demonstrate Continued NAAQS Compliance Comprehensive inventories were developed in collaboration with other states in the Mid-Atlantic/ Northeast Visibility Union (MANE-VU) to support future multi-pollutant planning efforts. That regional effort also served as the basis for developing inventories needed by states, such as Connecticut, seeking PM 2.5 redesignation. Figures E-4, E-5 and E-6 compare PM 2.5 , NO
x and SO 2 emission estimates, respectively, for Connecticut’s portion of the NY-NJ-CT area for the representative attainment year 1 (2007), an interim year (2017) and the end of the maintenance period (2025). Projected emission trends are also displayed for the
nonattainment area as a whole. Note that emission esti mates for the New York and New Jersey portions of the area are based on preliminary MARAMA inventory estimates (version 3_3) an d are subject to change by each
state in their PM 2.5 redesignation SIP submittals.

_________________________ 1 See Section 5.1.7 of this TSD for an explanation of wh y CT DEEP elected to use 2009 MOVES on-road estimates in the 2007 attainment year inventory.

### E-6 Table E-1 Adopted Post-2002 Federa l and Connecticut Control Measures

Control Measure PM NO X SO 2 Federal Programs

Tier 2 Vehicle Standards and Gasoline Sulfur Standards X X X Heavy-Duty Diesel and Gasoline Highway Vehicle Standards X X X Motorcycle Exhaust Standards X Large Non-road Diesel Engine Standards X X X Non-road Spark-Ignition Engines and Recreational Engine
Standards X X X

NOx SIP Call X

CAIR X X

State Programs

Control of Sulfur Dioxide and Nitrogen Oxide Emissions from Power Plants and Other Large Stationary Sources RCSA Sections 22a-174-19a and 22a-174-22(e)(3) X X

The Post-2002 Nitrogen Oxides (NOx) Budget Program
RCSA Section 22a-174-22b X

CAIR NO X Ozone Season Trading Program
RCSA Section 22a-174-22c X

Outdoor Wood Burning Furnace Restrictions
Section 22a-174k of the Connecticut General Statutes X

Improvements in the Control of Particulate Matter and Visible
Emissions RCSA Section 22a-174-18 X X

Connecticut Enhanced Inspection and Maintenance Program (ASM 2525 final standards and OBD II program)
RCSA Section 22a-174-27 X

CT’s California Low Emission Vehicle Phase 2 (CALEV2)
RCSA Section 22a-174-36b X X

Reductions in NOx emissions from Municipal Waste Combustors (Phase 2) RCSA Section 22a-174-38 X

NSR Permit to Construct and Operate Stationary Sources
RCSA Section 22a-174-3a X X X

### E-7 Figure E-4 Projected PM 2.5 Emissions for the CT Portion and All of the NY-NJ-CT Area*

* Emission estimates for NY and NJ are preliminary and are subject to change by each state in their PM 2.5 redesignation SIP submittals.

Figure E-5 Projected NO
x Emissions for the CT Portion and All of the NY-NJ-CT Area*

* Emission estimates for NY and NJ are preliminary and are subject to change by each state in their PM 2.5 redesignation SIP submittals. 0 10,000 20,000 30,000 40,000 50,000

0 1,000 2,000 3,000 4,000 5,000 6,000 7,000 8,000

2007 2017 2025 NY

‐ NJ

‐ CT

TPY CT

TPY 

## PM 2.5 

## Emission Trends for the

CT Portion and All of the NY

‐ NJ

‐ CT Area

CT Point
NonEGU

CT Point EGU

CT Onroad

MOVES

CT Nonroad

NMIM

CT Nonroad

MAR

CT Area

NY

‐ NJ

‐ CT
TOTALS

0 100,000 200,000 300,000 400,000 500,000

0 10,000 20,000 30,000 40,000 50,000 60,000

2007 2017 2025 NY

‐ NJ

‐ CT

TPY CT

TPY 

## NOx Emission Trends for the

CT Portion and All of the NY

‐ NJ

‐ CT Area CT Point
NonEGU

CT Point EGU

CT Onroad

MOVES

CT Nonroad

NMIM

CT Nonroad

MAR

CT Area

NY

‐ NJ

‐ CT
TOTALS

### E-8 Figure E-6 Projected SO 2 Emissions for the CT Portion and All of the NY-NJ-CT Area*

* Emission estimates for NY and NJ are preliminary and are subject to change by each state in their PM 2.5 redesignation SIP submittals.

Results demonstrate that total emissions of all three PM 2.5 -related pollutants decrease significantly through the maintenance period in both the Conn ecticut portion and throughout the entire NY-NJ-CT

area. PM 2.5 emissions are projected to decrease by 22%, NO
x by 52% and SO 2 by 43% between 2007 and 2025 in the Connecticut portion of the area, with si milar reductions expected for the entire area. These projected reductions occur due to the currently adopted federal and state control programs listed in Table E-1, with no additional control strategies necessary to maintain the NAAQS through 2025. Therefore, the Section 175A mandate to demonstrate continued comp liance during the maintenance period is satisfied.



### Motor Vehicle Emission Budgets The maintenance plan establishes PM 2.5 and NO
x transportation conformity budgets 1 for 2017 and 2025 to
ensure that future emissions from on-road mobile sources provide for continuing attainment of the PM 2.5 NAAQS. As depicted in Figure E-6, on-road emissions of SO 2 are de minimis, comprising less than 2%
of total SO 2 emissions from all source categories; therefor e, conformity budgets are not established for

SO 2 . Conformity budgets for direct PM 2.5 emissions do not include either re-entrained road dust or construction dust from transportation projects; however , emission estimates for both of those categories are included in the area source portion of the inventory.

______________________________ 1 EPA previously approved 2009 PM 2.5 and NOx conformity budgets for CT’s portion of the nonattainment area that were established using EPA’s emissions model, MOBILE6.2. Emissions budgets in the maintenance plan are based on EPA’s recently released MOVES model, which supplanted the MOBILE6.2 model as EPA’s required method of determining on-road emissions. CT DEEP is requesting withdrawal of the 2009 MOBILE6.2 budgets and approval of 2017 and 2025 MOVES budgets. See Section 5.1.9 of this TSD for an explanation of why 2009 budgets are no longer necessary and Section 5.1.7 of this TSD for an explanation of wh y CT DEEP elected to use 2009 MOVES on-road estimates in the 2007 attainment year inventory. 0 20,000 40,000 60,000 80,000 100,000 120,000 140,000

0 2,000 4,000 6,000 8,000 10,000 12,000 14,000 16,000 18,000

2007 2017 2025 NY

‐ NJ

‐ CT

TPY CT

TPY 

## SO 2 

## Emission Trends for the

CT Portion and All of the NY

‐ NJ

‐ CT Area CT Point
NonEGU

CT Point EGU

CT Onroad

MOVES

CT Nonroad

NMIM

CT Nonroad

MAR

CT Area

NY

‐ NJ

‐ CT
TOTALS

### E-9 Since total combined emissions from all source sector s are projected to decline significantly during the maintenance period (see Figures E-4 and E-5), both the 2017 and 2025 projected emission levels provide a “safety margin” relative to total emissions in the 20 07 attainment year. CT DEEP is allocating a small portion (i.e., 10%) of that safety margin to the 2017 and 2025 conformity budgets, as shown in Table E-2.

Table E-2 Transportation Conformity Budgets for the Connecticut Portion of the NY-NJ-CT Area

Year PM 2.5 (tons/year) NO
x (tons/year) 2017 On-Road Inventory 467.4 10,708.0 Safety Margin vs. 2007 1083.9 20,837.8 10% of Safety Margin 108.4 2,083.8 2017 Conformity Budget 575.8 12,791.8 2025 On-Road Inventory 378.9 7,113.4 Safety Margin vs. 2007 1371.3 26,146.9 10% of Safety Margin 137.1 2,614.7 2025 Conformity Budget 516.0 9,728.1



### Monitoring Commitment and Tracking Progress of the Maintenance Plan CT DEEP commits to maintaining an appropriate PM 2.5 monitoring network through the maintenance period, with any potential changes to be developed in collaboration with EPA and subject to stakeholder review that occurs with annual monitoring network plans and five-year network assessment reports. CT
DEEP will continue to conduct ambient PM 2.5 monitoring in accordance with 40 CFR 58 requirements and expeditiously review data as it becomes ava ilable to evaluate any risk of impending NAAQS violations. CT DEEP will also regularly review av ailable emission inventory updates produced by EPA
and CT DEEP. Both of these indicators will be u sed as potential triggers for early action in the contingency plan described below.



### Contingency Plan CT DEEP will implement a two-level plan to identify, examine and, if necessary, implement appropriate
action for monitored PM 2.5 levels that approach or violate the 1997 annual or 2006 24-hour PM 2.5 NAAQS. An initial Warning Level Response will be triggered based on PM 2.5 levels that approach the NAAQS. This voluntary commitment is intended to ev aluate the need for early actions to prevent violations of the NAAQS from ever occurring duri ng the maintenance period. The Warning Level Response will be triggered based on annual reviews of measured PM 2.5 levels. If either a single year’s 98th percentile daily value or a single year’s annual average exceeds the NAAQS ( note that violations are based on three year averages), CT DEEP will exam ine available information (e.g., meteorology, exceptional events, local changes in source activity, source malfunctions/noncompliance or unexpected emissions increases) to identify contributing factors and make a judgment on whether any early corrective
actions are warranted.

### E-10 Should early actions not be successful and a subse quent verified violation occurs, an Action Level Response will be triggered. CT D EEP will first conduct the same types of investigations described above to determine potential causes and available resolutio ns. If the causes are within the jurisdiction and control of CT DEEP (e.g., not predominantly due to in terstate transport or exceptional events), one or more control measures such as those in the example list below will be pursued for implementation. Ultimately, contingency measures will be selecte d from a comprehensive list of measures deemed appropriate and effective at the time the selection is made. The selection of measures will be based upon the presumed cause of the violation, cost effectiven ess, emission reduction potential, economic and social considerations, or other appropriate factors. Stak eholder input will be solicited from interested and affected persons in the maintenance area prior to selecting any appropriate contingency measures. Because it is not possible at this time to determine wh at control measure will be appropriate at any future time during the maintenance period, the list of possible measures below is not intended to be exclusive or
exhaustive.

• Control measures already adopted, but designe d to produce additional reductions after the verified violation occurred (e.g., mobile source measures that involve fleet turnover);

• New control measures that may be adopted fo r other purposes (e.g., Tier 3 or CALEV3);

• Corrections to source noncompliance or malfunctions;

• Alternative fuel and/or diesel retrofit programs for fleet vehicle operations;

• New or more stringent PM 2.5 , NOx or SO 2 controls on stationary sources;

• Wood stove change out program;

• “No burn” days during cold weather inversion events;

• Enhanced idle restrictions;

• Transportation control measures selected in consultation with the 

### Connecticut Department of Transportation (CTDOT) and affected local metropolitan pla nning organizations (e.g., traffic flow improvements, transit improvements, tr ip reduction programs, other new or innovative transportation measures).

CT DEEP commits to pursue adoption of any a ppropriate measures with a goal of achieving implementation within 18 months from the date when the violation triggering the Action Level Response is verified. As required by CAA 175A(d), upon ve rification of a NAAQS violation, CT DEEP also commits to implement all measures that were containe d in the SIP before the area was redesignated to
attainment.



### Commitment to Revise Plan CT DEEP commits to submit a revised maintenance pl an eight years after EPA finalizes redesignation.
The revision will demonstrate that attainment will c ontinue to be maintained for the 10 years following the initial 10-year period, as required by CAA section 175A(b).

### E-11 E.6 Withdrawal of the Attainment Demonstration

Connecticut submitted an attainme nt demonstration for Connecticut ’s portion of the NY-NJ-CT annual

PM 2.5 nonattainment area in November 2008. EPA sub sequently issued a Clean Data Determination (CDD) on November 15, 2010 (75 FR 69589), ruling that the NY-NJ-CT area attained the 1997 annual

PM 2.5 standard based on 2007-2009 monitoring data. Among other things, the CDD suspended the requirement for Connecticut to submit an attainment demonstration for the 1997 PM 2.5 NAAQS. Per 40 CFR 51.1004(c), suspension of that requirement remains in place until the area is redesignated to attainment or EPA determines that the area has recorded new violations of the NAAQS.

Citing the November 2010 CDD ruling, EPA has suggest ed that Connecticut withdraw its November 2008 attainment demonstration SIP revision, excep t for adopted control measures. Based on the requirements of 40 CFR 51.1004(c), however, the De partment believes withdrawing the attainment demonstration prior to the date on which EPA appr oves the redesignation/maintenance plan would be premature since violations measured prior to that date could result in reinstatement of the legal obligation
to submit an attainment demonstration.

In light of this concern, the Department hereby with draws the attainment demonstration SIP, effective one day after EPA signs the final rule approving Connectic ut’s redesignation request and maintenance plans. This timing ensures that either the attainment plan or the maintenance plan will be in place at all times for Connecticut’s portion of the area. The Department al so specifies this withdrawal does not apply to any control measure except for the general permit descri bed in Section E.4 of the Executive Summary. All
other control measures remain in the SIP to ensure continued maintenance of the NAAQS.

### 1 

## Chapter 1 Introduction and Background

This technical support document (TSD) presents the Connecticut Department of Energy and Environmental Protection’s (CT DEEP) request to re designate Connecticut’s portion of the New YorkNew Jersey-Connecticut (NY-NJ-CT) area to attain ment for the federal 1997 annual and 2006 24-hour National Ambient Air Quality Standard (NAAQS) for fine particulate matter less than a nominal 2.5 micrometers in diameter (PM 2.5 ). The plan demonstrates that Connecticut’s air quality meets both standards due to a combination of national, regiona l and local control measures implemented to reduce emissions and presents a maintenance plan that will ensure continued attainme nt through the year 2025.



### 1.1 Particulate Matter Format ion and Health Effects

Fine particles in the atmosphere are comprised of a complex mixture of components. Common constituents include: sulfate (SO 4 ); nitrate (NO 3 ); ammonium; elemental carbon; a great variety of organic compounds; and inorganic material, including metals, dus t, sea salt, and other trace elements (generally referred to as ‘crustal material’). Primary particles are emitted directly into the air as a solid or liquid particle (e.g., elemental carbon from diesel engines or fire activities, or condensable organic particles from gasoline engines). Secondary particles form in the atmosphere over time because of various chemical reactions (e.g., gaseous sulfur dioxide and ammonia reacting to form ammonium sulfate particles). Consequently, PM 2.5 experienced at one location can have origins both nearby and distant.

The annual average and 24-hour average PM 2.5 NAAQS were initially established by the United States Environmental Protection Agency (EPA) in 1997 and revised in 2006, based on evidence from numerous health studies demonstrating that serious health effects are associated with exposure to elevated levels of

PM 2.5 . Epidemiological studies have shown statistica lly significant correlations between elevated PM 2.5 levels and premature mortality. In dividuals particularly sensitive to PM 2.5 exposure include older adults, people with heart and lung disease, and children. 1

The health effects associated with exposure to fine particles are significant, mainly because very small particles of this size can easily reach into the deep est regions of the lungs. Significant health effects associated with fine particle exposure include:

• premature mortality;

• aggravation of respiratory and cardiovascula r disease (as evidenced by increased hospital admissions, emergency room visits, school/work absences, and restricted activity days);

• decreased lung function and difficulty breathing;

• asthma attacks; and

• certain cardiovascular problems such as heart attacks and cardiac arrhythmia. 2,3,4

1 62 FR 38652-690 (July 18, 1997).

2 72 FR 20586, April 25, 2007.

3 “Air Quality Criteria for Particulate Matter”, United St ates Environmental Protection Agency, Research Triangle Park, North Carolina: National Center for Environmenta l Assessment—RTP, Office of Research and Development; EPA/600/P–99/002aF and EPA/600/P–99/002bF. October 2004.

### 2 The EPA has estimated that attainment of the annual and daily PM 2.5 standards nationally would prolong tens of thousands of lives and prevent tens of thousands of hospital admissions each year. 5 In addition, these standards would prevent hundreds of thousands of doctor visits, absences from work and school, and respiratory illnesses in children. The elderly have b een shown to be particularly at risk for premature death from the effects of particulate matter. Health studies indicate that there is no clear threshold below which adverse effects are not experienced by at least certain segments of the population.

Although fine particulate matter gene rated from all sources can cause serious health impacts, particulate matter generated from diesel combustion is particular ly troublesome. The concern over diesel particulate matter is two-fold. First, while diesel engines collectively are large sources of NO
x and direct fine particle emissions, they also emit significant amounts of toxic air pollutants. 6 Second, the size of diesel particulate matter may add to its health impacts. Al most all of the particles produced by diesel exhaust are fine particulate matter (below 2.5 micrometers in diameter), much in the ultra-fine range (that is, particles with an aerodynamic diameter of less than 0.1 micrometer). Since both fine and ultra-fine particles are respirable, many of these particles ar e not captured by the human respiratory system’s defense mechanisms and enter deep into the lungs. Studies have shown that ultra-fine particles are so small that they are capable of penetrating all th e way to the cellular level, where they may induce structural damage in the body’s core building blocks.



### 1.2 Particulate Matter NAAQS History

The 1970 Clean Air Act (CAA) amendments established health and welfare protective limits, or national ambient air quality standards (NAAQS), for a number of air pollutants, including particulate matter. EPA first issued standards for total suspended particulat e matter in 1971 and revised the standards to target

PM 10 (i.e., particles less than a nominal 2.5 micrometers in diameter) in 1987 and PM 2.5 1997. In September 2006, the Agency revised the 1997 PM 2.5 standards.



### 1.2.1 1997 PM 2.5 

### NAAQS

On July 18, 1997, the EPA established two primary NAAQS for fine particles:

• An annual PM 2.5 health-based standard of 15 micrograms per cubic meter (μg/m 3 ) (annual arithmetic mean not to be exceeded over a three year average); and

• A daily (24-hour) PM 2.5 health-based standard of 65 μg/m 3 (the three year average of 98 th percentile days, not to be exceeded). 7,8

4 “Provisional Assessment of Recent Stud ies on Health Effects of Particulat e Matter Exposure; National Center for Environmental Assessment, Office of Re search and Development, U.S. Enviro nmental Protection Agency; Research Triangle Park, NC 27711; EPA/600/R-06/063; July 2006.

5 62 FR 38652-690, July 18, 1997.

6 Health Assessment Document for Diesel Engine Exhaus t. United States Environmen tal Protection Agency, Office of Research and Development, National Center for Environmental Assessment, Washington, DC, EPA/600/8- 90/057F, May 1, 2002.

7 62 FR 38652-760, July 18, 1997.

### 3 Simultaneously, the EPA established secondary (welfare-based) PM 2.5 standards identical to the primary
standards. These standards are hereafter referred to as the 1997 PM 2.5 standards. The EPA set the PM 2.5 standards with 24-hour and annual averaging times to protect against effects from short- and long-term exposure identified by a number of published epidemiological studies.

A number of events delayed implementation of the 1997 PM 2.5 standard. 9 Specifically, the EPA’s 1997 standards were challenged by the American Trucking Association, the U.S. Chamber of Commerce, and other state and business groups. The Transportation E quity Act for the Twenty-first Century (TEA-21) revised the deadline to publish nonattainment designati ons in order to provide additional time to collect three years of air quality monitoring data. In February 2001, the Supreme Court upheld the EPA’s authority under the Clean Air Act to set NAAQS th at protect the American public from the harmful effects of air pollution. The Supreme Court also sen t the case back to the D.C. Circuit Court of Appeals to resolve several additional issues. In March 2002, the D.C. Circuit Court addressed all remaining legal challenges to the EPA’s 1997 ambient air quality standards for PM 2.5
.

On December 17, 2004, the EPA finalized atta inment/ nonattainment designations for the 1997 PM 2.5 standards, which became effective on April 5, 2005. 10 EPA determined that air quality in Connecticut complied with the 1997 24-hour PM 2.5 NAAQS, but that emissions from Fairfield and New Haven
Counties contributed to measured violations of the annual PM 2.5 NAAQS in New York City. As a result,
EPA included those two Connecticut counties in a mul ti-state nonattainment area also comprised of the New York and New Jersey counties that make up the New York City Metropolitan Area. The multi-state NY-NJ-CT nonattainment area is depicted in Figure 1-1. The three affected stat es were responsible for developing and coordinating revisions to their respec tive air quality State Implementation Plans (SIPs) to provide for attainment of the 1997 annual PM 2.5 NAAQS by the 2010 attainment deadline. Connecticut
submitted an attainment demonstration SIP to EPA on November 18, 2008 for the 1997 annual PM 2.5 NAAQS. 11 See Section 6.5 for further discussion rela ted to that attainment demonstration.

