1

Technical Support Document for 2008 Ozone NAAQS Designations

New York-Northern New Jersey-Long Island, NY-NJ-CT

Nonattainment Area Designation for the 

2008 Ozone National Ambient Air Quality Standards

The table below identifies the areas and associated counties or parts of counties in the New York –

Newark – Bridgeport, NY, NJ, CT, PA Combined Statistical Area that EPA is designating as the 

New York-Northern New Jersey-Long Island, NY-NJ-CT nonattainment area for the 2008 ozone 

national ambient air quality standards (2008 NAAQS). This area is also called the New York City 

nonattainment area in various portions of this TSD. 

In accordance with section 107(d) of the Clean Air Act, EPA must designate an area (county or part of a 

county) “nonattainment” if it is violating the 2008 ozone NAAQS or if it is contributing to a violation of 

the 2008 ozone NAAQS in a nearby area. The technical analyses supporting the boundaries for the New 

York-Northern New Jersey-Long Island, NY-NJ-CT Nonattainment Area is provided below.

Table 1 New York – Newark – Bridgeport, NY, NJ, CT, PA CSA and EPA’s Attainment Designations 

for the New York-Northern New Jersey-Long Island, NY-NJ-CT (by State)

State

State's Recommendations for

Counties in the CSA EPA’s Determination by County

Pennsylvania Pike – Attainment Pike - Attainment

New York

Bronx, Kings, Nassau, New 

York, Queens, Richmond, 

Rockland, Suffolk, Westchester –

nonattainment in NYC area.

Dutchess, Putnam, Orange -

attainment in Poughkeepsie area 

Ulster – Attainment in Kingston 

area

Bronx, Kings, Nassau, New 

York, Queens, Richmond, 

Rockland, Suffolk, Westchester

– nonattainment in NYC area.

Dutchess, Putnam, Orange -

attainment in Poughkeepsie area 

Ulster – attainment in Kingston 

area

Connecticut

Fairfield, New Haven -

nonattainment in NYC area

Litchfield – nonattainment in 

Greater Connecticut area

Middlesex from Greater 

Connecticut – nonattainment in 

the NYC area

Fairfield, New Haven,

Middlesex – nonattainment in 

NYC area

Litchfield – nonattainment in

Greater Connecticut area

New Jersey

Bergen, Essex, Hudson, 

Hunterdon, Middlesex, 

Monmouth, Morris, Passaic, 

Somerset, Sussex, Union –

nonattainment in the NYC area

Warren (in the Allentown metro 

area) – nonattainment in the 

NYC area 

Bergen, Essex, Hudson, 

Hunterdon, Middlesex, 

Monmouth, Morris, Passaic, 

Somerset, Sussex, Union,

Warren – nonattainment in the 

NYC area
2

The New York – Newark – Bridgeport, NY, NJ, CT, PA CSA also includes Indian country of the

Shinnecock Indian Nation, which is in Suffolk County in New York State. The Shinnecock Indian 

Nation did not submit a designations recommendation for the 2008 ozone standards. EPA is designating 

this Tribe’s Indian country with the same designation as Suffolk County, that is, nonattainment.

Figure 1 is a map of the New York – Newark – Bridgeport, NY, NJ, CT, PA CSA and the New YorkNorthern New Jersey-Long Island, NY-NJ-CT nonattainment area. The map provides other relevant 

information including the locations and design values of air quality monitors, county and other 

jurisdictional boundaries, as well as the CSA/CBSA boundary, existing nonattainment or maintenance 

boundary for 1997 ozone NAAQS, major transportation arteries.

Additional data tables follow at the end of the TSD.

Each State made recommendations regarding whether all or part of the counties located within their 

State should be included as part of the designated nonattainment area. The analysis below provides a 

state-by-state technical analysis of the basis for the nonattainment area boundaries. 

Our decision relies on our analysis of whether and which monitors are violating the 2008 ozone 

NAAQS, based on certified air quality monitoring data from 2008-2010 and an evaluation of whether 

nearby areas are contributing to such violations. EPA has evaluated contributions from nearby areas 
3

based on a weight of evidence analysis considering the factors identified below. EPA issued guidance 

on December 4, 2008 that identified these factors as ones EPA would consider in determining 

nonattainment area boundaries and recommended that states consider these factors in making their 

designations recommendations to EPA.

1

 

1. Air quality data (including the design value calculated for each FRM or FEM monitor in the 

area);

2. Emissions and emissions-related data (including location of sources and population, amount of 

emissions and emissions controls, and urban growth patterns);

3. Meteorology (weather/transport patterns);

4. Geography and topography (mountain ranges or other basin boundaries);

5. Jurisdictional boundaries (e.g., counties, air districts, existing nonattainment areas, Indian 

country, metropolitan planning organizations (MPOs))

Ground-level ozone is not emitted directly into the air, but is created by chemical reactions between 

oxides of nitrogen (NOx) and volatile organic compounds (VOC) in the presence of sunlight. Because 

NOx and VOC emissions from a broad range of sources over a wide area typically contribute to 

violations of the ozone standards, EPA believes it is important to consider whether there are contributing 

emissions from a broad geographic area. Accordingly, EPA chose to examine the 5 factors with respect 

to the larger of the Combined Statistical Area (CSA) or Core Based Statistical Area (CBSA) associated 

with the violating monitor(s).

2 All data and information used by EPA in this evaluation are the latest 

available to EPA and/or provided to EPA by states or tribes.

In EPA’s designations guidance for the 2008 ozone NAAQS EPA recommended examining 

CSA/CBSAs because certain factors used to establish CSAs and CBSAs are similar to the factors EPA is 

using in this technical analysis to determine if a nearby area is contributing to a violation of the 2008

ozone NAAQS. EPA used the same basic approach in the designation process for the 1997 ozone 

NAAQS. Where a violating monitor is not located in a CSA or CBSA, EPA’s guidance recommended

using the boundary of the county containing the violating monitor as the starting point for considering 

the nonattainment area’s boundary. 

