7-1

7.0 REASONABLY AVAILABLE CONTROL MEASURE (RACM) 

ANALYSIS 

This section provides an analysis of both potential transportation control measures 

(TCMs) for onroad mobile sources and non-TCM potential control measures for point, 

area, off-road and onroad source categories in order to determine whether or not any of 

these measures could be considered reasonably available control measures (RACM) and 

would advance the attainment date. The analysis will determine if any RACM are 

available for inclusion in the 8-hour ozone attainment demonstration plans for the New 

Jersey portions of the Northern New Jersey/New York/Connecticut and Southern New 

Jersey/Philadelphia moderate 8-hour ozone nonattainment areas. 

In accordance with Section 172(c)(1) of the Clean Air Act, states, as part of their effort to 

attain National Ambient Air Quality Standards (NAAQS), such as those established for 

ozone, are required to implement all RACMs as expeditiously as practicable. 

Specifically, 42 U.S.C. §7502(c)(1) states the following: 

“In general – Such plan provisions shall provide for the implementation of all 

reasonably available control measures as expeditiously as practicable (including 

such reductions in emissions from existing sources in the area as may be obtained 

through the adoption, at a minimum, of reasonably available control technology) 

and shall provide for attainment of the national primary ambient air quality 

standards.”

Furthermore, in the Final Rule to Implement the 8-Hour Ozone National Ambient Air 

Quality Standard – Phase 2,1

 the USEPA describes how States must include with their 

attainment demonstration a RACM analysis. The purpose of the RACM analysis is to 

determine whether or not reasonably available control measures exist that would advance 

the attainment date for nonattainment areas. Control measures that would advance the 

attainment date are considered RACMs that must be included in the SIP. RACMs are 

necessary to ensure that the attainment date is achieved “as expeditious as practicable”. 

7.1 What is a RACM? 

A Reasonably Available Control Measure (RACM) is defined by the USEPA as any 

potential control measure for application to point2

, area, onroad and nonroad emission 

source categories that meets the following criteria: 

 

1

 70 Fed. Reg. 71701 (November 29, 2005) 2

 RACM applies only to those point sources not already addressed as part of the Reasonably Available 

Control Technology (RACT) analysis. New Jersey finalized its RACT analysis for 8-hour ozone on 

August 1, 2007. As a part of the RACT analysis, the State plans to amend various subchapters of New 

Jersey Administrative Code, Title 7, Chapter 27 (N.J.A.C. 7:27) to implement RACT. The changes 

primarily impact Subchapter 16, “Control of Air Pollution by Volatile Organic Compounds,” and 

Subchapter 19, “Control and Prohibition of Air Pollution from Oxides of Nitrogen.” The State has 

committed to propose all ozone RACT rules by November 2007, and adopt by May 2008, subject to public 

comment and in accordance with the New Jersey Administrative Procedures Act (APA) (N.J.S.A. 52:14B-1 

et. seq.) and the Air Pollution Control Act (APCA) (N.J.S.A. 26:2C-1 et. seq.). 
7-2

• The control measure is technologically feasible 

• The control measure is economically feasible 

• The control measure does not cause “substantial widespread and long-term 

adverse impacts” 

• The control measure is not “absurd, unenforceable, or impracticable” 

• The control measure can advance the attainment date by at least one year 

Each of these criteria is more fully discussed in Section 7.2. 

The USEPA has documented guidance regarding completion of a RACM analysis. These 

guidance documents are listed in Table 7.1. 

Table 7.1: USEPA RACM Guidance Documents 

Guidance Document Title Description 

Federal Register/Vol. 44, No. 66/April 4, 

1979/General Preamble for Proposed Rulemaking 

 Guidance on the Need to Include All RACM in the 

SIP 

Federal Register/Vol. 57, No. 74/April 16, 

1992/Proposed Rules/General Preamble 

Guidance on What the USEPA Does Not Consider 

RACM 

EPA Memorandum, “Guidance on the RACM 

Requirement and Attainment Demonstration 

Submissions for Ozone Nonattainment Areas”, from 

John S. Seitz, EPA Director Office of Air Quality 

Planning and Standards to the EPA Regional Air 

Division Directors Regions I-IX, dated November, 

1999. 

Guidance on Justification for Not Including Measures 

in the SIP 

EPA Memorandum, “Additional Submission on 

RACM From States With Severe 1-hour Ozone 

Nonattainment Area SIPs”, from John S. Seitz, EPA 

Director office of Air Quality Planning and 

Standards and Marge Oge, EPA Director Office of 

Transportation and Air Quality to Regional Air 

Division Directors, Regions I, II, III, V and VI, 

December 14, 2000. 