8 The EPA also revised the PM 10 NAAQS by revising the 24-hour form of the PM 10 standard to the 99 th percentile averaged over 3 years but retaining the 24-hour PM 10 level (i.e., 150 mg/m 3 ) (62 FR 38652 (July 18, 1997)). In 2006, the EPA revoked the annual PM 10 standard (71 FR 61144 (October 17, 2006)). Connecticut was not designated in nonattainment of the PM 10 NAAQS and continues to meet the revised PM 10 standards.

9 EPA Fact Sheet: Areas Designated No nattainment for the Fine Particle National Air Quality Standards. United States Environmental Protectio n Agency, December 17, 2004, http://www.epa.gov/pmdesignations/documents/f inal/factsheet.htm, acce ssed June 28, 2007.

10 72 FR 20586-667, April 25, 2007.

11 Revision to Connecticut’s State Implementation Plan: Annual PM 2.5 Attainment Demonstration ; Connecticut Department of Environmental Protection; November 18, 2008.4Figure 1.1 The NY-NJ-CT Annual and 24-hour PM2.5Nonattainment Areas

### 5 

### 1.2.2 2006 PM 2.5 

### NAAQS

Meanwhile, as required by Clean Air Act (CAA) section 109(d)(1) and governed by a March 2003
consent decree reached with national environmenta l organizations, EPA conducted a review of more
recent health effects studies to assess the adequacy of the 1997 PM 2.5 NAAQS. As result of that review, EPA promulgated 12 revised NAAQS for PM 2.5 . The EPA retained the annual PM 2.5 standard of 15 μ g/m 3

and revised the 24-hour PM 2.5 standard, changing it from 65 μg/m 3 to 35 μg/m 3 . The effective date for
the new 24-hour PM 2.5 standard became December 18, 2006. In December 2007, Connecticut submitted a

recommendation that New Haven and Fairfield C ounties be designated nonattainment for the PM 2.5 

### 24- hour NAAQS based on an analysis of monitored data for the 2004-2006 period. On November 13, 2009, EPA published final designations, effective December 13, 2009, 13 including those two counties in a NYNJ-CT 24-hour PM 2.5 nonattainment area (see Figure 1.1). EPA designated the remainder of the state as
unclassifiable/attainment.

As described in Section 2, PM 2.5 air quality has improved significantl y over the last decade due to emissions reductions resulting from various federal, regional and state control measures. Monitors throughout the NY-NJ-CT area are currently meas uring compliance with both the 1997 and 2006 PM 2.5 NAAQS, meeting one of several eligibility requirements for redesignation to attainment status for both
the annual and 24-hour standards. Other eligibility requirements are outlined below.



### 1.3 Required Elements for PM 2.5 

### Redesignation

Section 107(d) (3) (E) of the CAA provides the m echanism for EPA to redesignate an area from nonattainment to attainment. Redesignation is cont ingent upon the EPA Administrator finding that:

• The area has attained the subject NAAQS;

• The applicable implementation plan for the ar ea is fully approved under CAA section 110(k);

• The State containing such area has met all require ments applicable to the area under CAA section 110 and part D;

• The improvement in air quality is due to pe rmanent and enforceable emission reductions;

• The area has a fully approved a maintenance plan meeting CAA section 175A requirements.

EPA has provided guidance on redesignation in the Gene ral Preamble for the Implementation of title I of the CAA Amendments of 1990 (April 16, 1992, 57 FR 13498, and supplemented on April 28, 1992, 57 FR 18070) and has provided further guidance on processing redesignation requests in the following
documents:

• “Procedures for Processing Requests to Redesignate Areas to Attainment”; Memorandum from John Calcagni, Director, Air Quality Mana gement Division; September 4, 1992.

• “State Implementation Plan (SIP) Actions S ubmitted in Response to Clean Air Act (CAA) Deadlines”; Memorandum from John Calcagni, Director, Air Quality Management Division; October 28, 1992.

12 71 FR 61144, October 17, 2006.

13 74 FR 58688, November 13, 2009.

### 6 • “Part D New Source Review (Part D NSR) Requi rements for Areas Requesting Redesignation to Attainment”; Memorandum from Mary D. Nichols, Assistant Administrator for Air and Radiation; October 14, 1994.

The remainder of this TSD provides information d escribing how Connecticut’s portion of the NY-NJ-CT nonattainment area meets these requirements for redesigna tion to attainment for both the 1997 annual and
2006 24-hour PM 2.5 NAAQS. Section 2 provides a review of monitored PM 2.5 data, analyzing trends and showing that Connecticut’s monitors comply with the NAAQS. Section 3 documents that Connecticut’s SIP meets all applicable CAA Section 110 and part D requirements. Section 4 describes the regulatory control programs that have produced the improvements in PM 2.5 air quality. Section 5 presents the maintenance plan for the CT portion of the NY-NJ-CT area, addressing each of the required elements of CAA Section 175A, including transportation conformi ty emission budgets that will be used in the development of future transportation plans by the Connecticut Department of Transportation (CTDOT) and affected Metropolitan Planning Organizations (M PO) in the area. Section 6 summarizes the TSD, requesting EPA action to redesignate the area to a ttainment. Several appendices are also included, providing supporting details for the previous sections.

### 7 

## Chapter 2 Demonstration of Attainment of the PM 2.5 

## Standards

This section documents that the 1997 a nnual and 2006 24-hour (daily) NAAQS for PM 2.5 have been attained at all monitors located throughout the NY-NJ-CT nonattainment area. Measured attainment of the NAAQS is a key factor in meeting the eligibilit y requirements of CAA section 107(d)(3)(E) for redesignation to attainment. The EPA has already fina lized a finding that the area has attained the annual

PM 2.5 NAAQS. 14 On February 8, 2011, CT DEEP made a formal request 15 to EPA to make a similar
determination that the NY-NJ-CT non-attainment area has attained the 2006 24-hour NAAQS for PM 2.5
. EPA is currently considering this request. An analys is of relevant monitoring data is provided below, with a focus on Connecticut’s monitoring network. 16



### 2.1 Monitoring Network

The CT DEEP maintains a comprehensive network of PM 2.5 air quality monitors located throughout Connecticut with the primary objective be ing to determine compliance with the PM 2.5 NAAQS. The CT DEEP submits network reviews to the EPA Region 1 annually, demonstrating that air monitoring operations meet or surpass all applicable federal re quirements. Figure 2.1 is a map illustrating the portion
of Connecticut within the NY-NJ-CT nonattainment area and the locations of Connecticut’s federal reference method (FRM) PM 2.5 monitors, as of the end of 2010. CT DEEP continues to operate these
eleven FRM PM 2.5 sites, with seven of the monitors located in Connecticut’s portion of the nonattainment area. In addition, in 2009, CT DEEP shut down two sites in the City of New Haven that were operating as special purpose monitors. PM 2.5 levels at those sites were lower than measurements at the remaining two sites in the city.



### 2.2 Data Handling and Quality Assurance

State air monitoring data are submitted to EPA’s data repository called the Air Quality System (AQS).
All Connecticut data described in this section ar e included in AQS and have been quality assured, meeting the requirements specified in Title 40 of the Code of Federal Regulations (CFR) Part 58 Appendix A . The completeness criteria for ambien t monitoring data are specified in 40 CFR, Part 50, National Primary and Secondary Ambient Air Quality Standards: Appendix N. A minimum completeness of 75 percent per quarter for each year period is re quired at each monitoring site. Data completeness information is presented in Table 2.1. Six of Connecticut’s current seven PM 2.5 monitors located

14 75 FR 69589, November 15, 2010. EPA’s “clean data” finding established that the area is measuring compliance with the NAAQS, although the area remains classified as nonattainment until EPA approves a redesignation request documenting that all CAA sections 107(d)(3)(E) have been satisfied.

15 Clean Data Request Letter for 24-hr PM 2.5 NAAQS , February 8, 2011.

16 Design values for monitors in the NY and NJ portions of the nonattainment area ar e also summarized in this section. Both NY and NJ have indicated their intention to submit similar PM 2.5 redesignation requests, which will include more detailed descriptions of each state’s monitoring network and data trends.8Figure 2.1 Connecticut’s PM2.5MonitoringNetwork9SITE%Complete2008 Qtr1%Complete2008 Qtr2%Complete2008 Qtr3%Complete2008 Qtr4%Complete2009 Qtr1%Complete2009 Qtr2%Complete2009 Qtr3%Complete2009 Qtr4%Complete2010 Qtr1%Complete2010 Qtr2%Complete2010 Qtr3%Complete2010 Qtr4Bridgeport(090010010)87% 100% 81% 90% 87% 97% 93% 90% 97% 100% 77% 100%Danbury(90011123)94% 97% 94% 97% 93% 97% 93% 100% 90% 100% 100% 100%Norwalk(090013005)90% 97% 90% 87% 90% 90% 93% 97% 57%* 100% 100% 100%Westport(090019003)84% 100% 99% 99% 84% 93% 99% 86% 100% 97% 100% 98%New HavenFirehouse(090090026)100% 100% 97% 97% 100% 100% 100% 100% 37%**New HavenCriscuolo(090090027)96% 97% 95% 100% 94% 99% 98% 100% 98% 99% 98% 99%New HavenState Street(090091123)100% 100% 87% 100% 100% 100% 100% 94% 100% 100% 94% 94%New HavenAg Station(090092008)100% 100% 87% 83% 87% 100% 100% 100% 37%**Waterbury(090092123)97% 100% 100% 100% 100% 87% 100% 100% 100% 100% 100% 100%* Data incomplete due to roof construction.** Site removed 2/1/2010.Table 2.1 Connecticut PM2.5Monitors: Data Completeness byQuarter 2008 – 2010

### 10 in the NY-NJ-CT nonattainment area met the comple teness criteria for the 2008-2010 period. The Norwalk monitor was temporarily removed during the first quarter of 2010 to allow roof repair/construction. Historically, measured values at the Norwalk site have been among the lowest in Connecticut’s portion of the NY-NJ-CT area.



### 2.3 PM 2.5 

### Monitoring Data Analysis

Data from air quality monitors are used to calculate design values (DV) 17 at each site. The monitor with the highest DV dictates whether the area co mplies with the NAAQS. For the annual PM 2.5 NAAQS, the annual DV for each monitor is defined as the three-year average of valid annual means. When calculating an annual DV, intermediate calculations are not rounde d, while final values are rounded to the nearest 0.1

μ g/m 3 . Rounded values at or below 15.0 μ g/m 3 meet the standard. Rounded values equal to or greater
than 15.1 μ g/m 3 exceed the standard.

The design value for the 24-hour NAAQS is calculated for each site as the three-year average of the
annual 98 th percentile 24-hour average values. When cal culating a monitor’s 24-hour DV, intermediate calculations are not rounded, while final values rounded to the nearest 1 μ g/m 3 . Rounded values at or
below 35 μ g/m 3 meet the standard. Rounded values equal to or greater than 36 μ g/m 3 exceed the standard.

Current (i.e., 2010) PM 2.5 design values throughout the NY-NJ-CT nonattainment area are in compliance with both the annual NAAQS of 15.0 μg/m 3 and the 24-hour NAAQS of 35 μg/m 3 , as shown in Figures 2.2 and 2.3, respectively. The maximum 2010 DVs measured anywhere in the NY-NJ-CT area are 12.5 μg/m 3 for the annual standard (Morrisania monitor in the Bronx, NY) and 30 μg/m 3 for the 24-hour NAAQS (Elizabeth Turnpike site in New Jersey).

PM 2.5 air quality has improved significantly over the l ast decade in Connecticut and throughout the NYNJ-CT nonattainment area. Annual design values for 2007 through 2010 are summarized in Table 2.2 for monitors in Connecticut’s portion of the NY-NJ -CT nonattainment area. Annual DVs at each
Connecticut site have co mplied with the annual PM 2.5 NAAQS throughout the period, with maximum DVs in Connecticut of 13.2 μg/m 3 in 2007, 12.4 μg/m 3 in 2008, 11.4 μg/m 3 in 2009 and 10.3 μg/m 3 in 2010. Maximum DVs anywhere in the NY-NJ-CT area were 15.9 μg/m 3 in 2007, 14.3 μg/m 3 in 2008, 13.9 μg/m 3 in 2009 and 12.5 μg/m 3 in 2010, indicating that the NY-NJ -CT area first achieved attainment levels of the annual NAAQS in 2008.

Table 2.3 summarizes 24-hour design values for 2007 through 2010 for monitors in Connecticut’s portion
of the NY-NJ-CT nonattainment area. Maximum 24- hour DVs for the Connecticut monitors were 36 μg/m 3 in 2007, 34 μg/m 3 in 2008, 31 μg/m 3 in 2009 and 29 μg/m 3 in 2010. Maximum DVs in the

17 A basic summary of design value calculations is provided here. For a more complete description, see 40 CFR Part 50 Appendix N: Interpretation of the National Ambient Air Quality Standards for PM 2.5
.11Figure 2.2 2010 Annual Design Values12Figure 2.3 2010 24-hour Design Values

### 13 

## Table 2.2 Annual PM 2.5 

## Design Values 1 

## in Connecticut’s Portion of the NY-NJ-CT Nonattainment Area 2 

## ( μ g/m 3 

## )

Site 2007 2008 2009 2010

Bridgeport (09-001-0010) 13.2 12.4 11.3 10.0

Danbury (09-001-1123) 12.6 12.0 11.0 10.0

Norwalk (09-001-3005) 12.3 11.8 11.1 10.0

Westport (09-001-9003) 11.3 10.6 10.0 9.2

New Haven Fire House (09-009-0026) 12.1 11.6 10.8 Removed 3

New Haven Criscuolo (09-009-0027) 12.3 11.7 10.8 10.0

New Haven State St (09-009-1123) 12.8 12.2 11.4 10.3

New Haven Ag Station (09-009-2008) 11.1 10.7 9.9 Removed 3

Waterbury (09-009-2123) 12.6 11.9 11.0 10.1



## Table 2.3 24-hour PM 2.5 

## Design Values 1 

## in Connecticut’s Portion of the NY-NJ-CT Nonattainment Area 2 

## ( μ g/m 3 

## )

Site 2007 2008 2009 2010

Bridgeport (09-001-0010) 35 33 31 28

Danbury (09-001-1123) 33 31 29 27

Norwalk (09-001-3005) 34 31 29 26 (Inc 4 )

Westport (09-001-9003) 32 30 29 27

New Haven Fire House (09-009-0026) 34 32 30 Removed 3

New Haven Criscuolo (09-009-0027) 35 33 31 29

New Haven State Street (09-009-1123) 36 34 31 29

New Haven Ag Station (9-009-2008) 32 29 27 Removed 3

Waterbury (09-009-2123) 35 32 30 27

Notes for both tables:

1 The annual PM 2.5 NAAQS is 15.0 μ g/m 3 . The 24-hour PM 2.5 NAAQS is 35 μ g/m 3

. 2 Data from EPA’s design value website: http://www.epa.gov/airtrends/values.html

3 These sites were removed in 2010 after meas uring lower values than other New Haven sites

. 4 The Norwalk site had one incomplete calendar quarter in 2010 (less than 75% data capture), due to roof construction that required temporary monitor removal.

### 14 NY-NJ-CT nonattainment area were 41 μg/m 3 in 2007, 38 μg/m 3 in 2008, 33 μg/m 3 in 2009 and 30 μg/m 3

in 2010. Tables 2.2 and 2.3 demonstrate that Connec ticut’s portion of the nonattainment area have been in compliance with the 24-hour NAAQS since 2008, wh ile the NY-NJ-CT area as a whole first achieved
attainment levels in 2009.

The overall downward trend in PM 2.5 concentrations is evident in the 10-year DV trend plots displayed in Figures 2.4 through 2.9. Figures 2.4 through 2.6 respectively show the significant decline in annual DVs in the Connecticut, New York and New Jersey portions of the nonattainment area during the 2001-2010 period. Similar trends are obvious in Figures 2.7 through 2.9, which depict 24-hour DVs in each state’s portion of the nonattainment area. See Section 4 for a discussion of national, regional and state emission control programs that have prompted the improvements in PM 2.5 air quality. Existing control programs are expected to provide further air quality improvements through the maintenance period.15Figure 2.4 Annual Design Value Trends for Monitors in Connecticut’s Portion of the NY-NJ-CT Area0246810121416182001 2002 2003 2004 2005 2006 2007 2008 2009 2010

μ g/m 3ConnecticutAnnualPM2.5DesignValues2001‐2010Bridgeport(09‐001‐0010)Danbury(09‐001‐1123)StamfordHS(09‐001‐2124)Norwalk(09‐001‐3005)Westport(09‐001‐9003)NewHavenFireHouse(09‐009‐0026)NewHavenCriscuolo(09‐009‐0027)NewHavenStateSt(09‐009‐1123)NewHavenAgStation(09‐009‐2008)Waterbury(09‐009‐2123)HamdenMillrock(09‐009‐9005)AnnualNAAQS16Figure 2.5 Annual Design Value Trends for Monitors in New York’sPortion of the NY-NJ-CT Area024681012141618202001 2002 2003 2004 2005 2006 2007 2008 2009 2010

μ g/m 3NewYorkAnnualPM2.5DesignValues2001‐2010NewYorkMorrisania(36‐005‐0080)BotanicalGardens(36‐005‐0083)NewYorkIS52(36‐005‐0110)BotanicalGardensPfizer(36‐005‐0133)NewYorkPS321(36‐047‐0076)NewYorkJHS126(36‐047‐0122)CedarhurstHempstead(36‐059‐0008)NewYorkPS59(36‐061‐0056)CanalStreetPO(36‐061‐0062)NewYorkJHS45(36‐061‐0079)NewYorkPS19(36‐061‐0128)NewYorkPS124(36‐061‐0134)Newburgh(36‐071‐0002)NewYorkQueensCollege(36‐081‐0124)PortRichmond(36‐085‐0055)NewYorkSusanWagner(36‐085‐0067)BabylonMAM(36‐103‐0001)Babylon(36‐103‐0002)Mamaroneck(36‐119‐1002)AnnualNAAQS17Figure 2.6 Annual Design Value Trends for Monitors in New Jersey’sportion of the NY-NJ-CT Area024681012141618202001 2002 2003 2004 2005 2006 2007 2008 2009 2010

μ g/m 3NewJerseyAnnualPM2.5DesignValues2001‐2010FortLee(34‐003‐0003)Newark(34‐013‐0015)JerseyCity(34‐017‐1003)UnionCity(34‐017‐2002)Trenton(34‐021‐0008)WashingtonCrossing(34‐021‐8001)NorthBrunswickTownship(34‐023‐0006)Morristown(34‐027‐0004)Chester(34‐027‐3001)Paterson(34‐031‐0005)AnnualNAAQS18Figure 2.7 24-hour Design Value Trends for Monitors in Connecticut’sportion of the NY-NJ-CT Area0510152025303540452001 2002 2003 2004 2005 2006 2007 2008 2009 2010

μ g/m 3Connecticut24‐hrPM2.5DesignValues2001‐2010Bridgeport(09‐001‐0010)Danbury(09‐001‐1123)StamfordHS(09‐001‐2124)Norwalk(09‐001‐3005)Westport(09‐001‐9003)NewHavenFireHouse(09‐009‐0026)NewHavenCriscuolo(09‐009‐0027)NewHavenStateSt(09‐009‐1123)NewHavenAgStation(09‐009‐2008)Waterbury(09‐009‐2123)HamdenMillrock(09‐009‐9005)24‐hrNAAQS19Figure 2.8 24-hour Design Value Trends for Monitors in New York’sportion of the NY-NJ-CT Area051015202530354045502001 2002 2003 2004 2005 2006 2007 2008 2009 2010

μ g/m 3NewYork24‐hrPM2.5DesignValues2001‐2010NewYorkMorrisania(36‐005‐0080)BotanicalGardens(36‐005‐0083)NewYorkIS52(36‐005‐0110)BotanicalGardensPfizer(36‐005‐0133)NewYorkJHS126(36‐047‐0122)CedarhurstHempstead(36‐059‐0008)NewYorkJHS45(36‐061‐0079)NewYorkPS19(36‐061‐0128)NewYorkPS124(36‐061‐0134)NewYorkQueensCollege(36‐081‐0124)PortRichmond(36‐085‐0055)NewYorkSusanWagner(36‐085‐0067)Babylon(36‐103‐0002)Mamaroneck(36‐119‐1002)NewYorkPS321(36‐047‐0076)BabylonMAM(36‐103‐0001)Newburgh(36‐071‐0002)NewYorkPS59(36‐061‐0056)CanalStreetPO(36‐061‐0062)24‐hrNAAQS20Figure 2.9 24-hour Design Value Trends for Monitors in New Jersey’sportion of the NY-NJ-CT Area051015202530354045502001 2002 2003 2004 2005 2006 2007 2008 2009 2010

μ g/m 3NewJersey24‐hrPM2.5DesignValues2001‐2010FortLee(34‐003‐0003)Newark(34‐013‐0015)JerseyCity(34‐017‐1003)UnionCity(34‐017‐2002)Trenton(34‐021‐0008)WashingtonCrossing(34‐021‐8001)NorthBrunswickTownship(34‐023‐0006)Morristown(34‐027‐0004)Chester(34‐027‐3001)Paterson(34‐031‐0005)ElizabethTurnpike(34‐039‐0004)ElizabethDowntown(34‐039‐0006)Rahway(34‐039‐2003)24‐hrNAAQS

### 21 

## Chapter 3 Applicable Requirements Under CAA Section 110 and Title 1 Part D

As a precondition to redesignating a nonattainment area to attainment, the CAA requires EPA to determine that the state has met all applicable requi rements under section 110 and part D of title I of the CAA (per CAA section 107(d)(3)(E)(v)) and that the state has a fully approved SIP under section 110(k) for the area (per CAA section 107(d)(3)(E)(ii)). In previous PM 2.5 redesignation approvals for other

areas, 18 EPA has described the elements that must be in place to satisfy each of these requirements, differentiating between the elements that are appli cable for purposes of redesignation and those that are not. Drawing from these previous EPA rulemakings, this section describes how Connecticut has met the relevant requirements.