 1 The December 4, 2008 guidance memorandum “Area Designations for the 2008 Revised Ozone National Ambient Air 

Quality Standards” refers to 9 factors. In this technical support document we have grouped the emissions-related factors 

together under the heading of “Emissions and Emissions-Related Data,” which results in 5 categories of factors. 2 Lists of CBSAs and CSAs and their geographic components are provided at 

www.census.gov/population/www/metroareas/metrodef.html . The lists are periodically updated by the Office of 

Management and Budget. EPA used the most recent update, based on 2008 population estimates, issued on December 1, 

2009 (OMB Bulletin No. 10-02).
4

Technical Analysis for the New York – Newark – Bridgeport, NY, NJ, CT, PA CSA

On March 12, 2009, New York State recommended that the entire counties of Bronx, Kings, Nassau, 

New York, Queens, Richmond, Rockland, Suffolk and Westchester be designated as nonattainment for 

the 2008 ozone NAAQS based on air quality data from 2006-2008. New York State provided an update

to the original recommendation on October 26, 2011 based on air quality data from 2008-2010. This 

area includes the same counties designated as nonattainment for the 1997 ozone standard. These data 

are from Federal Reference Method (FRM) monitors sited and operated in accordance with 40 CFR Part 

58. New York also requested that EPA designate the counties of Dutchess, Putnam, Orange and Ulster 

Counties in the New York – Newark – Bridgeport, NY, NJ, CT, PA CSA as attainment.

Connecticut requested that the entire state be designated as nonattainment, with Fairfield and New 

Haven Counties in the New York – Newark – Bridgeport, NY, NJ, CT, PA CSA be kept in the New 

York-Northern New Jersey-Long Island, NY-NJ-CT nonattainment area; that Middlesex County in 

Greater Connecticut be included in the New York-Northern New Jersey-Long Island, NY-NJ-CT

nonattainment area; but Litchfield County in the New York – Newark – Bridgeport, NY, NJ, CT, PA 

CSA, be designated as nonattainment in the Greater Connecticut nonattainment area.

New Jersey requested that its counties presently in the nonattainment area of New York-Northern New 

Jersey-Long Island, NY-NJ-CT for the 1997 ozone standard remain in a New York-Northern New 

Jersey-Long Island, NY-NJ-CT nonattainment area for the 2008 standard. These counties are: Bergen, 

Essex, Hunterdon, Middlesex, Morris, Passaic, Somerset, Sussex, and Union Counties in the New York 

– Newark – Bridgeport, NY, NJ, CT, PA CSA, plus Warren County in the Allentown metropolitan area. 

New Jersey also asked that Ocean and Mercer Counties in the New York – Newark – Bridgeport, NY, 

NJ, CT, PA CSA be included in the Philadelphia nonattainment area for the 2008 ozone standard, just as 

they were for the 1997 ozone standard designations. 

Pennsylvania requested that Pike County, in the New York – Newark – Bridgeport, NY, NJ, CT, PA 

CSA, be designated as attainment, as they were for the 1997 ozone standard designations.

This multi-factor analysis is not needed for the following areas where the states have asked EPA to 

designate areas as nonattainment in the New York-Northern New Jersey-Long Island, NY-NJ-CT

nonattainment area for the 2008 ozone standard:

Bronx, Kings, Nassau, New York, Queens, Richmond, Rockland, Suffolk and Westchester in New 

York; 

Bergen, Essex, Hunterdon, Middlesex, Morris, Passaic, Somerset, Sussex, and Union Counties in New 

Jersey; and

Fairfield and New Haven Counties in Connecticut.

For these counties, EPA will approve the states’ request as these counties are remaining in the same area 

as for the 1997 ozone standard designations, they are in the New York – Newark – Bridgeport, NY-NJCT-PA CSA and based on the reasoning that EPA will approve states’ requests for areas to be 

nonattainment within their states. EPA has received no comments that these areas should be attainment 

for the 2008 ozone standard designations.
5

EPA will also approve Warren County in New Jersey as nonattainment in the New York-Northern New 

Jersey-Long Island, NY-NJ-CT nonattainment area for the 2008 ozone standard as requested by New 

Jersey. Since the rest of its metropolitan area is in Pennsylvania and will be designated as attainment, 

there is no effect of New Jersey’s request on other states’ attainment designations, so EPA will concur 

with New Jersey’s request for nonattainment. EPA did not receive any comments recommending that 

Warren County should be designated as attainment.

The multi-factor analysis will deal with the following counties:

New York’s Dutchess, Orange, Putnam and Ulster Counties, New Jersey’s Ocean and Mercer Counties, 

Connecticut’s Litchfield and Middlesex Counties, and Pennsylvania’s Pike County.

Factor Assessment

Factor 1: Air Quality Data 

For this factor, we considered 8-hour ozone design values (in ppm) for air quality monitors in the New 

York – Newark – Bridgeport, NY, NJ, CT, PA CSA based on data for the 2008-2010 period (i.e., the 

2010 design value, or DV), which are the most recent years with fully-certified air quality data. A 

monitor’s DV is the metric or statistic that indicates whether that monitor attains a specified air quality 

standard. The 2008 ozone NAAQS is met when the annual fourth-highest daily maximum 8-hour 

average concentration, averaged over 3 years is 0.075 ppm or less. A DV is only valid if minimum data 

completeness criteria are met. See 40 CFR part 50 Appendix P. Where several monitors are located in a 

county (or a designated nonattainment area or maintenance area), the DV for the county or area is 

determined by the monitor with the highest level.