Guidance on Justification for Not Including Measures 

in the SIP 

Federal Register/Vol. 66, No. 2/January 3, 

2001/Final Rule for Approval and Promulgation of 

Air Quality Implementation Plans; Connecticut; 

One-Hour Ozone Attainment Demonstration and 

Attainment Date Extension for the Greater 

Connecticut Ozone Nonattainment Area 

Guidance on Advancing the Attainment Date 

7.2 Methodology 

The 8-hour ozone RACM analysis involved a review of potential control measures for 

mobile (both onroad and nonroad), stationary area, and stationary/point (not already 

subject to ozone RACT requirements) emission source categories in order to document 

whether or not there are measures which would meet the reasonably available control 

 
7-3

measures criteria as defined in Section 7.1. The New Jersey Department of 

Transportation (NJDOT) conducted the RACM analysis for Transportation Control 

Measures (TCMs). In so much as VOC and NOx also contribute to the formation of 

PM2.5, any identified control measures from New Jersey’s ozone RACM analysis for 

these pollutants would also result in PM2.5 and regional haze benefits. As such, this 

ozone RACM analysis also serves as the PM2.5 RACM analysis for those precursors. 

The evaluation criteria used for the analysis are discussed in detail below: 

1. Technological Feasibility – This criterion is an evaluation of the following to 

determine feasibility of timely implementation: 

• Manufacturing processes, operating procedures, availability of raw materials and 

the physical layout of the plant (if applicable). Relevant technology must exist or 

be reasonably expected to exist within the schedule allotted, be sufficiently 

available, and be applied to achieve a stated result. 

• Other adverse environmental impacts such as water pollution, waste disposal 

issues, and energy requirements. 

• Technological changes to vehicles, fuels, necessary infrastructure and similar 

considerations (for transportation measures). 

2. Economic Feasibility – This criterion considers an evaluation of the following to 

determine feasibility of timely implementation: 

• The cost of reducing emissions (cost per ton of emission reduced), capital costs 

and operating costs. The costs associated with a measure must be justifiable 

relative to benefits, and compare favorably with other potential emissions control 

measures (of all types on all emissions sources). Operating costs include both 

direct or variable costs and indirect or fixed costs. 

• The NJDEP has determined the following about the economic feasibility of 

RACM measures3

: 

 Control measures with cost-effectiveness ratios below the local RACT 

amount4

 are presumptively feasible from an economic standpoint. 

 Control measures with cost-effectiveness ratios above the RACT level but 

below $5,000/ton (the San Joaquin and Houston-Galveston low-end cutoffs) 

are probably economically feasible. 

 

3

 “Economic Feasibility and Reasonably Available Control Measures (RACM)”. Internal NJDEP 

Communication prepared by the NJDEP Division of Science, Research, and Technology, August 3, 2006. 

4

 According to the NOx SIP Call (63 Fed. Reg. 57400 (10/27/98)), the RACT limit is $2,000/ton. The 

USEPA cutoff for de minimis exemption from RACT is $1,300/ton. 
7-4

 Control measures with ratios between $5,000/ton and $25,000 or $50,000/ton 

(the values cited by the Transportation Research Board (TRB) for Congestion 

Mitigation and Air Quality program (CMAQ)-funded TCMs) may be 

economically feasible but require further analysis. 

 Control measures with ratios above $25,000 or $50,000/ton are probably not

economically feasible. 

 In the absence of general rules, RACM feasibility decisions must continue to 

be made and justified on a case by case basis. 

3. Other local considerations including measures that do not cause “substantial 

widespread and long-term adverse impacts” and measures that are not “absurd, 

unenforceable, or impracticable” – These criteria will be evaluated based on the 

following to determine feasibility of implementation: 

• Considerations such as disruption of fuel supplies, discrimination among various 

population groups, critical reduction in mobility, and other similar concerns. 

• Must be legally enforceable, and legal under federal and state law. 

• Must be practical, realistic, and have a strong potential to achieve estimated 

emissions reductions. 

• Must be capable of being implemented and producing the anticipated emissions 

reductions in the required timeframe. This includes consideration of the schedule 

for planning, regulatory action, implementation and time to achieve the targeted 

results. 

4. Advancement of the Attainment Date – This criterion requires that selected 

measures advance the attainment date by at least one year. 