### 3.1 Satisfying Section 11 0 General SIP Requirements

Section 110(a) of Title I of the CAA contains the general requirements for a SIP. Section 110(a)(2) provides that the implementation plan submitted by a state must have been adopted by the state after reasonable public notice and hearing, and, among other things, must:

• Include enforceable emission limitations and ot her control measures, means or techniques necessary to meet the requirements of the CAA;

• Provide for establishment and operation of approp riate devices, methods, systems, and procedures necessary to monitor ambient air quality;

• Provide for implementation of a source perm it program to regulate the modification and construction of any stationary source within the areas covered by the plan;

• Include provisions for the implementation of pa rt C, Prevention of Significant Deterioration (PSD) and part D, New Source Re view (NSR) permit programs;

• Include criteria for stationary source emission c ontrol measures, monitoring, and reporting; and

• Include provisions for air quality modeling; and pr ovide for public and local agency participation in planning and emission control rule development.

Connecticut has submitted “infrastructure SIPs,” addressing each of these CAA section 110(a)(2) requirements, for both the 1997 annual 19 and 2006 24-hour 20 PM 2.5 NAAQS. EPA has found
Connecticut’s infrastructure SIP submittal for the 1997 annual NAAQS to be complete, 21 but has not
taken final action. EPA has not taken any action on the 24-hour PM 2.5 infrastructure SIP. Regardless, EPA’s previous rulemakings have c oncluded that, for purposes of redesignation, an area is only subject to
those section 110 elements connected with nonattainment plan submissions or an area’s attainment status because the area will still be subject to all other secti on 110 elements after redesignation to attainment.

Similarly, CAA section 110(a)(2)(D) requires that SI Ps contain measures to prevent sources in a state from significantly contributing to air quality problems in another state. EPA’s previous redesignation

18 For examples, see 76 FR 59512 (September 27, 2011), 76 FR 70078 and 76 FR 70091 (both November 10, 2011).

19 Submitted to EPA on 9/4/2008

. 20 Submitted to EPA on 9/18/2009 , with supplements submitted on 1/7/2011 and 8/19/2011

. 21 73 FR 62902 (October 22, 2008).

### 22 rulemakings have concluded that this requirement is not applicable for purposes of redesignation 22 because the transport SIP submittal requirements, where a pplicable, continue to a pply to a state regardless of the designation of any one particular area within that state.



### 3.2 Satisfying Part D Requirements

CAA Title I, Part D, Subpart 1 sets forth the b asic nonattainment requirements applicable to all nonattainment areas. All areas that were designate d nonattainment for the 1997 annual or the 2006 24-
hour PM 2.5 NAAQS were designated under this subpart of th e CAA, and the requirements applicable to
them are contained in sections 172 and 176. For purposes of evaluating redesignation requests, the applicable part D, subpart 1 SIP requirements are c ontained in sections 172(c )(1)–(9) and in section 176. 23

As described in Section 1 of this document, in December 2004, EPA designated the NY-NJ-CT area as
nonattainment for the 1997 annual PM 2.5 NAAQS, triggering the requirement for an implementation plan under CAA section 172(b). On April 25, 2007, EPA promulgated its PM 2.5 implementation rule, 24 providing guidance for states to develop implementation plans for the annual NAAQS. Connecticut subsequently submitted an attainme nt demonstration for its portion of the annual nonattainment area on November 18, 2008, meeting the requirements of EPA ’s implementation rule and CAA sections 172 and

176.

In 2006, EPA promulgated revisions to the PM 2.5 NAAQS, lowering the 24-hour standard to 35 μg/m 3

. Final designations for the revised 24-hour standard became effective in December 2009, retaining the
same NY-NJ-CT nonattainment boundaries as for the annual NAAQS. Attainment demonstrations addressing CAA sections 172 and 176 for the 24-hour NAAQS are due in December 2012. EPA issued guidance for implementing the 24-hour NAAQS on March 2, 2012. The requirement for a state to submit an attainment demonstration will no longer apply if EPA rules that an area measures attainment of the NAAQS (i.e., the area has “clean da ta” in accordance with 40 CFR 51.1 004(c)), or if EPA approves a redesignation request for the 24-hour NAAQS before the December 2012 due date.

Section 2 of this document described how PM 2.5 air quality has significantly improved over the last decade. In fact, all monitors in the NY-NJ-CT area have complied with both the annual and 24-hour NAAQS since 2009. EPA recognized the improvement by promulgating “clean data” findings 25 that the
multi-state nonattainment area has attained the annual NAAQS and that attainment was achieved by April 5, 2010, as required under the provisions of EPA’s PM 2.5 implementation rule. Connecticut has also formally requested 26 similar “clean data” findings for the 24-hour NAAQS and is awaiting EPA action.

22 Nonetheless, EPA modeling in support of the Cross-State Air Pollution Rule (76 FR 48208, August 8, 2011) shows that Connecticut does not significantly contribute to nonattainment or maintenance issues in any other state for the 1997 annual and 2006 24-hour PM 2.5 NAAQS, thus satisfying CAA sec tion 110(a)(2)(D) requirements.

23 A thorough discussion of the requirements contained in section 172 can be found in the General Preamble for Implementation of Title I (see 57 FR 13498, April 16, 1992 ). The preamble also includes EPA’s view of applicable requirements for purposes of evaluating redesignation requests when an area is attaining a standard.

24 72 FR 20664, April 25, 2007. Codified at 40 CFR Part 51, subpart Z.

25 75 FR 69589, November 15, 2010. See also see 40 CFR 51.1004.

26 Clean Data Request Letter for 24-hr PM 2.5 NAAQS , February 8, 2011.

### 23 As stipulated in 40 CFR 51.1004(c), EPA’s “clean data” finding for the annual NAAQS suspends the requirements for Connecticut to submit an attainment demonstration and associated reasonably available control measures (CAA section 172(c)(1) and (c )(6)), reasonable further progress requirements (172(c)(2)), contingency measures (172(c)(9)), and other planning SIPs related to attainment of the 1997

PM 2.5 annual NAAQS for so long as th e area continues to attain that NAAQS. As noted above, Connecticut previously submitted all of these CAA sec tion 172 planning elements to EPA for approval as part of the attainment demonstration for the annual PM 2.5 NAAQS, although EPA has yet to take action approving the implementation plan (see Section 6.5 for further discussion related to the attainment demonstration). Nonetheless, per the “clean dat a” finding, and since the NY-NJ-CT area continues to
measure attainment of the annual PM 2.5 NAAQS, the requirement for these implementation plan elements remains suspended, and therefore, are not applicable . A similar conclusion would apply for the 24-hour NAAQS, assuming EPA approves Connecticut’s pending request for a “clean data” finding, either prior to, or along with approval of the redesignation request and maintenance plan.

Section 172(c)(4) requires the identification and quantif ication of allowable emissions for major new and modified stationary sources in an area, and section 172(c)(5) requires source permits for the construction and operation of new and modified major stationa ry sources in the nonattainment area. EPA has previously issued approvals of Connec ticut’s new source review (NSR) program. 27 In addition, when the
1997 annual PM 2.5 NAAQS was promulgated, EPA allowed states to use the pollutant PM 10 as a surrogate
for PM 2.5 in new source review (NSR) permitting programs until certain technical problems were resolved and EPA issued guidance for the states. EPA subse quently issued two relevant implementation rules 28 and required states to adopt the necessary requirements by July 20, 2012. CT DEEP held a public hearing on November 9, 2011, to consid er revisions to RCSA sections 22a -174-1 and 22a-174-3a to include significant impact levels, significant emissions rates and increments for PM 2.5 , consistent with EPA’s requirements. CT DEEP anticipates that the revised regulations will be submitted as a SIP revision by the end of summer 2012, at which point Connecticut will have in place all applicable CAA Section 110 and Title 1 Part D requirements necessary for PM 2.5 redesignation.

EPA has previously ruled that areas need not ha ve a fully approved nonattainment NSR program for purposes of redesignation 29 since prevention of significant deterioration (PSD) requirements will apply after redesignation. Connecticut’s current PSD progr am will become effective in the Connecticut portion of the NY-NJ-CT area upon redesignation to attainment.

Section 172(c)(7) requires the SIP to meet the applicab le provisions of section 110( a)(2). As noted above in Section 3.1, EPA’s previous rule makings have concluded that this requirement is not applicable for purposes of redesignation because the transport SIP subm ittal requirements continue to apply to a state regardless of the designation of any one particular area within that state.

27 40 CFR 52.385.

28 73 FR 28321, May 16, 2008 and 75 FR 64864, October 20, 2010.

29 Memorandum from Mary Nichols, Assistant Administrator for Air and Radiation; “Part D New Source Review Requirements for Areas Requesting Redesignation to Attainment”; October 14, 1994,

### 24 Section 176(c) of the CAA requires states to establis h criteria and procedures to ensure that federally supported or funded activities, including highway proj ects, conform to the air quality planning goals in the applicable SIPs. The requirement to determine co nformity applies to transportation plans, programs, and projects developed, funded, or approved under Title 23 of the U.S. Code and the Federal Transit Act (transportation conformity) as well as to all other federally-supported or funded projects (general conformity). EPA interprets the conformity SIP re quirements as not applying for purposes of evaluating a redesignation request under section 107(d) because state conformity rules are still required after redesignation and federal conformity rules apply where state rules have not been approved. Section 5.1.9 of this document includes transportation conformity budgets that, upon approval by EPA, will be required for use in future transportation planning efforts.

The only remaining part D, subpart 1 element that must be addressed for both the annual and 24-hour

PM 2.5 NAAQS is the section 172(c)(3) requirement for an inventory of actual emissions for the area. Included as part of this redesignation request (see Sec tion 5), is a 2007 base year emissions inventory that meets the section 172(c)(3) requirement. When EPA a pproves this inventory, Connecticut’s portion of the NY-NJ-CT area will meet the applicable SIP re quirements for purposes of redesignation under title I, part D of the CAA.



### 3.3 Fully Approved SIP Under Section 110(k)

As described above, consistent with the pr evious EPA rulemakings approving other PM 2.5 redesignation requests, when EPA issues final approval of Connectic ut’s base year emissions inventory, EPA will have fully approved the applicable Connecticut SIP for Connecticut’s portion of the NY-NJ-CT annual and 24-
hour PM 2.5 nonattainment areas under CAA section 110(k) fo r all requirements applicable for purposes of redesignation.

### 25 

## Chapter 4 Permanent and Enfo rceable Emission Reductions

CAA section 107(d)(3)(E)(iv) specifies that a nonattain ment area cannot be redesignated to attainment unless EPA determines that the improvements in ai r quality are due to permanent and enforceable
emission reductions. This section doc uments that reductions in direct PM 2.5 and PM 2.5 precursor emissions (e.g., SO 2 and NO
x ) have occurred in Connecticut and in upwind areas as a result of permanent and enforceable federal and state control measures, accounting for the significant improvements realized
in measured PM 2.5 air quality. Post-2002 NOx, SO 2 and PM 2.5 control measures that have resulted in improvements in ambient PM 2.5 levels are listed in Table 4.1. D escriptions of the federal and state
measures follow.



### 4.1 Federal Control Measures

Improvements in Connecticut’s ambient PM 2.5 air quality are partially due to federal control programs that
have reduced emissions in Connectic ut and other states. Transported emissions are especially important
because PM 2.5 concentrations in Connecticut are strongly affected by PM 2.5 secondary components such as sulfates and nitrates that result from precursor emissions of SO 2 and NOx from upwind states. Post2002 30 federal measures that have contributed to me asured attainment of the annual and 24-hour PM 2.5 NAAQS are listed in Table 4.1 and described below.



### 4.1.1 Tier 2 Vehicle Standards and Gasoline Sulfur Standards

The federal Tier 2 rule 31 , promulgated in February 2000, phased in more stringent vehicle emission standards between 2004 and 2009, resulting in lower emissions of NOx, PM and sulfur compounds from new cars and light duty trucks, including large sport utility vehicles and passenger vans. The final Tier 2
standards limit NO
x levels for new vehicles to an average of 0.07 grams per mile (g/mi), requiring new vehicles to be 77% to 95% lower emitting than those on the road prior to the program. The Tier 2 standards also reduced the sulfur content of gaso line to 30 parts per million (ppm) by 2006, about an order of magnitude lower than 2002 levels. Sulfur in gasoline interferes with the operation of catalytic converters on vehicles resulting in higher NO
x emissions. In addition to facilitating lower emissions from new Tier 2 equipped vehicles, the required lower sulfur levels also produced immediate emission reductions from older pre-Tier 2 vehicles due to less poisoning of catalysts on those vehicles. Further reductions will occur through the maintenance peri od as vehicle turnover increases the proportion of Tier
2 vehicles in the fleet.

30 Designations for the 1997 annual PM 2.5 NAAQS were based on 2001-2003 monitored data; therefore, reductions since 2002 have contributed to measured air quality improvements since that period.

31 http://www.epa.gov/fedrgstr/EPA-AIR /2000/February/Day-10/a19a.pdf

### 26 

## Table 4.1 Post-2002 Control Measures

Control Measure PM NO X SO 2 Federal Programs

Tier 2 Vehicle Standards and Gasoline Sulfur Standards X X X Heavy-Duty Diesel and Gasoline Highway Vehicle Standards X X X Motorcycle Exhaust Standards X Large Non-road Diesel Engine Standards X X X Non-road Spark-Ignition Engines and Recreational Engine
Standards X X X

NOx SIP Call X

CAIR X X State Programs Control of Sulfur Dioxide and Nitrogen Oxide Emissions from Power Plants and Other Large Stationary Sources RCSA Sections 22a-174-19a and 22a-174-22(e)(3) X X

The Post-2002 Nitrogen Oxides (NOx) Budget Program
RCSA Section 22a-174-22b X

CAIR NO X Ozone Season Trading Program
RCSA Section 22a-174-22c X

Outdoor Wood Burning Furnace Restrictions
Section 22a-174k of the Connecticut General Statutes X

Improvements in the Control of Particulate Matter and Visible
Emissions RCSA Section 22a-174-18 X X

Connecticut Enhanced Inspection and Maintenance Program (ASM 2525 final standards and OBD II program)
RCSA Section 22a-174-27 X

CT’s California Low Emission Vehicle Phase 2 (CALEV2)
RCSA Section 22a-174-36b X X

Reductions in NOx emissions from Municipal Waste Combustors (Phase 2) RCSA Section 22a-174-38 X

NSR Permit to Construct and Operate Stationary Sources
RCSA Section 22a-174-3a X X X

### 27 

### 4.1.2 Heavy-Duty Diesel and Ga soline Highway Vehicle Standards

New U.S. EPA standards 32,33 designed to reduce NO
x and VOC emissions from heavy-duty diesel and gasoline highway vehicles took effect in 2004 and 2005, respectively. A second phase of standards, 34 commencing in 2007, established tighter PM and NO
x emission limits for heavy- duty diesel and gasoline highway engines and also required highway diesel fuel sulfur content to be re duced by 97% to 15 ppm to minimize potential damage to emission control devices. EPA estimates that the total program achieves a
90% reduction in PM emissions and a 95% reduction in NO
x emissions from new engines using low sulfur diesel, compared to previous generation engine s using higher sulfur content diesel. The reduction in fuel sulfur content also provided additional immedi ate reductions in sulfate particle emissions from all
on-road diesel vehicles. Further emission reductions will occur through the maintenance period with fleet

turnover.



### 4.1.3 Motorcycle Exhaust Standards

In 2004, EPA published a final rule to implement improved exhaust emission standards on new highway motorcycles. 35 These exhaust emission standards apply to all 2006 model year and newer motorcycles, including scooters and mopeds. In addition, motorcyc les with the largest engines are subject to more stringent NO
x and hydrocarbon standards beginning with the 2010 model year.



### 4.1.4 Large Non-road Di esel Engine Standards

In May 2004, EPA expanded on previous requirements 36 by adopting a new rule 37 establishing tighter emission limits for large non-road diesel engines, such as those used in construction, agricultural, and industrial equipment, to be phased in between 2008 and 2014. The non-road diesel rule also required
reductions in the sulfur content of non-road diesel fuel from pre-rule levels of approximately 3,400 ppm to 500 ppm by 2006, with a further reduction to 15 ppm by 2010, a total reduction of over 99 percent. The combined engine and fuel rules reduced NO
x and PM emissions from new large non-road diesel engines by over 90%, compared to previous generation non-road engines using higher sulfur content diesel fuel. Given the timing of the new requireme nts, most of the reductions will occur during the maintenance period as the fleet of older non-road diesel engines is gradually re placed with the newer, lower emitting engines. Nonetheless, the required reducti on in fuel sulfur content did yield an immediate reduction in sulfate particle emissions from all non-road diesel vehicles.

32 http://www.epa.gov/fedrgstr/EPA-AIR /1997/October/Day-21/a27494.htm

33 http://www.epa.gov/fedrgstr/EPA-AIR /2000/October/Day-06/a20144.pdf

34 http://www.epa.gov/fedrgstr/EPA-AIR /2001/January/Day-18/a01a.pdf

35 69 FR 2398; January 15, 2004. See http://www.epa.gov/fedrgstr/EP A-GENERAL/2004/January/Day15/g006.htm

36 http://www.epa.gov/fedrgstr/EPA-AIR /1998/October/Day-23/a24836.htm

37 http://edocket.acce ss.gpo.gov/2004/pd f/04-11293.pdf

### 28 

### 4.1.5 Non-road Spark-Ignition Engines and Recreational Engine Standards

In November 2002, EPA prom ulgated emission standards 38 for groups of previously unregulated non-road engines. These engines include large spark-ignition e ngines such as those used in forklifts and airport ground service equipment; recreational vehicles usi ng spark-ignition engines such as off highway motorcycles, all-terrain vehicles, and snowmobiles; and recreational marine diesel engines. Emission standards from large spark ignition engines were implem ented in two tiers, with Tier 1 starting in 2004
and Tier 2 in 2007. Recreational vehicle emission st andards are being phased in from 2006 through 2012. Marine diesel engine standards were phased in fro m 2006 through 2009. With full implementation of the entire non-road spark-ignition engine and recreationa l engine standards, an 80% reduction in NOx is expected by 2020, as the affected fleets are gradually replaced.