The 2010 DVs for the ozone NAAQS for the counties in the New York – Newark – Bridgeport, NY, NJ, 

CT, PA CSA and nearby surrounding area are listed below. Design values over the 2008 ozone NAAQS 

are also marked on the map at Figure 1.

Table 2. Air Quality Data

County

State Recommended 

Nonattainment?

2010 8-hour Ozone DV 

(ppb)

Bergen, NJ Yes 76

Bronx, NY Yes 72

Dutchess, NY No 75

Essex, NJ Yes --

Fairfield, CT Yes 81

Hudson, NJ Yes 77

Hunterdon, NJ Yes 78

Kings, NY Yes --

Litchfield, CT

Yes – in the Greater 

Connecticut area --

Mercer, NJ

Yes – see 

Philadelphia TSD 78

Middlesex, CT Yes 77

Middlesex, NJ Yes 78
6

Monmouth, NJ Yes 80

Morris, NJ Yes 75

Nassau, NY Yes --

New Haven, CT Yes 76

New York, NY Yes 73

Ocean, NJ

Yes – see 

Philadelphia TSD 81

Orange, NY No 73

Passaic, NJ Yes 74

Pike, PA No --

Putnam, NY No 75

Queens, NY Yes 74

Richmond, NY Yes 75

Rockland, NY Yes --

Somerset, NJ Yes --

Suffolk, NY Yes 84

Sussex, NJ Yes --

Union, NJ Yes --

Warren, NJ Yes --

Westchester, NY Yes 77

Suffolk and Westchester counties located in the NY State portion of the New York – Newark –

Bridgeport, NY, NJ, CT, PA CSA have monitors with 2010 DVs above the level of the 2008 ozone 

NAAQS. Both of these counties are currently part of the New York-Northern New Jersey-Long Island, 

NY-NJ-CT nonattainment area for the 1997 ozone NAAQS. These areas must be designated 

nonattainment for the 2008 ozone NAAQS. 

No other counties in the New York State portion of the New York – Newark – Bridgeport, NY, NJ, CT, 

PA CSA are violating the 2008 ozone standard, including those counties adjoining the New York –

Newark – Bridgeport, NY, NJ, CT CSA. All of Connecticut’s counties with monitors have violations of 

the ozone standard and are proposed to be designated as nonattainment. New Jersey’s is not requesting 

any of its counties to be designated as attainment, so this factor is not relevant. 

Counties without a monitor or with a monitor meeting the 2008 ozone NAAQS in the New York portion

of the New York – Newark – Bridgeport, NY, NJ, CT, PA CSA may need to be included as part of the 

2008 NAAQS nonattainment area because they are contributing to a violation of the standard in another 

county. Connecticut requested that Litchfield County be designated as nonattainment, but placed

outside the New York-Northern New Jersey-Long Island, NY-NJ-CT nonattainment area for the 2008 

ozone standard. For these counties, we will analyze contribution in the remaining four factors. 

Ocean and Mercer Counties in New Jersey and Middlesex County in Connecticut were requested by 

their states to be included in the nonattainment areas upwind of them, not in the metropolitan areas they 

are assigned to. The evaluation of Ocean and Mercer Counties is described in more detail in the 

Philadelphia area TSD. The evaluation of Middlesex County, Connecticut will continue in the 

remaining four factors.
7

New York’s Dutchess, Putnam, Orange and Ulster Counties have no violations of the new 2008 ozone 

standard. Pike County, Pennsylvania, does not have an ozone monitor, but the nearest counties upwind 

of Pike County, to its west and southwest, do not violate the 2008 ozone standard. Evaluation of these 

counties will continue in the remaining four factors.

Factor 2: Emissions and Emissions-Related Data

EPA evaluated emissions of ozone precursors (NOx and VOC) and other emissions-related data that 

provide information on areas contributing to violating monitors, based on data from the following 

sources:

Emissions Data

EPA evaluated county-level emission data for NOx and VOC derived from the 2008 National Emissions 

Inventory (NEI), version 1.5. This is the most recently available NEI. (See 

http://www.epa.gov/ttn/chief/net/2008inventory.html) Significant emissions levels in a nearby area 

indicate the potential for the area to contribute to observed violations. We will also consider any 

additional information we receive on changes to emissions levels that are not reflected in recent 

inventories. These changes include emissions reductions due to permanent and enforceable emissions 

controls that will be in place before final designations are issued and emissions increases due to new 

sources.

Population density and degree of urbanization

EPA evaluated the population and vehicle use characteristics and trends of the area as indicators of the 

probable location and magnitude of non-point source emissions. These include ozone-creating 

emissions from on-road and off-road vehicles and engines, consumer products, residential fuel 

combustion, and consumer services. Areas of dense population or commercial development are an 

indicator of area source and mobile source NOx and VOC emissions that may contribute to ozone 

formation. Rapid population or VMT growth (see below) in a county on the urban perimeter signifies 

increasing integration with the core urban area, and indicates that the associated area source and mobile 

source emissions may be appropriate to include in the nonattainment area. Table 5 shows the population, 

population density, and population growth information for each county in the area.

Sources: U.S. Census Bureau population estimates for 2010 as of August 4, 2011 

(http://factfinder2.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=DEC_10_PL_GCTPL2.STO5&

prodType=table).

