STATE OF CONNECTICUT 

DEPARTMENT OF ENVIRONJ\tIENTAL PROTECTION 

February 8, 2011 

Mr. David Conroy, Chief ofAir Programs Branch 

U.S. Environmental Protection Agency, Region I 

5 Post Office Square 

Mail Code: OEP05-2 

Boston, MA 02109-3912 

Re:	 Clean Data Detennination for the 2006 24-hr PM2.5 National Ambient Air Quality 

Standard 

Dear Mr. Conroy: 

The Connecticut Department of Environmental Protection (DEP) hereby requests the United· 

States Environmental Protection Agency (EPA) make a determination that the New YorkNorthern New Jersey-Long Island (NY-NJ-CT) nonattainment area has attained the 24-hour fine 

particulate (PM2.5) National Ambient Air Quality Standard (NAAQS) established by EPA in 

2006. This request is based on recent air quality data from monitors located throughout the NYNJ-CT nonattainment area, including Fairfield and New Haven Counties in Connecticut, all of 

which measure compliance with the NAAQS. 

DEP works diligently and in partnership with EPA, and the states ofNew York and New Jersey 

to assure clean air for our citizens. The air quality monitors throughout the area tell a compelling 

story - our air is cleaner and we are protecting public health. As demonstrated in the attachment 

to this correspondence, all air quality monitors in the Connecticut portion ofthe NY-NJ-CT area 

achieved attainment ofthe 24-hour PM2.5standard for the 2008-2010 period, the most recent 

period with fully quality assured, quality controlled and Connecticut certified monitoring data. 

Connecticut's maximum 2010 design value l of 291lg/m3, measured at Criscuolo Park and State 

Street in New Haven, is well below the 351lglm31evel of the 2006 PM2.5NAAQS. 

Air quality monitors in the New York and New Jersey portions ofthe NY-NJ-CT nonattainment 

area also reached attainment of the 2006 PM2.5 NAAQS for the most recent design value period 

ending in 2009, with maximum design values of 331lg/m3 in both states. Therefore, it is 

appropriate at this time to request a clean data detennination for the 2006 24-hr PM2.5NAAQS 

for the entire NY-NJ-CT nonattainment area. Notably and due to our ongoing partnership, 

attainment levels have been achieved well in advance of the December 2014 statutory deadline. 

It is our understanding that an EPA clean data detennination for the 2006 24-hr PM25 NAAQS 

suspends the requirement for DEP to submit an attainment demonstration and associated 

I Design Values are developed in accordance to 40 CRF 50 Appendix N 

(Printed on Recycled PapcO
 

79 Elm Sireet • Ilartford. CT 06106-51 n
 

www.ct.gov/dep 

A/I Equal OPI'0r!lll/;II' ElI/ployer 
reasonably available control measures, reasonable further progress plans, contingency measures, 

and other planning items related to attainment ofthe PM2.5NAAQS, in accordance with 40 CFR 

51.1004. The DEP also understands that the suspension ofthese planning requirements can be 

rescinded ifEPA subsequently issues a finding that the area is no longer attaining the NAAQS. 

As described in the attachment, the measured improvements in PM2.5air quality are due to a 

variety ofstate and federal control programs implemented to reduce emissions ofPM2.5 and its 

precursor pollutants. Connecticut was one of the first states to adopt annual limits for both 

nitrogen oxides and sulfur dioxide emissions from power plants and other large industrial 

sources. Connecticut has also adopted motor vehicle emission standards for new light and 

medium duty vehicles that are more stringent than the federal standards and continues to sponsor 

retrofit programs to reduce PM2.S emissions from the existing vehicle fleet. 

Our efforts notwithstanding, DEP recognizes and values our partnership with EPA; many federal 

programs have also furthered our clean air goals such as low sulfur fuel standards for gasoline 

and diesel fuel, and heavy duty diesel engine standards. As sound science provides an ever 

better understanding ofthe impact offme particles on public health, our cooperative efforts must 

continue to provide the additional reductions in locally generated emissions and interstate air 

pollution transport needed to assure clean air for all of Connecticut's citizens. 

