Technical Support Document 

for New Jersey’s Regional Haze State Implementation Plan

Air Programs Branch, EPA Region 2

July 2011

INTRODUCTION

Three Technical Support Documents

Technical Support Documents (TSD) describe EPA’s supporting documentation for its proposed 

approval of New Jersey’s Regional Haze State Implementation Plan (SIP), and provide more 

detailed evaluations of the SIP submitted by New Jersey. In addition, EPA should propose 

approval of New Jersey’s sulfur in fuel regulation, which, by reducing sulfur emissions, has the 

multiple purpose of improving visibility and reducing particulate matter. 

There are three Technical Support Documents that evaluate New Jersey’s Regional Haze SIP. 

First, this document evaluates the approvability of the SIP overall, focusing on the reasonable 

progress portion of the SIP. A second document, attached, evaluates New Jersey’s application of 

Best Available Retrofit Technologies. A third document, also attached, evaluates New Jersey’s

development and use of emission inventories.

Overview of New Jersey’s State Implementation Plan

New Jersey’s SIP includes emission controls measures that will reduce pollutants that impair the 

view at certain National Parks and wilderness areas, particularly the Brigantine Wilderness Area 

of the Edwin B. Forsythe National Wildlife Refuge, located in coastal New Jersey. New Jersey

adopted some of these controls specifically as part of its Regional Haze SIP. There are other 

controls listed in the SIP that were recently adopted (separately from this SIP) or were already 

existing; those also reduce haze. This portion of the TSD evaluates how well those emission 

measures reduce impairments to visibility at Brigantine and other areas. Additional documents 

evaluate the emission inventories New Jersey used and the emission controls on sources eligible 

for control using Best Available Retrofit Technologies (BART). 

Material Submitted by New Jersey

New Jersey’s Department of Environmental Protection (DEP) prepared the Regional Haze SIP, 

which the Commissioner submitted for the State of New Jersey. The main submittal was on July

28, 2009, containing the main document and Appendices A through O. The submittal was 

automatically declared complete six months after New Jersey’s submittal date. New Jersey

submitted additional information about BART sources on March 2, 2011; and its sulfur in fuel 

rule was adopted on September 20, 2010 and submitted to EPA on December 9, 2010. 
2

Background Information on the Nature of Regional Haze

Regional haze is visibility impairment that is produced by a multitude of sources and activities 

which are located across a broad geographic area and emit fine particles (PM2.5) (e.g., sulfates, 

nitrates, organic carbon, elemental carbon, and soil dust) and their precursors (e.g., sulfur oxides

(SOx), nitrogen oxides (NOx), and in some cases, ammonia (NH3) and volatile organic 

compounds (VOC)). Fine particle precursors react in the atmosphere to form fine particulate 

matter which impairs visibility by scattering and absorbing light. Visibility impairment reduces 

the clarity, color, and visible distance that one can see. PM2.5 can also cause serious health 

effects and mortality in humans and contributes to environmental effects such as acid deposition 

and eutrophication. 

The average visual range1in many Class I areas (i.e., national parks and memorial parks, 

wilderness areas, and international parks meeting certain size criteria) in the eastern United 

States, is less than 30 kilometers or about one-fifth of the visual range that would exist under 

estimated natural conditions (64 FR 35714, July 1, 1999). In section 169A of the 1977 

Amendments to the Clean Air Act (CAA), Congress created a program for protecting visibility in 

the nation’s national parks and wilderness areas. This section of the CAA establishes as a 

national goal the “prevention of any future, and the remedying of any existing, impairment of 

visibility in mandatory Class I Federal areas2 which impairment results from manmade air 

pollution.” On December 2, 1980, the Environmental Protection Agency (EPA) promulgated 

regulations to address visibility impairment in Class I areas that is “reasonably attributable” to a 

single source or small group of sources, i.e., “reasonably attributable visibility impairment” (45 

FR 80084). These regulations represented the first phase in addressing visibility impairment. 

The requirement to submit a regional haze SIP applies to all 50 states, the District of Columbia, 

and the Virgin Islands.3 Section 51.308(b) required states to submit the first implementation plan 

addressing regional haze visibility impairment no later than December 17, 2007. Regional haze 

SIPs must assure reasonable progress towards the national goal of achieving natural visibility

conditions in Class I areas. Section 169A of the CAA and EPA’s implementing regulations 

require states to establish long-term strategies for making reasonable progress toward meeting 

this goal. Implementation plans must also give specific attention to certain stationary sources 

that were in existence on August 7, 1977, but were not in operation before August 7, 1962, and 

require these sources, where appropriate, to install Best Available Retrofit Technology (BART) 

controls for the purpose of eliminating or reducing visibility impairment. 

 

1Visual range is the greatest distance, in kilometers or miles, at which a dark object can be viewed against the sky.

2Areas designated as mandatory Class I Federal areas consist of national parks exceeding 6000 acres, wilderness 

areas and national memorial parks exceeding 5000 acres, and all international parks that were in existence on 

August 7, 1977. 42 U.S.C. 7472(a). In accordance with section 169A of the CAA, EPA, in consultation with the 

Department of Interior, promulgated a list of 156 areas where visibility is identified as an important value (44 FR 

69122, November 30, 1979). The extent of a mandatory Class I area includes subsequent changes in boundaries, 

such as park expansions. 42 U.S.C. 7472(a). Although states and tribes may designate as Class I additional areas 

which they consider to have visibility as an important value, the requirements of the visibility program set forth in 

section 169A of the CAA apply only to ‘‘mandatory Class I Federal areas.” Each mandatory Class I Federal area is 

the responsibility of a ‘‘Federal Land Manager.’’ 42 U.S.C. 7602(i). When we use the term “Class I area” in this 

action, we mean a “mandatory Class I Federal area.”

3Albuquerque/Bernalillo County in New Mexico must also submit a regional haze SIP to completely satisfy the 

requirements of section 110(a)(2)(D) of the CAA for the entire State of New Mexico under the New Mexico Air 

Quality Control Act (section 74-2-4).
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STATE’S SUBMITTAL

The SIP revision addresses regional haze for the first implementation period. New Jersey has a

Class I areas within its borders, the Brigantine National Wildlife Refuge Class I area, and so is 

responsible for calculation of baseline and natural visibility conditions, establishment of 

reasonable progress goals, monitoring requirements, and meeting RAVI requirements. Also, 

New Jersey is responsible for developing a regional haze SIP that addresses this Class I area, that 

describes its long-term emission strategy, its role in the consultation processes, and how the SIP 

meets the other requirements in EPA’s regional haze regulations. 

Measures Adopted to Address Long-Term Strategy 

The LTS is a compilation of state-specific control measures relied on by the state to obtain its 

share of emission reductions to support the RPGs established by New Jersey and other Class I 

states. New Jersey’s LTS for the first implementation period addresses the emissions reductions 

from federal, state, and local controls that take effect in the State from the baseline period 

starting in 2002 until 2018. 

The LTS was developed by New Jersey in coordination with other states working together as the 

Mid-Atlantic NorthEast Visibility Union (MANE-VU), as they identified emission controls that 

were reasonable and addressed the goal of meeting the RPG for the Brigantine National Wildlife 

Refuge Class I area. 

On June 20, 2007, the MANE-VU states agreed to adopt emission control strategies that MANEVU modeled to determine the amount of progress that the MANE-VU states would make toward 

improving visibility by the end of the first control period, ending in 2018. 

By adopting all the measures identified in the MANE-VU analysis and applying BART to 

eligible sources, New Jersey’s LTS achieves its share of emissions reductions that are reasonable 

and which modeling shows will achieve the reasonable progress goals for the Brigantine 

National Wildlife Refuge Class I area. The following chart compares measures adopted by New 

Jersey with the measures agreed to by the MANE-VU states (often referred to as the MANE-VU 

‘ask’). 
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MANE-VU Measures Measures Adopted or Action Taken by New Jersey

Timely implementation of BART on 

all sources identified as BART –

eligible

Implementing BART on all eligible sources, except those that 

have emission limits less than the 250 tons per year BART 

eligibility thresholds in their permits.