EPA has assembled data into a chart that ranks the counties in and around the New York – Newark –

Bridgeport, NY, NJ, CT, PA CSA for the following statistics:

Emissions of nitrogen oxides (NOx), volatile organic compounds (VOCs); population, vehicle miles 

traveled (VMT), emissions density for NOx and VOC, population density, VMT density, VMT 

percentage growth, population growth and percentage population growth.
8

Table_2 Rankings of Counties in and Around the New York – Newark – Bridgeport, NY-NJ-CT-PA

CSA 

As noted in Table 1, four states requested that several counties be excluded from the New YorkNorthern New Jersey-Long Island, NY-NJ-CT nonattainment area. Table 2 is helpful for evaluating the 

request that EPA exclude these counties from the New York-Northern New Jersey-Long Island, NY-NJCT nonattainment area: In New York, Dutchess, Putnam, Orange and Ulster, and in Pennsylvania, Pike 

County, and in Connecticut, Litchfield County.

Table 2 lists the counties in and around the New York – Newark – Bridgeport, NY, NJ, CT, PA CSA, 

rank ordered for several factors that EPA uses to determine the appropriateness of contributing to the 

nonattainment of the ozone standard in the nonattainment area. 

As seen in this table, Dutchess, Putnam, Orange, Litchfield, Pike and Ulster Counties are more 

commonly ranked with counties outside the New York – Newark – Bridgeport CSA than with the 

counties in the core of the CSA. This is particularly obvious when factors such as emissions, population 

and vehicle miles traveled are compared using density of these factors per square miles. For example, 

Rockland County is a small county within, but on the edge of, the NYC nonattainment area. However, 

Rank Nox Emissions VOC Emissions Population VMT Rank Nox Density VOC Density Pop Density VMT Density Rank % VMT Grow th Pop Grow th Percent Pop Grow