### 4.1.6 NO
x 

### SIP Call, CAIR and CSAPR Programs

In October 1998, EPA issued a NO
x SIP Call 39 requiring the District of Columbia and 22 states (including Connecticut) to reduce emissions of NO
x . The program was primarily targeted at securing emission reductions from electric generating units (EGUs or power plants) in states that were determined to be significantly contributing to violatio ns of the 1-hour ozone NAAQS in other, downwind states. Affected states were required to comply with Phase I of the SIP Call beginning in 2003/2004 and Phase II beginning in 2007.

Subsequent to the 1997 revisions to the ozone and PM 2.5 NAAQS, EPA promulgated the Clean Air
Interstate Rule 40 (CAIR) in May 2005 and associat ed Federal Implementation Plans 41 (FIPs) in April 2006 in order to reduce transported SO 2 and NO
x emissions from 28 states (including Connecticut) and improve air quality in many areas across the Eastern United Stat es. However, on July 11, 2008, the United States Court of Appeals for the District of Columbia Circuit vacated and remanded both CAIR and the associated CAIR FIPs in their entirety. 42 EPA petitioned for a rehearing, and the D.C. Circuit issued an order in December 2008 remanding CAIR and the CAIR FIPs to EPA without vacatur, 43 directing that CAIR remain in place in order to ‘‘temporarily preserve the environmenta l values covered by CAIR’’ until EPA replaced it with a rule cons istent with the Court’s opinion.

EPA responded to the Court’s directive in August 2011, finalizing the Cross-State Air Pollution Rule 44 (CSAPR) to address interstate transport of emissions and resulting secondary air pollutants and to replace CAIR. In response to subsequent challenges to CSAPR, the D.C. Circuit issued a stay 45 of CSAPR on December 30, 2011, specifying that CAIR requireme nts remain in place while the Court considers and

38 http://www.epa.gov/fedrgstr/EPA-AIR /2002/November/Day-08/a23801.pdf

39 63 FR 57356; October 27, 1998. See http://www.epa.gov/fedrgs tr/EPA-AIR/1998/October/Day-27/a26773a.htm

40 70 FR 25162; May 12, 2005.

41 71 FR 25328; April 28, 2006.

42 North Carolina v. EPA, 531 F.3d 836 (D.C. Cir. 2008).

43 See North Carolina v. EPA, 550 F.3d 1176 (D.C. Cir. 2008).

44 76 FR 48208; August 8, 2011.

45 See http://epa.gov/airtranspor t/pdfs/CourtDecision.pdf

.

### 29 rules on pending petitions in the case. CSAPR woul d retain the CAIR emission reduction requirements 46 through 2011, requiring similar or greater emission reductions of SO 2 and/or NO
x from EGU’s in 28 eastern states in 2012 and beyond. Assuming CSAPR is ultimately upheld by the Court, the post-2011
emission reductions will further redu ce transport into Connecticut, helpi ng to ensure continued attainment through the maintenance period. On March 1,201 2, EPA filed its brief defending CSAPR. Oral arguments were held on April 13, 2012.

Because PM 2.5 concentrations in Connecticut are significantly impacted by the transport of sulfates and nitrates, the area’s air quality is strongly affected by regulation of SO 2 and NO
x emissions from power plants in upwind states. Table 4.2 presents actual EGU emissions data downloaded from EPA’s Clean
Air Markets Division 47 (CAMD) website for the years 2002 and 2007 through 2009, the period when the
NY-NJ-CT area first attained both the annual and 24-hour PM 2.5 NAAQS. EGU emissions are included for all states that, according to EPA’s CSAPR modeling, 48 are estimated to significantly impact Connecticut monitors at a level equal to or exceeding 1% of the annual or 24-hour PM 2.5 NAAQS in the
absence of CAIR or CSAPR. Emissions for 2002 refl ect implementation of the federal acid rain program and, for states in the Ozone Transport Region, a regional NO
x control program that was implemented during the late 1990’s. Emissions for 2007 al so include reductions implemented under the NO
x SIP Call,
with CAIR Phase 1 NO
x requirements reflected by 2009. Although CAIR SO 2 limits were not in place until 2010, some early reduc tions were realized by 2009. Overall, the table shows a dramatic decrease in EGU emissions across the states impacting Connecticut, totaling 66% reductions in NO
x and 48%
reductions in SO 2 emissions between 2002 and 2009.



### 4.2 Connecticut Control Measures

In addition to the federal control measures describ ed above, Connecticut implemented several statespecific programs that contributed to the significant improvements observed in ambient PM 2.5 levels. Details regarding state measures were provided in Connecticut’s attainment demonstration SIP 49 for the
1997 annual PM 2.5 NAAQS. Connecticut’s post-2002 NO
x , SO 2 and PM 2.5 control measures that have resulted in improvements in ambient PM 2.5 levels are listed in Table 4.1. Descriptions of the state
measures follow.

Connecticut requests withdrawal of one control meas ure cited in the attainment demonstration for the
1997 annual PM 2.5 NAAQS (submitted November 18, 2008). No applications were ever received for a general permit issued for distributed generation sources (authorized under CGS 22a-174(k) and section 102 of Public Act 07-242). The general permit has since expired, with no plans for renewal. Therefore, there is no need to include the general permit in the SIP.

46 Note that EPA’s revised technical analysis for CSAP R determined that Connecticut was not contributing to downwind attainment issues in any other state, thus Conn ecticut sources are not subject to CSAPR. However, as described in Section 5, Connecticut plans to adopt a rule to ensure that CAIR emission caps are retained in the state.

47 Using CAMD’s “Quick Report” application, specifying st ate-level annual acid rain program sources for each year because 2002 data are not available for the CAIR program sources. Diff erences are judged to be minimal.

48 http://epa.gov/crossstaterule/pdfs/CSAPR_Ozone%20and%20PM 2.5 _Contributions.xls

49 PM 2.5 Attainment Demonstration SIP submit ted to EPA on November 18, 2008. See: http://www.ct.gov/dep/cwp/view.asp?a=2684&Q=419074&depNav_GID=1619

.

### 30 NOx (tpy) SO 2 (tpy)

State 2002 2007 2008 2009 2002 2007 2008 2009

CT 5,102 3,739 3,120 1,604 10,814 4,782 3,955 1,754
GA 146,456 107,471 105,894 57,566 512,654 635,484 514,539 262,258
IL 174,247 118,230 119,976 72,286 353,699 272,571 257,431 229,364
IN 281,146 196,553 196,580 110,969 778,868 714,529 595,966 413,726
KY 198,599 174,841 157,847 78,767 482,653 379,837 344,356 252,002
MA 28,797 10,368 9,357 7,640 90,727 53,863 46,347 35,182
MD 71,457 50,121 35,902 16,946 255,360 272,879 227,197 198,254
MI 132,623 105,862 103,473 78,947 342,999 338,014 326,501 272,621
MO 139,799 105,921 88,600 53,475 235,532 255,202 258,269 240,202
NC 145,706 59,418 54,652 38,783 462,993 370,826 227,030 110,948
NJ 27,960 11,808 9,143 5,219 48,269 34,189 21,204 10,867
NY 69,665 41,167 31,060 22,587 231,984 107,210 65,427 43,616
OH 370,497 237,876 235,018 95,785 1,132,069 954,646 709,444 600,687
PA 200,909 178,656 175,219 110,218 889,766 951,186 831,915 573,619
TN 155,996 102,886 85,543 27,912 336,995 237,231 208,069 108,042
VA 78,868 53,488 43,017 25,881 230,846 172,685 125,985 93,163
WV 225,371 150,849 97,331 36,120 507,110 371,996 301,574 174,583

Total 2,455,200 1,711,261 1,553,737 842,712 6,905,340 6,129,139 5,067,219 3,622,899 Change vs. 2002

(tpy) -- -743,939 -901,463 -1,612,488 -- -776,201 -1,838,120 -3,282,441 % Change

vs. 2002 -- -30% -37% -66% -- -11% -27% -48% 

### Table 4.2 Comparison of Actual EGU Emissions from States Impacting Connecticut’s PM 2.5 Air Quality

### 31 

### 4.2.1 Control of SO 2 

### and NO
x 

### Emissions from Power Plants and Other Large Stationary Sources

The CT DEEP was required by an executive order of the Governor to adopt regulations to reduce
emissions of SO 2 

### and NO
x 

### from major stationary sources, in cluding power plants. In response, CT DEEP adopted RCSA section 22a-174-19a a nd amended section 22a-174-22, in December 2000, with the requirements phased in from 2002 to 2003. The requirements apply in general to the Acid Rain program sources and NO
x 

### Budget sources.

The SO 2 

### emissions reduction requirements include lo w sulfur fuel requirements (0.3% or 0.5% sulfur, by weight, depending on source type) and co mparable quarterly average emissions limits.
Revision to the NO
x 

### provisions included the add ition of a non-ozone season NO
x 

### limit of 0.15 pounds per MMBtu, which applied to the owne rs of all sources subject to the NO
x 

### Budget Program of RCSA section 22a-174-22b.



### 4.2.2 The Post-2002 Nitrogen Oxides (NO x 

### ) Budget Program

EPA’s NO
x SIP Call of October 1998 led to Connecticut's adoption of its NO
x Budget Program under RCSA section 22a-174-22b, which was approved by EPA as a SIP strengthening measure on December 27, 2000. 50 RCSA section 22a-174-22b established a statewide NO
x budget and NO
x allowance trading program for large electric generators and other indus trial sources beginning with the 2003 ozone season. The budget cap was consistent with EPA's NO
x SIP Call and the September 1994 OTC Memorandum of Understanding establishing the OTC NO
x Budget Program (NBP). In Connecticut, the OTC program was conducted pursuant to RCSA section 22a-174-22a. Both of these regulations were repealed in Connecticut’s CAIR regulation, described below.



### 4.2.3 CAIR and Connecticut’s CAIR Replacement Rule

Connecticut complied with EPA’s 200 5 promulgation of CAIR by electing to participate in the federal

CAIR ozone-season NO
x trading program, adopting RCSA section 22a-174-22c on September 4, 2007. EPA subsequently approved 51 the rule on January 24, 2008. Conn ecticut’s CAIR regulation supplanted the previous NOx Budget regulations, which were repeal ed. All the sources that participated in the RCSA
section 22a-174-22b NO
x budget program are subject to Connecticut’s CAIR ozone season NO
x trading program, albeit subject to a reduced statewide ozone season budget and a revised allocation system.

As described earlier, in August 2011, EPA published CSAPR in the Federal Register 52 to comply with the Court remand of CAIR. EPA’s updated analysis for CSAPR concluded that Connecticut was not

50 65 FR 81743, D ecember 27, 2000.

51 73 FR 4105; January 24, 2008.

52 76 FR 48208, August 8, 2011.

### 32 significantly contributing to nonattainment or maintenance issues in any other state, thus CSAPR requirements do not apply to sources in Connecticut. Connecticut is obligated to maintain in-state emission reductions realized by RCSA section 22a-174- 22c, but must revise its regulations due to EPA’s
exclusion of Connecticut from CSAP R’s interstate trading programs.

On December 15, 2011, CT DEEP held a hearing on the proposed adoption of a new intrastate ozone season nitrogen oxides (NO
x ) trading program (RCSA section 22a-174-22d), which would replace the interstate Clean Air Interstate Rule (CAIR) NO
x Trading Program now in effect under RCSA section 22a174-22c when CSAPR is implemented. CT D EEP subsequently submitted the proposed CAIR replacement rule to EPA for approval, requesting pa rallel processing. EPA proposed approval of the rule on March 26, 2012 (77 FR 17367). CT DEEP expects to submit the final version of rule to EPA shortly.

The proposed program is structured similarly to th e program now in effect under RCSA section 22a-174- 22c, and EPA will administer the intrastate trading prog ram in a similar manner. The regulated units will be subject to an emission budget of 2,691 tons per ozone season, exactly the same state emissions budget
now in effect under RCSA section 22a-174-22c. As note d earlier, the D.C. Circuit issued a stay of CSAPR on December 30, 2011, specifying that CAIR requirements remain in place while the Court considers and rules on pending petitions in the case. As a result, the new regul ation would be effective when CAIR sunsets by federal action after the CSAP R issues are resolved, ther eby ensuring that the emission reductions originally secured in Connec ticut by CAIR are retained into the future.



### 4.2.4 Outdoor Wood Burning Fu rnace (OWBF) Restrictions

As of July 2005, CGS Section 22a-174k prohibits the construction and use of an OWBF unless the OWBF is located more than 200 feet from any residen ce, meets certain stack height criteria and the owner complies with certain operating practices, including a requirement to burn only clean wood. These requirements address the siting and operation of these un its in a manner that will work to limit exposure to particulate matter emissions.

The statute includes a sunset clause 53 that is triggered upon “ ... the effective date of regulations promulgated by the United States Environmental Pr otection Agency to regulate outdoor wood-burning furnaces.” EPA is currently considering pursuing adoption of a New Source Performance Standard (NSPS) that would include emission limits for OWBF s. The requirements of CGS Section 22a-174k would no longer apply upon the effective date of a fe deral NSPS, if one were ev entually adopted in final
form.



### 4.2.5 Improvements in the Control of Particulate Matter and Visible Emissions

RCSA section 22a-174-18 was revised in 2004 to: (1) improve enforceab ility of the opacity requirements by specifying the form an d averaging time of the existing opacity standards for stationary sources and

53 The full text of CGS Section 22a-174k is available at http://www.cga.ct.gov/2011/pub/ch ap446c.htm#Sec22a-174k.htm

.

### 33 including provisions specific to sources with contin uous emissions monitors; (2) add particulate matter standards appropriate to fuel-burning equipment using certain fossil fuels; and (3) add particulate matter emissions standards and requirements for stationary reciprocating internal combustion engines.



### 4.2.6 Connecticut Enhanced I/M (ASM 2525 final standards) and OBD-II
Enhanced I/M

In August 2004, CT DEEP updated the motor vehicle emissions testing program standards implemented by the Connecticut Commissioner of Motor Vehicles to conform to revisions to the underlying federal program standards. Specifically, the revisions to RCSA section 22a-174-27: (1) defined new on-board diagnostic test requirements; (2) added new emissions standards for vehicles subject to a pre-conditioned two speed idle exhaust emissions test procedure; (3) required ASM 2525 exhaust emission standards consistent with federal guidance but for which the federal government has not adopted analogous standards; and (4) added new emissions standards for diesel vehicles subject to a modified snap acceleration smoke opacity test.

In 2003, Connecticut began operating a decentrali zed I/M testing infrastructure through a new I/M contractor. The revised I/M program requires the u se of the on-board diagnostics II (OBDII) test, the ASM 2525 test, the pre-conditioned two-speed idle (PCTS I) test, or one of two types of opacity testing, depending on the age, weight and fu el type of each vehicle. Virtually all vehicles that weigh less than 10,000 pounds (gross vehicle weight rating) and that are between 4 and 25 years of age are subject to the program. DEEP filed a SIP revision with EPA on December 20, 2007 to incorporate these changes to the I/M program.



### 4.2.7 California Low Emission Vehicle 2 (CALEV2)

The State of Connecticut is implementing the light-dut y motor vehicle emission standards of the State of California applicable for model year 2008 and later mo tor vehicles. California’s revision of their Low Emission Vehicle (LEV) standards also includes adoption of greenhouse gas emission standards for passenger cars, light-duty trucks and medium dut y passenger vehicles commencing with 2009 and subsequent model year vehicles. The program is implemented through RCSA section 22a-174-36b, which was adopted in Connecticut in December 2005.



### 4.2.8 Reducing NO
x 

### Emissions from Municipa l Waste Combustors

Connecticut’s regulation to limit air pollutant emissions from the state’s municipal waste combustor (MWC) units is described in the previous section. An October 26, 2000 amendment to RCSA section
22a-174-38 reduced the NO X emission limits below the 1999 levels beginning May 1, 2003. EPA approved the amended regulation and associated emissions reductions for 1-hour ozone NAAQS attainment on December 6, 2001. 54

54 66 FR 63311, D ecember 6, 2001.

### 34 

### 4.2.9 Conclusions

Connecticut’s attainme nt demonstration SIP 55 for the annual PM 2.5 NAAQS included emission reduction estimates between 2002 and 2009 resulting from the fede ral and state control programs cited above. Significant annual emission reductions were estimated in Connecticut for direct PM 2.5 (679 tons, or 4%),

NO
x (36,166 tons, or 30%) and SO 2 (9,233 tons, or 29%) between 2002 and 2009. When paired with the upwind impact of the federal controls described previously, the combined emission reductions are responsible for the NAAQS-compliant levels of PM 2.5 that continue to be measured in Connecticut and
the rest of the NY-NJ-CT area.

55 Connecticut Attainment Demonstration SIP for the 1997 Annual PM 2.5 NAAQS; Technical Support Document (Section 5); Submitted to EPA on November 18, 2008.

### 35 

## Chapter 5 Maintenance Plan

Section 107(d)(3)(E)(iv) of the CAA stipulates that, fo r an area to be redesignated to attainment, EPA must fully approve a maintenance plan that meets the requirements of section 175A. A state may submit both the redesignation request and the maintenance pl an at the same time and rulemaking on both may proceed on a parallel track.

CAA section 175A establishes the required elemen ts of a maintenance plan for areas seeking redesignation from nonattainment to attainment. Under section 175A, the plan must demonstrate continued attainment of the applicable NAAQS for at least 10 years after EPA approves an area’s redesignation to attainment. The plan must contain ad ditional measures, if any, necessary to ensure such maintenance. Eight years after the redesignation ap proval, the state must submit a revised maintenance plan demonstrating that attainment will continue fo r the 10 years following the initial maintenance period. To address the possibility of future NAAQS violations , section 175 also specifies that the maintenance plan must contain contingency measures necessary to assure prompt correction of any violation of the standard that occurs after redesignation of the area to attainment.

EPA has provided further guidance 56 expanding on the required content of a maintenance plan, explaining that a maintenance plan should include the following five elements:

• An inventory sufficient to ensure attainment;

• A demonstration that the plan ensures continue d maintenance of the NAAQS through a 10 year maintenance period commencing when EPA approves the redesignation request;

• A commitment to maintain an appropriate monitoring network;

• A method to track the progress of the maintenance plan; and

• Contingency measures to be implemented if NAAQS violations occur during the maintenance period.

The remainder of this section addresses each of the required elements. The first two elements, the attainment inventory and demonstrati on of continued maintenance, are addr essed together in Section 5.1.



### 5.1 Attainment Inventory and Demons tration of Continued Maintenance

EPA’s guidance for maintenance plans calls for states to provide an emissions inventory representative of the level of emissions sufficient to attain the NAAQS. In addition, the maintenance plan should include a demonstration of continued complia nce by showing that future emissions during the maintenance period
will not exceed the level of emissions in the attainment inventory.

As previously discussed in Section 2 of this TSD, three-year design values measured in the NY-NJ-CT area have shown compliance with the annual NAAQS since 2008 and the 24-hour NAAQS since 2009.

56 ”Procedures for Processing Request s to Redesignate Areas to Attainment”; Memorandum from John Calcagni, Director, Air Quality Management Division; September 4, 1992.

### 36 In the Connecticut portion of the area, annual complia nce extends back to at least 2001, while compliance with the 24-hour NAAQS was initially achieved in 2008. As a result, 2007 was selected as an appropriate year for the attainment inventory. The end of th e maintenance period was established as 2025, consistent with the CAA section 175A(a) requirement that the pl an provide for maintenance of the NAAQS for at least 10 years after EPA formally approves the redesignation request. Emission estimates were developed
for direct PM 2.5 , as well as for the most important PM 2.5 precursors, SO 2 and NO
x . As described below, emissions are projected to decrease from the levels in the 2007 attainment inventory through the end of the maintenance period in 2025, including in the sel ected interim year of 2017, thus providing for continuous maintenance of the NAAQS.

Annual inventories used for the PM 2.5 redesignation effort were devel oped as an extension of regional efforts in the Mid-Atlantic/Northeast Visibility Uni on (MANE-VU) area to create inventories for use in photochemical modeling for the 2008 ozone NAAQS , potential future revisions to the PM 2.5 NAAQS, and regional haze SIPs. Representatives from MANE-VU states and the Mid-Atlantic Regional Air Management Association (MARAMA), with contr actor support, were already in the process of developing multi-pollutant invent ories for 2007, 2017 and 2020 for th e MANE-VU states (Connecticut, Delaware, the District of Columbia, Maine, Maryla nd, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, and Vermont) and Virginia. When the opportunity arose in several areas to pursue PM 2.5 redesignation, MARAMA took the lead on coordinating with affected states to create a supplemental inventory for 2025 and to make appropriate modifications to the 2007 inventory for use in the redesignation effort.

