Gina McCarthy

Commissioner

STATE OF CONNECTICUT

DEPARTMENT OF ENVIRONMENTAL PROTECTION

79 ELM STREET HARTFORD, CT 06106-5127

PHONE: 860-424-3001

November 18, 2008

Robert W. Varney

Regional Administrator

United States Environmental Protection Agency Region 1

1 Congress Street, Suite 1100

Boston, MA 02114-2023

Connecticut Attainment Demonstration for the

1997 Annual Fine Particulate Matter (PM2.5) National Ambient Air Quality Standard

Dear Administrator Varney:

Pursuant to Clean Air Act (CAA) Section 172(b) and (c), I am pleased to submit the

enclosed State Implementation Plan revision demonstrating Connecticut’s attainment of the 1997

annual PM2.5 national ambient air quality standard (NAAQS). Connecticut’s history of

monitored compliance with the 1997 PM2.s NAAQS and the continuing emissions reductions

from the control measures described in the demonstration attest to the Connecticut Department

of Environmental Protection’s (CTDEP’s) successful implementation of air quality improvement

strategies in the State and in coordination with other states in the nonattainment area and wider

region. CTDEP looks forward to the approval of this submission, allowing us and our

counterparts at U.S. Environmental Protection Agency (EPA) to devote our attention to the more

complex air quality challenges of the future, such as complying with more stringent ozone and

PM2.s NAAQS and developing more effective programs to limit emissions from electricity

generation.

Although CTDEP recommended that all of the State of Connecticut be designated

attainment for the 1997 PM2.s NAAQS, EPA combined two counties in Connecticut, Fairfield

and New Haven, with counties in downstate New York and northern New Jersey in a single

PM2.s nonattainment area based on measured violations in New York and New Jersey.

Meanwhile, all Connecticut monitors continue to measure compliance with the annual PM2.5

NAAQS. The enclosed demonstration describes the national, regional and local control

measures that have been or will be implemented to further reduce emissions of PM2.s and its

precursors as well as the modeling and other analyses required to demonstrate the likelihood of

reaching attainment throughout the NY-NJ-CT nonattainment area by the mandated 2010

attainment date.

Achieving compliance with the 1997 annual PM2.5 NAAQS throughout the nonattainment

area is contingent on efforts in upwind states to comply with the NAAQS and the transport

provisions of the CAA. Emissions in the NY-NJ-CT area are being reduced sufficiently to attain

the annual PMz.s NAAQS, provided that upwind states comply with CAA Section 110(a)(2)(D)

to reduce transported air pollution so as to no longer contribute significantly to nonattainment in

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Robert W. Varney

November 18, 2008

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the NY-NJ-CT nonattainment area. EPA’s technical support documents for the Clean Air

Interstate Rule (CAIR) demonstrate that emissions from numerous upwind states make

significant PM2.5 contributions in the NY-NJ-CT area. EPA must ensure that these upwind states

comply with the transport provisions of the CAA, regardless of the eventual fate of the CAIR

program.

We look to EPA’s leadership in the coming months to reach beyond the short-term

planning horizons of the 1997 annual PM2.5 and ozone NAAQS and the emissions reductions of

the CAIR program. While important increments of progress are made in complying with those

standards, additional long-term strategies to improve air quality are essential to ensure adequate

protection of public health. Such long-term strategies should include the most stringent possible

non-road and on-road emission standards for all mobile source categories; more stringent

national limitations on the sulfur content in fuels, including home heating oil, and effective

programs to limit emissions from electricity generation in a manner that also reduces demand. In

striving to meet more stringent environmental goals, we will reap rewards in reduced public

health costs, new technologies and new American jobs.

To satisfy the administrative requirements of 40 CFR 51, Appendix V and facilitate your

review, this submission includes the following documents:

 ̄ Annual PM2.5 Attainment Demonstration Technical Support Document;

 ̄ A hearing report including a summary of comments received and responses thereto; and

 ̄ An appendix of control measures in support of the demonstration.

If you have any questions or comments regarding the submission, or if CTDEP may be of any

assistance in this matter, please contact Anne Gobin at 860-424-3026.

Gina McCarthy

Commissioner

David Conroy, EPA Region 1

Anne R. Gobin, CTDEP