1 Suffolk Suffolk Kings Suffolk 1 New York New York New York New York 1 Wayne Suffolk Pike

2 Hudson Queens Queens Nassau 2 Hudson Kings Kings Bronx 2 Pike Ocean Monroe

3 Queens Kings New York Hartford 3 Kings Bronx Bronx Kings 3 New Haven Middlesex Ocean

4 New York New York Suffolk Westchester 4 Queens Queens Queens Queens 4 Hartford Bronx Lehigh

5 Kings Nassau Bronx Bergen 5 Bronx Hudson Hudson Hudson 5 Lackawanna New York Northampton

6 Fairfield Westchester Nassau Fairfield 6 Union Richmond Richmond Union 6 Fairfield Kings Wayne

7 Nassau Bronx Westchester Middlesex 7 Essex Union Essex Essex 7 Monroe New Haven Orange

8 Essex Fairfield Fairfield New Haven 8 Richmond Nassau Union Nassau 8 Lehigh Lehigh Atlantic

9 Middlesex Bergen Bergen Queens 9 Bergen Essex Nassau Bergen 9 Bucks Hartford Middlesex

10 New Haven Middlesex Hartford Monmouth 10 Nassau Bergen Bergen Richmond 10 Hampden Fairfield Somerset

11 Hartford Bucks New Haven Morris 11 Middlesex Middlesex Middlesex Middlesex 11 Berkshire Northampton Rockland

12 Union Hartford Middlesex Bucks 12 Northampton Westchester Passaic Westchester 12 Hudson Monroe Burlington

13 Bergen New Haven Essex Essex 13 Mercer Suffolk Westchester Suffolk 13 Union Orange Dutchess

14 Westchester Ocean Hudson Burlington 14 Westchester Passaic Mercer Passaic 14 Essex Bucks New London

15 Bucks Monmouth Monmouth Kings 15 Fairfield Rockland Rockland Mercer 15 Bergen Hudson Middlesex

16 Northampton Essex Bucks Bronx 16 Suffolk Mercer Fairfield Monmouth 16 Middlesex Somerset Warren

17 Monmouth Morris Ocean Orange 17 Passaic Lehigh Suffolk Rockland 17 Passaic Rockland Suffolk

18 Orange Union Union Union 18 New Haven Fairfield New Haven Fairfield 18 Mercer Burlington New Haven

19 Morris Orange Passaic New York 19 Rockland Bucks Monmouth New Haven 19 Monmouth Westchester Richmond

20 Bronx Burlington Morris Ocean 20 Lehigh Monmouth Hartford Morris 20 Morris Richmond Hunterdon

21 Lehigh Hampden Richmond Hampden 21 Monmouth Morris Somerset Putnam 21 Somerset Atlantic Bronx

22 Burlington Lehigh Hampden Mercer 22 Bucks New Haven Morris Hartford 22 Burlington Morris Hartford

23 Ocean Hudson Burlington Somerset 23 Hartford Somerset Bucks Somerset 23 Northampton Bergen Fairfield

24 Mercer Atlantic Orange New London 24 Morris Hartford Lehigh Lehigh 24 Ocean Dutchess Bucks

25 Hampden Richmond Mercer Lehigh 25 Somerset Ocean Northampton Bucks 25 Atlantic Mercer Hudson

26 Richmond Dutchess Lehigh Passaic 26 Hampden Northampton Ocean Hampden 26 Hunterdon New London Morris

27 New London Passaic Somerset Atlantic 27 Lackawanna Putnam Hampden Burlington 27 Warren Union Mercer

28 Somerset New London Rockland Dutchess 28 Putnam Hampden Burlington Northampton 28 Sussex Monmouth Litchfield

29 Passaic Somerset Northampton Putnam 29 Orange Atlantic Lackawanna Ocean 29 Washington Pike Putnam

30 Lackawanna Northampton Dutchess Rockland 30 Burlington Orange Atlantic Orange 30 New York Passaic Sullivan

31 Rockland Rockland Atlantic Hudson 31 Ocean Burlington Orange Atlantic 31 Bronx Middlesex New York

32 Atlantic Mercer New London Ulster 32 Warren Lackawanna Middlesex Hunterdon 32 Kings Litchfield Westchester

33 Dutchess Monroe Lackawanna Northampton 33 New London Middlesex Putnam Lackawanna 33 Queens Hampden Union

34 Monroe Lackawanna Litchfield Lackawanna 34 Middlesex New London New London Warren 34 Nassau Hunterdon Sussex

35 Ulster Ulster Ulster Berkshire 35 Hunterdon Monroe Washington New London 35 Richmond Warren Ulster

36 Berkshire Wayne Monroe Hunterdon 36 Atlantic Washington Dutchess Middlesex 36 Westchester Wayne Kings

37 Hunterdon Berkshire Middlesex Richmond 37 Monroe Dutchess Warren Dutchess 37 Suffolk Sussex Bergen

38 Middlesex Litchfield Sussex Monroe 38 Washington Warren Hunterdon Washington 38 Rockland Ulster Monmouth

39 Warren Putnam Berkshire Warren 39 Dutchess Hunterdon Sussex Monroe 39 Putnam Putnam Passaic

40 Greene Middlesex Hunterdon Middlesex 40 Sussex Sussex Monroe Sussex 40 Orange Nassau Hampden

41 Putnam Sussex Washington Sussex 41 Greene Wayne Litchfield Berkshire 41 New London Sullivan Washington

42 Litchfield Sullivan Warren Litchfield 42 Pike Pike Ulster Ulster 42 Dutchess Washington Greene

43 Sussex Hunterdon Putnam Washington 43 Berkshire Berkshire Berkshire Litchfield 43 Ulster Lackawanna Lackawanna

44 Pike Pike Sullivan Columbia 44 Ulster Litchfield Pike Pike 44 Columbia Greene Nassau

45 Washington Washington Columbia Greene 45 Litchfield Ulster Columbia Columbia 45 Greene Queens Queens

46 Wayne Warren Pike Sullivan 46 Columbia Columbia Sullivan Greene 46 Sullivan Columbia Columbia

47 Columbia Columbia Wayne Pike 47 Wayne Sullivan Greene Wayne 47 Delaware Delaware Delaware

48 Sullivan Delaware Greene Wayne 48 Sullivan Greene Wayne Sullivan 48 Litchfield Berkshire Essex

49 Delaware Greene Delaware Delaware 49 Delaware Delaware Delaware Delaware 49 Middlesex Essex Berkshire
9

when the density per square mile of its emissions, population and vehicle miles traveled are compared 

with other counties’, it is clear that Rockland is more densely settled and is more like Westchester, 

which has a violating monitor as well as the other nearby counties in the existing New York-Northern 

New Jersey-Long Island, NY-NJ-CT nonattainment area, since Rockland County has more emissions 

and traffic per square mile than the counties adjoining it on the outer edge of the CSA. 

Some of these counties have higher emissions and traffic than counties in the core of the New York –

Newark – Bridgeport, NY-NJ-CT-PA CSA, but when the density of the emissions, population and 

vehicle miles traveled is evaluated, as in Table 2, these counties are found near the bottom of the list and 

are have lower values by density compared to areas in the core of the CSA.

Emissions of nitrogen oxides (NOx) and volatile organic compounds (VOC)

County

State 

Recommended 

Nonattainment? NOx (tpy) VOC (tpy)

Suffolk, NY Yes

 

39,737 

 

55,566 

Hudson, NJ Yes

 

32,087 

 

11,073 

Queens, NY Yes

 

31,661 

 

47,240 

New York, NY Yes

 

30,058 

 

45,066 

Kings, NY Yes

 

26,731 

 

47,212 

Fairfield, CT Yes

 

24,983 

 

22,700 

Nassau, NY Yes

 

24,574 

 

37,235 

Essex, NJ Yes

 

22,235 

 

15,376 

Middlesex, NJ Yes

 

20,820 

 

21,598 

New Haven, CT Yes

 

20,789 

 

19,705 

Union, NJ Yes

 

19,833 

 

14,042 

Bergen, NJ Yes

 

19,221 

 

22,310 

Westchester, NY Yes

 

18,692 

 

27,906 

Monmouth, NJ Yes

 

13,910 

 

16,492 

Orange, NY No

 

12,423 

 

13,320 

Morris, NJ Yes

 

11,963 

 

15,282 

Bronx, NY Yes 11,643 26,550 

Ocean, NJ

Yes – see 

Philadelphia 

TSD

 

9,909 

 

19,572 

Mercer, NJ

Yes – see

Philadelphia 

TSD

 

9,909 

 

8,160 
10

Richmond, NY Yes

 

9,273 

 

10,254 

Somerset, NJ Yes

 

7,379 

 

8,712 

Passaic, NJ Yes

 

7,270 

 

9,687 

Rockland, NY Yes

 

6,529 

 

8,375 

Dutchess, NY No

 

5,900 

 

9,922 

Hunterdon, NJ Yes

 

4,558 

 

4,626 

Middlesex, CT Yes

 

4,484 

 

5,130 

Warren, NJ Yes

 

4,483 

 

3,925 

Putnam, NY No

 

3,736 

 

5,428 

Litchfield, CT

Yes – Greater 

Connecticut 

area

 

3,429 

 

6,115 

Sussex, NJ Yes

 

3,132 

 

4,892 

Pike, PA No

 

2,793 

 

4,489 

Area wide:

 

464,148 

 

567,960 

Population information

County

State

Recommended 

Nonattainment?