The paragraphs below summarize the inventory deve lopment process. Further inventory details are provided in the following appendices prepared by MARAMA’s contractor in cooperation with the

MANE-VU states.

Appendix A: VERSION 3.3 Technical Support Document for the Development of the 2007 Emission Inventory for Regional Air Quality Modeling in the Northeast/Mid-A tlantic Region; Prepared for MARAMA by AMEC Environment & Infrastructure and SRA International, Inc.; January 23, 2012. Appendix B: VERSION 3.3 Technical Support Document for the Development of the 2025 Emission Inventory for PM Nonattainment Counties in the MANE-VU Region; Prepared for MARAMA by AMEC Environment & Infrastructure and SRA International, Inc.; January 23, 2012. Appendix C: VERSION 3.3 Technical Support Document for the Development of the 2017 / 2020 Emission Inventories for Regional Air Quality Mode ling in the Northeast / Mid-Atlantic Region; Prepared for MARAMA by AMEC Environment & Infr astructure and SRA International, Inc.; January 23, 2012.

Detailed inventory data and other related documentation can be accessed through MARAMA’s ftp website. See Appendix D for directions for accessing that site.

### 37 

### 5.1.1 Pollutants

The inventories developed for the PM 2.5 redesignation effort include directly emitted PM 2.5 and PM 2.5 - precursors (i.e., NO
x and SO 2 ). The PM 2.5 species in the inventory are categorized as particles with an aerodynamic diameter less than or equal to a nominal 2.5 micrometers (PM25-PRI), which includes both condensable particles (PM-CON) and filterable particles (PM25-FIL).



### 5.1.2 Source Categories

Emission estimates were developed for sources in the following categories:

• Electric Generating Unit (EGU) Point Sources are units that generate electric power and sell most of the power generated to the electrical grid.

• Non-EGU Point Sources are individual industrial, commercial, and institutional facilities and are further subdivided by stack, emission unit, and emission process.

• Stationary Area Sources include small, non-permitted sources that in aggregate may contribute significant emissions. Examples include small industrial/commercial facilities, residential heating furnaces, and road dust re-entrainment.

• Non-road Mobile Sources include internal combustion engines used to propel marine vessels, airplanes, and locomotives, or to operate equipmen t such as forklifts, lawn and garden equipment, portable generators, etc. For activities other than marine vessels, airplanes, and railroad locomotives (MAR), the inventory was develope d using the most current version of EPA’s
NONROAD model as embedded in the National Mo bile Inventory Model (NMIM). Because the NONROAD model does not include emissions from MAR sources, these emissions were estimated based on data and methodologies used in recent EPA regulatory impact analyses.

• On-road Mobile Sources are sources of air pollution from internal combustion engines used to propel cars, trucks, buses, and other vehicles on public roadways. Emission projections for onroad mobile sources were developed using EPA ’s Motor Vehicle Emission Simulator (MOVES)
model.

Biogenic/geogenic emissions are not included in this inventory.



### 5.1.3 Geographic and Temporal Resolution

The MANE-VU PM 2.5 redesignation inventories were prepared only for those areas classified as
nonattainment for the annual or 24-hour PM 2.5 NAAQS (e.g., Fairfield County and New Haven County in Connecticut). The inventories were developed at the county level for the area and mobile source categories and at the process level for point sour ces categories, then summed to the county level.

Discussions between MANE-VU states and EPA concluded that the use of annual inventories would also be appropriate for demonstrating c ontinued compliance with the 24-hour PM 2.5 NAAQS during the maintenance period if monitoring data analysis for an area showed that elevated 24-hour PM 2.5 levels occur in multiple seasons. CT DEEP performed such an analysis, summarized in Appendix E, and found
that elevated PM 2.5 levels do occur in multiple seasons (pri marily summer and winter) in Connecticut;

### 38 therefore, annual inventories can be used to dem onstrate compliance with both the annual and 24-hour NAAQS during the maintenance period.



### 5.1.4 Point Source Inventory Procedures

As part of the regional MANE-VU inventory e ffort, CT DEEP supplied MARAMA with actual 2007 emissions for all EGU and non-EGU point sources. For consistency in both reporting emissions and projecting emissions to the future, states agreed to group as EGU sources only those EGU sources that report hourly emissions to EPA’s CAMD database. All other point sources (including non-EGUs in CAMD, small non-CAMD EGUs and all other non- EGUs) were grouped as non-EGU point sources.

Quality Assurance The point source inventory underwent a multi-step iterative review process to ensure data quality. 57 The review process included:

• EPA’s Basic Format and Content Checker tool was u sed to verify format and check for referential integrity and duplicate record issues;

• Facility-level comparisons were made betw een the 2007 source list and the 2002 MARAMA inventory to identify and verify/correct any fac ilities included in only one of those inventories;

• For facilities included in both inventories, la rge emission changes between 2002 and 2007 were examined for reasonableness, with corrections made if warranted;

• Crosswalks were developed to compare and verify linkages between the CAMD and statesupplied NIF source data sets.

• Source location coordinates were checked to ensure location in the correct county;

• Source files were made available for stakeholde r review, with requested changes evaluated by states for possible revisions.

The quality assurance process resulte d in several changes to CT DEEP’s original 2007 point source
submittal. Revisions included corrections for PM -related pollutant codes for some combustion sources
and recalculation of actual emissions where rule effect iveness should not have been included. In addition,
stakeholder comments resulted in minor revisions to emission estimates for two facilities.

PM Augmentation Similar to other states, Connecticut’s 2007 point source inventory, as supplied to MARAMA, did not include all components of PM emissions (i.e., PM-P RI, PM-FIL, PM-CON). The contractor applied PM augmentation procedures 58 to calculate missing components, with different procedures used for EGU and non-EGU sources. The EGU process used updated conde nsable emission factors, with preference given to the use of emission factors developed from EGU s ource tests where nitrogen purging occurred so as to
minimize overestimation of condensable emissions du e to sulfur artifact. For non-EGU sources, PM augmentation employed essentially the same process used in developing the 2002 MANE-VU Version 3 inventory.

57 See Section 2.1 through 2.7 of Appendix A for a full description of point source qu ality assurance procedures.

58 See Section 2.2 of Appendix A for a more complete explanation of PM augmentation procedures.

### 39 Banked Emission Reduction Credits CT DEEP maintains a registry of continuous em ission reduction credits (CERCs) for potential use as offsets in new source review permits. In order to preserve potential future use of these credits, any CERCs initiated prior to the 2007 attain ment inventory year must be accounted for in the 2007 and future year inventories that are included in this maintenan ce plan. Table 5-1 summarizes CERCs that have been
included in the inventories. These emissions are re flected in the non-EGU inventory on a county-bycounty basis under source classification code (SCC) 23- 99-000-000. All county- level emissions were assigned to a fictitious facility located at the county centroid with an assumed release height of 30 feet.



### Table 5.1 CT DEEP Banked Emission Reduction Credits

DEEP Emission Reduction Credit Bank of
NOx Emissions Included in 2007, 2017 and 2025 Inventories FIPS NOx (tpy)

Totals by County*: Fairfield 09001 392.0

Hartford 09003 0.0

Litchfield 09005 0.0

Middlesex 09007 23.0

New Haven 09009 476.8

New London 09011 179.0

Tolland 09013 0.0

Windham 09015 247.0
* Fairfield and New Haven Counties are part of the NY-NJ-CT PM 2.5 nonattainment area.

Non-EGU Point Source Growth Factors Non-EGU point source growth factors were devel oped for Connecticut using employment or fuel consumption projections, de pending on the source category. 59 Connecticut Department of Labor 2006- 2016 employment forecasts by industry sector were provided for use as growth factors for non-fuel burning sources (such as manufacturing operations). MARAMA’s contractor extrapolated the employment forecasts through 2025 to develop emission estimates for these sources. Manufacturing employment projections for Connecticut are projected to decline by about 7% during the period, although declines are not as severe as those pr ojected for other MANE-VU states. Annual Energy Outlook (AEO) fuel use projections p ublished in 2010 by the U.S. Energy Information Administration were used to develop gr owth factors for fuel consuming sources. 60 AEO provides regional fuel-use forecasts for various fuel types (e.g., co al, residual oil, distillate oil, natural gas) by end

59 See Section 3.1.1 and 2.3.1 of Appendix B for more detailed discussions of non-EGU growth factors.

60 The 2011 update to the annual AEO forecasts was published midway through the inventory development process. MARAMA compared AEO2010 and AEO2011 projections, concluding that only one sector, industrial natural gas usage, was significantly different. Connecticut’s future y ear inventories were then changed to reflect the AEO2011 forecast for that sector, with growth for all others non-EGU sectors rema ining tied to the AEO2010 forecast.

### 40 uses (e.g., residential, commercial, industrial, tran sportation, and electric pow er). New England region forecasts were applied to Connecticut fuel burning sources.

The AEO forecasts show declining trends for many fuel consumption sectors, especially industrial, residential, and commercial distillate fuel oil use. In order to be conservative in future emission estimates, Connecticut and several other states decide d to apply a no-growth assumption (growth factor = 1.0) for any non-EGU point source sector with a ne gative growth projection based on AEO forecasts. Such an approach could also help justify the crea tion of additional CERCs for facilities that might shut down during the maintenance period.

Non-EGU Point Source Control Factors MARAMA’s contractor examined adopted federal and regional control strategies to determine those that would result in post-2007 emission reductions of PM 2.5 or PM 2.5 precursors from non-EGU point

sources. 61 Two federal toxics-related maximum achievabl e control technology (MACT) standards were identified that affect Connecticut sources, one for r eciprocating internal combustion engines (RICE) and the other for industrial/commercial/institutional (ICI) boilers and process heaters. The contractor examined EPA guidance and documentation to dete rmine that the RICE MACT will provide NOx or

PM 2.5 emission reductions and the ICI/process heater MACT will provide PM 2.5 emission reductions from several non-EGU source classifications during the maintenance period.

EGU Point Source Growth and Control Factors 62 The 2007 EGU emissions were grown to future years based on AEO2011 electricity generation projections that delineated by market region and fuel type. The 2007 emissions were extracted for those units flagged as EGUs in the MANE-VU 2007 inventor y. The appropriate AEO2011 growth factor was applied to the 2007 emissions to calculate a “gro wth only” emission value for 2017 and 2025. The following key assumptions were made because these inve ntories are not intended to be used for SIPquality photochemical modeling:

• Any growth beyond unit capacity or permit limits was not limited (e.g., fuel consumption was allowed to grow beyond a unit’s phys ical capacity or permit limit);

• Generation from any new units that may come on lin e and operate prior to 2025 but did not exist in 2007 is not explicitly included, but instead is assumed to be implicitly accounted for in the AEO2011 growth forecasts;

• Similarly, generation from specific units that have or may shut down after 2007 is not explicitly accounted for, but instead, is assumed to be implicitly accounted for in the AEO2011 growth
forecasts.

• States indicated where post-2007 controls were to be applied on a unit-by-unit basis. The control factors were applied to the grown emissions to calculate a “growth and control” emission value
for 2025.

61 See Section 3.3.2 of Appendix B for a discussion and references related to the identification of appropriate nonEGU control factors.

62 See Sections 3.4.1 and 3.4.2 of Appendix B for a more complete description of EGU growth and control factors.

### 41 

### 5.1.5 Area Source Inventory Procedures

Area sources are relatively small, but often numerous, sources of air pollutants spread over a wide geographical area. They include sources that indivi dually are insignificant, but in the aggregate may comprise significant emissions. Examples include emi ssions from home heating systems, small industrial or commercial operations that are not permitted as point sources, and road dust re-entrainment. There are 356 individual area source categories in the MANE-VU inventory, categorized by a 10-digit SCC.

The EPA regularly develops emission estimation me thodologies and estimates for the National Emission Inventory (NEI). The NEI is developed on a three-year cycle, and inventories are available for 2002, 2005, and 2008. CT DEEP initially inst ructed MARAMA to use EPA’s 2008 NEI 63 emission values for all area source categories for the attainment year inventory. As described below, during the quality assurance effort, a number of categories were either discovered to be missing from the 2008 NEI, or used incorrect emission factor assumptions for Connecticut , so substitutions were made from either the 2005

NEI 64 or from CT DEEP’s draft 2005 periodic emission inventory 65 (PEI). For residential wood combustion (RWC), MARAMA’s cont ractor ran EPA’s RWC tool with updated 2007 data to produce emission estimates. EPA’s 2011-upda ted methodology for developing emission factors for re-entrained particulate matter from vehicles traveling over a paved surface was also used.

A full description of the area source development process is provided in the MANE-VU inventory documentation included as Appendix A (Section 4) and A ppendix B (Sections 3 and 4). Note that Exhibit 4.3 of Appendix A provides a tabular summary of da ta sources used for each state, including Connecticut, for each area source category. A summarized descrip tion of the area source inventory procedures is provided below, highlighting aspects unique to Connecticut for pollutants impacting the PM 2.5 redesignation effort.

Quality Assurance The area source inventory underwent a multi-step ite rative review process to ensure data quality. 66 The review process included:

• Checks for missing categories, double counting, outliers and incorrect emission factors;

• Comparisons between the 2007 and previously developed 2002 MANE-VU inventories to identify/verify/correct any facilities included in only one of those inventories;

• For facilities included in both inventories, la rge emission changes between 2002 and 2007 were examined for reasonableness, with corrections made if warranted;

• Source files were made available for stakeholde r review, with requested changes evaluated for possible revisions.

The quality assurance process resulted in additions, revisions and correc tions to emission estimates for several area source categories in Connecticut, which we re initially based solely on EPA’s 2008 NEI. The review process identified several area source categor ies that were not included in the 2008NEI. Missing

63 See http://www.epa.gov/ttnchie1/net/2008inventory.html

. 64 See http://www.epa.gov/ttnchie1/net/2005inventory.html

. 65 See Appendix F for excerpts from Connecticut’s dr aft 2005 PEI for selected area source categories.

66 See Section 2.1 through 2.7 of Appendix A for a full description of point source qu ality assurance procedures.

### 42 PM 2.5 -related categories included industrial fuel burni ng sources, commercial/institutional fuel burning sources, miscellaneous area source other-combus tion (SCC 2810), industrial process mining/quarrying (SCC 2325), and miscellaneous area source crop agri cultural crop production (SCC 2801). These missing categories were filled in with emission estimates from EPA’s 2005 NEI-v2.

More detailed review discovered that EPA’s fuel burning estimates assumed a 2.25% sulfur level for residual fuel oil compared to a Connecticut regulator y maximum of 1.0% sulfur. In addition, CT DEEP could not verify whether EPA’s 2005 NEI-v2 adjusted its area source estimates to avoid double counting of point sources. CT DEEP addressed these issu es by providing further updates to 2007 emission
estimates for non-wood fuel combustion for the reside ntial, commercial/institutional and industrial source categories. CT DEEP decided to use emission estimates from its draft-2005 PEI for the non-wood fuel combustion portions of the cited categories. The draft-2005 PEI includes only CO, VOC and NO
x emissions, so fuel use values were multiplied by appropriate EPA emission factors obtained from the
2008 NEI to calculate estimates of annual SO 2 and PM 2.5 emissions. CT DEEP’s PEI also combined
kerosene fuel use with distillate fuel use for the residential, commercial/ins titutional, and industrial sectors. Therefore, the 2007 MANE-VU inventory was modified by setting emissions for kerosene combustion SCCs to zero to avoid double counting of emissions.

CT DEEP’s review of 2008 NEI emission estimates from land clearing debris activities also resulted in changes to the 2007 MANE-VU inventory. The me thodology used for the 2008 NEI assumes all land clearing debris in rural counties is open burned, with no burning of debris in urban counties. This assumption greatly overestimates the mass of land cleari ng debris occurring in Connecticut, which is very limited. As a result, the 2005 NEI emission estimat es were used instead becau se they are similar to estimates previously calculated by CT DEEP based on issued open burning permits.

PM Transport Fractions Grid air quality models have consis tently overestimated fugitive dust im pacts when compared to ambient samples, indicating the importance of accounting for near-source removal mechanisms such as vegetation and other surface features. To address this issue, EPA developed a methodology to reduce fugitive dust emissions for use in grid modeling analyses. 67 The MANE-VU 2007 and future year inventories apply the EPA defined county-level sta ndard transport fractions and SCC assignments from EPA’s CHIEF website to adjust PM25-PRI emissions for specifi c fugitive dust categories such as paved and unpaved roads, construction activities and agricultural activiti es. Transport fractions in Connecticut’s two PM 2.5 nonattainment counties (Fairfield & New Haven) areas are both about 0.44, midway in the range of 0.14 to 0.80 used for other nonattainment counties in the MANE-VU region.

Area Source Growth Factors Growth factors were applied to the 2007 MANE-V U area source inventory to account for anticipated changes in fuel use, population and economic activity 68 during the maintenance period. For Connecticut, growth factors were developed using six sets of data:

• Annual Energy Outlook (AEO) New England region fuel consumption forecasts;

• County-level population projections;

67 See the EPA CHIEF website at: http://www.epa.gov/ttnchie1/emch/dustfractions/

. 68 See Section 2.3.1 of Appendix B for a more detailed discussion of area source growth factors.

### 43 • State-level employment projections;

• County-level vehicle miles traveled (VMT) projections; and

• EPA projections for residential wood combustion.

As described earlier for the non-EGU sector, AEO fu el projections published in 2010 (AEO2010) were used for all fuel burning area source sectors, excep t for industrial natural gas combustion, which was updated to use AEO2011 projections. Industrial na tural gas usage was the only sector showing a significant difference in future projections between the AEO2010 and AEO2011 forecasts.

CT DEEP provided MARAMA’s contract or with county-level population projections developed in March 2007 by the Connecticut Data Center at the Univer sity of Connecticut. Projected population increases
between 2007 and 2025 are 6.7% for Fairfield C ounty and 5.1% for New Haven County. These population-based growth factors were used for cons umer-related area source sectors such as residential
fuel combustion.

The state-level employment projections previously described in Section 5.1.4 were also applied to manufacturing-related area source sectors.

The Connecticut Department of Transportation (CT DOT) supplied VMT growth estimates that were used to project future year emission for re-entrained road dust from paved roads. Total VMT growth of 13.3%
and 17.9% between 2007 and 2025 were used for Fa irfield and New Haven Counties, respectively.

For several area source categories, it seems reasonabl e that emissions would not change from the 2007 values. No growth was applied to the 2007 emissions for PM 2.5 -related area source categories such as open burning and unpaved road dust.

For residential wood combustion (RWC), the MANE-VU inventories are based on emission projection parameters made available by EPA. EPA’s project ed RWC emissions are based on the expected increase in the number of lower-emitting woodstoves. As newer, cleaner woodstoves replace older, more polluting stoves, there will be an overall reduction of em issions from this category. The approach used by EPA was developed as part of a modeling exercise to estimate the expected benefits of the woodstove change-out program. This methodology is based on activity, not pollutant. Growth and control are accounted for in a single factor for each residen tial wood SCC (certain SCCs represent controlled equipment, while others represent unc ontrolled equipment). Control factors are indirectly incorporated
based on which stove is used.

Area Source Control Factors MARAMA’s contractor examined adopted federal an d regional control strategies to identify any that would result in post-2007 emission reductions of PM 2.5 or PM 2.5 precursors from area source categories. 69 As part of this process, EPA made available its 2020 emissions projections associated with its 2005-based v4 modeling platform. EPA’s modeling accounted for federal control strategies for four area source categories, only one of which was identified as reducing emissions of PM 2.5 or PM 2.5 precursors, the

69 See Section 2.3.2 of Appendix B for a discussion and re ferences related to the identification of appropriate area source control factors.

### 44 replacement of retired woodstoves installed before promulgation of the new source performance standard (NSPS). As mentioned above, MA RAMA’s contractor applied EPA’s latest RWC methodology 70 , which uses a combination growth and control factor and is based on activity and not pollutant. The growth and control are accounted for in a single factor for specifi c SCCs that account for the turnover from pre-NSPS to post-NSPS woodstoves.

One post-2007 MACT standard was also incorporat ed into the MANE-VU future year area source inventories, EPA’s 2010 rule promulgated for recipr ocating internal combustion engines (RICE). EPA made available estimates of the percent reductions in PM 2.5 and NO
x emissions attributable to the RICE
MACT rule in 2012 and 2014.