If the DEP can be of assistance in processing this request, please contact me at 860-424-3026. 

Thank you for your consideration ofthis matter. 

Yours truly, 

a~~ ~' Anne Gobin, Chief 

Bureau of Air Management 

Enclosure 

2 
ATTACHMENT 

Connecticut's 24-Hour PM2.5 Ambient Data Summary 

(February 2011) 

EPA's revision to the 24-hour PM2.5 NAAQS went into effect on December 18,2006, reducing 

the standard to 35J.lg/m3 from 65J.lg/m3

• On December 14,2007, in accordance with Section 

107(d)(l) ofthe Clean Air Act (CAA), Connecticut recommended that EPA include Fairfield and 

New Haven Counties as part of a multi-state nonattainment area with northern New Jersey and 

southern New York counties, based on 2006 design values that violated the NAAQS. On 

November 13, 2009 the EPA finalized designations for the standard, concurring with 

Connecticut's recommendations. 

Summary of PM~5 Ambient Monitoring Data 

Connecticut's December 2007 letter to EPA cited several ongoing state and federal control 

efforts that were expected to result in improved PM2.5 air quality, including programs targeting 

power plants, mobile source fuels, new on-road and non-road engine standards, and retrofit. 

controls for portions ofthe existing heavy-duty mobile source fleet. As anticipated, the 

implementation of these programs has resulted in improved air quality. Recent ambient 

monitoring data for 2008, 2009 and 2010 (see Figure 1) demonstrate that 24-hour PM2.

5design 

values in Connecticut comply with the NAAQS. 

A-l 
Table 1. 24 Hr PM2.5 Design Values and Associated 98th Percentiles for 2009 and 2010.2 

Current 98th Percentiles and Design Values for the New York-No New Jersey-Long Island, NY-NJ·CT Non­ ·w~;··;;'·;·';; ; 'f?;,' "y"_,; ,';"" i"",:, ,'; ••if ,., 

State Site 

Bridgeport 

Danbury 

Norwalk 

Westport 

Connerllrut New Haven Firehouse 

New Haven Cri""uolo 

New Haven State St 

New Haven Ag Station 

200798th 

Perrentlle 

30.2 

30.4 

31.9 

29.0 

29.8 

30.S 

30.6 

28.5 

'~"""$;,:' ".".".'" "';,".:, ~.;£t" .• ",; 

200898th 

Perrentile 

30.3 

275 

263 

30.7 

30.9 

31.S 

32.1 

25.4 

200998th
 

Perrentile
 

29.3
 

27.6
 

293
 

26.4 

28.5 

32.3 

30.8 

27.3 

20tO 98th 

Perrentlle 

23.3 

25,7 

23.0' 

24.2 

SSD 

25.5 

23.9 

SSD 

", .~'. '" ''*1<:'\';' ,~,;" .f, ;;;)~;"

2009 Design 2010 D~illn

"alue "alue 

31 28 

29 ,".' 

29 261 

29 27 

30 SSD 

31 29 

31 29 

27 SSD f------=:----+------+------f------~------I------~---

Waterbury 32.7 28.4 28.1 25.7 30 27 ...--- .--l-----l-----~-....+---......----__I 

Fort lee 34.5 322 27.1 NA 31 NA 

Jen;ey City 34.9 32.0 29.2 NA 32 NA 

I----....:c.----.:---....--------·-·--·I------I----.J-------I·---­

Newark .14.9 28.7 NA NA NA 

UnionCily 39.1 33.4 26.6 NA 33 NA 

Trenton 32.5 31.0 23.0 NA 29 NA 

NA 

New Jersey 

Washington Crossing 27.2 280 22.2 NA 26 

North Bruns,,;ck Township 30.4 28.9 20.7 NA 27 NA ._-_..._-------- ---_. "--'--- -------_._- -_.---­

Morristown 32.4 23.8 2\.9 NA 26 NA 

Chester 31.4 24.3 20,9 NA 26 NA 

Paterson 36.6 28.6 26.1 NA JO NA 

\----....+-----1----_.­

Elizabeth Turnpike 35.0 33.8 27.7 NA 32 NA ........ )._ " \_ .
 