2010 

Population

2010 Population 

Density (1000 

pop/sq mi)

Absolute change in 

population (2000-

2010)

Population 

% change 

(2000-2010)

New York, NY Yes

 

1,585,873 

 

69.56 

 

45,263 +3% 

Kings, NY Yes

 

2,504,700 

 

37.11 

 

38,943 +2% 

Bronx, NY Yes

 

1,385,108 

 

32.36 

 

51,389 +4% 

Queens, NY Yes

 

2,230,722 

 

20.24 

 

539 0% 

Hudson, NJ Yes

 

634,266 

 

11.79 

 

24,782 +4% 

Richmond, NY Yes

 

468,730 

 

7.52 

 

23,318 +5% 

Essex, NJ Yes

 

783,969 

 

6.06 

 

(8,350) -1% 

Union, NJ Yes

 

536,499 

 

5.09 

 

13,359 +3% 

Nassau, NY Yes

 

1,339,532 

 

4.31 

 

3,459 0% 

Bergen, NJ Yes

 

905,116 

 

3.73 

 

19,636 +2% 

Middlesex, NJ Yes

 

809,858 

 

2.55 

 

57,056 +8% 

Passaic, NJ Yes

 

501,226 

 

2.55 

 

10,402 +2% 

Westchester, NY Yes +3% 
11

949,113 1.99 23,442 

Mercer, NJ

Yes – see 

Philadelphia TSD

 

366,513 

 

1.60 

 

14,979 +4% 

Rockland, NY Yes

 

311,687 

 

1.56 

 

24,278 +8% 

Fairfield, CT Yes

 

916,829 

 

1.41 

 

32,348 +4% 

Suffolk, NY Yes

 

1,493,350 

 

1.39 

 

69,686 +5% 

New Haven, CT Yes

 

862,477 

 

1.39 

 

37,492 +5% 

Monmouth, NJ Yes

 

630,380 

 

1.30 

 

13,290 +2% 

Somerset, NJ Yes

 

323,444 

 

1.06 

 

24,558 +8% 

Morris, NJ Yes

 

492,276 

 

1.02 

 

20,928 +4% 

Ocean, NJ

Yes – see 

Philadelphia TSD

 

576,567 

 

0.76 

 

62,913 +12% 

Orange, NY No

 

372,813 

 

0.45 

 

29,694 +9% 

Middlesex, CT Yes

 

165,676 

 

0.43 

 

10,061 +6% 

Putnam, NY No

 

99,710 

 

0.41 

 

3,643 +4% 

Dutchess, NY No

 

297,488 

 

0.36 

 

16,521 +6% 

Warren, NJ Yes

 

108,692 

 

0.30 

 

5,745 +6% 

Hunterdon, NJ Yes

 

128,349 

 

0.29 

 

5,807 +5% 

Sussex, NJ Yes

 

149,265 

 

0.28 

 

4,655 +3% 

Litchfield, CT

Yes – see Greater 

Connecticut

 

189,927 

 

0.20 

 

7,313 +4% 

Pike, PA No

 

57,369 

 

0.10 

 

10,759 +23% 

Area wide:

 

22,177,524 1.84

 

697,908 +3%

While Dutchess, Orange and Pike Counties are increasing in population faster than many other counties 

in the New York – Newark – Bridgeport, NY, NJ, CT, PA CSA, this fact is overwhelmed by the other 

data in Table 2 that show these areas emissions and traffic are not contributing to nonattainment in the 

New York-Northern New Jersey-Long Island, NY-NJ-CT nonattainment area as much as other counties 

nearer the violating monitors. Overall, these factors show that Dutchess, Putnam, Orange, Ulster, Pike 

and Litchfield Counties are not like the core counties of the New York City area. 

Ocean and Mercer Counties have emissions fairly typical of counties in the CSA, but the location of 

these counties and where they are relative to emissions that affect them are more important factors.

Traffic and commuting pattern

EPA evaluated the commuting patterns of residents in the area, as well as the total Vehicle Miles 

Traveled (VMT) for each county. In combination with the population/population density data and the 
12

location of main transportation arteries (see above), this information helps identify the probable location 

of non-point source emissions. A county with high VMT and/or a high number of commuters is 

generally an integral part of an urban area and indicates the presence of motor vehicle emissions that 

may contribute to ozone formation. Rapid population or VMT growth in a county on the urban perimeter 

signifies increasing integration with the core urban area, and indicates that the associated area source

and mobile source emissions may be appropriate to include in the nonattainment area. Table 4 shows 

traffic and commuting pattern data, including total 2005 VMT and 10-year VMT growth, number of 

commuters in each county who drive to another county within the area, the percent of total commuters in 

each county who commute to other counties within the area, and the total vehicle miles traveled (VMT) 

for each county.

Table 4. Traffic and Commuting Patterns.

Dutchess, Orange, Putnam, Ulster, Pike and Litchfield Counties are on the edge of the New York –

Newark – Bridgeport CSA and have a large number of commuters transiting into the core of the New 

York – Newark – Bridgeport CSA. However, the number of commuters is less than counties in the core 

of the CSA that the states requested that EPA designate as the NYC nonattainment area, and previous 

nonattainment areas, e.g., carbon monoxide and particulate matter, which are strongly affected by 

mobile sources, have not included these outlying counties in the past NYC nonattainment areas. Based 

on data from the U.S. Census Bureau estimates for 2000, County-to-County Worker Flow found at 

http://www.census.gov/hhes/commuting/data/commuting.html used here.

Vehicle data and commuting patterns

County

State 

Recommended 

Nonattainment?