### 5.1.6 Non-Road Source Inventory Procedures

Non-road sources include internal combustion engines used to propel marine vessels, airplanes, and locomotives, or to operate equipment such as forklifts , lawn and garden equipment, portable generators, etc. For activities other than marine vessels, airp lanes, and railroad locomotives (MAR), the inventory was developed using the most current version of EPA’s NONROAD model as embedded in the National Mobile Inventory Model (NMIM). Because the NONROAD model does not include emissions from MAR sources, these emissions were estimated based on data and methodologies used in recent EPA regulatory impact analyses. The procedures u sed to run the NMIM/NONROAD platform and to
determine emissions from MAR sources are discussed below.



### 5.1.6.1 NMIM/NONROAD Modeling Methodology NMIM was developed by EPA to estimate county- level emissions for certain types of non-road equipment. NMIM uses the current version the NONROAD model, which estimates emissions from equipment such as recreational marine vessels, recreational land-based vehicles, farm and construction machinery, lawn and garden equipment, aircraft ground support equipment (GSE) and rail maintenance equipment. The NMIM national county database contai ns monthly input data to reflect county specific fuel parameters and temperatures. Most of the work associated with executing NMIM involved updating the NMIM county database with state-specific inform ation. For this analysis, MARAMA’s contractor used the NMIM2008 software (version NMIM20090504), the NMIM County Database (version NCD20090531), and NONROAD2008a (Jul y 2009 version) as a starting point. Changes were made to
the NCD20090531 based on state review. 71

Connecticut Changes to the NMIM Nati onal County Database and Other Inputs MANE-VU States, including Connecticut, reviewed the NCD20090531 version of the National County Database (NCD) to determine if any parameters s hould be corrected or updated. CT DEEP requested changes to several fuel-related characteristics to make them consistent with reformulated gasoline (RFG)

70 See Section 2.3.1.6 of Appendix B for a more complete description of EPA’s methodology for projecting RWC emissions.

71 See Section of 4 of Appendix A for a more complete description of NMIM/NONROAD modeling procedures.

### 45 sampling results reported by EPA for RVP, sulfur a nd ethanol oxygen weight pe rcents in Connecticut’s multiple RFG areas.

Several NONROAD categories use housing unit or populatio n data to allocate the emissions to the county
level from state calculations. States identified some discrepancies in the housing and population data contained in the NONROAD model and requested that MARAMA’s contractor update the allocation files for those categories. Consequently, the contractor obtained and applied 1 and 2 unit housing information and updated Census Bureau 2007 population estimates for each state, including Connecticut. The revised housing unit data affected the allocation of residentia l lawn and garden equipment. Revised population files applied to railroad maintenance e quipment and AC/refrigeration equipment.

Removal of Airport Ground Support Equipment Emissions The NMIM/NONROAD model includes emissions from airport ground support equipment. Emissions from airport ground support equipment can also be calculated using the Federal Aviation Administration’s (FAA) Emissions and Disper sion Modeling System (EDMS). MARAMA’s correspondence with EPA indicated that EPA consider s the emissions calculated by EDMS to be better than those calculated by NONROAD. For this r eason, all emissions calculated by NMIM/NONROAD for airport ground support equipment were rem oved from the 2007, 2017 and 2020 inventories and replaced with EDMS estimates, as described in Section 5.1.6.2.

Future Year NMIM/NONROAD Growth and Control Information In estimating future year emissions, the NMIM/N ONROAD model includes growth and scrappage rates for equipment in addition to a variety of control program s. It is not possible to separate out the future year emissions due to “growth only” or “control only” in a single run. That is, the model run provides a single future year estimate that is a “growth a nd control” scenario. The GROWTH packet of the NONROAD model cross-references each SCC to a growth indicator code. The indicator code is an arbitrary code that identifies an actual predicted va lue such as human population or employment that is used to estimate the future year equipment populatio n. The GROWTH packet also defines the scrappage
curves used to estimate the future year model year distribution.

The NMIM/NONROAD model accounts for all adopted EPA emission standards for non-road equipment. There are multiple standards that vary by equipment t ype, rated power, model year , and pollutant. Exhibit 4.1 of Appendix C provides a tabular summary of the emission control programs accounted for in the
NMIM/NONROAD model.

Finally, as mentioned above, airport ground service emissions were removed from the future year NMIM/NONROAD runs and were replaced by estimates calculated by the FAA EDMS model.



### 5.1.6.2 MAR Methodology This category of sources is collectively referred to as the MAR (marine, airports, and railroads) sector. It includes non-road engines associated with the following activities:

• Marine Vessels: The Commercial Marine Vehicle (CMV) sector includes all boats and ships used either directly or indirectly in the conduct of commerce or military activity. The majority of

### 46 these vessels are powered by diesel e ngines that are fueled with either distillate or residual fuel oil blends. For the purpose of this inventory, it is assumed that Category 3 vessels primarily use residual blends, while Category 1 and 2 v essels typically used distillate fuels.

• Airports: The aircraft sector includes all aircra ft types used for public, private, and military purposes. This includes four types of aircraf t: commercial, air taxis, general aviation and military. Ground support equipment (GSE) and auxiliary power units (APU) are also included.

• Railroads: The railroad sector includes railroad lo comotives powered by diesel-electric engines.
Locomotives are divided into Class I line haul , Class II/III line haul, commuter/passenger and Class I yard.

2007 Commercial Marine Vessel Inventory Development Along with several other MANE-VU states, Connectic ut elected to use EPA’s 2008 NEI data for all commercial marine vessel categories. These estim ates include emissions from CMV operation generally
within 12 nautical miles of shore. The 2008 NEI data were used directly for 2007 (i.e., the 2007 emissions were assumed to be equal to 2008).

Future Year Commercial Marine Vessel Inventory Development For the purpose of emission calculations, marine vessel engines are divided into three categories based on displacement (i.e. swept volume) per cylinder. Cate gory 1 and Category 2 marine diesel engines typically range in size from about 500 to 8,000 kW (700 to 11,000 hp). These engines are used to provide propulsion power on many kinds of vessels including tugboats, pushboats, supply vessels, fishing vessels, and other commercial vessels in and around ports. Th ey are also used as stand-alone generators for auxiliary electrical power on vessels. Category 3 marine diesel engines typically range in size from 2,500 to 70,000 kW (3,000 to 100,000 hp). These are very large marine diesel engines used for propulsion power on ocean-going vessels such as container ships, oil tankers, bulk carriers, and cruise ships.

The majority of marine vessels are powered by diesel engines that are fueled with either distillate or residual fuel oil blends. For the purpose of emi ssion inventories, EPA has assumed that Category 3 vessels primarily use residual blends, while Category 1 and 2 vessels typically use distillate fuels. EPA developed national emission inventories for Categor y 1 and 2 vessels and Category 3 vessels for calendar years 2002 through 2040 as part of its effort to develop emission standards for these vessels. The methodologies used to develop the emission projectio ns (for both a baseline and controlled scenario) are documented in three EPA regulatory impact assessments (RIA). 72 MARAMA’s contractor used EPA data and methodologies from these RIAs to develop separate growth and control factors for Category 1 and 2 vessels (diesel) and Category 3 vessels (residual).

2007 Airport Inventory Development
Connecticut aircraft emissions in the 2007 MANE -VU inventory are available on a county-by-county basis for six types of aircraft operations:

• Air carrier operations represent landings and take -offs (LTOs) of commercial aircraft with seating capacity of more than 60 seats;

72 See Section 5.3.1 of Appendix B for a full description of the EPA methodology used for CMV emission projections and the associated EPA references.

### 47 • Commuter/air taxi operations are one category. Commuter operations include LTOs by aircraft with 60 or fewer seats that transport regional passengers on scheduled commercial flights. Air taxi operations include LTOs by aircraft with 60 or fewer seats conducted on non-scheduled or for-hire flights;

• General aviation represents all civil avia tion LTOs not classified as commercial;

• Military operations represent LTOs by military aircraft;

• Ground Support Equipment (GSE) typically includ es aircraft refueling and baggage handling vehicles and equipment, aircraft towing vehicles, and passenger buses;

• Auxiliary power units (APUs) provide power to start the main engines and run the heating, cooling, and ventilation systems prio r to starting the main engines.

CT DEEP calculated 2007 airport-related emissions based on the 2008 NEI for airport ground support equipment and auxiliary power units, detailed 2005 aircraft activity data from Connecticut-specific survey data and emission factors obtained from EDMS 5.1, augmented by PM emission factors from EPA 2008 documentation for non-International Civil Aviati on Organization (ICAO) certified engines. Growth factors were developed from the 2009 Terminal Air Fo recast (TAF) database. No growth was assumed if a TAF-based growth factor was not available. Resu lts were provided to MARAMA for inclusion in the 2007 MANE-VU inventory. See Appendix G for further detail.

Future Year Airport Inventory Development CT DEEP provided MARAMA with state-specific grow th factors through 2025 by SCC and county. These growth factors closely followed the approach used and described in the MARAMA effort; however, the airport specific activity was grown based on the Terminal Air Forecasts for each airport where available (or no growth when not available) rather than applying a composite average growth factor for a county. See Appendix G for further detail.

MARAMA’s contractor reviewed NO
x aircraft engine emissions standa rds adopted by EPA in November 2005. The standards are equivalent to the NO
x emission standards (adopted in 1999 for implementation beginning in 2004) of the United Nations Interna tional Civil Aviation Organization (ICAO), and will bring the US aircraft standards into alignment with the international standards. The standards apply to new aircraft engines used on commercial aircraft in cluding small regional jets, single-aisle and twin-aisle aircraft, and 747s and larger aircraft. The standards also apply to general avia tion and military aircraft, which sometimes use commercial engines. For exampl e, small regional jet engines are used in executive general aviation aircraft, and larger co mmercial aircraft engines may be used in military transport aircraft.

Nearly all previously certified or in-production engine models currently meet or perform better than the standards EPA adopted in the November 2005 rule. In addition, manufacturers have already been developing improved technology in response to the ICAO standards. This rule is expected to reduce NO
x emissions by approximately 2 percent in 2015 and 3 percent in 2020. Because of the relatively small
amount of NO
x reductions, the MANE-VU future year aircraft emission projections do not account for this control program.

2007 Railroad Inventory Development Railroad locomotive engine emissions in the 2007 M ANE-VU inventory are classified into the following categories:

### 48 • Class I line haul locomotives are operated by larg e freight railroad companies and are used to power freight train operations ove r long distances (SCC 22-85-002-006);

• Class II/III line haul locomotives are operated by smaller freight railroad companies and are used to power freight train operations over long distances (SCC 22-85-002-007);

• Inter-city passenger train locomotives are operate d primarily by Amtrak to provide inter-city passenger transport (SCC 22-85-002-008);

• Independent commuter rail systems operate loco motives that provide passenger transport within a metropolitan area (SCC 22-85-002-009); and

• Yard/switch locomotives are used in freight yards to assemble and disassemble trains, or for short hauls of trains that are made up of only a few cars (SCC 22-85-002-010).

Along with many other MANE-VU states, Connecticut participated in the Eastern Regional Technical Advisory Committee (ERTAC) inventory effo rt for railroad locomotives and rail yards 73 as the starting point for developing the 2007 railroad emissions inve ntory. The ERTAC rail inventory included only larger categories of locomotive emissions, such as la rge Class I line-haul and Class I rail yard switchers. This focus did not fit Connecticut’s railroad profile of predominantly line haul commuter (e.g. Shoreline East) and passenger (e.g., AMTRAK) activity, with Class II/III short line and regional railroads and a Class I railroad isolated from the Class I hub by Cl ass II and III owned rail and a substandard bridge associated with an inconvenient pa thway thru New York. Consequently, the ERTAC effort was not of
direct use and CT DEEP calculated all the emissi ons needed for the 2007 railroad inventory. See Appendix H for further detail.

Future Year Railroad Inventory Development In March 2008, EPA finalized a three-part program that will dramatically reduce emissions from diesel locomotives of all types -- line-haul, switch, and passenge r rail. As part of this work, EPA developed a national emission inventory for calendar years 2002 through 2040. Emission projections methodologies
for a baseline and controlled scenario were developed and documented. 74 MARAMA’s contractor used the EPA methodology, updated with AEO2010 projections for passenger rail and freight rail energy use to develop MANE-VU future year inventories.



### 5.1.7 On-Road Mobile Sour ce Inventory Procedures

EPA’s recently released MOVES2010 ( MO tor V ehicle E mission S imulator) is now the official model for estimating air pollution emissions from on-road m obile sources including buses, cars, trucks and motorcycles for SIP purposes 75 . MOVES2010 replaces MOBILE6.2, EPA’s previous mobile source model. MOVES input files are more detailed than the MOBILE6.2 input files. To assist in the transition to the new model, EPA developed software tools to convert certain MOBILE6.2 inputs for MOVES.

73 See Section 6.3 of Appendix A for more information on the ERTAC railroad inventory and associated ERTAC reference material.

74 See Section 5.3.3.1 of Appendix B for a more complete discussion of how the projected railroad emissions were determined, as well as for associated EPA references.

75 Emission estimates in this SIP revision were developed us ing MOVES2010a, EPA’s latest version at the time. EPA subsequently released a minor update , MOVES2010b in April2012. EPA documen tation indicates that MOVES2010b does not significantly affect criteria pol lutant emissions compared to previous versions of MOVES2010.

### 49 These inputs were loaded into the MOVES County Da ta Manager (CDM), which together with LEV database files and MOVES run Specifications, were used to generate MySQL database output files generated by the MOVES Model. Post processing was accomplished using SQL in either MySQL or MS

Access.

States involved in the regional MARAMA inventory e ffort were offered the option of having NESCAUM perform the MOVES modeling using input data provided by and/or reviewed by the states. CT DEEP initially selected this option and provided the re quested 2007 and 2025 inputs to MARAMA/NESCAUM in 2010 from data available at that time. By early 2012, CT DEEP was able to assemble updated MOVES data sets for several required pa rameters and elected to perform its own MOVES runs (using the inventory mode) with the updated data for 2009, 20 17 and 2025. Connecticut’s MOVES input data sets are summarized in Tables 5.2 through 5.4, with more detailed documentation provided in Appendix I.
Table 5.2 describes the selections made when creatin g the MOVES 2010a run specifications. Table 5.3 summarizes the CDM inputs loaded into the MOVES model. Table 5.4 lists references cited in the previous two tables.

Connecticut decided to include 2009 MOV ES on-road emission estimates in the PM 2.5 attainment year inventory, rather than developing updated 2007 emission estimates. Th is was done for several reasons. First, EPA had previously approved 2009 transpor tation conformity motor vehicle emission budgets (MVEB) for Connecticut that were determined using MOBILE6.2; the 2009 MOVES estimates were initially intended to replace those budgets using EPA’s state-of-the art model (see Section 5.1.9 for an explanation of why 2009 MVEBs are no longer necessary) . Second, since on-road emissions are steadily decreasing due to fleet turnover to lower emitting ve hicles, 2009 on-road emissions are lower than 2007 estimates (see the next paragraph for a comparison of 2007 and 2009 on-road emissions). Use of the
lower 2009 on-road emission estimates fo r 2007 ensures that the total attainment year inventory across all source sectors will be more conservative (i.e., lower) th an if 2007 on-road emissions were used. Since emissions through the end of the maintenance peri od must be no higher than the attainment year inventory, this approach provid es additional assurance that NAAQS co mpliance will continue through the maintenance period.

### 50 

## Table 5.2 MOVES Run Specifications

Scale Description MOVES Scale input page (panel) allows the selection of the Domain/Scale and Calculation Type for the run specification. Data Source EPA recommends the use of the county scale for SIP analyses [R3]. The Inventory Calculation type was used to integrate input calculations for a direct result for quick and reliable calculation of emissions.



### Time Spans Description MOVES Time Spans panel allows the selection of Time Aggregation Level (inputs), Years, Months, Type of Days and Hours. [R3] Data Source For SIP and regional conformity analysis, hour should be selected for Time Aggregation Level. Because emissions of criteria pollutants are dependent on ambient temperature, diurnal, daily, and monthly variations in temperature can have large impacts on emission results. [R3]

MOVES can model calendar years 1990 and 1999-2050, inclusive. The County scale in MOVES allows only a single calendar year in a run specification [R3]. For the
PM 2.5 redesignation effort, 2009, 2017 and 2025 were selected. A separate run and run specification was needed for each year and for each county.

To obtain an annual estimation of direct PM 2.5 emissions, SO 2 and NO
x , all twelve months, week and weekday were selected under the Day submenu and all hours (24 hours per day) were selected for the time span applicable to the MOVES run.



### Geographic Bounds Description MOVES requires the selection of a single county for each year when County is selected for the Domain/Scale. [R1]
Data Source The Connecticut counties associated with the PM 2.5 redesignation effort are Fairfield and New Haven. Individual run specifica tions and detailed c ounty data manager inputs were provided for each count and each year modeled. County Data Manager inputs are further described in the table for MOVES Inputs below.



### Vehicles/Equipment - On Road Vehicles Description Allows the selection of Fuels and Source Use Types (types of vehicles) combinations. Data Source For SIP and regional conformity an alyses, the appropriate fuel and vehicle type combinations in the On Road Vehicle Equipment panel must be selected to reflect the full range of vehicles that will operate in the county for the year selected. [R3]

Liquefied Petroleum Gas (LPG) and the Place holder Fuel Type were not included in the selection of fuels/vehicle combination included in Connecticut’s run specification. EPA discourages the inclusi on of the placeholder fuel. LPG was not included due to warnings produced at the time of the creation of the RunSpec, which was judged not worth investigating due to zero or extremely low vehicle LPG vehicle populations and VMT.

### 51 Road Type Description There are five ava ilable road types: Off-network, Rural Restricted Access, Rural Unrestricted Access, Urban Restricted Access, Urban Unrestricted Access. Data Source All five road type categories were selected to calculate a total annual emission estimate for direct PM 2.5 pollutants.



### Pollutants and Processes Description Pollutants, precursors and the processes th at can generate them can be selected in this input page [R3]
Data Source The PM 2.5 redesignation effort requires estimates for direct PM 2.5 , NO
x and SO 2
.



### Manage Input Data Sets (MIDS) Description This panel allows users to create and u se alternate data tables that are not part of the County Data Manager (CDM) inputs and that will be used in place of data from the MOVES default database [R3]. Data Source Connecticut was required to use the MIDS option to adjust emission factors associated with early adoption of the Low Emission Vehicle Standards. Connecticut adopted California Low Emission Vehicle (LEV) II standards in 2008 and also adopted early implementation of Nationa l Low Emission Vehicle (NLEV) standards for the 1999 and 2000 model years. Connec ticut used the EPA’s early LEV database and a database created following EPA directions for creating a CALEV database to properly model Connecticut emissions. The early adoption of National LEV (early LEV) and a database for CA LEV II were included in MIDS to adjust emissions for all years considered in this analysis [R5].



### Output - General Output Description This panel includes general information about the output. Data Source The name of the output database, the units (mass in U. S. Tons, energy in Joules and distance in Miles) for the output and the Activity Output requested. For activity, Distance Traveled and Population were sel ected to provide a quick check for these inputs.



### Output - Output Emissions Description In this subpanel several options can be selected. These options tell the model the level of aggregation of the outputs and how the results should be aggregated.
Data Source Since the PM 2.5 redesignation relies on an annual analysis, aggregation of the results at a monthly level greatly simplifies pos t processing requirements. This makes post processing easy and reduces the possibility of introducing errors. Results were segregated by Fuel Type, Emissions Processes Road Type and Source Use Type to provide the capability to view/review results in different ways. 

## Table 5.2 MOVES Run Sp ecifications (continued)

### 52 

## Table 5.3 MOVES County Data Manager (CDM)

Age Distribution Description Vehicle age is used to determine th e vintage of vehicle emission control technologies and vehicle deterioration. Fleets with a higher percentage of older vehicles have higher emissions than fleets with newer ve hicles. MOVES covers a 31-year range of vehicle ages, with vehicles 30 years and older grouped together [R3]. Data Source The 2011 registration data set wa s fully evaluated, assigned a model year and assigned a MOBILE6.2 16-vehicle type classification based on CT DMV registration data. A MOBILE6.2 age distribution and a MOVES age distribution were developed directly from the results of the DMV data analysis. The EPA’s default diesel sales algorithm was used to convert the MOBILE6 .2 16-vehicle type classifications to MOBILE6.2 28-vehicle type classifications. Table A.1 of the MOVES Technical Guidance [R3] was used to map the MO BILE6.2 28-vehicle type classification populations to MOVES source type populations.



