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Analysis in Support of New York State's Recommendations - Summary

On September 21, 2006, the United States Environmental Protection Agency (EPA) published a revision in the 24-hour fine particle National Ambient Air Quality Standard (NAAQS) that lowered the standard from 65 micrograms per cubic meter (µg/m3) to 35 µg/m3. Areas meet the 24-hour standard if the 98th percentile of the measured 24-hour PM2.5 concentrations in a year, averaged over three years, are less than or equal to 35 µg/m3. The 98th percentile 24-hour values are referred to as the design values or DVs.

The existing annual PM2.5 NAAQS of 15 µg/m3 was retained. As such, a recommendation of attainment status for the annual standard is not required, and the previous nonattainment areas established in 2004 for the annual standard remain in effect. The Department is preparing a State Implementation Plan (SIP) for the area designated by EPA as not meeting the annual PM2.5 NAAQS for an April 5, 2008 submission.

EPA has also revoked the annual PM10 standard because available evidence generally does not suggest a link between long-term exposure to current levels of coarse particles and health problems. However, the existing daily PM10 standard of 150 µg/m3 was retained to protect against the inhalation of coarse particulates on an acute (24-hour) basis.

Air quality data collected from the years 2004-2006 indicates that there are two areas of the state that either do not attain the standard or attain the standard by a sufficient margin to lend certainty to a determination that the areas are in attainment with the 35 µg/m3 PM2.5 standard. These areas include the New York City metropolitan area and the Buffalo/Niagara Falls area.

Section 107(d)(1)(A) of the Clean Air Act (CAA) requires that any area that does not meet, or that contributes to areas not meeting, the ambient air quality standard be designated nonattainment. The U.S. Environmental Protection Agency (EPA) April 1, 2003 guidance document entitled, "Designations for the Fine Particle National Ambient Air Quality Standards," identifies considerations to be applied when evaluating the attainment status of a given area. This guidance prescribes nine specific factors to be assessed when recommended nonattainment areas deviate from the presumptive boundaries of the metropolitan statistical areas in which nonattainment occurs. New York State has completed such an assessment and, based on that analysis, is recommending the creation of the New York City Metropolitan PM2.5 Nonattainment Area as a result of exceedances of the 24-hour standard at several monitors in this area as well as other factors. The ten counties in New York State that would be encompassed in this nonattainment area include Bronx, Kings, New York, Orange, Queens, Richmond, Rockland, Nassau, Suffolk and Westchester Counties. This recommendation excludes Dutchess and Putnam Counties, and so deviates from the presumptive boundaries of the New York Consolidated Metropolitan Statistical Area (CMSA).

For the Buffalo/Niagara Falls Metropolitan Statistical Area (MSA), which includes the counties of Erie and Niagara, the design values met the 24-hour standard only in 2004-2006, and only by a small margin. Compounding this, the annual values upon which the three-year averages are based fluctuate significantly. For this area, there is no clear downward trend for PM2.5 concentrations. Given the influence of the weather on a seasonal and annual basis, an absence of a clear decreasing trend in PM2.5 concentrations, and the lack of other factors that would lead the Department to conclude otherwise, New York State is recommending an "unclassifiable" designation for these counties, which comprises the entire MSA. As prescribed under Section 107(d)(1)(A)(iii), this classification is appropriate for areas either meeting the standard or having insufficient data to determine air quality, and not contributing to nearby nonattainment.

It should be noted that the conclusions reached in this recommendation are based on monitored data from the 2004-2006 time period and before. When these recommendations are reviewed by EPA in 2008, data for the three-year 2005-2007 period will be available. EPA's approval will consider monitored data from this later period as well as the 2004-2006 periods and those from prior intervals.

Recommended classifications and design values for these areas are summarized in Table 1 below.

Criteria for Assessment of Boundaries for Nonattainment Areas

Aside from the design values resulting from monitoring data in a given area, the classification of an area is influenced by a number of other considerations. These factors are important not only because of their influence on the counties and other jurisdictions within the area being evaluated, but also because of their potential impact on other locations to which the area under consideration might cause or contribute to an exceedance. EPA's April 1, 2003 guidance outlined the criteria that states are expected to consider when making their nonattainment boundary recommendations. These factors are based on Section 107(d)(1)(A) of the CAA, where the definition of a nonattainment area includes any area that does not meet, or that contributes to nearby areas not meeting, the NAAQS.

For areas whose attainment areas are under consideration EPA's guidance recommends that the boundaries of MSA's, as discussed in the June 30, 1999 OMB memorandum, serve as the presumptive boundaries for nonattainment areas. The presumptive use of the MSA is based on evidence that violations of an NAAQS generally include a significant urban-scale contribution as well as significant regional contributions, and is therefore especially useful in complex metropolitan areas, such as the New York City metropolitan area.

In those cases where it is thought that changes to a presumptive boundary encompassed by an MSA are appropriate, as is the case here for one of the two areas specifically discussed in this assessment, EPA's guidance requires all states to address the following factors or criteria:

  • Air Quality
  • Meteorological Influences (Weather and Transport Patterns)
  • Population Density and Degree of Urbanization including Commercial Development
  • Traffic and Commuting Patterns
  • Expected Growth
  • Emissions
  • Geography and Topography
  • Jurisdictional Boundaries
  • Level of Current Emission Controls (Emission Control Potential)

Of the above factors, New York State believes the monitored PM2.5 air quality and associated meteorological conditions that create elevated PM2.5 episodes are among the most significant. The PM2.5 design values for all PM2.5 monitors in New York are shown in Table 2 and are discussed specifically for each area. Their locations appear in Figures 1 and 2. The other factors are also discussed in detail in the following sections for each of the areas that were evaluated.