Low sulfur fuel oil strategy: for NJ 

distillate oil to 0.05% sulfur by 2012 

and to 15ppm by 2016, #4 residual oil 

to 0.25% sulfur no later than 2012, #6 

residual oil to 0.3 to 0.5% by 2012 

No. 2 & lighter: 0.05 percent by 2014; 0.0015 percent (15 ppm) 

by 2016

No. 4: 0.25 percent by 2014

No. 5, No. 6 & heavier: 0.5 percent by 2014

All lower sulfur targets met well before 2018.

90% or more reduction in SO2 

emissions from 167 stacks or 

alternative measures

90% or greater reductions of sulfur emissions at the four stacks 

located in New Jersey at: BL England, PSEG (2) - Hudson, and 

PSEG – Mercer. Plus nearly 90% reduction of other pollutants 

responsible for haze.

Continued evaluation of other 

measures, including energy efficiency, 

alternative clean fuels, reduce SO2 

and NOx from coal units by 2018 and 

NSPS for wood combustion if 

reasonable and cost-effective

Energy Master Plan and Greenhouse Gas Plan

Smoke Management Plan and Construction Activities

Residential Wood Burning Strategies

Measures to Reduce Organic Carbon Emissions

These measures were agreed-to by MANE-VU states and tribes on June 20, 2007.

New Jersey Adoption of Measures

• BART Controls 

A more detailed review of New Jersey’s implementation of BART is found in the companion 

Technical Support Document: Review of Application of Best Available Retrofit Technology in 

New Jersey’s Regional Haze State Implementation Plan, July 29, 2011, which is attached to this 

TSD.

In summary, New Jersey initially identified eleven sources that could be subject to BART (letter 

to EPA, September 8, 2005). Of these, the five sources listed in EPA’s Notice of Proposed 

Rulemaking were determined to be potentially subject to BART controls. From the five sources, 

two had - or are in the process of taking - permit limits that reduce their BART-eligible 

emissions to less than the 250 ton per year BART eligibility limit. New Jersey evaluated three 

sources for controls under the BART rules. 

EPA, in a separate review, found two sources that might meet BART-eligibility requirements. 

New Jersey had not evaluated these two sources, since they were to be shutdown or controlled 

under other programs. One source had additional controls under New Jersey’s EGU strategy

described in Section 9-2 of New Jersey’s SIP. As described in companion Technical Support 

Document on BART, New Jersey has since evaluated these two sources with respect to BART 

controls and is documenting the appropriate level of control for these two sources in permit 

modifications to be submitted to EPA. 
5

While BART controls were included in the modeling that forecasted visibility in the reasonable 

progress goal year of 2018, emission reductions due to New Jersey’s BART controls were not 

included in the 2018 modeling. (See Figure 5-3 in MANE-VU Modeling for Reasonable 

Progress Goals, submitted by New Jersey as Appendix N-2 in its SIP and at 

http://www.nescaum.org/documents/modeling-for-reasonable-progress-final-021208.pdf.) Thus, 

emission reductions from New Jersey’s application of BART will result in additional 

improvements in visibility beyond that predicted by the modeling and will provide additional 

likelihood that the Brigantine Class I area will meet or exceed the Progress Goal for 2018. 

• Electric Generating Units 

New Jersey is home to four of the 167 EGU stacks identified in the setting of the 2018 

reasonable progress goals for Brigantine and five other Class I areas in MANE-VU. New Jersey

has addressed emissions from these stacks through Advanced Consent Orders or Consent 

Decrees that require all four facilities to meet performance standards for sulfur, nitrogen and 

particulate emissions. 

EPA proposed that states could use their involvement under the Clean Air Interstate Rule to 

fulfill their commitment to implementing controls on EGUs. However, New Jersey chose to 

implement control on each of its EGUs, outside of EPA’s CAIR. Thus the court remand of 

CAIR, and EPA’s development of an improved transport rule to replace CAIR, does not affect 

the amount of control that New Jersey implemented on its sources and has no negative impact on 

New Jersey’s efforts to meet the visibility Progress Goals. 

The four EGU stacks are located in the following facilities: BL England, PSEG - Hudson, and 

PSEG – Mercer. These facilities all have coal-fired EGU boilers. The BL England facility is 

under an Administrative Consent Order (ACO) [New Jersey Department of Environmental 

Protection Administrative Consent Order (ACO) NEA 040002-73001, effective January 24, 

2006] to meet performance standards for SO2, NOx, and PM. The Hudson and Mercer facilities 

are under a Consent Decree to also meet performance standards for SO2, NOx and PM 

[http://www.epa.gov/compliance/resources/decrees/amended/psegfossil-amended-cd.pdf]

These orders/decrees will require more than a 90 % SO2 emission reduction by 12/15/2012, in 

addition to about 90% reduction of NOx and PM. New Jersey has also adopted a mercury rule 

that sets performance standards for coal-fired boilers, for companies which choose the multipollutant strategy in that rule. The four of the167 EGU stacks located in New Jersey are 

committed to multi-pollutant controls, as part of their mercury rule compliance plan. For the 

other electric generating units not specifically identified, New Jersey adopted new rules (April 

20, 2009 New Jersey Register) to implement a multi-pollutant control strategy to reduce 

allowable NOx, SO2, and particulate emissions from all coal-fired boilers. Details regarding this 

rule proposal are available at NJDEP’s website, http://www.state.nj.us/dep/aqm/index.html. 

• Sulfur in Fuel Oil - Proposed Approval of Subchapter 9 – Sulfur in Fuels

NJDEP proposed revisions to Subchapter 9 on November 16, 2009 at 41 N.J.R. 4156(a) which 

established a comment period running until January 15, 2010. A public hearing was held on 
6

January 5, 2010. The public comment period was extended to March 15, 2010 and New Jersey

held an informal stakeholder meeting on March 8, 2010. New Jersey evaluated all the comments 

received throughout this period and adopted the revisions on September 20, 2010 at 42 N.J.R. 

2244 with an operative date of October 25, 2010. New Jersey’s responses to the public 

comments and stakeholder recommendations are posted at 

http://www.nj.gov/dep/aqm/1997adop.html under ‘Sulfur in Fuels’.

New Jersey proposed these amendments to help the State attain and maintain the Federal healthbased National Ambient Air Quality Standards (NAAQS) for fine particles (particles smaller 

than 2.5 microns in diameter (PM2.5)), SO2 and ozone, and to reduce haze in New Jersey and the

region. The rulemaking is part of a regional effort to reduce regional haze and fine particles 

through the implementation of a low sulfur fuel strategy. New Jersey committed to propose this 

course of action as a member of MANE-VU.

New Jersey included the MANE-VU states’ long term strategy for reducing the sulfur content in 

fuel in the 1997 fine Particulate Matter (PM2.5) SIP that was submitted to EPA on April 1, 2009. 

New Jersey had specifically noted that NJDEP planned to propose to amend NJAC 7:27-9, 

Sulfur in Fuels, specifically section 9.2, anticipating lowering the maximum allowable sulfur 

content in fuel and the maximum allowable SO2 emissions from fuel combustion in order to 

reduce the emissions of SO2 and other pollutants from the combustion of fuel in New Jersey. 

Under the MANE-VU agreement on the proposed standards, phase one establishes limits of 0.05 

percent sulfur by weight (500 ppm) for distillate oil (No. 2 and lighter); 0.25 percent sulfur by

weight (2,500 ppm) for No. 4 residual oil; and between 0.3 and 0.5 percent sulfur by weight 

(3,000 to 5,000 ppm) for No. 6 residual oil. Under the MANE-VU strategy, these standards are 

to go into effect no later than 2012. New Jersey proposed additional time, until July 1, 2014, to 

achieve these standards to ensure sufficient time for production and distribution of lower sulfur 

fuel oil.

In addition, the MANE-VU strategy provides for a phase two reduction by 2016 for distillate oil 

(No. 2 and lighter) to 15 ppm. The proposed new standards for maximum allowable SO2 

emissions at N.J.A.C. 7:27-9.2 Table 2B represent, as do the existing standards, the emissions 

level for each grade of fuel oil under combustion scenarios without add-on SO2 air pollution 

control equipment.

