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Designation Recommendations for the 2012 Particulate Matter NAAQS

The following is the content of a letter sent to the Regional Administrator at the USEPA, Region 2, Judith A. Enck. The letter was signed on October 2, 2013 by Joseph J. Martens, Commissioner.

On December 14, 2012, the EPA announced its revisions to the National Ambient Air Quality Standards (NAAQS) for particulate matter (PM). In this action, EPA revised the primary annual fine particulate matter (PM2.5) standard to 12.0 micrograms per cubic meter (µg/m3) from 15.0 µg/m3. We commend EPA on strengthening the primary annual PM2.5 standard as a means to protect human health. Pursuant to guidance issued by EPA,1 I am submitting New York State's designation recommendations on behalf of Governor Cuomo.

Based on a review of statewide monitoring data, DEC is recommending that the entirety of the state be designated as attainment for the revised annual PM2.5 NAAQS. The 2012 design values (based on 2010 - 2012 monitoring data) are presented in an enclosed table. Also enclosed are the design values from the portions of Connecticut and New Jersey that are part of the New York-Northern New Jersey-Long Island, NY-NJ-CT metropolitan area. The highest design value in New York State or the tri-state metropolitan area occurred at PS 19 in New York County, with a three-year average of 11.8 µg/m3.

While the 2012 annual average for the IS 52 monitor in Bronx County is recorded in EPA's Air Quality System as 13.9 µg/m3, it is a misleading value based on poor data substitution practices. Operation of the IS 52 monitor was halted for approximately two years due to extensive construction at the school; it recommenced sampling on June 29, 2012, recording a single value (21.9 µg/m3) at the end of the second quarter. This value was erroneously used as the second quarter average and, combined with the much lower third and fourth quarter averages (9.5 µg/m3 and 10.5 µg/m3, respectively), resulted in an inflated annual average. Although the monitor still does not satisfy the data completeness requirements of 40 CFR Part 50 Appendix N, a 2012 annual average of 10.0 µg/m3 has been included in the enclosed table as a better representation of the monitored values and of local ambient air quality.

On December 31, 2012, EPA issued a clean data finding for the New York-Northern New Jersey-Long Island, NY-NJ-CT nonattainment area for the 2006 24-hour PM2.5 NAAQS.2 The tri-state metropolitan area, as well as the rest of New York State, continues to demonstrate compliance with this 35 µg/m3 standard. Tables containing 2012 design values in New York State and the Connecticut and New Jersey portions of the tri-state metropolitan area are enclosed. The highest 24-hour PM2.5 design value in New York State was 26 µg/m3 recorded at the PS 19 and Division Street monitors in New York County; the highest design value in the tri-state metropolitan area was 29 µg/m3 at a site adjacent to the New Jersey Turnpike.

The state remains in attainment of the 150 µg/m3 24-hour PM10 NAAQS. DEC has requested a clean data finding from EPA for this standard.3

As part of the June 27, 2013 request to redesignate the New York portion of the tri-state metropolitan area to attainment for the 1997 annual and 2006 24-hour PM2.5 NAAQS, DEC completed emissions projections for the New York portion of the tri-state area that predict significant reductions of PM and PM precursors between 2007 and 2025. 4, 5 These projections are presented in an enclosed chart. During this timeframe, emissions of sulfur dioxide (SO2) and oxides of nitrogen (NOx)-two of the primary precursors to particulate formation-are expected to decline by over 30 percent and 40 percent, respectively. While the precise levels of emission reductions will vary throughout the state, this trend is seen as a predictor of continuing attainment of the annual and 24-hour PM2.5 NAAQS. The Connecticut and New Jersey portions of the tri-state PM2.5 nonattainment area have also demonstrated declining PM2.5 ambient levels and emissions. EPA has approved New Jersey's and proposed approval of Connecticut's redesignation requests for the 1997 annual and 2006 24-hour PM2.5 NAAQS based on their continued compliance with these standards.6, 7

The downward trend in emissions in New York State is a direct result of the permanent and enforceable reductions that occur statewide from the many state and federal air quality regulations. Recent updates to several state regulations account for a portion of the projected emission reductions. Chief among these are updates to 6 NYCRR Subpart 227-2, which requires Reasonably Available Control Technology (RACT) for major combustion sources, and 6 NYCRR Subpart 225-1, which establishes sulfur-in-fuel limitations.