It should be noted that the nine-factor analysis is appropriate where changes to a presumptive boundary encompassed by an MSA are contemplated. For the New York portion of the New York CMSA, the presumptive area would include 12 New York counties. However, two of the 12 counties are not proposed for inclusion in the nonattainment area for reasons detailed in the submittal. Thus, a nine-factor analysis has been conducted in accordance with EPA guidance.

The second area, the Erie and Niagara County MSA, is proposed in this submittal to be designated as "unclassifiable." Erie and Niagara counties are the only two counties included in this MSA. However, a nine-factor analysis has been conducted to strengthen the "unclassifiable" recommendation.

Table 1: Classification and Design Value Recommendations
New York State Proposed Attainment, Nonattainment & Unclassifiable Areas for the 24-hour PM2.5 Standard (35 µg/m3)
Area Name Classification Design Value (µg/m3) Data Set Monitoring Location AIRS Monitor ID
New York City Metropolitan Area Nonattainment Area (Bronx, Kings, New York, Orange, Queens, Richmond, Rockland, Nassau, Suffolk & Westchester Counties) Nonattainment 41 2004-2006 PS 59 (Manhattan) 360610056
Buffalo/Niagara Falls Area (Erie & Niagara Counties) Unclassifiable 34 2004-2006 Buffalo CAM 360290005
Rest of State Attainment -- -- -- --
Table 2 - PM2.5 24-Hour 98th Percentile and Design Values (DV): Standard = 35 µg/m3
PM2.5 24 Hour 98th Percentile and Design Values (µg/m3)
Site AIRS ID County 98th %ile 2002 98th %ile 2003 98th %ile 2004 98th %ile 2005 98th %ile 2006 2002-2004 DV 2003-2005 DV 2004-2006 DV
Hempstead 360590008 Nassau 32.04 39.29 30.83 35.08 33.00 34 35 33
Babylon MAM 361030002 Suffolk 35.96 38.83 30.92 34.33 31.90 35 35 32
J.H.S.45 (Manhattan) 360610079 New York 36.29 46.17 38.00 36.58 37.60 40 40 37
J.H.S.45 duplicate (new) 360610079dup New York 37.80 n/a n/a
P.S.59 (Manhattan) 360610056 New York 38.46 36.58 41.13 40.08 40.70 39 39 41
P.S.59 duplicate 360610056dup New York 38.08 36.79 40.96 39.46 closed 39 39 40
P.S.19 (Manhattan) 360610128 New York 38.08 48.46 38.92 38.25 38.20 42 42 38
Morrisania II (Bronx) 360050080 Bronx 35.15 44.83 38.21 37.67 39.70 39 40 39
NY Botanical Garden (Bronx) 360050083 Bronx 33.42 38.21 31.30 36.57 34.80 34 35 34
I.S.52 (Bronx) 360050110 Bronx 40.63 37.67 28.79 36.75 38.10 36 34 35
I.S.52 duplicate 360050110dup Bronx 37.08 46.00 38.25 38.04 closed 40 41
J.H.S. 126 (Brooklyn) 360470122 Kings 35.67 40.75 36.93 36.27 37.70 38 38 37
Queens College 2 (PS219) 360810124 Queens 38.63 39.00 33.42 34.29 33.60 37 36 34
Susan Wagner (Staten Isl) 360850067 Richmond 28.17 32.26 33.50 33.25 32.00 31 33 33
Port Richmond PO (S.I.) 360850055 Richmond 39.96 46.38 31.33 33.38 36.20 39 37 34
Canal St. P.O. 360610062 New York 38.54 46.21 39.08 39.50 35.90 41 42 38
Newburgh F.D. 360710002 Orange 31.58 31.29 27.42 29.63 27.50 30 29 28
Mamaroneck (Larchmont) 361191002 Westchester 32.96 36.79 33.54 32.85 34.40 34 34 34
Albany (County DOH) 360010005 Albany 41.50 33.96 32.42 35.92 30.90 36 34 33
Albany duplicate 360010005dup Albany 14.25 34.50 31.92 36.42 30.20 27 34 33
Whiteface Base 360310003 Essex 31.34 20.38 23.22 26.58 18.80 25 23 23
Potsdam Airport 360893001 St. Lawrence 42.66 20.00 20.79 26.83 19.00 28 23 22
East Syracuse 360671015 Onondaga 38.75 22.71 24.63 34.79 19.20 29 27 26
Pinnacle State Park 361010003 Steuben 36.54 26.17 29.29 29.25 25.60 31 28 28
Rochester Downtown 360556001 Monroe 31.86 28.37 28.92 closed 30 n/a n/a
360551007 Monroe 25.60 n/a n/a n/a
Westfield CAM 360130011 Chautauqua 37.79 26.33 26.63 34.08 24.30 30 29 28
Buffalo CAM 360290005 Erie 43.09 38.67 32.75 39.75 28.40 38 37 34
Lackawanna 360291007 Erie 38.08 37.21 31.46 37.08 28.20 36 35 32
Niagara Falls CAM 360632008 Niagara 33.54 29.63 30.08 43.29 27.30 31 34 34

Note: July 7, 2002 Quebec fire data not included
This sheet is based on DEC data - it may differ from EPA data because EPA includes flagged data
PS59 had only five samples in 3rd quarter of 2003 - 11 is minimum unless EPA says there are compelling reasons to use it

Figure 1 - Locations of PM2.5 Monitors in Table 2 (Excluding New York City)

Locations of PM2.5 Monitors in Table 2 (Excluding New York City)

Figure 2 - Locations of New York City PM2.5 Monitors in Table 2

Locations of New York City PM2.5 Monitors in Table 2