### Average Speed Distribution Description Average speed is used to calculate vehicle run times and to determine the emission factor of the vehicles. Higher speeds for a given VMT reduces run time and the total time for running emissions, however higher speeds are typically associated with higher emission factors. Average speed data specific to vehicle type (sourceTypeID), road type (roadTypeID), and time of day/type of day (hourdayID) provides the data necessary for MOVES to calculate emissions. MOVES defines 16 "speed bins" which describe the average dr iving speed on a road type or link. MOVES uses a time-based distribution, whereas MOBILE6.2 used a VMT-based speed distribution. Data Source Connecticut used EPA Average Speed converters to produce MOVES inputs from MOBILE6.2 Speed-VMT files.



### Fuel Description Fuels inputs include both fuel formulation and fuel supply. Fuel Formulation specifies the components of the fuels cons idered. Fuel Supply indicates the fuel formulation’s fraction of the volume consumed in the area (i.e. market share) [R3]. Data Source MOVES default fuels inputs were used for all fuels except diesel and gasoline. Sulfur is the key parameter for diesel fuel. Diesel values were set at values specified in EPA guidance (i.e. 43 ppm in 2009 and 43 ppm after 2010). [R4] Connecticut specific reformulated gasoline data were used to establish gasoline parameters.



### Meteorology Description MOVES meteorological inputs cons ist of temperature and humidity data for months, zones (counties) and hours included in the MOVES run specification. Temperature and to a lesser extent humidity affect emission estimates; thus, assumptions used for regional conformity analyses must be consistent with those used to establish the emissions budget in the SIP as required in the transportation conformity rule, 40 CFR §93.122(a)(6) [R3]. Data Source MOVES meteorological inputs used the NMIM National County Database (version NCD20090531) for 2007, 2017 and 2025 to maintain consistency. [R5]

### 53 Road Type Distribution Description Road Type Distribution provides VMT fraction data relating to the vehicle miles traveled by road type (roadTypeV MTFraction) for the county being modeled. This data is entered as a distribution across road types (roadTypeID), where only road types selected by the user in the run specification are included in the distribution. The distribution must sum to one for each source type. Data Source Road Type Distribution was calculated for each Connecticut county using a preprocessor to produce a MOVES input table based on localization of adjusted default VMT mixes and Connecticut specific 2010 HPMS vehicle counts. This preprocessor table output county VMT estimates, MOBILE6.2 age distribution from 2011 DMV registration data, Connecticut 2009 VMT by hour observations and ramp fractions were input into EPA’s 16 vehicle type / 12 road type level VMT converter to obtain road type distribution outputs.



### Source Type Population Description Source type (vehicle type) populat ion is used by MOVES to calculate start and evaporative emissions. Because vehicle population directly determines start and evaporative emission, local data for this input must be developed.

Data Source The MOVES model categorizes vehicles into 13 source types, which are subsets of 6 MOVES HPMS vehicle types. 2011 Connecticut DMV Registration data was analyzed to develop population data for Mobile 6.2 16- vehicle type classifications. The EPA’s default diesel sales algorithm was used to convert the MOBILE6.2 16-vehicle type classifications to MOBILE6.2 28-vehicle type classifications. Table A.1 of the MOVES Technical Guidance [R3] was used to map the MOBILE6.2 28-vehicle type classification populations to MOVES source type populations. Connecticut Specific 2009 HPMS vehicle miles travelled (VMT) fr om MOVES input files were used to augment vehicle counts for Source Types within the HPMS 50 and 60 type obtained directly from the 2011 registration data. Growth factors based on Connecticut specific DOT estimates for each of the 6 MOVES HPMS vehicle type VMT for each Connecticut county were applied to each of the associated MOVES Source Types to develop Source Type Populations for 2017 and 2025. [R8]



### Ramp Fraction Description Ramp Fraction is the fraction of ramp driving time on selected road types. Only limited access road types (freeways and interstates) may have their ramp fractions modified. [R2] MOVES converters improperly indicate ramp VMT fraction. [R2, R9]

Data Source Ramp VHT was estimated by dividing Ramp VMT by the average speed for the appropriate road types set forth in MOBILE6.2 guidance. 

## Table 5.3 MOVES County Data Manager (continued)

### 54 Vehicle Type VMT Description As input, MOVES requires annual VM T by HPMS vehicle class but users can input average annual daily VMT as well as monthly and weekend day adjustment factors to create the annual VMT by HPMS class and appropriate monthly and daily adjustments needed by MOVES [R3].
Data Source Annual vehicle type VMT was calculated for each Connecticut county using a preprocessor to produce a MOVES input table based on localization of adjusted default VMT mixes and Connecticut specific 2010 HPMS vehicle counts. This preprocessor table output, county VMT estimates, MOBILE62 age distribution from 2011 DMV registration data, Connecticut 2009 VMT by hour observations and ramp fractions were input into EPA’s 16 vehicle type / 12 road type level VMT converter to obtain road type distribution outputs, hourVMTFraction, MOVES Source Type Age Distribution, and road type ramp fractions. The HPMSVTypeYear – daily VMT together with monthly adjustment factor based on seasonal VMT variations and EPA default weekend-day adjustment factor were input into the EPA Annual Average Weekday Vehicles Miles Travelled conv erter (aadvmtcalculator_hpms.xls) to generate the HPMSVTypeYear (annual), monthVMTFraction, and dayVMTFraction tables from Annual Average Weekday Vehicles Miles Travelled (AADVMT) and monthly/w eekend-day adjustment factors [R9]



### Inspection and Maintenance (I/M) Description The MOVES I/M input is used to calculate the emission benefit of the I/M program. A unique set of I/M inputs is needed for each calendar year and county modeled. The Connecticut vehicle I/M program is an important part of the strategy to ensure that Connecticut is positioned to attain the National Ambient Air Quality Standard for Ozone. [R6]. Data Source Connecticut I/M inputs were developed in accordance with the MOVES SIP and conformity Technical Guidance [R3]. I/M program inspection frequency, inspection program, process, polluta nt and vehicle regulatory class / MOVES source type applicability mappings were determined based on EPA technical guidance. Compliance factor was calculated based on the light duty vehicle fleet only and the following I/M data: 2009 I/M inputs were based on I/M compliance and waiver rate observations. Future year I/M inputs were based on I/M SIP compliance & waiver rate commitments. [R6,R7] All EPA MOVES default I/M inputs were deactivated by setting the “useIMyn” field to “N”. 

## Table 5.3 MOVES Count y Data Mana g er ( continued )

### 55 

## Table 5.4 References Cited in Table 5.2 and 5.3

Reference

Number Reference

[R1] EPA. Final Rule to Add PM 2.5 

### Precursors to the Trans portation Conformity Rule.
EPA-420-F-05-005 . May 2005. http://www.epa.gov/otaq/statere sources/transconf/regs/420f05005.pdf

[R2] EPA. Motor Vehicle Emission Simulator (MOVES) User Guide for
MOVES2010a. EPA-420-B-10-036 . December 2009. http://www.epa.gov/otaq/models/moves/MOVES2010a/420b10036.pdf

[R3] EPA. Technical Guidance on the Use of MOVES2010 for Em ission Inventory Preparation in State Implementation Plans and Transportation Conformity. EPA420-B-10-023. April 2010. http://www.epa.gov/otaq/models/moves/420b10023.pdf

[R4] EPA. Technical Guidance on the Use of MOBILE6.2 for Emission Inventory Preparation. EPA-420-R-04-013 . August 2004. http://www.epa.gov/otaq/models/mobile6/420r04013.pdf

[R5] NESCAUM. Development of MANE-VU On road Mobile Source Emissions for 2007 and 2020 using MOVES. December 2011.

[R6] De la Torre Klausmeir Consulting. 2 007 Connecticut’s Insp ection/Maintenance Program Evaluation. June 2008. http://www.ct.gov/dep/lib/dep/air/vehicle_e missions/2007imreport&appendicesfinal.pdf



### [R7] Connecticut Department of Environm ental Protection. Revision to the Connecticut’s State Implementation Plan. Enhanced Motor Vehicle Inspection and Maintenance Program. December, 2007. http://www.ct.gov/dep/lib/dep/air/regulations/pr oposed_and_reports/final2007_im_sip_revision.pdf



### [R8] EPA. Fleet Characterization Data for MOBILE6: Development and Use of Age Distributions, Average Annual Mileage Accumulation Rates, and Projected Vehicle Counts for Use in MOBILE6 (M6.FLT.007). EPA-420-R-01-047

. September 2001. http://www.epa.gov/oms/models/mobile6/r01047.pdf

[R9] EPA MOVES Converters. http://www.epa.gov/otaq/models/moves/tools.htm

### 56 Although CT DEEP did not devel op MOVES estimates of 2007 on- road emissions with updated Connecticut inputs, MARAMA’s inventory does in clude 2007 MOVES estimates for Connecticut’s portion of the NY-NJ-CT area using the previous vi ntage of Connecticut inputs. The 2009 CT DEEP runs include updates to input parameters such as the vehicle age distribution, which has become slightly older due to lower vehicle sales during the recent rece ssion. The updated inputs were also used to develop the 2017 and 2025 conformity budgets.

Table 5.5 compares MARAMA’s 2007 estimates to the 2009 estimates produced by CT DEEP. The 2009 on-road emission estimates are lower than those de veloped for 2007, supporting CT DEEP’s decision to use 2009 estimates in the attainment year inventory.



## Table 5.5 Comparison of MOVES Emissions for 2007 and 2009

MOVES On-Road Emission Estimates for Fairfield and New Haven Counties PM2.5 (tons/year) NOx (tons/year) SO2 (tons/year) 2007 MARAMA 815 24,384 187 2009 CT DEEP 794 23,391 176

When these results are considered together with the significant emission reductions projected through 2025 by CT DEEP’s MOVES runs (see Tables 5.6 thr ough 5.8 of the TSD), it is clear that on-road emissions have been declining and will continue to decline throughout the maintenance period.



### 5.1.8 Comparison of Attainment Year and Projected Future Year Emissions

As described earlier, EPA’s maintenance plan guidan ce requires states to provide an emissions inventory representative of the level of emissions sufficient to attain the NAAQS. In addition, the maintenance plan should include a demonstration of continued compliance by showing that future emissions during the maintenance period will not exceed the level of emissi ons in the attainment i nventory. The inventory procedures described above were applied to determ ine emission levels for 2007, the representative attainment year. Emissions during the maintenance pe riod were estimated for both an interim year (2017) and the final year (2025) of the maintena nce period to show continuing compliance.

Table 5.6 summarizes estimated annual PM 2.5 emissions in 2007 76 , 2017 and 2025 by major source sector for the two Connecticut counties that are part of the NY-NJ-CT PM 2.5 nonattainment area, as well totals
for the both counties combined. Also listed are the changes (tons/year and perc entage) between 2007 and
2025. Tables 5.7 and 5.8 summarize the same information for NO
x and SO 2 emissions, respectively. Appendix D provides information to access MARAMA’s ftp site, which includes detailed breakdowns of emissions for all categories except for the on-road m obile source emission estimates. Further information for on-road mobile emissions is included in Section 5.1.7 and Appendix I.

76 As described in Section 5.1.7, Connectic ut elected to combine on-ro ad mobile source emission estimates for 2009 with 2007 emission estimates for all other source categories when establishing the level of emissions that provides for attainment. Sinc e onroad emissions are steadily decreasing due to fleet turnover to lower emitting vehicl es, 2009 on-road estimat es are lower than 2007 estimates. Therefor e, the total attainment year inventory is more cons ervative (i.e., lower) than if 2007 on-road emissio ns were used. Since emissions through the end of the maintenance pe riod must be no higher than during the attainment year, this approach provides additional assurance that NAAQS comp liance will continue thr ough the maintenance period.

### 57 Particulate Matter (PM25

‐ PRI) V3.3 2007 2017 2025 2007 to
2025 2007 to
2025

Annual Annual Annual Change Change

State FIPS County SECTOR (tons) (tons) (tons) (tons) (Percent)

CT 09001 Fairfield AREA 1,991.5 1,892.3 1,827.5 ‐ 163.9 ‐ 8%

CT 09001 Fairfield NONROAD MAR 119.9 61.7 45.0 ‐ 74.8 ‐ 62%

CT 09001 Fairfield NONROAD NMIM 403.0 292.5 244.1 ‐ 158.9 ‐ 39%

CT 09001 Fairfield ONROAD MOVES 404.4 238.0 192.7 ‐ 211.7 ‐ 52%

CT 09001 Fairfield POINT EGU 283.5 79.4 131.5 ‐ 152.0 ‐ 54%

CT 09001 Fairfield POINT NONEGU 44.7 47.3 49.6 4.9 11%
Fairfield Total 3,247.0 2,611.2 2,490.4

‐ 756.5

‐ 23%

CT 09009 New Haven AREA 1,900.3 1,804.9 1,746.3 ‐ 153.9 ‐ 8%

CT 09009 New Haven NONROAD MAR 168.5 73.0 51.6 ‐ 117.0 ‐ 69%

CT 09009 New Haven NONROAD NMIM 279.1 181.7 136.8 ‐ 142.3 ‐ 51%

CT 09009 New Haven ONROAD MOVES 389.6 229.4 186.2 ‐ 203.4 ‐ 52%

CT 09009 New Haven POINT EGU 88.1 84.4 83.8 ‐ 4.2 ‐ 5%

CT 09009 New Haven POINT NONEGU 40.4 44.5 46.6 6.2 15%

New Haven Total 2,866.0 2,417.9 2,251.3

‐ 614.7

‐ 21%
Total CT
Portion of

NY

‐ NJ

‐ CT Area 6,113.0 5,029.1 4,741.7

‐ 1,371.2

‐ 22%

Oxides of Nitrogen (NOx) V3.3 2007 2017 2025 2007 to
2025 2007 to
2025

Annual Annual Annual Change Change

State FIPS County SECTOR (tons) (tons) (tons) (tons) (Percent)

CT 09001 Fairfield AREA 3,088.8 2,771.3 2,740.1 ‐ 348.7 ‐ 11%

CT 09001 Fairfield NONROAD MAR 3,034.2 1,957.5 1,345.4 ‐ 1,688.8 ‐ 56%

CT 09001 Fairfield NONROAD NMIM 4,648.1 2,615.8 2,057.3 ‐ 2,590.8 ‐ 56%

CT 09001 Fairfield ONROAD MOVES 11,888.9 5,414.1 3,573.2 ‐ 8,315.7 ‐ 70%

CT 09001 Fairfield POINT EGU 2,268.5 741.7 1,108.2 ‐ 1,160.3 ‐ 51%

CT 09001 Fairfield POINT NONEGU 1,875.4 2,224.0 2,543.5 668.1 36%
Fairfield Total 26,804.0 15,724.4 13,367.8

‐ 13,436.2

‐ 50%

CT 09009 New Haven AREA 2,936.1 2,636.8 2,608.1 ‐ 328.0 ‐ 11%

CT 09009 New Haven NONROAD MAR 3,945.9 2,487.0 1,736.2 ‐ 2,209.7 ‐ 56%

CT 09009 New Haven NONROAD NMIM 3,688.1 2,076.6 1,603.9 ‐ 2,084.3 ‐ 57%

CT 09009 New Haven ONROAD MOVES 11,502.7 5,293.9 3,540.1 ‐ 7,962.6 ‐ 69%

CT 09009 New Haven POINT EGU 639.6 386.6 384.5 ‐ 255.0 ‐ 40%

CT 09009 New Haven POINT NONEGU 822.7 896.0 951.6 128.9 16%

New Haven Total 23,535.1 13,776.9 10,824.4

‐ 12,710.7

‐ 54%
Total CT
Portion of

NY

‐ NJ

‐ CT Area 50,339.1 29,501.3 24,192.2

‐ 26,146.9

‐ 52% 

### Table 5.6 Connecticut PM 2.5 

### Emissions Inventor y Pro j ections 2007-2025

Table 5.7 Connecticut NO x 

### Emissions Inventory Projections 2007- 2025

### 58 Sulfur Dioxide (SO2) V3.3 2007 2017 2025 2007 to
2025 2007 to
2025

Annual Annual Annual Change Change

State FIPS County SECTOR (tons) (tons) (tons) (tons) (Percent)

CT 09001 Fairfield AREA 3,917.3 3,157.5 2,835.2 ‐ 1,082.1 ‐ 28%

CT 09001 Fairfield NONROAD MAR 353.4 39.6 18.5 ‐ 334.9 ‐ 95%

CT 09001 Fairfield NONROAD NMIM 215.8 8.5 9.4 ‐ 206.4 ‐ 96%

CT 09001 Fairfield ONROAD MOVES 84.3 71.5 66.4 ‐ 17.9 ‐ 21%

CT 09001 Fairfield POINT EGU 3,311.2 849.4 1,421.3 ‐ 1,889.9 ‐ 57%

CT 09001 Fairfield POINT NONEGU 154.8 167.8 180.0 25.2 16%
Fairfield Total 8,036.7 4,294.2 4,530.8

‐ 3,505.9

‐ 44%

CT 09009 New Haven AREA 3,707.7 2,984.5 2,677.1 ‐ 1,030.6 ‐ 28%

CT 09009 New Haven NONROAD MAR 727.4 85.1 35.7 ‐ 691.6 ‐ 95%

CT 09009 New Haven NONROAD NMIM 174.1 6.9 7.6 ‐ 166.5 ‐ 96%

CT 09009 New Haven ONROAD MOVES 91.8 79.7 74.7 ‐ 17.2 ‐ 19%

CT 09009 New Haven POINT EGU 822.7 400.1 398.4 ‐ 424.3 ‐ 52%

CT 09009 New Haven POINT NONEGU 55.6 58.5 59.5 3.9 7%

New Haven Total 5,579.2 3,614.8 3,252.9

‐ 2,326.3

‐ 42%
Total CT
Portion of

NY

‐ NJ

‐ CT Area 13,615.9 7,909.0 7,783.7

‐ 5,832.2

‐ 43%

Results set forth in Tables 5.6, 5.7 and 5.8 demonstrate that total emissions of all three PM 2.5 -related pollutants decrease significantly through the maintena nce period in Connecticut’s portion of the NY-NJCT area, with PM 2.5 emissions decreasing by 22%, NO
x by 52% and SO 2 by 43% between 2007 and 2025. These projected reductions occur due to the current ly adopted federal and state control programs described in Section 4, with no additional contro l strategies necessary to maintain the NAAQS in Connecticut through the end of the maintenance period.

Similar reductions are projected for the remaining por tions of the nonattainment area. Tables 5.9 and 5.10 provide preliminary estimates from the MARA MA inventory for the New York and New Jersey portions of the area, respectively. Although fina l emission estimates for New York and New Jersey are subject to change, the projected declines in all thr ee states demonstrate that continued compliance during the maintenance period will occur, satisfy ing the CAA Section 175A requirement. 