DEC has estimated that the Subpart 227-2 revisions, which strengthen NOx limits on 766 boilers and 55 combined cycle combustion turbines beginning in 2014, will result in statewide reductions of about 28,800 tons of NOx per year, or 78.9 tons per day, from 2007 levels. The Subpart 225-1 revisions primarily lower the sulfur-in-fuel limits for distillate and residual oils, and will result in an estimated statewide reduction of 97,800 tons of SO2 per year, or 268.0 tons per day, when it is fully implemented in 2014.

DEC has also promulgated, and periodically updates, a number of regulations to control emissions of volatile organic compounds (VOCs) from various sources (e.g., architectural and industrial maintenance coatings, consumer products, surface coating processes, and adhesives, sealers, and primers). These VOC control programs primarily benefit ozone, but result in strong side-benefits for particulate formation. Periodically strengthened automobile emission standards and continuous vehicle turnover also greatly benefit statewide air quality, particularly in urban areas.

Additional near-road monitoring is required by the 2012 NAAQS revision. These monitors are being established in the major urban areas of New York State over the next few years. Once three years of data have been collected by these monitors, they could potentially factor into future revisions to the attainment designations.

If you have any questions regarding these recommendations, please contact David J. Shaw, Director of DEC's Division of Air Resources, at (518) 402-8452.

2012 Annual PM2.5 Design Values in New York State
AQS ID Monitoring Site County Annual Average (µg/m3) Design Value
2010 2011 2012
36-001-0005 Albany Co. Health Dept. Albany 7.9 8.8 7.6 8.1
36-001-0012 Loudonville Reservoir Albany 7.9 7.2 7.0 7.4^
36-005-0080 Morrisania Center Bronx 11.4 11.6 11.0 N/A*
36-005-0110 IS 52 Bronx 10.2 N/A 10.0 N/A*
36-005-0133 Botanical Garden Bronx 10.0 10.0 9.5 9.8
36-013-0011 Westfield - Hardscrabble Rd Chautauqua 7.5 7.3 7.6 7.5
36-029-0005 Buffalo - Dingens St Erie 10.0 9.6 9.5 9.7
36-031-0003 Whiteface Lodge - Base Essex 4.3 4.2 4.5 4.3^
36-047-0122 JHS 126 Kings 9.9 10.3 9.7 10.0
36-055-1007 Rochester - Yarmouth Rd Monroe 8.3 9.2 8.7 N/A*
36-061-0079 JHS 45 New York 9.8 10.4 9.0 9.7
36-061-0128 PS 19 New York 11.5 12.1 11.7 11.8
36-061-0134 Division Street New York 11.5 12.0 11.0 11.5
36-063-2008 Niagara Falls - Frontier Ave Niagara 8.3 8.1 8.1 N/A*
36-067-1015 E. Syracuse - Enterprise Pkwy Onondaga 7.6 8.1 7.1 7.6
36-071-0002 Newburgh Orange 8.1 8.6 7.8 8.2^
36-081-0124 Queens College Queens 9.4 9.3 8.5 9.1^
36-085-0055 Port Richmond Richmond 9.7 9.9 9.4 9.7^
36-101-0003 Pinnacle State Park Steuben 7.2 7.0 6.8 7.0^
36-103-0002 Babylon Suffolk 8.4 8.8 7.9 8.4

Values marked in bold do not fulfill 75% quarterly data capture rate
* Monitor does not satisfy completeness criteria of 40 CFR Part 50 Appendix N
^ Monitor has at least one quarter with data capture rate less than 75%, but at least 50%, and satisfies the "maximum quarterly value data substitution test" specified in 40 CFR Part 50 Appendix N Section 4.1(c)(ii)