According to USEPA guidance,5

 areas that have an attainment date of no later than 

June 15, 2010 must implement the emission reductions needed for attainment no later 

than the beginning of the 2009 ozone season (June 2009). Otherwise the emission 

reductions will not affect the monitored ozone in 2009 which is the last ozone season 

before the attainment date of June 15, 2010. In order to advance the attainment date 

by one year, the potential RACM measures would have to achieve the emission 

reductions needed for attainment by June 2008.6

 

5

 USEPA. Guidance on the Use of Models and Other Related Analyses in Attainment Demonstrations for 

the 8-Hour Ozone NAAQS. United States Environmental Protection Agency, Office of Air Quality 

Planning and Standards, Emissions, Monitoring, and Analysis Division, Air Quality Modeling Group, 

Research Triangle Park, NC, EPA-454/R-05-002, October 2005. 

6

 In order to assess the level of emission reductions required to advance the attainment date for each area it 

was necessary to quantify the VOC and NOx reductions expected in the year prior to the attainment year. 
7-5

7.2.1 Potential Control Measure Evaluation for Non-Transportation Control 

Measures 

Step I - Identification of Potential Control Measures 

A list of 457 original potential non-transportation control measures (TCMs) was 

compiled through review of various sources, including Regional Planning Organizations 

(RPOs), other State Organizations, existing NJDEP documents, USEPA regions, and 

Early Action documents. 

The initial list of potential control measures was reviewed to eliminate any measures that 

did not address a top VOC or NOx emitting category in the 2002 inventory or in the 

regional inventory. However, measures that had the potential to achieve high emission 

reductions were not excluded, regardless of whether or not they addressed a top inventory 

category (either state or regional). The top 15 VOC and NOx emitting categories in the 

New Jersey 2002 Periodic Emission Inventory are included in Figures 7.1 and 7.2. 

Measures that are already in place in New Jersey or are more stringently addressed at the 

Federal level were also eliminated from the analysis at this time. 

Finally, measures whose potential emission reduction benefit was not quantifiable and 

measures that had no net emission reduction benefit in New Jersey were eliminated from 

the analysis. 

 

One year is used as the advancement time since ozone attainment is based on measurements taken during a 

5 month ozone season each year. 
7-6

Figure 7.1: 2002 New Jersey VOC Emission Inventory Top 15 by SCC

157.81

82.93

66.70

50.61

41.48

24.42

23.66

23.00

22.00

19.18

17.16

14.87

13.78

13.52

12.92

0 20 40 60 80 100 120 140 160 180

LIGH T D UT Y GA S VEH IC LE

COM M /CONSUM ER SOLVENT USE

LIGH T D UT Y GA SOLIN E T R UC K (<6K LB S.)

A R C H IT EC T UR A L SUR F A C E C OA T IN G

OUT B OA R D P LEA SUR E C R A F T - 2 ST R OKE, GA SOLIN E

P OR T A B LE F UEL C ON T A IN ER S

LIGH T D UT Y GA SOLIN E T R UC K (>6K LB S. <8.5K LB S.)

D EGR EA SIN G

IN D UST R IA L P R OC ESSES - P ET R OLEUM IN D UST R Y F LA R ES N OT C LA SSIF IED

P ER SON A L WA T ER C R A F T - 2 ST R OKE, GA SOLIN E

OT H ER SP EC IA L P UR P OSE C OA T IN GS

M ET A L C ON T A IN ER S SUR F A C E C OA T IN G

C OM M ER C IA L T R IM M ER S/ED GER S/B R USH C UT T ER - 2 ST R OKE, GA SOLIN E

B A LA N C ED SUB M ER GED F ILLIN G

IN D UST R IA L A D H ESIVES

Summer Tons per Day

 Area

 Point

 OnRoad

 NonRoad

04/26/06

Figure 7.2: 2002 New Jersey NOx Emission Inventory Top 15 by SCC

285.37

139.27

70.58

70.45

34.33

30.12

27.24

26.15

25.98

21.76

18.41

15.70

14.17

13.88

12.09

0.00 50.00 100.00 150.00 200.00 250.00 300.00

H EA VY D UT Y D IESEL VEH IC LES

LIGH T D UT Y GA S VEH IC LE

EXT ER N A L C OM B UST ION - ELEC T R IC

B OILER B IT UM IN OUS C OA L M ISC .

LIGH T D UT Y GA SOLIN E T R UC K (<6K LB S.)

H EA VY D UT Y GA SOLIN E VEH IC LE

C OM M ER C IA L M A R IN E

LIGH T D UT Y GA SOLIN E T R UC K (>6K LB S.

<8.5K LB S.)