2008 VMT 

(million miles)

Number commuting to 

or within any violating 

counties

% commuting to or 

within any 

violating counties

Suffolk, NY Yes

 

18,230 

 

495,594 74%

Nassau, NY Yes

 

10,908 

 

57,742 9%

Westchester, NY Yes

 

8,309 

 

291,504 69%

Bergen, NJ Yes

 

8,037 

 

284,046 67%

Fairfield, CT Yes

 

7,803 

 

378,743 90%

Middlesex, NJ Yes

 

7,494 

 

247,103 68%

New Haven, CT Yes

 

7,248 

 

353,015 91%

Queens, NY Yes

 

7,179 

 

30,638 3%

Monmouth, NJ Yes

 

6,066 

 

234,477 80%

Morris, NJ Yes

 

5,495 

 

25,593 11%

Essex, NJ Yes

 

4,941 

 

48,882 15%

Kings, NY Yes

 

4,511 

 

21,196 2%

Bronx, NY Yes

 

4,339 

 

39,805 10%
13

Orange, NY No

 

4,180 

 

14,509 10%

Union, NJ Yes

 

4,143 

 

45,149 19%

New York, NY Yes

 

4,007 

 

30,750 4%

Ocean, NJ

Yes – see 

Philadelphia TSD

 

3,834 

 

182,776 87%

Mercer, NJ

Yes – see 

Philadelphia TSD

 

3,306 

 

142,459 87%

Somerset, NJ Yes

 

3,116 

 

43,474 29%

Passaic, NJ Yes

 

2,877 

 

64,487 31%

Dutchess, NY No

 

2,830 

 

18,155 14%

Putnam, NY No

 

2,786 

 

23,996 50%

Rockland, NY Yes

 

2,486 

 

26,607 20%

Hudson, NJ Yes

 

2,241 

 

156,937 59%

Hunterdon, NJ Yes

 

1,889 

 

36,829 59%

Richmond, NY Yes

 

1,835 

 

8,793 5%

Warren, NJ Yes

 

1,530 

 

9,290 18%

Middlesex, CT Yes

 

1,394 

 

60,254 75%

Sussex, NJ Yes

 

1,305 

 

7,652 11%

Litchfield, CT

Yes – see Greater 

Connecticut

 

1,258 

 

25,872 28%

Pike, PA No

 

689 

 

1,127 6%

Area wide:

 

146,267 

 

3,407,454 36%

Ocean and Mercer Counties have more commuters that work in their own county or travel to the rest of 

the Philadelphia CSA than to the New York City CSA as seen in the 2000 County-to-County Worker 

Flow.

Factor 3: Meteorology (weather/transport patterns)

EPA evaluated available meteorological data to help determine how meteorological conditions, such as 

weather, transport patterns and stagnation conditions, would affect the fate and transport of precursor 

emissions contributing to ozone formation. This report uses the 32-year average summer surface-level 

wind direction for the design value county and for the counties in the Poughkeepsie area. 

The prevailing winds during the ozone season have a strong southwesterly component, indicating that 

the counties in and north of the Poughkeepsie area do not, almost all cases, affect the air quality at the 

peak monitors in Connecticut, Westchester County and on Long Island. The location of the 
14

Poughkeepsie area counties outside the line of high ozone concentrations along the northeast corridor of 

major cities is additional evidence that the Poughkeepsie area counties are not part of the ozone problem 

in the New York-Northern New Jersey-Long Island, NY-NJ-CT nonattainment area. We are also using 

these wind roses for surrounding counties.

Summer

COUNTY STATE NNE ENE ESE SSE SSW WSW WNW NNW

Dutchess NY 0.12 0.06 0.07 0.10 0.24 0.18 0.12 0.11

Putnam NY 0.10 0.10 0.07 0.08 0.22 0.19 0.13 0.11

Ulster NY 0.11 0.06 0.04 0.19 0.21 0.09 0.19 0.10

Orange NY 0.11 0.11 0.06 0.09 0.23 0.16 0.14 0.11

Litchfield County is on the northern edge of the New York – Newark – Bridgeport, NY, NJ, CT, PA 

CSA and is in the prevailing downwind direction from the core counties and violating monitors in the 

CSA. 

Middlesex County in Connecticut is a violating county east and northeast of the core counties of the 

CSA, which has the second highest 2010 design values in Connecticut outside the New York – Newark 

– Bridgeport, NY, NJ, CT, PA CSA. Previously, Middlesex County had the highest design value in 

Connecticut during the last round of ozone nonattainment designations. For that reason, Connecticut 

requested that Middlesex County be included in a New York-Northern New Jersey-Long Island, NY-NJCT nonattainment area. This time, Connecticut wants to continue with the previous designation, but the 

higher design value county staying with the upwind nonattainment area is also a good reason. 

Pike County is west, and generally upwind of, the central core counties of the New York – Newark –

Bridgeport, NY, NJ, CT, PA area.

Factor 4: Geography/topography (mountain ranges or other air basin boundaries)

The geography/topography analysis evaluates the physical features of the land that might affect the 

airshed and, therefore, the distribution of ozone over the area.

While the New York – Newark – Bridgeport, NY, NJ, CT, PA CSA does have some variation in 

topography, and land use, as well as many water bodies separating its constituent parts, there are no

geographical or topographical barriers significantly limiting air pollution transport within its air shed. 

Therefore, this factor did not play a significant role in this evaluation.

Factor 5: Jurisdictional boundaries

Once the general areas to be included in the nonattainment area were determined, EPA considered

existing jurisdictional boundaries for the purposes of providing a clearly defined legal boundary and 

carrying out the air quality planning and enforcement functions for nonattainment areas. Examples of 

jurisdictional boundaries include existing/prior nonattainment areas for ozone or other urban-scale 

pollutants, counties, air districts, townships, metropolitan planning organizations, state lines, urban 

growth boundary, etc. Where existing jurisdictional boundaries are not adequate to describe the 

nonattainment area, other clearly defined and permanent landmarks or geographic coordinates were 

considered.
15

Dutchess, Putnam, Orange, Ulster, Pike, Ocean, Mercer and Litchfield Counties have previously been 

designated as separate from the New York-Northern New Jersey-Long Island, NY-NJ-CT eight-hour 

nonattainment area for the 1997 ozone standard and the states have requested that EPA continue those 

affiliations. 