Elizabeth Downtown 35.9 JI I 25.6 SA .11 1'A 

Rahway .,4.4 299 25.2 NA .'0 1':A 

New York Morrisania J6.2 31.3 30.0 .n NA 

200lh Street And Southern 32.5 29.8 27.4 NA JO 1':A 

Bh'd'Botanical Garden 

New York IS-52 33.9 299 30.6 32 NA 

N~y York mS·126 J3.6 29.4 26..9 NA JO NA 

Cedarhurst Hempstead 28.5 29.2 25.8 NA 28 NA 

New York mS-4S 34.3 32.3 28.8 NA 32 NA 

New York PS·19 37.8 25.7 29.0 NA 31 NA :Sew York
 

PS·124 37.1 31.8 29.0 NA 33
 NA 

Newburgh 30.4 26.0 20.6 NA 26 

N~w York Queens Colleg~ 11.8 10 -' 267 NA 

New York Port Richmond 32.8 28.7 24.6 29 NA 

New York Susan Wagner 28.8 27.7 2.1.0 27 NA 

East Fanningdale Babylon 28.8 26.8 21.6 NA 26 NA 

Mamaroneck 30.6 30.4 27.0 NA 29 NA 

'Slte shut down ID 2009, new Newark SIte opened on 6,30109
 

SSD= Site Shut down in 2010
 

1 Value not valid, year is incomplete due to site construction
 

NA~QA'd data from NJ and NY will be available early 2011
 

2 Values were calculated and derived from each states representative agency using their certified data. 

A-4 
Figure 1. Connecticut's Maximum, Mean and Minimum PM2.5 Design Value Trend. 

Distribution of Connecticut's 24 Hr PM2.

5 Design Value Trend 

50 -r------------------------~

40 

M -

E

- 30

-Q) 

a; 

> 

l: 20 .~fI)
 

Q)
 

Q
 

Number of Sites 

-- CT Maximum 10 -- CTMean 

-- CT Minimum 

- .- - 2006 NAAOS (35mg1m3

) 

0 

8 8 H C'II C'II

14 

12 

rIl 

.! 

en 10 C)

c:: 

'i:: 

0 

.1: 8 c:: 

0 

'0 6 

Q,) 

.Q 

E 

Z 4 

2 

0 

.... 8 0

0

C'II C'II 

Year 

Improved ambient PM25 levels have occurred not only in Connecticut, but throughout the 

remainder of the nonattainment area as well. Figure 2 displays 2009 design values for 

Connecticut and the rest ofthe NY-NJ-CT nonattainment area. The highest design values in 

2009 (33!lglm3) occurred at the Union City, NJ and the New York City Morrisania and PS-124 

monitors. These levels represent attainment because they are less than the 35!lglm3 PM25 

NAAQS. The maximum Connecticut design value in 2009 was 31 !lglm3, measured at both the 

New Haven Criscuolo Park and State Street monitors. Table 1 provides more detail, including 

the 98th percentile values from 2007 through 2009 which are used to calculate the design value at 

each monitoring location. Data are also provided for 2010 for the CT sites where quality assured 

data recently became available. 

A-2 
Figure 2. 2009 Design Values in Connecticut and the NY-NJ-CT Nonattainment Area 

'2009 PM2•S 24-bour Design Values· 

for the New-York-New JerseyConn....aU East Ha.tf",d ~l<Alllin;, Connecticut Nonattainment Area 23 26 J 

Thomas'oll ""'-- . lEas, Ha';tonl High:' 

24 • -Wale,ltmy ,r . 26 •. JNO~~iCh ") jsJ- lJO -1 

\ • I---.....Sl.f· 1 \ t \ r 1 

't./\. ,r:- New HavellAg Sta'i"~U.-\ Dalluu~~ ~' ,

4 29 New ~~~ Cnscuolo New Ha' eu State --------_. 31 ? 