EXT ER N A L C OM B UST ION - ELEC T R IC

B OILER P ULVER IZ ED B IT UM IN OUS C OA L

IN T ER N A L C OM B UST ION - ELEC T R IC

UT ILIT Y N A T UR A L GA S M ISC .

IN D UST R IA L F OR KLIF T S - LP G

EXT ER N A L C OM B UST ION - ELEC T R IC

B OILER N A T UR A L GA S M ISC .

LOC OM OT IVE

IN T ER N A L C OM B UST ION - ELEC T R IC

UT ILIT Y N A T UR A L GA S T UR B IN E

R UB B ER T IR E LOA D ER S - D IESEL

C R A WLER T R A C T OR /D OZ ER S - D IESEL

Summer tons per Day

 Point

 OnRoad

 NonRoad

04/26/06
7-7

All identical measures that remained in the analysis at this point were combined. 

There were 81 potential non-TCM control measures that advanced to the next phase of 

the analysis, as shown in Table F2.1 in Appendix F2. 

NJDEP Workgroup Efforts

The NJDEP organized the “Reducing Air Pollution Together Initiative”, which began at a 

public workshop on June 29, 2005. This workshop served to initiate a dialogue between 

the NJDEP and interested and affected parties about reducing emissions in order to 

improve air quality in New Jersey. Over 200 persons representing various industries, 

environmental and civic groups attended the initial workshop. 

At the workshop, six workgroups were formed to focus on key sources of emissions 

resulting in nonattainment of federal air quality standards and to recommend control 

strategies to reduce these emissions. 

The goals of each workgroup were to: 

 

• Identify strategies to achieve emission reductions 

• Prioritize reasonable and effective control measures 

• Identify implementation issues and potential solutions 

• Identify additional sources of data to enhance the state’s future emissions 

inventories 

Table 7.2 lists the six workgroups and their mission. 
7-8

Table 7.2: Reducing Air Pollution Together Initiative Workgroups 

Workgroup Workgroup Mission 

Diesel Initiatives (DI) To recommend potential ways to control and/or reduce emissions from 

diesel engines. Topics include vehicles (all categories – Light Duty Diesel 

Vehicles (LDDVs), Medium Duty Diesel Vehicles (MDDVs) and Heavy 

Duty Diesel Vehicles (HDDVs), nonroad equipment (e.g. construction 

equipment), commercial marine vessels (ships), locomotives and 

stationary diesel engines. Discussion topics include use of fuels that would 

reduce emissions, as well as retrofit technologies and idling strategies. 

Gasoline Cars and Trucks 

(C&T) 

To recommend potential ways to control and/or reduce emissions from 

gasoline-fueled motor vehicles and trucks (including SUVs and heavier 

trucks) and their use. This includes inspection and maintenance as well as 

transportation control measures. 

Homes and Restaurants (HR) To recommend potential ways to control and/or reduce emissions from the 

varied sources of combustion used by homeowners and restaurants. Topics 

include wood burning, space heating, energy efficiency, and emissions 

from restaurant operations. 

Non-Automobile Gasoline 

Engines (NA) 

To recommend potential ways to control and/or reduce emissions from 

gasoline engines other than those used in cars and trucks. Topics include 

engines used on outboard pleasure craft and in lawnmowers. 

Stationary Combustion 

Sources (SCS) 

To recommend potential ways to control and/or reduce emissions from 

facilities identified as stationary sources of combustion, including both 

Electric Generating Units (EGUs) and non-EGUs. The focus will be on 

NOx, SO2, VOC and particulate emissions. 

Volatile Organic Compounds 

from Processes and 

Consumer Products (VOC) 

To recommend potential ways to control and/or reduce VOC emissions 

from various chemical products and/or processes. Topics include all 

consumer products (from paints and deodorants to gas cans) as well as 

industrial processes. 

The workgroups met during the summer of 2005 and developed potential air emission 

control strategies. Reports containing their recommendations for further consideration 

were submitted to the NJDEP on October 31, 2005. A total of 250 potential control 

measures (See Table F2.2 in Appendix F2) were submitted to NJDEP. The members of 

the workgroup ranked the measures from highest to lowest potential. 

The workgroup process is discussed in further detail in Section 4 of this SIP document. 

