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Buffalo/Niagara Falls Metropolitan Area Classification and Boundary Determination

In establishing the nonattainment area boundaries for the Buffalo and Niagara Falls metropolitan statistical area, the environmental characteristics of Erie and Niagara counties were evaluated in light of EPA's nine factors to determine the attainment status of this area as well as the potential influence of this area on other jurisdictions. Together, these two counties comprise the Buffalo/Niagara Falls Metropolitan Statistical Area (MSA). This area is shown in Figure 7 below.

The Buffalo/Niagara Falls MAS Monattainment Area
Figure 7 - The Buffalo/Niagara Falls
MAS Monattainment Area

1. Air Quality

An area with a monitor that records a violation of the PM2.5 NAAQS must be designated nonattainment. As can be seen in Table 2 above, the design values for the Buffalo/Niagara Falls area met the 24-hour standard only in 2004-2006, and only by a small margin. Data for the 2002-2004 and 2003-2005 periods exceeded the 24-hour standard at the Buffalo and Lackawanna monitors. The data for 2004-2006 may be an anomaly based on the 2006 data which was one of the three years averaged together to obtain the 2004-2006 average. The 24-hour values for the Buffalo, Niagara Falls and Lackawanna monitors for 2006 are 25-35% less than the values for 2005. The 2005 values are, in turn, significantly higher than the 2004 values. Given the wide variation in the figures from year to year and the lack of a clear trend in the data either upward or down, no definitive conclusion can be reached on the attainment status of these areas when viewed in light of the monitoring data. This is a strong factor that clearly justifies the Department's recommendation that the area be designated as unclassifiable, which is appropriate for areas either meeting the standard or having insufficient data to determine air quality, and not contributing to nearby nonattainment.

2. Meteorological Influences

To assess the influence of weather patterns on observed PM2.5 mass concentration in the Buffalo/Niagara Falls area, the meteorological conditions associated with the days on which the highest 5% of PM2.5 readings occurred were examined for the 2004-2006 period of interest. These events occurred throughout the year, though they were more prevalent in the May through October period.

The result of this assessment indicates that on most days in which high PM2.5 levels were measured, wind flows originated from the WSW, SW and S of the Buffalo and Niagara Falls areas. Although there is always a local contribution, the stable conditions and steady winds from these directions are strongly suggestive that the contributions to the particulate concentrations were from the directions of Pittsburgh and Erie, Pennsylvania, and the Cleveland, Ohio areas. Additionally, on several of the days in which the highest 24-hour PM2.5 values were recorded in the Buffalo/Niagara Falls area, high values were also recorded at the Westfield monitor in Chautauqua County at which the concentrations being measured are indicative of the quality of the air entering New York State. Thus, the conclusion to be reached is that, on high PM2.5 days, there is a significant impact due to transport from upwind states.

Typical Speciation for a High PM2.5 Day - Buffalo CAM
Figure 8: Typical Speciation for a High PM2.5 Day (9-13-2005)
Buffalo CAM

In addition to conducting an assessment of the meteorology for the days of highest PM2.5, speciation data for the days on which the highest PM2.5 concentrations occurred (where the dates concurred) were also assessed to determine if there was an indication of whether local or transported pollution would have been a primary source. As can be seen by Figure 8, approximately half of the mass of the PM2.5 collected was composed of sulfates on a typical day of high PM2.5. Sulfates are formed after sulfur oxides are emitted and react in the atmosphere during transport to form sulfates. Time is required for this transformation. The large fraction of sulfate is strongly suggestive that the PM2.5 measured in those days was transported into the area from the direction of Ohio and Pennsylvania, as well as other of the southern and Midwest states, and that combustion sources such as the large power plants located outside on New York were the sources of the sulfate. This further supports the conclusion that PM2.5 is transported from outside of New York State. Before the PM2.5 concentrations in the Buffalo/Niagara Falls area can be reduced, emission reductions to the west, southwest and south must be achieved.

3. Population Density and Degree of Urbanization including Commercial Development

To address the population density and degree of urbanization factors, various demographics and economic indicators were examined for the Buffalo/Niagara Falls area. Figure 4, which depicts the population density of the entire state, indicates that the Buffalo/Niagara Falls area is one of the more densely populated regions of the state. Likewise, data from the New York State Department of Labor1 indicates that employment will increase as well in the Western New York area, averaging 5% for the 2004 to 2014 period, suggesting that commercial development will continue to increase as well, though more modestly than in the New York CMSA.

4. Traffic and Commuting Patterns

The Buffalo/Niagara Falls area is primarily urban in nature, though it is not as heavily populated or industrialized as the New York City area as a whole. A number of major transportation corridors are located in the area, including the New York State Thruway which passes through the area. Additionally, the Buffalo/Niagara Falls area is one of the main thoroughfares for traffic between the United States and Canada via four bridges. Travel also takes place on many other local highways and intermediate roads.