The amendments to N.J.A.C. 7:27-9.2 include the addition of Tables 1B and 2B, which contain 

the new maximum allowable sulfur-in-fuel and maximum allowable SO2 emission standards, 

effective July 1, 2014 and July 1, 2016. The new standards at Table 1B are given in parts per

million by weight (ppm), rather than percent sulfur by weight, as the existing standards are

described. In addition, the existing standards in Table 1 have been converted to equivalents in 

parts per million (now Table 1A) for greater ease in comparing the existing standards to the new 

standards in effect in 2014 and 2016. For sources that chose to control their emissions by use of 

control equipment, Table 2B contains the new maximum allowable sulfur dioxide emissions that 

are release to the atmosphere in pounds per million BTU.
7

These new standards in Tables 1B and 2B are consistent with the MANE-VU emission 

management strategy for new standards for maximum allowable sulfur in fuel, which would 

reduce sulfur content in the inner zone states (including New Jersey).

New Jersey has repealed section 9.5 which allowed the limited use of higher content sulfur fuel 

for units that were converting to coal. This provision was counter to the new sulfur standards. 

New Jersey included a “sell-through” provision, which allows the storage, sale, distribution, 

delivery or use of newly-noncompliant fuel that is already in tanks in New Jersey as of July 1, 

2014 and July 1, 2016.

It should be noted that EPA’s current SIP approved version of Subchapter 9 has a condition that 

sulfur dioxide “bubble” permits issued by the State pursuant to section 9.2 and not waived under 

the provisions of section 9.4 become applicable parts of the SIP only after receiving EPA 

approval as a SIP revision. See 7/8/83, 48 FR 31400. This is necessary because detailed air 

quality simulation modeling involves many factors that can impact the results, such as, source 

location, stack height, distance between stacks and local topography and EPA review is required 

to insure replicable results. This provision has not changed in the latest revision and EPA is 

continuing its previous finding as it appears in 40 CFR 52.1605, under Subchapter 9 in the 

comment column. 

New Jersey asked for a longer period of time than agreed to in the MANE-VU ‘ask’ to 

implement these rules that reduce sulfur in fuels. EPA notes that New Jersey has provided a 

reasonable justification for the new effective dates and that they will be in place well before the 

end of the first planning period in 2018. 

With the limitation that sulfur dioxide bubbles must continue to be approved on a case-by-case 

basis as SIP revisions, EPA is proposing to approve the revisions to Subchapter 9 as part of the 

Regional Haze SIP and the PM2.5 SIP. 

• Additional Measures 

The following additional measures also are part of New Jersey’s Regional Haze Plan, but were 

not adopted specifically for the Plan. The following summaries are excerpted from New Jersey’s 

Regional Haze Plan, July 2009:

• Energy Master Plan and Greenhouse Gas Plan 

New Jersey developed an Energy Master Plan2 (EMP) to address New Jersey’s electricity and 

heating challenges. The draft plan was released on April 17, 2008, and finalized on October 22, 

2008. One component of the Energy Master Plan addresses ways to increase energy efficiency in 

the State. New Jersey is also developing a Greenhouse Gas Reduction Plan pursuant to the 

Global Warming Response Act. Measures which will be implemented as a result of these plans 

will reduce multiple air contaminants and improve visibility. 

• Smoke Management Plan and Construction Activities 

Since New Jersey is home to the federally protected visibility area, the Brigantine Wilderness 

Area, New Jersey is required by the USEPA rules to: Develop and implement a smoke 

management plan and address emissions from construction activities.
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New Jersey addresses smoke management through its Open Burning rules at N.J.A.C. 7:27-2. 

New Jersey addresses “fugitive dust” emissions from construction activities through its “Soil 

Erosion and Sediment Control Standards: Standards for Dust Control.” The USEPA has 

promulgated several regulations which limit exhaust emissions from non-road vehicles, such as 

those used at construction sites. In addition, New Jersey has existing rules to limit the idling of 

vehicles and equipment. New Jersey will consider additional mitigating measures for 

construction activities on a case-by-case basis depending on the size and nature of the 

construction work, and the review of the potential emissions on the property in relation to any

potential off-site impacts. New Jersey is considering amendments to its Open Burning Rule. 

• Residential Wood Burning Strategies 

Residential wood burning from woodstoves and fireplaces is one of the largest sources of direct 

fine particulate matter, PM2.5, emissions in New Jersey. New Jersey is considering strategies to 

reduce the emissions of wood smoke. Implementation of these strategies will reduce fine particle 

emissions and improve visibility. One strategy under consideration is a Home Wood Heating 

Advisory Program, similar to those in Oregon and Washington states. In general, these programs 

request wood burning be limited during times when unhealthy air quality is forecast or 

monitored. Other control measures under investigation include woodstove and fireplace changeout programs. 

• Measures to Reduce Organic Carbon Emissions 

Even though the focus of the Reasonable Progress Goal is to reduce emissions of sulfur dioxide, 

the largest contributor to regional haze, for the 2018 reasonable progress plan, New Jersey is 

taking actions to reduce emissions of organic carbon, the second largest contributor to visibility

impairment at Brigantine Wilderness Area. Some of New Jersey’s existing and proposed rules 

which reduce emissions from organic carbon include: 

• Existing Diesel Idling Rule

N.J.A.C 7:27-14.3 removes or further limits the exemptions to the State’s idling restrictions, 

removes sleeper berth exemption from vehicles effective May 1, 2010, and includes additional 

idling restrictions for gasoline vehicles.

• Existing Open Burning Rule

N.J.A.C 7:27-2 limits open burning.

• Existing Industrial, Commercial and Institutional (ICI) Boilers 

N.J.A.C. 7:27-16.8, -19.7 sets performance standards for NOx, CO and VOC which ensure good 

combustion, and requires annual tune ups to reduce NOx emission and may also help reduce fuel 

consumption. 

• Existing Heavy Duty Diesel Trucks Rule

N.J.A.C 7:27-14 sets tighter opacity standards for the Inspection and Maintenance (I/M) 

program. 
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Emissions Inventory for 2018 with Federal and State Control Requirements 

The emissions inventory used in the regional haze technical analyses was developed by MidAtlantic Regional Air Management Association (MARAMA) for MANE-VU with assistance 

from the MANE-VU states. The 2018 emissions inventory was developed by projecting 2002 

emissions, and assuming emissions growth due to projected increases in economic activity as 

well as applying reductions expected from federal and state regulations affecting the emissions 

of VOC and the visibility-impairing pollutants NOx, PM10, PM2.5, and SO2. The BART 

guidelines direct states to exercise judgment in deciding whether VOC and NH3 impair visibility

in their Class I area(s). MANE-VU demonstrated that anthropogenic emissions of sulfates are 

the major contributor to PM2.5 mass and visibility impairment at Class I areas in the Northeast 

and Mid-Atlantic region. It was also determined that the total ammonia emissions in the MANEVU region are extremely small. In addition, since VOC emissions are aggressively controlled 

through New Jersey’s ozone SIPs, the pollutants New Jersey considered under BART are NOx, 

PM10, PM2.5, and SO2. 

Additional information on the emission inventory used in the Regional Haze SIP, see the

companion Technical Support Document, attached: Review of New Jersey State-wide 2002 

and 2018 Projection Modeling Inventories and Reasonable Progress Goal Inventory 

Demonstration for the Regional Haze SIP, December 7, 2010.

Modeling to Support the LTS and Determine Visibility Improvement for Uniform Rate of 

Progress

MANE-VU performed modeling for the regional haze LTS for the 11 Mid-Atlantic and 

Northeast states and the District of Columbia. The modeling analysis is a complex technical 

evaluation that began with selection of the modeling system. MANE-VU used the following 

modeling system:

 Meteorological Model: The Fifth-Generation Pennsylvania State University/National 

Center for Atmospheric Research (NCAR) Mesoscale Meteorological Model (MM5) 

version 3.6 is a nonhydrostatic, prognostic meteorological model routinely used for 

urban- and regional- scale photochemical, PM2.5, and regional haze regulatory modeling 

studies.