White Paper Measures

After the workgroup reports were submitted, the 250 workgroup measures were further 

evaluated by NJDEP and ranked (High, Medium, Low, Not Ranked) so that every 

measure could be compared equally. Each workgroup state team worked with the 

NJDEP Air Quality Management Team to determine which of the workgroup 

recommended strategies should be further evaluated for possible inclusion in the SIP 

and/or implementation. The final list of measures to be further evaluated was provided to 

the workgroup members. Sixty draft white papers were developed by the NJDEP staff. 
7-9

The draft white papers were presented to the public at a workshop on May 17, 2006.7

 

The NJDEP accepted public comments on the white papers and updated the white papers, 

as appropriate. 

The 60 white papers were evaluated to identify additional potential control measures for 

the RACM analysis. After this evaluation, 21 white papers were added to the RACM 

analysis and were fully evaluated according to RACM criteria (3 of the 21 white papers 

overlapped with regional control measures and 3 overlapped with existing potential 

RACM measures). A total of 9 white paper control measures passed all of the RACM 

criteria. The 21 white paper measures that were added to the RACM analysis are 

included in Table 7.3 along with measures suggested by the Ozone Transport 

Commission (OTC). 

The remaining 39 white papers were not considered as part of the RACM analysis for one 

of the following reasons: the measure addressed in the white paper was subject to RACT, 

the white paper addressed a PM control measure, emission reduction benefits could not 

be quantified for the measure, or the white paper did not address one specific control 

measure. 

Ozone Transport Commission (OTC) Identified Measures

New Jersey worked with other states in the Ozone Transport Region to explore 

reasonable control measures for potentially significant reductions to attain the 8-hour 

ozone NAAQS and to achieve regional haze goals. The OTC staff and member states 

formed workgroups to: review stationary point and area source categories, electric 

generating units, and mobile sources; identify candidate emission units; and consider 

potential control strategies to reduce NOx, VOC and SO2 emissions. The workgroups 

were made up of staff from OTC member states. 

The NJDEP incorporated the OTC potential candidate measures into New Jersey’s 

RACM analysis. The OTC potential candidate measures were analyzed according to the 

RACM criteria discussed in Section 7.2. There were 4 OTC measures that fit the RACM 

criteria. Three of these measures overlapped with NJDEP white paper measures. 

Measures identified by the OTC regional effort, in addition to measures identified by 

NJDEP workgroup efforts that were added to the RACM analysis are included in Table 

7.3. 

 

7

 A complete list of white papers, as well as links to these white papers, can be found at 

http://www.nj.gov/dep/airworkgroups/docs/wp_summary_table_web.xls. 
7-10

Table 7.3: Measures Identified from NJDEP Workgroup and OTC Regional Efforts 

New Jersey 

Identifier 

Measure Name NJDEP White Paper Identifier/OTC 

Regional Measure Source 

Area 

2 Consumer Products OTC, VOC001 

3 Portable Fuel Containers OTC, VOC002 

4 Adhesives and Sealants (Industrial) OTC, VOC011 

5 Smoke Management Plan GEN001 

6 Vapor Recovery Systems at Gasoline Service Stations VOC003 

7 Architectural and Industrial Maintenance Coatings VOC010 

Onroad 

30 Diesel Engine Chip Reflash OTC 

31 Efficient Vehicle Purchase Incentives/Disincentives CT004 

32 Onroad Vehicle Idling DI001 

33 Early Retirement Program for Heavy Duty Diesel 

Vehicles 

DI009 

34 Opacity Cutpoint Revision DI011 

35 Light Duty Diesel Vehicle Inspection DI012 

36 Medium Duty Vehicle Inspection DI013 

46 Low Income Vehicle Repair Assistance Program 

(LIRAP) 

CT002 

Nonroad 

74 Nonroad Idling DI002 

75 Idling Reduction for Train Engines DI003 

76 Leveraging Airport Leases to Achieve Reductions 

from Ground Support Equipment 

DI006 

77 Increasing the Rate of Small Engine Turnovers and 

Portable Fuel Container Turnovers through the Use of 

Incentive-Based Initiatives 

NA002 (& NA006) 

78 Insure Proper Disposal of Fuel Samples After Daily 

Aircraft Pre-Flight Checks 

NA005 

79 Stage II Vapor Recovery Compatibility for Boat 

Fueling and Marina Gasoline Fueling Facilities 

NA007 

85 Providing Electric Power to Ships (Cold Ironing) at 

the Ports (Shoreside Power) 

DI004 

89 Graduated Registration Fees for Recreational Boats NA008 

Step II – RACM Criteria Analysis 

Technological Feasibility Analysis:

The 103 identified non-TCM measures (81 from the sources discussed in Section 7.2.1, 

21 from NJDEP white papers, and 1 OTC measure) were analyzed according to the 

RACM criterion discussed in Section 7.2 for technological feasibility. A total of 85 

measures passed the technological feasibility criterion. Table F2.1 in Appendix F2 

includes a list of all measures considered and the reasons that they passed or failed each 

RACM criterion. If sufficient information was not available for a technological 

feasibility determination to be made for a measure, the measure was evaluated for the 

remaining criteria, and a “N/A” determination was made for technological feasibility. 
7-11

Only measures that passed the technological feasibility evaluation (or were N/A) moved 

on to the economic feasibility determination. 