The breakdown of commuting options according to the United State Census Bureau2 for the Buffalo/Niagara Falls area is summarized below in Table 7. Compared to the New York metropolitan area, a far smaller fraction of commuters use public transportation, with the overwhelming majority of commuting taking place in single-occupant vehicles.

Table 7 - Commuting Methods for the Buffalo/Niagara Falls MSA

Commuting Mode Number of Commuters Percent
Car, truck, or van -- drove alone 418,526 82.0
Car, truck, or van -- car pooled 45,682 9.0
Public Transportation 18,751 3.7
Walked 13,618 2.7
Other means 1,948 0.4
Work at home 11,025 2.2
Total Commuters 509,550 100
Mean travel time to work 19.4 minutes --

According to the Greater Buffalo-Niagara Regional Transportation Council (GBNRTC), the annual vehicle mile traveled has been increasing, contributing to the potential for increased motor vehicle emissions, though this will likely be somewhat offset by fewer emissions from individual vehicles as older vehicles are removed from service and are replaced by newer ones. Rail transportation is not as prevalent as it is in the New York Metropolitan area, with less commuting taking place by rail and other mass transit. Other contributions from mobile sources include buses and marine vessels operating in ports at the east end of Lake Erie.

An examination of the Vehicle Miles Traveled (VMT) for the Buffalo/Niagara Falls MSA counties for 2005 was also done. As can be seen in Table 8 below, the VMT in Erie County is significantly higher than that in Niagara County, likely reflecting the high traffic rate in the I-90 corridor, the "drive alone" commuter traffic indicated in Table 7 above, and the routine commercial traffic in the Buffalo urban area. Erie County's VMT is comparable to that in several of the core New York metropolitan area counties (see Table 4 above).

Table 8 - Buffalo/Niagara Falls MSA 2005 Vehicle Miles Traveled3

2005 Vehicle Miles Traveled (VMT)
County VMT (Millions)
Erie 9248
Niagara 1695

5. Expected Growth

The population of the Buffalo and Niagara Falls area has experienced a downturn in recent years. Population projections out to 2015 indicate that the population will continue to decrease. This trend is opposite to the expected trend for employment and commercial growth discussed in Section II.3 above. The cause of the population shift is likely the movement of populations from central city locations to suburbs where the perception is that better educational resources for children, better housing and a desire to be near employment that is available in outside of the cities.4

Table 9 - Population Projections for the Buffalo/Niagara Falls MSA5

Projected Population by County, 2000 to 2015
County 2000 2005 2010 2015 Change 2000-2015
Number Percent
Erie 950,265 929,506 906,480 883,909 -66,356 -6.98
Niagara 219,846 217,316 213,695 209,519 -10,327 -4.70

6. Emissions

Fine particulate consists of both primary and secondary particles. Primary particles are generally directly emitted into the atmosphere from motor vehicles, power generation facilities, industrial facilities, residential wood and forest product burning sources. Secondary particles are formed from precursor gases reacting in the atmosphere from the combination of various pollutants: oxides of sulfur (SOx), oxides of nitrogen (NOx), volatile organic compounds (VOCs), and ammonia (NH3). These pollutants are emitted from many of the same emission sources as precursors of ozone.

Emission sources of particulate matter in the Buffalo/Niagara Falls area vary. Combustion processes are the main source of primary and secondary PM. Sources include fossil fuel combustion in heating as well as mobile sources such as trucks, cars and buses. A number of large electric utility plants presently operate in the Buffalo/Niagara Falls areas, including the Somerset, Dunkirk and Huntley power generation facilities as well as several cogeneration plants. VOC emissions from industrial and commercial operations, and gasoline use, also contribute. Industrial operations include the 3M, Dupont Yerkes, Goodyear, General Motors and Tonawanda Coke facilities. Emissions from mobile sources, both on-road and non-road, contribute significantly as well, as do gasoline fueling and transfer operations.

Table 10a below presents the 2005 emissions for VOC, CO, NOx, SOx and total PM for the counties in the New York CMSA. Table 10b shows the percent contribution for each county by pollutant.

Table 10a - 2005 Emissions of Particulate Matter and its Precursors for the Buffalo/Niagara Falls MSA Counties6

County VOC NOx SOx NH3 PM2_5 OC EC PMFINE (Crustal)
Erie 47172 33057 30867 3161 5107 1071 557 3113
Niagara 15133 11361 6991 954 2068 392 138 1419
Area Totals 62305 44418 37858 4115 7175 1463 695 4532

Table 10b - 2002 Emission Percent contributions of Particulate Matter and its Precursors for the Buffalo/Niagara Falls MSA Counties

County VOC NOx SOx NH3 PM2_5 OC EC PMFINE (Crustal)
Erie 75.71 74.42 81.53 76.82 71.18 73.21 80.14 68.69
Niagara 24.29 25.58 18.47 23.18 28.82 26.79 19.86 31.31
Area Totals 100.00 100.00 100.00 100.00 100.00 100.00 100.00 100.00

The Department is currently assessing its stationary, point, mobile and area source PM2.5 emission inventory preparation plans since the inventory will be a necessary component of its PM2.5 State Implementation Plan submission in April of 2008. Projections are not presently available for all of these pollutants. In general, emissions of particulate matter and its precursors can be expected to decrease as a result of programs such as the Clean Air Interstate Rule (CAIR) and Acid Deposition Reduction Program (ADRP) that affect large emitters in both New York State and downwind states. Improvements in mobile emissions are also expected due to New York's Low Emission Vehicle (LEV), and Inspection and Maintenance (I/M) programs. Other efforts, such as the 8-hour ozone and Haze SIPs, will reduce the emission of particulates and precursors.