 Emissions Model: The Sparse Matrix Operator Kernel Emissions (SMOKE) version 2.1 

modeling system is an emissions modeling system that generates hourly gridded 

speciated emission inputs of mobile, non-road mobile, area, point, fire and biogenic 

emission sources for photochemical grid models.

 Air Quality Model: The EPA’s Models-3/Community Multiscale Air Quality (CMAQ) 

version 4.5.1 and REMSAD modeling system is a photochemical grid model capable of 

addressing ozone, PM, visibility and acid deposition at a regional scale. 

 Air Quality Model: The Regional Model for Aerosols and Deposition (REMSAD), 

version 8 is a Eulerian grid model used for a source apportionment analysis.

 Air Quality Model: The California Puff Model (CALPUFF), version 5 is a non-steadystate Lagrangian puff model used to access the contribution of individual states’ 

emissions to sulfate levels at selected Class I receptor sites.
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The MANE-VU was tasked with the assignment of preparing a PM2.5 modeling platform that all 

member states could use to model their LTSs to demonstrate reasonable progress by 2018 in 

meeting the ultimate goal of natural visibility conditions by 2064. The New York State 

Department of Environmental Conservation (NYSDEC) was the lead agency for coordinating 

and running the modeling platform used by the MANE-VU RPO. Modeling centers responsible 

for running the platform included the NYSDEC, the University of Maryland at College Park 

(UMD), the Northeast States for Coordinated Air Use Management (NESCAUM), the New 

Jersey Department of Environmental Protection (NJ DEP), and the Virginia Department of 

Environmental Quality (VA DEQ). Each modeling center was responsible for installing the 

modeling platform, conducting diagnostic tests and completing a benchmark run to ensure 

accurate results. 

 

MANE-VU used the CMAQ version 4.5.1 as its photochemical grid model. The model uses 

simulations of chemical reactions, emission of PM2.5 and PM2.5 precursors and a sophisticated 

meteorological model (The Pennsylvania State University/National Center for Atmospheric 

Research Mesoscale Meteorological Model) to produce speciated PM2.5 concentrations over the 

eastern United States. The meteorological data used in the meteorological model was for the 

2002 base year. The photochemical grid model was run with the base year meteorology and base 

year emissions to determine if the model performance was satisfactory. Once the model 

performance was determined to be adequate, PM 2.5 concentrations were modeled by running the 

model with projected emissions for 2018 and the original 2002 meteorology. The meteorology

was held constant so that the results of changing the emissions would not be influenced by 

changing meteorology.

Conceptual Description of the Problem

A conceptual model describes how weather patterns affect the formation and transport of PM2.5, 

accounting for emissions and photochemistry.

New Jersey’s SIP includes, in Chapter 7, numerous methods that provide information about how 

haze occurs in New Jersey and the sources of haze. The methods include emissions information 

(and the distance to sources), trajectory analyses, and impacts predicted by dispersion and 

various grid models. Monitoring data is used to show that sulfates are the predominate species 

that reduce visibility at the Brigantine Class I area. The various models support the hypothesis 

that many sources across a wide range of states in the eastern United States contribute to haze in 

New Jersey. 

Modeling Platforms

Two regional-scale air quality models were evaluated and used by NESCAUM to perform air 

quality simulations. These are the Community Multi-scale Air Quality modeling system 

(CMAQ; Byun and Ching, 1999) and the Regional Modeling System for Aerosols and 

Deposition (REMSAD; SAI, 2002). CMAQ was developed by EPA, while REMSAD was 

developed by ICF Consulting/Systems Applications International (ICF/SAI) with EPA support. 

CMAQ has undergone extensive community development and peer review (Amar et al., 2005) 

and has been successfully used in a number of regional air quality studies (Bell and Ellis, 2003;
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Hogrefe et al., 2004; Jimenez and Baldasano, 2004; Mao and Talbot, 2003; Mebust et al., 2003). 

REMSAD has also has been peer reviewed (Seigneur et al., 1999) and used by EPA for 

regulatory applications (www.epa.gov/otaq/regs/hd2007/frm/r00028.pdf and 

www.epa.gov/clearskies/air_quality_tech.html) to study ambient concentrations and deposition 

of sulfate and other PM species.

Five modeling centers, worked collectively to maximize efficiency of computing resources in 

MANE-VU for SIP modeling. These centers include NY DEC, NJ DEP/Rutgers, VA DEQ,

UMD, and NESCAUM. 

Use of Air Quality Models: Contribution Assessment

The 1999 Regional Haze Rule requires State Implementation Plans to include a “contribution 

assessment” to identify those states or regions that may be influencing specially protected federal 

lands known as Federal Class I areas.4These states or regions would then be subject to the 

consultation provisions of the Haze Rule. The Haze Rule also requires a “pollution 

apportionment” analysis as part of the long-term emissions management strategy for each site.

As described in the Conceptual Description portion of this TSD, sulfate alone accounts for 

anywhere from one-half to two-thirds of total fine particle mass on the 20 percent haziest days at 

MANE-VU Class I sites. As a result of the dominant role of sulfate in the formation of regional 

haze in the Northeast and Mid-Atlantic region, MANE-VU concluded that an effective emissions 

management approach would rely heavily on broad-based regional SO2 control efforts in the 

eastern United States.

Use of Air Quality Models: Area of Influence for MANE-VU Class I Areas 

States with Class I areas calculate the baseline and natural visibility for their Class I areas, and 

the determination of reasonable progress goals. 

Class I States calculated baseline visibility conditions for the period between 2002 and 2004. The 

average impairment for the most and least impaired days were determined for each calendar year 

and compiled into the average of three annual averages (40 CFR 51.308 (d)(2)(i)). The natural 

visibility conditions were determined for the same baseline period with the most and least 

impaired days determined by available monitoring data or an appropriate data analysis technique 

(40 CFR 51.308 (d)(iii-iv)). 

There are seven Class I areas located in the Mid-Atlantic and Northeast, of which Brigantine in 

New Jersey is one. In order to identify states whose emissions are most likely to influence 

visibility in MANE-VU Class I areas, MANE-VU prepared the Contributions to Regional Haze 

 

4

The Class I designation applies to national parks exceeding 6,000 acres, wilderness areas and national memorial 

parks exceeding 5,000 acres, and all international parks that were in existence prior to 1977. In the MANE-VU area, 

this includes: Acadia National Park, Maine; Brigantine Wilderness (within the Edwin Wilderness, Vermont; 

Moosehorn Wilderness (within the Moosehorn National Wildlife Refuge), Maine; B. Forsythe National Wildlife 

Refuge), New Jersey; Great Gulf Wilderness, New Hampshire; Lye Brook Presidential Range – Dry River 

Wilderness, New Hampshire; and Roosevelt Campobello International Park, New Brunswick.
12

in the Northeast and Mid-Atlantic United States (Contribution Assessment). The full report can 

be found in Appendix H-1 of the New Jersey Regional Haze SIP. 

Based on that work, MANE-VU concluded that it was appropriate to define an “Area of 

Influence” (AOI) including all of the states participating in MANE-VU plus other states outside 

MANE-VU for which modeling indicated they contributed at least two percent (2%) of the 

sulfate ion in MANE-VU Class I areas in 2002. The Visibility Improvement State and Tribal 

Association of the Southeast (VISTAS)5also conducted an AOI analysis, which used a level of 

one percent (1%) to assess whether an upwind state significantly contributed. The VISTAS AOI 

did not show New Jersey to be a contributor to any VISTAS Class I area. 

The primary contribution assessment tool used in the New Jersey Regional Haze SIP was the 

Regional Modeling System for Aerosols and Deposition (REMSAD) (SAI, 2002). A significant 

feature of the REMSAD work used to evaluate regional contributions is that NESCAUM 

reprocessed the SO2 emission data from each state to take advantage of REMSAD’s tagging 

capabilities. Thus, all SO2 emissions included in the model for the eastern half of the country 

were tagged according to state of origin, and emissions from Canada and the boundary

conditions were also tagged. This allowed for a rough estimation of the total contribution from 

elevated point sources in each state to simulated sulfate concentrations at eastern receptor sites. 