### Table 5.8 Connecticut SO 2 

### Emissions Inventor y Pro j ections 2007-2025

### 59 

### 5.1.9 Motor Vehicle Emission Budgets

Under CAA section 176(c), new transportation plans, pr ograms, and projects, such as the addition of new highways, must “conform” to (i.e., be consistent w ith) motor vehicle emission budgets (MVEBs), the part of the state’s air quality plan that addresses emissions from cars and trucks. Conformity to the SIP means that transportation activities will not cause new air quality violations, worsen existing violations, or delay timely attainment of the NAAQS or any interim milest ones. If a transportation plan does not conform, most new projects that would expand the capacity of roadways cannot move forward. Regulations at 40 CFR 93 set forth EPA policy, criteria, and procedures for demonstrating and assu ring conformity of such Interpolated Values Oxides of Nitrogen (NOx) Particulate Matter (PM25

‐ PRI) Sulfur Dioxide (SO2)
Missing: assumed

same as 2017 Annual Annual Annual Annual Annual Annual Annual Annual Annual

NEW YORK (tons) (tons) (tons) (tons) (tons) (tons) (tons) (tons) (tons)

SECTOR 2007 2017 2025 2007 2017 2025 2007 2017 2025

AREA 41899.7 36640.4 35467.7 9145.6 9403.9 10126.7 29513.2 4412.2 4389.5

NONROAD MAR 24142.8 18316.2 16617.0 916.3 474.7 392.8 6189.5 1199.2 1067.5

NONROAD NMIM 38580.0 22795.0 22795.0 3197.9 2241.8 2241.8 612.9 598.4 598.4

ONROAD MOVES 146859.1 93104.7 50101.2 6690.7 4773.4 3239.5 970.4 945.2 925.0

POINT EGU 26165.8 26132.8 26121.4 2128.7 2102.9 2102.9 40269.6 39926.4 39920.0

POINT NONEGU 10663.9 9596.7 10185.5 303.0 314.4 320.6 3616.7 3552.5 3671.0

NY TOTALS 288311.4 206585.7 161287.8 22382.3 19311.1 18424.3 81172.5 50634.0 50571.5

Interpolated Values Oxides of Nitrogen (NOx) Particulate Matter (PM25

‐ PRI) Sulfur Dioxide (SO2)

NEW JERSEY Annual Annual Annual Annual Annual Annual Annual Annual Annual

(tons) (tons) (tons) (tons) (tons) (tons) (tons) (tons) (tons)

SECTOR 2007 2017 2025 2007 2017 2025 2007 2017 2025

AREA 16118.9 15965.9 16057.5 5475.0 5472.5 5617.2 4983.4 452.2 451.7

NONROAD MAR 15719.4 13899.9 12121.0 500.6 287.0 265.7 4552.4 684.3 835.4

NONROAD NMIM 24105.2 13149.8 10110.1 2046.3 1438.4 1147.4 1201.4 34.7 38.7

ONROAD MOVES 81479.5 45687.4 17053.8 2683.5 1873.9 1226.3 592.4 530.8 481.5

POINT EGU 7854.2 6604.3 6226.9 3767.1 1899.0 1955.4 18832.6 2228.1 2399.5

POINT NONEGU 7623.4 6907.4 7200.8 1141.8 1232.0 1287.5 1465.7 1355.0 1441.0

NJ TOTALS 152900.6 102214.8 68770.0 15614.4 12202.9 11499.5 31627.9 5285.1 5647.7

Table 5.9 New York Preliminary Emissions Projections 2007-2025

Table 5.10 New Jersey Preliminary Emission Projections 2007-2025

### 60 transportation activities to a SIP. Transportation c onformity is a requirement for both nonattainment and
maintenance areas.

Under the CAA, states submit, at various times, control strategy SIPs and maintenance plans for nonattainment areas. These control strategy SIPs (e.g ., attainment demonstrations) and maintenance plans create MVEBs for criteria pollutants and/or their pr ecursors to address pollution from cars and trucks. Per 40 CFR 93, a MVEB must be established for the last year of the maintenance plan. A state may adopt MVEBs for other years as well. The MVEB is the portion of the total allowable emissions in the
maintenance demonstration that is allocated to hi ghway and transit vehicle use and emissions (see 40 CFR 93.101). The MVEB serves as a ceiling on emissions from an area’s planned transportation system.

For PM 2.5 nonattainment and maintenance areas, MVEBs must be established for direct PM 2.5 emissions
and for NO
x emissions 77 . The MVEB concept is further explaine d in the preamble to the November 24, 1993, Transportation Conformity Rule (58 FR 62188). The preamble also describes how to establish the
MVEB in the SIP and how to revise the MVEB.

Connecticut has elected to develop MVEBs for PM 2.5 78 and NO
x for the years 2017 and 2025. The 2017 budgets will apply to transportation plan years 2017 th rough 2024, while the 20 25 budgets will apply for plan years 2025 and later.

Connecticut requests that the previously approved 2009 PM 2.5 -related MVEBs be withdrawn from the SIP. These budgets were devel oped using EPA’s now outdated MOBILE6.2 model. Since this redesignation request is establishing new MOVES-base d MVEBs for 2017 and 2025 that are less than the attainment year on-road emissions, it is not necessar y to establish 2009 MVEBs with MOVES. Given the expected timing for EPA approval of the redesignati on/maintenance SIP revision (i.e., late 2012), any subsequent conformity determination prepared by the CTDOT/MPOs will not be required to examine

PM 2.5 -related emissions for any analysis years prior to th e first budget year (i.e., 2017) to be included in
the revised SIP.

The MVEBs for 2017 and 2025 are summarized in Tabl e 5.11 for the Connecticut portion of the NY-NJCT area. The 2017 and 2025 MVEBs reflect the tota l on-road emissions projected by MOVES for those years, plus an allocation from the available PM 2.5 and NO
x “safety margins”. Under 40 CFR 93.101, the term “safety margin” is the differe nce between the attainment level (from all sources) and the projected level of emissions (from all sources) in the maintenance plan. All or a portion of the safety margin can be allocated to the transportation sector; however, total emissions across all source sectors must remain
below the attainment level. Connecticut has elected to use only 10% of the available safety margins for each pollutant in the 2017 and 2025 MVEBs to account for uncertainties in potential future changes to emission factor models and to provide some flexibility in future vehicle miles traveled projections while still ensuring that emissions remain well below attainment levels.

77 On-road mobile sources produce less than 2% of total SO 2 emissions from all source categories and are judged to be de minimis; thus SO 2 MVEBs are not necessary.

78 MVEBs established for direct PM 2.5 do not include emissions of either re-entrained road dust or construction dust from transportation projects; however, emission estimates for both of those categories are accounted for in the area source portion of the inventory.

### 61 

## Table 5.11 Transportation Conformity Budget s for Connecticut’s Portion of the NY-NJ-CT Area

Year PM 2.5 (tons/year) NO
x (tons/year)
2017 On-Road Inventory 467.4 10,708.0 Safety Margin vs. 2007 1083.9 20,837.8 10% of Safety Margin 108.4 2,083.8 2017 Conformity Budget 575.8 12,791.8 2025 On-Road Inventory 378.9 7,113.4 Safety Margin vs. 2007 1371.3 26,146.9 10% of Safety Margin 137.1 2,614.7 2025 Conformity Budget 516.0 9,728.1

When these budgets are deemed adequate or are approve d by EPA (whichever occurs first), subsequent transportation plans must show compliance with the 2017 budgets for any analysis years from 2017 through 2024, and compliance with the 2025 budgets for any analysis years from 2025 onward.



### 5.2 Ambient Monitoring Network Commitment

EPA’s guidance calls for states to commit to mainta in an appropriate monitoring network during the maintenance period. As described in Section 2.1, DEEP currently operates a monitoring network with

seven PM 2.5 FRM locations in the Connecticut portion of the NY-NJ-CT nonattainment area (see Figure 2.1). Annual monitoring network plans and five-y ear network assessment reports are prepared and submitted to EPA. These reports describe, among other th ings, plans for future changes to the monitoring network. Potential changes in the number and/or lo cation of monitors are discussed with EPA well in advance of implementation. DEEP commits to continuing operation of an appropriate PM 2.5 monitoring network through the maintenance period. Any pote ntial changes to the existing network will be considered in collaboration with EPA through the network planning and assessment procedures to make sure the monitoring requirements of the maintenance plan are satisfied. CT DEEP will also continue to quality assure the monitoring data to meet the require ments of 40 CFR 58 and enter all data into AQS on a timely basis in accordance with federal guidelines.



### 5.3 Verification of Continued Attainment

EPA’s guidance also calls for states to track the pr ogress of the maintenance plan to verify continued compliance during the maintenance period. CT DEEP plans to use two indicators to verify continued compliance, monitoring data and emissions estimates . CT DEEP will continue to conduct ambient PM 2.5 monitoring in accordance with 40 CFR 58 requirement s and expeditiously review data as it becomes

### 62 available to evaluate any risk of impending NAAQS violations. CT DEEP will also regularly review available emission inventory updates produced by EP A (e.g., NEI updates or inventories developed for potential national rules) and/or CT DEEP (e.g., periodic inventories required by the Federal Consolidated Emissions Reporting Rule under 40 CFR 51 Subpart A) to identify any projected increases in emissions that might threaten NAAQS compliance. Both of th ese indicators will be used as potential triggers for early action in the continge ncy plan described below.



### 5.4 Contingency Plan

CAA section 175A and EPA guidance specify that main tenance plans include contingency provisions to promptly correct any violation of the NAAQS that occurs after redesignation of the area. Such provisions shall include a requirement that the State will implemen t all measures with respect to the control of the air pollutant concerned that were contained in the SIP befo re redesignation of the area to an attainment area. For the purposes of section 175A, a state is not require d to have fully adopted contingency measures that will take effect without further action by the state in order for the maintenance plan to be approved. 79 However, the contingency plan is considered an enfo rceable part of the SIP and should ensure that the contingency measures are adopted in a timely fashion once they are triggered. The plan should clearly identify the measures to be adopted, a schedule and procedure for adoption and implementation, and a specific time limit for action by the state. As a nece ssary part of the plan, the state should also identify specific indicators, or triggers, which will be used to determine when the con tingency measures need to be implemented.

CT DEEP will implement a two-level plan to identify, examine and, if necessary, implement appropriate
action for monitored PM 2.5 levels that approach or violate the 1997 annual or 2006 24-hour PM 2.5 NAAQS. An initial Warning Level Response will be triggered based on PM 2.5 levels that approach the NAAQS, as described in Section 5.4.1. This voluntary commitment is intended to evaluate the need for early actions to prevent violations of the NAAQS from ever occurring during the maintenance period. Should early actions not be successful and a violation occurs, an Action Level Response will be triggered,
as described in Section 5.4.2.



### 5.4.1 Warning Level Response

The initial Warning Level Response is intended to av oid the occurrence of future NAAQS violations by tracking air quality monitoring data and available em ission inventory estimates to identify when the area is at risk of violating the NAAQS. For the 24-ho ur NAAQS, a violation occurs when the three-year average of annual 98 th percentile daily values is greater than 35 μg/m 3 at any site. For the annual NAAQS, a violation occurs when the three-year av erage of annual averages is greater than 15 μg/m 3 at any site. The Warning Level Response will be triggered if either a single year’s 98 th percentile daily value or a single year’s annual average exceeds those respec tive values at any CT DEEP site in the
maintenance area and is verified. CT DEEP will exam ine available information to identify contributing factors such as atypical meteorological conditions, ex ceptional events, local changes in source activity, or

79 ”Procedures for Processing Request s to Redesignate Areas to Attainment”; Memorandum from John Calcagni, Director, Air Quality Management Division; September 4, 1992.

### 63 source malfunctions or noncompliance. CT DEEP will also evaluate available emission inventories and other data repositories (e.g., EPA’s CAMD datab ase of hourly EGU emissions) to determine if unexpected emissions increases have occurred. Base d on any findings, CT DEEP will evaluate available and feasible options and make a judgment on whet her any early corrective actions are warranted.



### 5.4.2 Action Level Response

If a verified violation of either PM 2.5 NAAQS occurs, CT DEEP will first conduct the same types of investigations described above to determine potentia l causes and available resolutions. If the causes are within the jurisdiction and control of CT DEEP (e.g., not predominantly due to interstate transport or exceptional events), one or more control measures such as those in the example list below will be pursued for implementation. Ultimately, contingency meas ures to be considered will be selected from a comprehensive list of measures deemed appropriate and effective at the time the selection is made. The selection of measures will be based upon cost eff ectiveness, emission reduction potential, economic and social considerations, or other appropriate factors. Stakeholder input will be solicited from interested and affected persons in the maintenance area prior to selecting any appropriate contingency measures. Because it is not possible at this time to determine wh at control measure will be appropriate at any future time during the maintenance period, the list of possible measures below is not intended to be comprehensive or exhaustive.

• Control measures already adopted, but designe d to produce additional reductions after the verified violation occurred (e.g., mobile source measures that involve fleet turnover);

• New control measures that may be adopted fo r other purposes (e.g., Tier 3 or CALEV3);

• Alternative fuel and/or diesel retrofit programs for fleet vehicle operations;

• New or more stringent PM2.5, NOx or SO2 controls on stationary sources;

• Wood stove change out program;

• “No burn” days during cold weather inversion events;

• Enhanced idle restrictions;

• Transportation control measures, selected in consultation with CTDOT and affected local metropolitan planning organizations (e.g., traffic flow improvements, transit improvements, trip reduction programs, other new or innovative transportation measures)

CT DEEP commits to pursue adoption of any a ppropriate measures with a goal of achieving implementation within 18 months from the date when the violation triggering the Action Level Response is verified. As required by CAA 175A(d), upon ve rification of a NAAQS violation, CT DEEP also commits to implement all measures that were containe d in the SIP before the area was redesignated to
attainment.



### 5.5 Commitment to Revise Plan

CT DEEP commits to submit a revised maintenance pl an eight years after EPA finalizes redesignation.
The revision will demonstrate that attainment will c ontinue to be maintained for the 10 years following the initial 10-year period, as required by CAA section 175A(b).

### 64 

## Chapter 6 Summary and Conclusions

This TSD justifies CT DEEP’s request to redesigna te Connecticut’s portion of the NY-NJ-CT area to
attainment for the federal 1997 annual and 2006 24-hour PM 2.5 NAAQS. As summarized below, this redesignation request satisfies all the requirements of Section 107(d)(3)(E) and 175A of the CAA, which specify the conditions that must be met for EPA to re designate an area from nonattainment to attainment.



### 6.1 Area Has Atta ined the NAAQS

As demonstrated in Section 2, PM 2.5 air quality has improved sign ificantly over the last decade throughout the NY-NJ-CT nonattainment area. The entir e area first achieved attainment levels of the 15 μg/m 3 annual NAAQS in 2008 and the most recent (i .e., 2010) maximum design value is 12.5 μg/m 3

. Connecticut’s portion of the nonattainment area h as measured compliance with the annual NAAQS throughout the period, with a maximum 2010 design value of 10.3 μg/m 3

.

The NY-NJ-CT area first achieved compliance with the 35 μg/m 3 24-hour NAAQS in 2009 and has a most recent (i.e. 2010) maximum design value of 30 μg/m 3 . Connecticut’s portion of the area first measured attainment in 2008, with a maximum 2010 design value of 29 μg/m 3

.



### 6.2 Applicable CAA Section 110 and Title 1 Part D Requirements are Satisfied

As demonstrated in Section 3.1, Connecticut has submitted “infrastructure SIPs” addressing CAA section 110(a) requirements, for both the 1997 annual and 2006 24-hour PM 2.5 NAAQS. EPA has found
Connecticut’s infrastructure SIP submittal for the 1997 annual NAAQS to be complete, but has not yet issued rulemakings to approve the infrastructure SI Ps for either of the NAAQS. Nonetheless, previous redesignation rulemakings issued by EPA for other areas have concluded that section 110 elements not connected with nonattainment plan submissions and not linked with an area’s attainment status are also not applicable requirements for purposes of red esignation because a state remains subject to these requirements after an area is redesignated to attainment.

As described in Section 3.2, CAA Subpart 1 of pa rt D sets forth the basic nonattainment requirements applicable to all nonattainment areas. All areas that were designated nonatta inment for the 1997 annual
or the 2006 24-hour PM 2.5 NAAQS were designated under this subpart of the CAA and the requirements applicable to them are contained in sections 17 2 and 176. For purposes of evaluating redesignation requests, the applicable part D, subpart 1 SIP require ments are contained in sections 172(c)(1)–(9) and in
section 176.

States with nonattainment areas are required to submit a plan to reach attainment. Connecticut submitted
an attainment demonstration for its portion of the 1997 annual PM 2.5 nonattainment area in November

### 65 2008, meeting the requirements of CAA sections 172 and 176. EPA has not yet acted on that plan. See
Section 6.5 for further discussion related to the attainme nt demonstration. Attain ment demonstrations for
the 24-hour PM 2.5 NAAQS are due in December 2012.

As demonstrated in Section 2, all air quality mon itors in the NY-NJ-CT area now comply with both the annual and 24-hour NAAQS. EPA has already recognized that the multi-state area has “clean data”, in
accordance with 40 CFR 51.1 004(c), for the annual PM 2.5 NAAQS. Connecticut has requested a similar “clean data” finding for the 24-hour PM 2.5 NAAQS and is awaiting EPA action. The requirement to
submit the 24-hour PM 2.5 NAAQS attainment demonstration w ould no longer apply if EPA issues a “clean data” finding for that NAAQS, or if EPA a pproves a redesignation request for the 24-hour PM 2.5 NAAQS before the December 2012 due date.

CAA section 172(c)(3) requires an inventory of actual emissions. Included as part of this redesignation request is a 2007 base year emissions inventory that meets the requirement.

EPA’s PM 2.5 implementation rules require states to adopt specified new source review (NSR) permitting revisions by July 20, 2012. CT DEEP held a public hearing in November 2011 to consider revisions to
RCSA sections 22a-174-1 and 22a-174-3a to include si gnificant impact levels, significant emissions rates
and increments for PM 2.5 , consistent with EPA ’s requirements. CT DEEP anticipates that the revised regulations will be submitted as a SIP revision by the end of summer 2012, at which point Connecticut will have in place all applicable CAA Section 110 and Title 1 Part D requirements necessary for PM 2.5 redesignation.



### 6.3 Attainment is Due to Permanent and Enforceable Emission Reductions

Section 4 described adopted federal and state emissi on control programs that have improved annual and
24-hour PM 2.5 air quality to levels that qualify the ar ea for redesignation to attainment. As was summarized in Table 4.1, federal controls include mo re stringent engine emission and fuel standards for on-road and non-road sources, and more restrictive li mits on emissions from power plants. State controls include tighter emission limits for power plants and other large sources, improvements to PM and visible emission requirements for stationa ry sources, adoption of the CALEV2 program for on-road vehicles, enhancements to the on-road vehicle inspection a nd maintenance program, as well as other measures. The combination of these control programs provides an estimated 30% reduction in NOx emissions, 29%
in SO2 emissions and 4% reduction in direct PM 2.5 emissions in Connecticut between 2002 and 2009, leading to the improvements in ambient PM 2.5 air quality.

### 66 

### 6.4 Maintenance Plan Ensu res Continued Attainment

CAA section 175A establishes the required elemen ts of a maintenance plan for areas seeking redesignation from nonattainment to attainment. S ection 5 provides Connecticut’s maintenance plan, which includes an inventory sufficient to ensure atta inment, a demonstration us ing inventory projections that the plan provides for continued NAAQS complian ce through the first 10-year maintenance period, a commitment to maintain an appropriate monitoring network, methods to track the progress of the maintenance plan and contingency measures to be implemented if NAAQS violations occur during the maintenance period.

Having addressed all the requirements of CAA sections 107(d)(3)(E) and 175A, Connecticut requests that EPA take action to redesignate the Connecticut portio n of the NY-NJ-CT area to attainment status for
both the 1997 annual and 2006 24-hour PM 2.5 NAAQS.



### 6.5 Withdrawal of the A ttainment Demonstration

Connecticut submitted an attainme nt demonstration for Connectic ut’s portion of the NY-NJ-CT 1997
annual PM 2.5 nonattainment area in November 2008. EPA subsequently issued a Clean Data Determination (CDD) on November 15, 2010 (75 FR 695 89), ruling that the NY-NJ-CT area attained the
1997 annual PM 2.5 standard based on 2007-2009 monitori ng data. Among other things, the CDD suspended the requirement for Connecticut to subm it an attainment plan for the 1997 NAAQS. Per 40 CFR 51.1004(c), suspension of that requirement remains in place until the area is redesignated to attainment (at which time the requirement no longer applies) or EPA determines that the area has recorded new violations of the NAAQS (at which time the area is again required to submit such a plan).

Citing the November 2010 CDD ruling, EPA has suggest ed that Connecticut withdraw its November 2008 attainment demonstration SIP revision, excep t for adopted control measures. Based on the requirements of 40 CFR 51.1004(c), however, the De partment believes withdrawing the attainment demonstration prior to the date on which EPA appr oves the redesignation/maintenance plan would be premature since violations measured prior to that date could result in reinstatement of the legal obligation
to submit an attainment demonstration.

In light of this concern, the Department hereby with draws the attainment demonstration SIP, effective one day after EPA signs the final rule approving Connectic ut’s redesignation request and maintenance plans. This timing ensures that either the attainment plan or the maintenance plan will be in place at all times for Connecticut’s portion of the area. The Department al so specifies this withdrawal does not apply to any control measure except for the general permit described in Section 4.2 of this TSD. All other control
measures remain in the SIP to ensure continued maintenance of the NAAQS.