2012 Annual PM2.5 Design Values in Connecticut and New Jersey
AQS ID Monitoring Site County Annual Average (µg/m3) Design Value
2010 2011 2012
Connecticut 09-001-0010 Roosevelt School Park Ave. Fairfield 8.8 10.0 9.3 9.4
09-001-1123 White St. at 8th Ave. Fairfield 9.1 9.6 8.4 9.0
09-001-3005 137 East Ave. Fairfield 8.7 10.0 8.6 9.1^
09-001-9003 Sherwood Island State Park Fairfield 8.6 9.5 8.0 8.7
09-009-0027 James St. New Haven 8.9 10.0 8.3 9.1
09-009-1123 715 State St. New Haven 9.0 10.0 9.2 9.4
09-009-2123 Bank St. at Meadow St. New Haven 9.2 9.9 8.4 9.2
New Jersey 34-003-0003 Fort Lee Library - 320 Main St. Bergen 8.8 9.8 8.9 9.2
34-013-0003 360 Clinton Ave. Essex 9.2 10.5 9.0 9.5
34-017-1003 Consolidated Firehouse Hudson 9.6 10.8 9.9 10.1
34-017-2002 Health Dept. - 714 31st St. Hudson 10.6 11.8 10.9 11.1
34-021-0008 Trenton Library Mercer 9.5 10.3 8.8 9.5
34-021-8001 Washington Crossing St. Park Mercer 8.1 8.4 7.9 8.2^
34-023-0006 Cook College Middlesex 7.4 8.3 8.3 8.0^
34-027-0004 16 Early St. Morris 8.5 8.7 7.9 8.4
34-027-3001 Dept. Public Works Bldg #1 Morris 7.5 7.9 7.5 7.6
34-031-0005 Health Dept. - 176 Broadway Passaic 8.9 10.1 9.1 9.3^
34-039-0004 NJ Turnpike Interchange 13 Union 10.6 12.2 10.7 11.2
34-039-0006 Mitchell Bldg., 500 N Broad St. Union 9.2 10.0 9.6 9.6^
34-039-2003 Fire Dept. Bldg., 1300 Main St. Union 9.3 10.1 9.7 9.7

This table features only the monitors included in the tri-state New York metropolitan area
Values marked in bold do not fulfill 75% quarterly data capture rate
^ Monitor has at least one quarter with data capture rate less than 75% but at least 50%, and satisfies the "maximum quarterly value data substitution test" specified in 40 CFR Part 50 Appendix N Section 4.1(c)(ii)

2012 24-Hour PM2.5 Design Values in New York State
AQS ID Monitoring Site County 98th Percentile Value (µg/m3) Design Value
2010 2011 2012
36-001-0005 Albany Co. Health Dept. Albany 24.1 23.5 17.7 22
36-001-0012 Loudonville Reservoir Albany 27.5 18.1 17.8 21^
36-005-0080 Morrisania Center Bronx 27.0 27.0 26.1 N/A*
36-005-0110 IS 52 Bronx 26.6 N/A 23.7 N/A*
36-005-0133 Botanical Garden Bronx 24.8 23.0 25.1 24
36-013-0011 Westfield - Hardscrabble Rd Chautauqua 23.5 21.6 19.5 22
36-029-0005 Buffalo - Dingens St Erie 27.9 24.6 23.1 25
36-031-0003 Whiteface Lodge - Base Essex 15.7 14.4 16.5 16^
36-047-0122 JHS 126 Kings 24.8 24.3 22.1 24
36-055-1007 Rochester - Yarmouth Rd Monroe 23.4 25.3 20.5 N/A*
36-061-0079 JHS 45 New York 25.2 25.2 21.3 24
36-061-0128 PS 19 New York 25.4 26.4 24.9 26
36-061-0134 Division Street New York 27.0 26.8 24.0 26
36-063-2008 Niagara Falls - Frontier Ave Niagara 24.8 19.9 20.2 N/A*
36-067-1015 E. Syracuse - Enterprise Pkwy Onondaga 22.5 24.1 15.7 21
36-071-0002 Newburgh Orange 26.5 20.8 20.2 23^
36-081-0124 Queens College Queens 25.5 24.7 20.5 24^
36-085-0055 Port Richmond Richmond 25.5 23.2 22.1 24^
36-101-0003 Pinnacle State Park Steuben 21.4 20.4 18.9 20^
36-103-0002 Babylon Suffolk 26.1 21.7 18.7 22