Bnd!!;;' H veu F...e House I. INew 8 JO 

NewYOIkffiS-126
 

30
 

New York PS-19
 

31 PM1.5 uglm' levels 

(24-bour NAAQS= 35 uglm') 

• ~35 uglm3 

• >35 uglm' 

"The deelgn ..II'" 3-yMr__oI ... 1l8Ih of2+11our concentnotlon.....vmenlor. (Up"" o-mbe, ~. 2010) 

A-3 
Control Strategies 

As listed in Table 2 below, numerous Federal and Connecticut control programs implemented 

since 2002 have resulted in decreased emissions ofPM2.5 and its precursors. These programs are 

responsible for the significant improvements in ambient PM2s levels, which now comply with 

the 24-hour PM2.5 NAAQS. 

Table 2. 

Federal Tier 2 Motor Vehicle ControlslLow Sulfur Gasoline 

Federal On-board Refueling Vapor Recovery 

Federal Heavy-Duty Diesel Vehicle Controls and Fuels 

Federal 2007 Highway Rule 

Federal Highway Motorcycle Exhaust Emission Standards 

Federal Non-Road Control Programs 

(See Table 4-2 for details of each strategy) 

Federal CAIR Requirements for S02 Sources· 

Outdoor Wood Burning Furnace Restrictions 

Section 22a-174k of the Connecticut General Statutes 

General Permit to Construct and/or Operate a New or Existing 

Distributed Generation Resource 

Permit to Construct and Operate Stationary Sources 

RCSA Section 22a-I74-3a 

Improvements in the Control of Particulate Matter and Visible 

Emissions RCSA Section 22a-I74-I8 

Control of Sulfur Dioxide and Nitrogen Oxide Emissions from 

Power Plants and Other Large Stationary Sources 

RCSA Sections 22a-I74-I9a and 22a-I74-22(e)(3 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

Restrictions on Asphalt Paving Operations 

RCSA Section 22a-I74-20(k) 

Reduced Vapor Pressure Limitation for Solvent Cleaning 

RCSA Section 22a-I74-20(1) 

The Post-2002 Nitrogen Oxides (NOx) Budget Program 

RCSA Section 22a-I74-22b 

X 

X 

X 

A-5 
CAIR NOx Ozone Season Trading Program 

X 

RCSA Section 22a-174-22c 

CT On-Board Diagnostic Inspection & Maintenance Program X X 

RCSA 22a-174-27 X 

Pressure-Vacuum Gas Station Vent Valves and Increased Testing X 

for Stage 11 Controls RCSA Section 22a-174-30 

Heavy Duty Diesel Engines X X X RCSA Section 22a-174-36a 

CT's California Low Emission Vehicle Phase 2 (CALEV2) X X X 

RCSA Section 22a-174-36b 

Standards for Municipal Waste Combustion (Phase 2) 

X 

RCSA Section 22a-174-38 

VOC Content Limits for Consumer Products 

X 

RCSA Section 22a-174-40 

VOC Content Limits for Architectural and Industrial Maintenance 

X (AIM) Coatings RCSA Section 22a-174-41 

Design Improvements for Portable Fuel Containers 

X 

RCSA Section 22a-174-43 

Restrictions on the Manufacture and Use ofAdhesives and Sealants 

X RCSA Section 22a-174-44 

Additionally, EPA has proposed the Transport Rule3 to replace the court remanded CAIR rule. 

The upwind reductions required in this rule are critical to future emission reductions and the 

prevention of backsliding ofthe current accomplishments. 

Conclusion 

As demonstrated above, all of the air quality monitoring sites within the NY-NJ-CT 24-hour 

PM2.5 nonttainment area recorded design values below the standard for 2009. Connecticut has 

maintained attainment levels since 2008. Therefore, DEP believes a clean data determination for 

Connecticut's New Haven and Fairfield counties is both reasonable and justified at this time. 

Connecticut recognizes that the clean data determination suspends the requirement to submit all 

SIP revisions concerning reasonable further progress, attainment demonstrations and . 

contingency measures related to this NAAQS unless DEP submits and EPA approves a 

redesignation request or future nonattainment levels are monitored. DEP will continue to operate 

its monitoring network to track continued attainment. 

3 Federal Register Vol. 75, No. 147 

A-6