Using identical emission and meteorological inputs to those prepared for the CMAQ SIP 

modeling platform, described earlier in this TSD, REMSAD was used to simulate the annual 

average impact of each state’s SO2 emission sources on the sulfate fraction of PM2.5 over the 

northeastern United States. A more in-depth description of the REMSAD modeling used for 

contribution assessment can be found in Appendix H-1 of New Jersey’s SIP.

The REMSAD contribution assessment modeling used by New Jersey’s Regional Haze SIP

conforms to EPA modeling requirements and is acceptable to EPA. 

Use of Air Quality Models: REMSAD Contribution Assessment Results

New Jersey determined that a number of states contributed to haze in the Brigantine Class I area, 

and notified these states via the letters included in Appendix I-1 of New Jersey’s plan. Many 

states responded (Appendix I-2). New Jersey also contributes to haze in a number of Class I 

areas in MANE-VU. These impacts were determined using a variety of methods as described

below. 

MANE-VU States decided that any state or region that contributed at least 2 percent of total 

sulfate observed on 20 percent worst visibility days in 2002 is contributing significantly to the 

haze problem in that particular Class I area. With respect to sulfate, the Contribution 

Assessment estimated emissions from within MANE-VU in 2002 were responsible for about 25-

30 percent of the sulfate at Class I areas located within and nearby to the MANE-VU region. The 

 

5

VISTAS is comprised of the following: the states of Alabama, Florida, Georgia, Kentucky, Mississippi, North 

Carolina, South Carolina, Tennessee, Virginia, West Virginia, and the Eastern Band of Cherokee Indians, and Knox 

County, TN 
13

contribution of sulfate at these Class I areas from other regions, Canada, and outside the 

modeling domain were also significant. 

Use of Air Quality Models: CMAQ Modeling of Relative Contributions of Pollutants to

Visibility Impairment

An important step toward identifying reasonable progress measures is to identify the key

pollutants contributing to visibility impairment at each Class I area. To understand the relative 

benefit of further reducing emissions from different pollutants, MANE-VU developed emission 

sensitivity model runs using CMAQ to evaluate visibility and air quality impacts from various 

groups of emissions and pollutant scenarios in the Class I areas on the 20 percent worst visibility

days. 

Regarding which pollutants are most significantly impacting visibility in the MANE-VU region, 

MANE-VU’s contribution assessment, demonstrated that sulfate is the major contributor to 

PM2.5 mass and visibility impairment at Class I areas in the Northeast and Mid-Atlantic region. 

Sulfate particles commonly account for more than 50 percent of particle-related light extinction 

at northeastern Class I areas on the clearest days and for as much as or more than 80 percent on 

the haziest days. In particular, for the Brigantine National Wildlife Refuge Class I area, on the 20 

percent worst visibility days in 2000 – 2004, sulfate accounted for 66 percent of the particle 

extinction. After sulfate, organic carbon (OC) consistently accounts for the next largest fraction 

of light extinction. Organic carbon accounted for 13 percent of light extinction on the 20 percent 

worst visibility days for Brigantine, followed by nitrate that accounts for 9 percent of light 

extinction. 

 

The emissions sensitivity analyses conducted by MANE-VU predict that reductions in SO2

emissions from EGU and non-EGU industrial point sources will result in the greatest 

improvements in visibility in the Class I areas in the MANE-VU region, more than any other 

visibility-impairing pollutant. As a result of the dominant role of sulfate in the formation of 

regional haze in the Northeast and Mid-Atlantic region, MANE-VU concluded that an effective 

emissions management approach would rely heavily on broad-based regional SO2 control efforts 

in the eastern United States. 

Use of CMAQ Modeling to Develop 2018 Control Case Predictions:

Meteorological Time Periods Used in the Modeling

All of 2002, which represents the baseline period from 2000 to 2004, was included in CMAQ 

modeling. 2002 was divided into five periods. UMD is responsible for modeling the period from 

January 1 to February 28; NJ DEP/Rutgers are responsible for the period from March 1 to May

14; NY DEC is responsible for the period from May 15 to September 30; VA DEQ is responsible 

for the period from October 1 to October 31; and NESCAUM is responsible for the period from 

November 1 to December 31. Each period uses a 15 day spin up run to minimize the impact of 

the default initial concentration fields. Each group performs CMAQ simulations on its period for 

a series of scenarios including 2002 Base Case, 2009 Base Case, 2018 Base Case, 2009 Control 

Case, and 2018 Control Case. All scenarios adopt the same meteorological field (2002) and 
14

boundary conditions, varying only emission inputs. To ensure consistency between modeling 

groups, a benchmark test was conducted by each group.

Meteorological Data Used in the CMAQ Air Quality Model

The MANE-VU states decided to use a prognostic meteorological model that provides life-like 

meteorological inputs to the photochemical grid model. The Pennsylvania State 

University/National Center for Atmospheric Research Mesoscale Meteorological Model version 

3.6 was chosen for the modeling analysis. The MM5 model provides a reasonable representation 

of weather conditions at the surface and aloft. 

Use of CMAQ Modeling to Develop 2018 Control Case Predictions:

Domain of the Model, Horizontal/Vertical Resolution and the Initial and Boundary 

Conditions

MANE-VU adopted the Inter-RPO domain description for its modeling runs. This 36-km 

domain covers the continental United States, southern Canada and northern Mexico. The 

dimensions of this domain are 145 and 102 cells in the east-west and north-south directions, 

respectively. A 12-km inner domain was selected to better characterize air quality in MANE-VU 

and surrounding RPO regions. This domain covers the eastern region, which includes the 

northeastern, central, and southeastern U.S., as well as southeastern Canada. It extends from 

66W - 94W in longitude and 29N - 50N in latitude with 172 × 172 grid cells.

 

Vertical resolution is the number of layers and the size of each layer in the model. The layers in 

the photochemical grid model were set up to be compatible with the model that produced 

weather conditions for the photochemical grid model. The vertical resolution used in the 

modeling exercise followed EPA’s modeling guidance and therefore adequately represents the 

atmosphere where PM2.5 is emitted, forms and is transported. 

Baseline and Future Year Emission Inventories for CMAQ Modeling 

Section 51.308(d)(3)(iii) of EPA’s Regional Haze Rule requires the States to identify the 

baseline emission inventory on which strategies are based. The baseline inventory is intended to 

be used to assess progress in making emission reductions. Based on EPA guidance entitled, 2002 

Base Year Emission Inventory SIP Planning: 8-hour Ozone, PM 2.5, and Regional Haze 

Programs, which identifies 2002 as the anticipated baseline emission inventory year for regional 

haze, MANE-VU and New Jersey are using 2002 as the baseline year. Future year inventories 

were developed for the years 2009, 2012 and 2018 based on the 2002 base year. These future 

year emission inventories include emissions growth due to projected increases in economic 

activity as well as the emissions reductions due to the implementation of control measures. 

The 2002 emissions were first generated by the individual states in the MANE-VU area. 

MARAMA then coordinated and quality assured the 2002 inventory data. The 2002 emissions 

from non-MANE-VU areas within the modeling domain were obtained from other Regional 

Planning Organizations for their corresponding areas. These Regional Planning Organizations 
15

included the Visibility Improvement State and Tribal Association of the Southeast (VISTAS), 

the Midwest Regional Planning Organization and the Central Regional Air Planning Association. 

Version 3 of the 2002 base year emission inventory was used in the regional modeling exercise. 

Technical support documentation for the MANE-VU 2002 base inventory is presented in 

Technical Support Document for 2002 MANE-VU SIP Modeling Inventories, Version 3, which 

is Appendix F-1 of the New Jersey SIP. This document explains the data sources, methods, and 

results for preparing this version of the 2002 base year criteria air pollutant and ammonia 

emissions inventory. Documentation for the future year estimations of EGUs is presented in 

Appendix F-2 of the SIP – MARAMA’s Development of Emission Projections for 2009, 2012, 

and 2018 for Non-EGU Point, Area, and Nonroad Source in the MANE-VU Region Final

Report, February, 2007. 