Economic Feasibility Analysis and Other Local Considerations:

The remaining 85 measures were analyzed according to the RACM criteria outlined in 

Section 7.2 for economic feasibility and other local considerations. Local considerations 

are those measures that do not cause “substantial widespread and long-term adverse 

impact” and measures that are not “absurd, unenforceable, and impracticable”. The 

analysis for these criteria was done simultaneously on all 85 measures. There were 27 

measures eliminated solely because they could not be implemented by June 2008 (in 

order to advance the attainment date by one year, the potential RACM measures would 

have to achieve the emission reductions needed for attainment by June 2008). These 

measures will be further evaluated and considered by New Jersey for possible 

implementation in the future. A total of 17 viable measures listed in Table 7.4 advanced 

to the final stage of the analysis. Table F2.5 in Appendix F2 lists the determinations for 

each RACM criterion for all 103 identified measures. 

Table 7.4: List of 17 Potential Non-TCM RACMs 

Identifier Measure Name 

Area 

2 Consumer Products 

3 Portable Fuel Containers 

4 Adhesives and Sealants (Industrial) 

5 Smoke Management Plan 

18 Degreasing Controls 

20 Tehama County: TCAPCD Rule 4.22: Industrial Use of Organic Solvents 

25 Emission Reductions from Composting 

26 Reformulation of Aerosol Coatings to CARB Tier 2 Standards 

Onroad 

32 Onroad Vehicle Idling 

34 Opacity Cutpoint Revision 

36 Medium Duty Vehicle Inspection 

63 Technology to Identify Smoking Vehicles 

Nonroad 

74 Nonroad Idling 

75 Idling Reduction for Train Engines 

78 Insure Proper Disposal of Fuel Samples After Daily Aircraft Pre-Flight Checks 

89 Graduated Registration Fees for Recreational Boats 

97 Auxiliary Power Units (APUs) for Locomotives 
7-12

7.2.2 NJDOT Potential Control Measure Analysis for Transportation Control 

Measures and Other Onroad Mobile Measures 

Transportation Control Measures (TCMs) are transportation strategies specific to onroad 

mobile sources, which reduce emissions by reducing the number and/or length of vehicle 

trips and/or improve traffic flow. After the passage of the Clean Air Act Amendments of 

1990, New Jersey made a full-scale commitment to TCMs.8

 The State’s transportation 

capital program continues to stress transit projects, system preservation, and systems 

management over the provision of new highway capacity. The NJDOT has continued to 

commit to the support and implementation of air quality-friendly transportation projects 

and programs. 

Step I – Evaluation Criteria for Potential Transportation Control Measures 

The TCMs considered for this RACM evaluation were identified by NJDOT in 

consultation with the NJDEP. Detailed summaries of each of the 26 measures identified 

by NJDOT (including TCMs and onroad mobile measures) are located in Appendix F1. 

Two of the 26 measures were combined with similar measures that were identified during 

the pre-screening analysis discussed in Section 7.2.1 and were eliminated from the 

analysis. 

Step II – Identification of Potential Transportation Control Measures 

The 26 TCMs and onroad mobile measures were evaluated based on the criteria outlined 

in Section 7.2. These criteria include technological and economic feasibility, other local 

considerations (measures that do not cause “substantial widespread and long-term 

adverse impact” and measures that are not “absurd, unenforceable, and impracticable”), 

and advancement of the attainment date. Emissions reductions must be sufficient to 

advance the attainment date in each 8-hour ozone nonattainment area from 2010 to 2009 

(meaning reductions by summer 2008 instead of 2009). 

The NJDOT performed a political feasibility analysis on the 26 measures and ranked the 

measures as “high”, “medium”, or “low”. The political feasibility analysis is included in 

Appendix F3. The NJDEP evaluated the rationale for measures that were ranked 

“medium” or “low” for political feasibility by NJDOT against the RACM criteria 

described in Section 7.2. The results of this analysis are included in table F2.5 in 

Appendix F2. There were 11 measures that were ranked “high” for political feasibility 

by NJDOT. The 11 measures advanced to the final stage of the RACM analysis. These 

measures are included in Table 7.5. 