Values marked in bold do not fulfill 75% quarterly data capture rate
* Monitor does not satisfy completeness criteria of 40 CFR Part 50 Appendix N
^ Monitor has at least one quarter with data capture rate less than 75% but at least 50%, and satisfies the "maximum quarterly value data substitution test" specified in 40 CFR Part 50 Appendix N Section 4.2(c)(i)

2012 24-Hour PM2.5 Design Values in Connecticut and New Jersey
AQS ID Monitoring Site County 98th Percentile Value (µg/m3) Design Value
2010 2011 2012
Connecticut 09-001-0010 Roosevelt School Park Ave. Fairfield 23.3 23.7 21.5 23
09-001-1123 White St. at 8th Ave. Fairfield 25.7 24.8 21.6 24
09-001-3005 137 East Ave. Fairfield 23.0 25.2 22.5 24^
09-001-9003 Sherwood Island State Park Fairfield 24.2 28.7 19.5 24
09-009-0027 James St. New Haven 25.5 27.5 20.6 25
09-009-1123 715 State St. New Haven 23.9 26.6 22.0 24
09-009-2123 Bank St. at Meadow St. New Haven 25.7 24.3 20.6 24
New Jersey 34-003-0003 Fort Lee Library - 320 Main St. Bergen 25.1 23.5 19.2 23
34-013-0003 360 Clinton Ave. Essex 24.0 23.9 21.5 23
34-017-1003 Consolidated Firehouse Hudson 25.9 28.2 24.1 26
34-017-2002 Health Dept. - 714 31st St. Hudson 26.7 25.7 24.6 26
34-021-0008 Trenton Library Mercer 26.9 27.7 20.5 25
34-021-8001 Washington Crossing St. Park Mercer 18.5 19.7 19.3 19^
34-023-0006 Cook College Middlesex 19.1 20.5 17.5 19^
34-027-0004 16 Early St. Morris 23.3 21.0 18.2 21
34-027-3001 Dept. Public Works Bldg #1 Morris 22.7 24.4 16.2 21
34-031-0005 Health Dept. - 176 Broadway Passaic 24.4 25.4 21.4 24^
34-039-0004 NJ Turnpike Interchange 13 Union 28.1 32.9 25.8 29
34-039-0006 Mitchell Bldg., 500 N Broad St. Union 25.1 21.5 25.1 24^
34-039-2003 Fire Dept. Bldg., 1300 Main St. Union 23.8 23.8 23.0 24

This table features only the monitors included in the tri-state New York metropolitan area
Values marked in bold do not fulfill 75% quarterly data capture rate
^ Monitor has at least one quarter with data capture rate less than 75% but at least 50%, and satisfies the "maximum quarterly value data substitution test" specified in 40 CFR Part 50 Appendix N Section 4.2(c)(i)

Projected Emissions of PM and PM Precursors in the New York State Portion
of the New York-N. New Jersey-Connecticut Nonattainment Area

Graph showing a general decrease in projected emissions of PM and PM precursors from 2007 to 2025 for the NY portion of the NYNJCT nonattainment area

__________

1 EPA memorandum from Gina McCarthy, Assistant Administrator, to Regional Administrators, "Initial Area Designations for the 2012 Revised Primary Annual Fine Particle National Ambient Air Quality Standard," April 16, 2013
2 77 FR 76867, Approval and Promulgation of Air Quality Implementation Plans; New York, New Jersey, and Connecticut; Determination of Attainment of the 2006 Fine Particle Standard
3 Letter from Joseph Martens, DEC Commissioner, to Judith Enck, EPA Region 2 Administrator, January 14, 2013
4 http://www.dec.ny.gov/chemical/92166.html
5 The New York portion of the tri-state metropolitan area consists of the following counties: Bronx, Kings, Nassau, New York, Orange, Queens, Richmond, Rockland, Suffolk, and Westchester
6 78 FR 54396, Approval and Promulgation of Air Quality Implementation Plans; State of New Jersey; Redesignation of Areas for Air Quality Planning Purposes and Approval of the Associated Maintenance Plan
7 78 FR 43096, Approval and Promulgation of Air Quality Implementation Plans; Connecticut; Redesignation of Connecticut Portion of the New York-New Jersey-Connecticut Nonattainment Area to Attainment of the 1997 Annual and 2006 24-Hour Standards for Fine Particulate Matter