7. Geography and Topography

The Buffalo and Niagara Falls areas are in a location in the state where topography plays no role. Without the presence of any significant terrain, topography is unlikely to be a factor in the attainment status.

From a geographic perspective, the most significant physical features influencing air quality are Lakes Erie and Ontario, which affect the weather, climate, humidity and precipitation. Additionally, the close proximity of Canada and the Ohio Valley affects the air quality, given the emission of PM2.5 precursors from power plants in these regions as well as those south of Buffalo/Niagara Falls. These emissions are likely the primary source of PM2.5 on many days in the Buffalo/Niagara Falls area, especially on the days with high PM2.5 levels as discussed under Section II.2. above. Emission reductions in these other states and in Canada would be needed to maximally reduce the PM2.5 levels in the ambient air.

Finally, neither of the counties are severely disproportionate in their dimensions (north-south vs. east-west, for example) in a manner that would magnify or otherwise affect the other factors that influence air quality and transport.

8. Jurisdictional Boundaries

There are no jurisdictional boundary issues affecting attainment status. The two counties involved are equally affected by both the state and federal air quality programs presently in effect, and are subject to the same requirements as surrounding New York State counties. They are also both a part of the Greater Buffalo-Niagara Regional Transportation Council (GBNRTC), which has served as the interagency group for transportation planning in Erie and Niagara Counties since 1975, and has addressed the needs of these counties related to mobile sources and transportation, and the associated emissions.

9. Level of Current Emission Controls

The Buffalo/Niagara Falls area has been regulated under both the state and federal air quality programs for over 30 years. Throughout this time, controls have been required on a wide variety of sources under New York's Reasonably Available Control Technology (RACT) and Prevention of Significant Deterioration (PSD) programs as well

as requirements applying to a wide variety of other sources. Both the New York State air permitting program and the federal Title V program have provided a vehicle to require emission reductions to take place in the Buffalo/Niagara Falls area as well as across the state. Past requirements will continue to apply so that no "backsliding" on controls already in place will occur.

The Buffalo/Niagara Falls area is presently a nonattainment area for 8-hour ozone. A SIP is under development that will result in the control of several of the pollutants that are precursors of PM2.5. Additionally, a regional haze SIP must be submitted to EPA that will require the reduction of precursors from several major facilities in the state through the application of Best Available Retrofit Technology requirements and general measures intended to reduce haze, including reduced fuel sulfur limits. Finally, a PM2.5 SIP for the annual PM2.5 standard promulgated in 1997 is due to EPA in April of 2008 which will propose controls for several sources of PM2.5 and its precursors.

Conclusions for the Buffalo/Niagara Falls MSA:

After considering the nine factors required by EPA guidance, the Department recommends that the entire two county Buffalo/Niagara Falls MSA be designated as an "unclassifiable" area for the 24-hour PM2.5 standard. This recommendation is based on the insufficient margin between the monitored values and the 24-hour PM2.5 standard to support a definitive conclusion that the attainment that was monitored in the 2004-2006 period will persist. The annual 24-hour values are also inconsistent, exhibiting no downward trend in the data. This is likely due, at least in part, to weather differences from year to year, and the variation in PM2.5 transported into the areas from out-of-state. Additionally, the result of the application of the nine factors required by EPA taken together does not weight this recommendation toward a clear conclusion that the area should be either attainment or nonattainment.

A map depicting the Buffalo/Niagara Falls Metropolitan Area Classification and Boundary Determination
Figure 9: Proposed 24-Hour PM2.5 Nonattainment and Unclassifiable Areas

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1 http://www.labor.state.ny.us/workforceindustrydata/apps.asp?reg=wny&app=projections

2 http://www.census.gov/acs/www/Products/Profiles/Single/2003/ACS/Tabular/380/38000US12803.htm

3 http://www.epa.gov/ttn/naaqs/pm/docs/2005_vmt_county_level.xls

4 http://www.ci.buffalo.ny.us/files/1_2_1/Mayor/COB_Comprehensive_Plan/section_2459139390.html

5 http://www.aging.state.ny.us/explore/project2015/projections/index.htm

6 http://www.epa.gov/ttn/naaqs/pm/docs/2005_ei_new_york.xls. It should be noted that these emissions were produced by EPA, and may change when the Department's final 2005 inventory is prepared. However, the Department does not expect that the conclusions reached in this analysis will be affected.