The emission inventory submitted by New Jersey is evaluated in the attached technical support 

document: Review of New Jersey State-wide 2002 and 2018 Projection Modeling 

Inventories and Reasonable Progress Goal Inventory Demonstration for the Regional Haze 

SIP, December 7, 2010.

CMAQ Model Performance Evaluation

The modeling is described in MANE-VU Modeling for Reasonable Progress Goals, prepared by 

NESCAUM, listed as Appendix N-2 of New Jersey’s SIP. 

NESCAUM evaluated the 2002 annual 12 km resolution meteorological fields generated by 

MM5 using ENVIRON's METSTAT program. Model results of surface wind speed, wind 

direction, temperature, and humidity were paired with measurements from EPA’s Clean Air 

Status and Trends Network (CASTNET) and National Center for Atmospheric Research’s 

Techniques Data Laboratory (TDL) network by hour and by location and then statistically

compared. Based on this statistical comparison between model prediction and data from the two 

networks for wind speed, wind direction, temperature, and humidity, MM5 performs well. An 

acceptable small bias, high index of agreement and strong correlation with CASTNET and TDL 

data are shown. Since MM5 uses TDL data for nudging, the model predictions are in better 

agreement with TDL data than with CASTNET data. MM5 performs better in Midwest and 

Northeast than Southeastern US.

CMAQ modeling was conducted for year 2002 by cooperative modeling efforts from NYDEC, 

UMD, NJDEP, Rutgers, VADEP, and NESCAUM. CMAQ Performance for PM2.5 species and 

visibility was examined based on this CMAQ run on a 12 km resolution domain. Measurements 

from IMPROVE and STN networks were paired with model predictions by location and time for 

evaluation. The goal and the criteria for PM2.5 evaluation suggested by Boylan and Baker (2004) 

were adopted by every RPO for SIP modeling. The performance goals are: Mean Fractional 

Error (MFE) ≤ +50%, and Mean Fraction Bias (MFB) ≤ ±30%; while the criteria are proposed 

as: MFE ≤ +75%, and MFB ≤ ±60%. CMAQ prediction of PM2.5 species from 40 STN sites and 

17 IMPROVE sites within the MANE-VU Region were paired with measurements and 

statistically analyzed to generate MFE and MFB values. Considering CMAQ performance in 

terms of MFE and MFB goals, sulfate, nitrate, OC, EC, and PM2.5 all had the majority of data 

points within the goal curve, some were between the goal and acceptable criteria, and only a few 
16

were outside the criteria curve. Only fine soil has the majority of points outside the criteria curve,

but there were some sites still within the goal. For the MANE-VU region, CMAQ performs best 

for PM2.5 sulfate, followed by PM2.5, EC, nitrate, OC, and then fine soil. Regional haze modeling 

also requires CMAQ performance evaluation for aerosol extinction coefficient (Bext) and the 

haze index. Modeled daily aerosol extinction at each improve site was calculated following the 

IMPROVE formula with modeled daily PM2.5 species concentration and relative humidity

factors from IMPROVE. The approach used natural background visibility estimates and the haze 

index following EPA Guidance. The modeled Bext showed a near 1:1 linear relationship (slope of 

0.78 and r2 of 0.46) with IMPROVE observed Bext. The regression excluded three points from 

July 7, 2002; the monitors were directly impacted by Canadian fires whose emissions were not 

modeled. 

How to Calculate Uniform Rate of Progress Goals

The key difference between SIPs from States with Class I areas and those States without Class I

areas, but may have sources that impact visibility on Class I areas, is the calculation of the 

baseline and natural visibility for their Class I areas and the determination of uniform rate of 

progress goals - expressed in deciviews - that provide for reasonable progress towards achieving 

natural visibility by 2064. It is the Class I states’ responsibility to assess these calculations. The 

Class I States must also consult with those States which may reasonably be anticipated to cause 

or contribute to visibility impairment in their Class I areas (40 CFR 51.308 (d)(1)(i-vi)). 

The baseline visibility conditions are calculated for the baseline period between 2002 and 2004. 

The average impairment for the 20 most and 20 least impaired days are determined for each 

calendar year and compiled into the average of three annual averages (40 CFR 51.308 (d)(2)(i)). 

The natural visibility conditions are determined for the same baseline period with the most and 

least impaired days determined by available monitoring data or an appropriate data analysis 

technique (40 CFR 51.308 (d)(iii-iv)). 

The calculations used to determine the natural conditions used as the 2064 visibility goal are 

described at the MANE-VU SIP Template document, June 10, 2004: NATURAL

BACKGROUND VISIBILITY CONDITIONS CONSIDERATIONS AND PROPOSED 

APPROACH TO THE CALCULATION OF NATURAL BACKGROUND VISIBILITY 

CONDITIONS AT MANE-VU CLASS I AREAS, following EPA’s guidance at: U.S. EPA 

(2003). Guidance for Estimating Natural Visibility Conditions under the Regional Haze Rule. 

EPA-454/B-03-005. September 2003.

EPA released guidance on June 7, 2007 to use in setting reasonable progress goals. The goals 

must provide improvement in visibility for the most impaired days, and ensure no degradation in 

visibility for the least impaired days over the SIP period. The following figure illustrates an 

example of how Uniform Rate of Progress is calculated. 

 
17

Example Calculation of Uniform Rate of Progress

CMAQ Modeled Visibility Projections for 2018

The CMAQ air quality model was used to simulate base period emissions and future emissions. 

The modeling results for the base year period (2002) and the year representing the end of the first 

planning period (2018) are used to develop relative response factors (RRF) for each component 

of particulate matter identified previously in this TSD. The relative response factors are 

multiplied by the measured species concentration data during the base period (for the measured 

20% best and worst days). This results in daily future year species concentrations data. The 

projected concentrations are then used to derive daily visibility in deciviews and are averaged 

across all best and worst days to create the projected future visibility. The results of this 

procedure are plotted along with the uniform progress glide slope below, and in Table 8.4 and 

Figure 8.1 in New Jersey’s SIP, taken from Figure 3-2, and 4-1B in 2018 Visibility Projections, 

Appendix J-1 in New Jersey’s SIP.
18

Reasonable Progress Goals and Projected Future Visibility for the Brigantine 

Wilderness Area

Baseline 

Visibility

(2000-2004)

Natural Background 

Conditions for 2064

Reasonable Progress 

Goal for 2018 

2018 CMAQ 

Projections 

20% 

Worst 

Days 

29.0 12.2 25.1 25.1 

20% Best 

Days 

14.3 5.5 14.3 12.2 

(All values expressed as deciviews – lower deciviews means better visibility.) 

From: 2018 Visibility Projections (NESCAUM for MANE-VU States, May 2008), Appendix J1 in New Jersey’s SIP.

By interpolating between the base year of 2004 and the natural background year of 2064, the 

Progress Goal for 2018 is 25.1 deciviews, 3.9 deciviews lower than the 29.0 deciviews starting 

point. State plans must adopt all reasonable controls, with the objective of improving visibility

to equal to, or better than, the Progress Goal. MANE-VU modeled the effects of reducing 

emissions on air quality and visibility. Based on the emission controls agreed-to by the MANEVU states, visibility at the Brigantine Class I area is forecast to improve to 25.1 deciviews in 

2018, meeting the Progress Goal. New Jersey evaluated the control measures agreed-to by the 

MANE-VU states and implemented all the agreed-to measures and placed BART controls on its 

BART-eligible sources. Thus, New Jersey has met the test of Reasonable Progress by adopting 

all reasonable measures, as well as meeting the 2018 progress goal. Since NJ’s BART sources 

were not included in the modeled reductions and New Jersey achieved 90 percent or better 
19

control at its CAIR-eligible sources, NJ is likely to have exceeded the modeled reductions. If 

other states implemented the MANE-VU measures, then visibility in the Brigantine area is likely

to exceed the progress goal in 2018.