 

8

 The State included 134 TCMs in the original 15% Rate of Progress SIP in 1993. While New Jersey has 

since opted not to include TCMs in the SIP, the New Jersey Department of Transportation (NJDOT) has 

continued to commit to the support and implementation of air quality friendly transportation projects and 

programs. 
7-13

Table 7.5: Potential Transportation Control Measures (TCMs) 

Identifier Measure Name Description 

 

Onroad 

DOT8 Truck Idling Restrictions Truck idling restrictions will be implemented 

statewide. It is assumed, in an effort to avoid 

fines and other negative repercussions resulting 

from continued idling, both fleet and individual 

truck owners will invest in idling reduction 

technology (auxiliary power units, diesel driven 

heating systems and automatic shut-down/startup systems). 

DOT9 Impact of Various Transit Projects Encourage the use of transit through the 

completion of significant fixed guideway/rail 

projects 

DOT11 Adoption of Smart Growth Land Use Policies Analysis of compact development in the NYNJ-CT Region 

DOT13 Clean Fleets Replacements 100 9 year old vehicles replaced with 100 

hybrid vehicles in each county 

DOT16 School Bus Replacements Twenty percent (4,246) of all Model Year 2002 

and older school buses are replaced by Model 

year 2007 diesel buses 

DOT17 IdleAire Installations A total of 210 parking spaces at truck stops 

would be equipped with IdleAire technology 

statewide. 

DOT18 Transit Bus Replacements All Model Year 2002 and older transit buses 

are replaced by Model Year 2007 diesel buses 

DOT20 School Bus Retrofit All Model Year 1992-2002 school buses will 

utilize retrofit technology 

DOT22 Commercial Vehicle Information Systems and 

Networks (CVISN). 

Analyzed as the adoption of high-speed weigh 

in motion devices to replace off-line weigh 

stations 

DOT23 Implementation of Express E-Z Pass Toll 

Collection 

Analysis includes the impacts of adding high 

speed, no toll booth EZ-Pass lanes to the 

Union, Essex and Barnaget toll plazas 

Nonroad 

DOT3 Retrofit Construction Equipment Assume 10% of total inventory of equipment 

will be used on state contracted projects and 

that 20% of those vehicles must use a 

combination of ULSD and retrofit technology 
7-14

7.3 Potential Measures Identified 

A total of 28 measures (11 TCM and 17 Non-TCM) passed the technological feasibility, 

economic feasibility, and “other local considerations” RACM criteria (as shown in Figure 

7.3) 

Figure 7.3: Identification of Potential Control Measures

81 Measures

Pass Pre-Screening

and Advance to

RACM Analysis

457 Non-TCM Measures

21 White Paper Measures

Advance to

RACM Analysis

60 White Paper Measures

Discuss Strategies

for Possible

SIP Inclusion

250 Workgroup Measures

3 OTC Measures

Overlap with White Paper Measures

(One additional Measure

Advances to RACM Analysis)

4 OTC Measures

11 TCMs

Pass technological, economic,

other local considerations

criteria

26 TCMs

New Jersey specific potential emission reductions were estimated for the 28 measures. 

The potential New Jersey specific emission reduction benefits for the area source 

measures were estimated by using population ratios. Population data for the year 2002 

was obtained online from the U.S. Census Bureau.9

 Daily Vehicle Miles Traveled 

(DVMT) was used to allocate the New Jersey specific emission reduction benefit for the 

onroad mobile measures. The DVMT data was obtained from the Federal Highway 

Administration10 and the New Jersey 2002 Periodic Emission Inventory.11 

 

9

 United States Census Bureau (http://www.census.gov). 

10 US Department of Transportation Federal Highway Administration – “Selected Measures for Identifying 

Peer States” (http://www.fhwa.dot.gov/policy/ohim/hs02/ps1.htm). 

103 Non-TCM Measures

Advance to RACM 

Analysis 

17 Non-TCM Measures

Pass technological, 

economic, other local 

considerations criteria 
7-15

The measures were then ranked by potential statewide VOC reductions and NOx

reductions (see Table F2.3 and F2.4 in Appendix F2). It is unlikely that control measures 

that provide emission benefits of less than one ton per day would be significant enough, 

alone or in aggregate, to advance the attainment date.12 Therefore, only control measures 

that provide emission benefits greater than one ton per day are considered for this 

analysis. There were four measures that had a potential VOC reduction greater than 1 

tpd. There were also four measures that had a potential NOx reduction 1 tpd or greater. 