The states have asked that EPA include all the counties previously included in the nonattainment area 

for the 1997 eight-hour ozone standard, including Warren and Middlesex (CT) counties, in the New 

York City nonattanment area for the 2008 eight-hour ozone standard.

Connecticut requested that EPA retain the boundaries for its nonattainment areas to be the same as for 

the 1997 ozone standard designations, which moved Middlesex County into the New York-Northern

New Jersey-Long Island, NY-NJ-CT nonattainment area. The boundaries of the one-hour ozone 

nonattainment areas in Connecticut are different from the eight-hour designation for the 1997 ozone 

standard. Not keeping the same eight-hour standard designations would mean three sets of 

nonattainment area boundaries. Connecticut wants to “avoid unnecessary confusion among 

Connecticut’s regulated community and the general public that may otherwise result from having three 

distinct nonattainment area boundaries within Connecticut for the 2008 8-hour ozone NAAQS.” EPA 

has determined that this is the most important factor for determining which nonattainment area 

Connecticut’s counties are to be in which Connecticut nonattainment area. This factor would be 

important to the Litchfield area as well, since it is a recent addition to the New York – Newark –

Bridgeport CSA and placing it in the New York-Northern New Jersey-Long Island, NY-NJ-CT 

nonattainment area would be a new boundary, different from the nonattainment area boundary for the 

1997 ozone standard nonattainment area.

Dutchess, Putnam and Orange Counties are not part of the same transportation planning organization as 

much of the New York-Northern New Jersey-Long Island, NY-NJ-CT nonattainment area. Dutchess, 

Putnam and Ulster Counties are part of the Poughkeepise-Newburgh Transportation Management Area. 

Dutchess, Putnam and Orange Counties are the Poughkeepsie 1997 ozone nonattainment area and Ulster 

County was not part of the Poughkeepsie area. This also supports keeping the Poughkeepsie area and 

Ulster County as separate from the New York City area, even if they are part of the New York Citybased CSA.

Pike County is not part of the transportation planning area for areas in New York, New Jersey or 

Connecticut, but is part of the Northeast Pennsylvania Rural Transportation Planning Organization with 

four other rural Pennsylvania counties.

 

The New York-Northern New Jersey-Long Island, NY-NJ-CT area also includes the Indian country of 

the Shinnecock Indian Nation. As defined at 18 U.S.C. 1151, “Indian country” refers to: “(a) all land 

within the limits of any Indian reservation under the jurisdiction of the United States Government, 

notwithstanding the issuance of any patent, and, including rights-of-way running through the 

reservation, (b) all dependent Indian communities within the borders of the United States whether within 

the original or subsequently acquired territory thereof, and whether within or without the limits of a 

state, and (c) all Indian allotments, the Indian titles to which have not been extinguished, including 

rights-of-way running through the same.” EPA recognizes the sovereignty of tribal governments, and 

has attempted to take the desires of the tribes into account in establishing appropriate nonattainment area 

boundaries. In this case, the Shinnecock Indian Nation’s Indian country is being designated 

nonattainment as part of the New York-Northern New Jersey-Long Island, NY-NJ-CT nonattainment 

area. 
16

Conclusions

Based on the assessment of factors described above, EPA has concluded that no counties in New York 

State meet the requirements for being added to the previously existing New York – Northern New Jersey 

– Long Island, NY, NJ, CT ozone nonattainment area, which will have the same boundaries as the area 

designated for the 2008 eight-hour ozone standard. The nonattainment area requested by the states 

includes all counties with violating monitors and the counties with the highest emissions densities in the 

New York – Newark – Bridgeport CSA. 

Four counties, Dutchess, Putnam and Orange in the Poughkeepsie Area, and Ulster County, are included 

in the New York – Newark – Bridgeport CSA, but the density of these areas’ emissions and vehicle 

usages are not of the level of the other counties in the CSA that are in New York’s proposed New YorkNorthern New Jersey-Long Island, NY-NJ-CT nonattainment area. These four counties and Litchfield 

County are generally not upwind of the proposed New York-Northern New Jersey-Long Island, NY-NJCT nonattainment area. The downwind peak monitors are northeast and east of the center of the 

nonattainment area: on Long Island, in Westchester County and in Connecticut. And the four counties 

are north of the peak ozone areas. Thus, EPA will continue with these four counties outside the New 

York-Northern New Jersey-Long Island, NY-NJ-CT nonattainment area as they have much less 

influence on ozone in the nonattainment area than counties in the nonattainment area.

 

Ocean and Mercer Counties are affected more strongly by emissions from counties in the Philadelphia 

area than the New York area, so they should be part of the Philadelphia area. They are also part of the 

present Philadelphia nonattainment area. Details are in the Philadelphia TSD.

Middlesex County, Connecticut was part of the previous New York-Northern New Jersey-Long Island, 

NY-NJ-CT nonattainment area as a county downwind of the NYC area because of its higher ozone 

design values than the rest of Connecticut and will remain so based on EPA’s analysis. 

Pike County is generally upwind of the nonattaining monitors in New Jersey, New York and 

Connecticut, but its small emissions density and distance from the violating counties makes Pike County 

not a likely contributor of much ozone to the New York-Northern New Jersey-Long Island, NY-NJ-CT

area. These factors, combined with the lack of violating monitors in nearby Pennsylvania and western 

New Jersey, support Pennsylvania’s request for Pike County to remain separate from the New YorkNorthern New Jersey-Long Island, NY-NJ-CT nonattainment area. 

Air quality data and the analysis of the factors in this report support New York, New Jersey, Connecticut 

and Pennsylvania’s requests that the boundaries from the 1997 ozone NAAQS are appropriate for the 

nonattainment boundaries of the New York-Northern New Jersey-Long Island, NY-NJ-CT eight-hour 

ozone nonattainment area for the 2008 ozone standard.