 

The modeling results presented in 2018 Visibility Projections, Appendix J-1 in New Jersey’s 

SIP, show all MANE-VU sites are projected to meet or exceed the uniform rate of progress goals 

for 2018 on the 20 percent worst days. In addition, no site anticipates increases in visibility

impairment relative to the baseline on the 20 percent best days. 

Summary of Photochemical Grid Modeling Results

In summary, the photochemical grid modeling, documented in New Jersey’s Regional Haze SIP, 

follows EPA’s modeling guidance and is acceptable to EPA. All MANE-VU sites impacted by 

New Jersey are projected to meet or exceed the uniform rate of progress goal for 2018 on the 20 

percent worst days. In addition, no site anticipates increases visibility impairment relative to the 

baseline on the 20 percent best days. 

Monitoring

In section 10.2.3 of its SIP, New Jersey commits to operate and maintain the monitoring site at 

the Brigantine Wilderness Area for the foreseeable future. New Jersey contends that this 

commitment is contingent upon continued Federal and State funding. SIPs cannot place 

obligations on EPA when the rules and guidance require states to be responsible for continued 

assessment of visibility impairment. At present, visibility assessment is based on IMPROVE 

network monitoring at the Class I area in Brigantine. We acknowledge and appreciate New 

Jersey’s support for monitoring at this location. EPA agrees that monitoring to assess visibility

impairment will be included in the annual network review process between EPA and New 

Jersey. 

RAVI

EPA requires that states take responsibility for assessing and preventing visibility impairment 

reasonably attributable to a source or group of sources. This includes a commitment for New 

Jersey to insure that new sources do not affect the achievement of reasonable progress goals and 

continued coordination with the Federal Land Manager on issues with reasonably attributable 

visibility impairment (RAVI). 

New Jersey, in section 10.2.1, commits to continue to review the impact of new sources on 

visibility under its prevention of significant deterioration program for all major new or modified 

sources in New Jersey within 100km of the Brigantine Class I area, or further from Brigantine on 

a case-by-case basis. This commitment is affirmed in the New Jersey’s recently modified new 

source review delegation agreement. 

Public Hearing and Response to Comments and Consultation with Federal Land Manager

In Appendix O of the New Jersey Regional Haze SIP, New Jersey addressed the comments from 

the public, stakeholders, EPA and the Federal Land Manager.

On May 10, 2006, the MANE-VU State Air Directors adopted the Inter-RPO State/Tribal and 

FLM Consultation Framework that documented the consultation process within the context of 
20

regional phase planning, and was intended to create greater certainty and understanding among 

RPOs. MANE-VU states held ten consultation meetings and/or conference calls from March 1, 

2007 through March 21, 2008. In addition to MANE-VU members attending these meetings 

conference calls participants from VISTAS, Midwest RPO and relevant Federal Land Managers 

were also in attendance at many of these meetings and conference calls. In addition to the 

conference calls and meeting, the FLMs were given the opportunity to review and comment on 

each of the technical documents developed by MANE-VU. 

In addition to the conference calls and a meeting, the FLMs were given the opportunity to review 

and comment on each of the technical documents developed by MANE-VU and included as 

appendices in New Jersey’s SIP submittal. 

New Jersey consulted with the FLMs in person at a meeting that EPA Region 2 attended on 

October 20, 2009 during the development of the Regional Haze SIP. In addition, New Jersey

submitted the draft plan for review by the FLMs for the required ninety-day review period before 

New Jersey submitted the SIP to EPA. These actions fulfill EPA’s requirements in 40 CFR 

51.308(i). 

New Jersey held a public hearing on this proposed SIP revision on October 27, 2008 at the New 

Jersey Department of Environmental Protection Public Hearing Room, Trenton, New Jersey. 

Written comments relevant to the proposal were accepted through November 28, 2008. The only 

comments were submitted by USEPA, the Fish and Wildlife Service and one of the potential 

BART sources. New Jersey responded to the comments, as listed in Appendix O-3 of New 

Jersey’s Regional Haze Plan. New Jersey commits in their SIP to ongoing consultation with the 

FLMs on Regional Haze issues throughout the implementation of the SIP as required in 40 CFR 

51.308(i)(4). 

Periodic SIP Revisions and Five-Year Progress Reports

Consistent with the requirements of 40 CFR 51.308(g), New Jersey committed to submitting a 

report on reasonable progress (in the form of a SIP revision) to the EPA every five years 

following the initial submittal of its regional haze SIP. The reasonable progress report will 

evaluate the progress made towards the RPGs for the Brigantine National Wildlife Refuge Class 

I area. 

CONCLUSIONS AND RECOMMENDED AGENCY ACTION

New Jersey’s Regional Haze SIP establishes the reasonable progress goal for the Brigantine 

Wilderness Area Class I area in New Jersey. New Jersey’s SIP adopts long-term strategies 

assuring reasonable progress towards the national goal of achieving natural visibility conditions 

in Class I areas affected by New Jersey. The SIP includes all measures necessary to obtain New 

Jersey’s share of emissions reductions needed to meet the RPGs of the Brigantine Wildlife 

Refuge class I area. Furthermore, the submittal meets the requirements for New Jersey’s 

contribution toward meeting the reasonable progress goals for other Class I areas in the 

northeastern United States. This submittal also meets the applicable visibility-related 

requirements of the CAA and EPA regulations. In order for EPA to give final approval to New 
21

Jersey’s SIP, New Jersey needs to adopt its BART controls as described in its plan as SIP 

submittals. When that requirement is met, EPA can approve New Jersey’s Regional Haze SIP, 

including its BART determinations. 
22

Attachment

 Review of Application of Best Available Retrofit Technology 

in New Jersey’s Regional Haze State Implementation Plan, July 29, 2011

BART 

Best Available Retrofit Technology (BART) is an element of New Jersey’s Long Term Strategy

(LTS). The BART Regional Haze requirement consists of three components: (a) identification 

of all the BART eligible sources; (b) an assessment of whether the BART eligible sources are 

subject to BART; and (c) the determination of the BART controls. 

BART Eligible Sources 

The first component of a BART evaluation is to identify all the BART eligible sources. The 

BART eligible sources were identified utilizing the criteria in the BART Guidelines (70 FR 

39158-39161; July 6, 2005) as follows:

 Determine whether one or more emissions units at the facility fit within one of the 26 

categories listed in the BART Guidelines;

 Determine whether the emission unit(s) was in existence on August 7, 1977 and begun 

operation after August 6, 1962;

 Determine whether potential emissions of SO2, NOx, and PM10 from subject units are 250 

tons or more per year (tpy).

The BART Guidelines recommend addressing SO2, NOx, and PM10 as visibility-impairment 

pollutants and leave it up to the discretion of states to evaluate VOC or ammonia emissions. 

Because of the lack of tools available to estimate emissions and subsequently model VOC and 

ammonia effects on visibility, and because New Jersey is aggressively addressing VOCs through 

its ozone SIPs, New Jersey determined that SO2, NOx and PM10/2.5 are the only reasonable 

contributing visibility impairing pollutants to target under BART. 

New Jersey identified five facilities as BART eligible in their July 2009 RH SIP but New Jersey

later determined in its March 2011 supplement to the RH SIP that two of these facilities, namely

Amerada Hess and Sunoco Eagle Point, had potential emissions of SO2, NOx, and PM10 below 

the 250 tpy threshold and therefore were not BART eligible. Of the remaining three facilities 

that are BART eligible, one is an electric generating facility and the other two are petroleum 

refineries, as described in Table 1. Electric generating units and petroleum refineries fit within 

the 26 categories listed in the BART Guidelines. For additional details regarding New Jersey’s 

identification of sources that are BART eligible, the reader is referred to pp 2-14 of New Jersey’s 

technical support document (TSD)6located in the electronic docket for this rulemaking. On 

March 2, 2011, New Jersey submitted the TSD to EPA for approval as a supplement to the July

2009 RH SIP. 

 

6

“Final BART Determinations for Affected BART-eligible Sources in the State of New Jersey” March 2, 2011.
23

Table 1. New Jersey’s BART Eligible Facilities

Facility Pollutants Facility

Category

Location 

(County)

Facility I.D.