These measures are listed in Tables 7.6 and 7.7. A potential ozone benefit was also 

allocated for each of the measures. The ozone benefit was estimated as a simple sum of 

VOC and NOx benefits. 

Table 7.6: Potential RACMs Ranked by Potential VOC Reduction (Top 4) 

Rank* Identifier Measure Name NJ Statewide Potential 

VOC Reduction (tpd) 

1 4 Adhesives and 

Sealants (Industrial)** 

9.2 

2 26 Reformulation of 

Aerosol Coatings to 

CARB Tier 2 Standards 

5.9 

3 2 Consumer Products** 1.4 

4 18 Degreasing Controls 1.1 

Total Potential VOC Reduction 17.6 

Table 7.7: Potential RACMs Ranked by Potential NOx Reduction (Top 4) 

Rank* Identifier Measure Name NJ Statewide Potential 

NOx Reduction (tpd) 

1 DOT8 Truck idling restrictions 1.6 

2 DOT17 IdleAire Installations 1.5 

3 DOT11 Adoption of Smart 

Growth Land Use 

Policies 

1.0 

4 DOT22 Commercial Vehicle 

Information Systems 

and Networks (CVISN). 

1.0 

Total Potential NOx Reduction 5.1 

*Based on potential emission benefits 

**New Jersey is in the process of proposing these measures 

 11 NJDEP. State Implementation Plan (SIP) Revisions for the Attainment and Maintenance of the 8-Hour 

Carbon Monoxide National Ambient Air Quality Standard, 1-Hour Ozone National Ambient Air Quality 

Standard, and Fine Particulate Matter National Ambient Air Quality Standard; and the 2002 Periodic 

Emission Inventory, Appendix D, Attachment 13. New Jersey Department of Environmental Protection, 

May 2006. 

12 NJDEP. State Implementation Plan (SIP) Revision for the Attainment and Maintenance of the 1-Hour 

Ozone National Ambient Air Quality Standard. Update to Meeting the Requirements of the Alternative 

Ozone Attainment Demonstration Policy: Additional Emission Reductions, Reasonably Available Control 

Measure Analysis, and Mid-Course Review. Appendix III: Reasonably Available Control Measures 

Analysis. New Jersey Department of Environmental Protection, September 12, 2001. 
7-16

7.4 Advancement of the Attainment Date

The 28 TCMs and Non-TCMs that passed all previously discussed (technological, 

economic, social, legal) RACM criteria were analyzed to determine whether or not they 

had the potential to advance the attainment date. As stated in Section 7.2, in order to 

advance the attainment date in each 8-hour ozone nonattainment area from 2010 to 2009, 

the measures would have to, alone or collectively, achieve reduction benefits by June 

2008 instead of June 2009. Although the 8 measures that pass the previously discussed 

RACM criteria have a potential reduction benefit of 15.5 tpd for the Northern New 

Jersey/New York/Connecticut nonattainment area and 7.4 tpd for the Southern New 

Jersey/Philadelphia nonattainment area, the measures do not show these benefits by June 

2008. Table 7.8 includes a summary of the estimated potential 2009 benefits of the 

measures for each nonattainment area. 

Table 7.8: Summary of the Potential RACMs 

 Estimated 2009 Benefits (VOC tpd + NOx tpd 

Combined) 

New Jersey Identifier Measure Name NNJ/NY/CT NAA SNJ/Phila. NAA 

4 Adhesives and Sealants 

(Industrial) 

6.1 2.9 

26 Reformulation of 

Aerosol Coatings to 

CARB Tier 2 Standards 

3.9 1.8 

2 Consumer Products 0.9 0.4 

DOT11 Adoption of Smart 

Growth Land Use 

Policies 

1.1 0.6 

DOT8 Truck idling restrictions 1.1 0.5 

DOT17 IdleAire Installations 1.0 0.5 

DOT22 Commercial Vehicle 

Information Systems 

and Networks (CVISN). 

0.7 0.4 

18 Degreasing Controls 0.7 0.3 

Total Benefit 15.5 7.4 

7.5 RACM Conclusion 

The State has reviewed all of the potential control measures to determine if they could 

meet the RACM criteria discussed in Section 7.2. Several measures are available that can 

provide moderate levels of emission reductions, however, none of these measures can 

provide benefits by the 2008 ozone season. Therefore, none of the potential control 

measures can be considered to be RACM and it is unnecessary to include any of these 

measures in the State’s attainment plan.