PSEG – Hudson SO2, NOx, PM Electric 

Generating

Hudson 12202

Chevron SO2, NOx, PM Petroleum

Refinery

Middlesex 18058

Conoco Phillips SO2, NOx, PM Petroleum 

Refinery

Union 41805

Amerada Hess SO2, NOx Petroleum 

Refinery

Middlesex 17996

Sunoco Eagle Point SO2, NOx, PM Petroleum 

Refinery

Gloucester 55781

Additional BART Eligible Sources

During EPA’s review of New Jersey’s RH SIP, EPA discovered two other facilities in New 

Jersey that might be BART eligible, Vineland Municipal Electric Utility and BL England 

Generating Station. These facilities had planned to shut down several years ago, but later each 

facility withdrew their request. New Jersey has updated its technical support document to 

determine BART for the two facilities. EPA evaluates New Jersey’s BART determinations later 

in this document, following our review of the initial five BART eligible facilities. 

BART Subject Sources

The second component of the BART evaluation is to identify those BART eligible sources that 

may reasonably be anticipated to cause or contribute to visibility impairment at any Class I area 

are subject to BART. As discussed in the BART Guidelines, a state may choose to consider all 

BART eligible sources to be subject to BART. (70 FR 39161) Consistent with the MANE-VU 

Board’s decision in June 2004 that because of the collective importance of BART sources BART 

determination should be made by the MANE-VU states for each BART eligible source. New 

Jersey identified each of its BART eligible sources as subject to BART, except, as explained in 

the previous paragraph, for Amerada Hess and Sunoco Eagle Point. 

Determination of BART

The final component of a BART evaluation is making BART determinations for all BART 

subject sources. In making BART determinations, section 169A(g)(2) of the CAA requires that 

States consider the following five factors: (1) the costs of compliance; (2) the energy and non-air 

quality environmental impacts of compliance; (3) any existing pollution control technology in 

use at the source; (4) the remaining useful life of the source; and (5) the degree of improvement 

in visibility which may reasonably be anticipated to result from the use of such technology. 

Section 51.308(e)(2) of the Regional Haze Rule provides that a State may opt to implement an 

emissions trading program or other alternative measure rather than to require sources subject to 

BART to install, operate, and maintain BART. To do so, the State must demonstrate that the 
24

emissions trading program or other alternative measure will achieve greater reasonable progress 

than would be achieved through the installation and operation of BART. New Jersey did not opt 

to implement any alternative measures or programs to BART.

The following section reviews New Jersey’s BART determinations for the remaining three 

BART eligible facilities identified in Table 1 above and EPA’s evaluation of each determination. 

PSEG-Hudson Generating Station

New Jersey identified four units that are subject to BART at the PSEG facility located in Hudson 

County. The four units include two boilers (E1 and E2) serving electric generating units (EGUs) 

and two coal handling systems (E22 and E23) that support the coal fired boiler (E2). The 

following summarizes New Jersey’s determination of BART for each of the four units and

EPA’s evaluation. For additional details concerning New Jersey’s BART determination, the 

reader is referred to pp 29-38 of New Jersey’s March 2011 TSD located in EPA’s electronic 

docket for this rulemaking. In addition, the reader is referred to PSEG’s preliminary BART 

control plan, submitted to New Jersey on July 15, 2009, located in Appendix G8 of the State’s 

July 2009 RH SIP. New Jersey approved the Significant Modifications to PSEG’s title V permit 

for BART on March 8, 2011. 

(a) Boiler Unit 1 (E1)

This unit is a cyclone boiler generating electricity having a rating of 420 MWe and fires 

natural gas (only natural gas since 2005) but is also permitted to combust No. 6 Fuel Oil. 

Pre-BART control measures do not include any combustion technology or add-on 

controls for limiting emissions of NOx, SO2 or PM, however the use of either natural gas 

or low sulfur fuel oil limits emissions of SO2 and PM. Unit 1 is primarily a standby unit7

and the area dispatcher (PJM Interconnection8) requested PSEG to operate this unit on an 

as needed basis to provide system reliability through at least 2012, and perhaps longer, 

otherwise PSEG would have retired this unit around 2005. The following summarizes 

New Jersey’s BART determinations for NOx, SO2 and PM for this unit. 

NOx

New Jersey evaluated eight control measures as BART for control of NOx emissions and 

determined that SCR (or an equivalent control measure), although not cost effective, 

would be required to meet an emission limit of 1.00 pound per megawatt hour (lb/MWh) 

[equivalent to about 0.10 pounds per million BTU heat input (lb/MMBTU)], as measured 

on a 24-hr average, when combusting natural gas by May 1, 2015, pursuant to the New 

Jersey Administrative Code, Title 7, Chapter 27, Subchapter 19 (N.J.A.C. 7:27-19). 

When Unit 1 combusts No. 6 Fuel Oil, Subchapter 19 requires compliance with an 

emission limit of 2.00 lb/MWh (equivalent to about 0.20 lb/MMBTU), as measured on a 

24-hr average, by May 1, 2015. The aforementioned emission limits and compliance date 

for gas and oil firing to meet Subchapter 19 requirements are also New Jersey’s 

requirements for Unit 1’s implementation of BART. In addition to requiring the 

installation of SCR (or equivalent), for meeting BART, New Jersey is requiring PSEG to 

combust only natural gas in the boiler unless there is a gas curtailment in which case No. 

 

7

From 2007 to 2010, the annual capacity factor for Unit 1 ranged from 1.6% to 6.7% with an arithmetic mean of 

about 3.6%. 

8

PJM Interconnection is a regional transmission organization (RTO) that coordinates the movement of wholesale 

electricity in all or parts of 13 states and the District of Columbia, including the State of New Jersey.
25

6 Fuel Oil may be combusted. Table 23 on p34 of New Jersey’s March 2011 TSD 

summarizes the NOx control measures evaluated for BART and the cost effectiveness of 

each. 

SO2

New Jersey determined that the combustion of natural gas and the restricted use of No. 6 

Fuel Oil is BART for controlling emissions of SO2 from Unit 1. The BART requirement 

to combust fuel oil only during periods of gas curtailment is effective upon New Jersey’s 

approval of the permit modification (i.e., March 8, 2011) but no later than December 31, 

2011. In addition, New Jersey restricts the sulfur content of No. 6 Fuel Oil to 0.30% 

(equivalent to approximately 0.33 lb SO2/MMBTU) by weight which will further limit 

emissions of SO2 from Unit 1. The unit’s predominant use of natural gas and its low 

capacity factor minimize emissions of SO2 (and PM). SO2 emission limits when 

combusting natural gas and No. 6 Fuel Oil are summarized in Table 25 (p 37) of New 

Jersey’s TSD. 

PM10

New Jersey determined that the combustion of natural gas and the restricted use of No. 6 

Fuel Oil is BART for controlling emissions of PM10 from Unit 1. The combustion of 

natural gas is inherently low in PM emissions and the restricted use of low sulfur fuel oil 

also limits PM emissions. The State’s BART PM emission limits when combusting 

natural gas and No. 6 Fuel Oil are summarized in Table 25 (p 37) of New Jersey’s TSD. 

(b) Boiler Unit 2 (E2)

This unit is a dry-bottom wall-fired boiler generating electricity having a rating of 660 

MWe and fires low sulfur bituminous coal but is permitted to also fire natural gas or No. 

6 Fuel Oil. Pre-BART control measures include the use of the following: Selective noncatalytic reduction (SNCR) to control NOx emissions; Ultra low sulfur (≤ 0.25%) coal to 

control SO2 emissions; and, optimization of an existing electrostatic precipitator (ESP) to 

control PM emissions. In July 2002, a Federal consent decree 9(CD) required PSEG to 

install state-of-the-art (SOTA) controls for NOx, SO2 and PM on all coal-fired boilers in 

the State of New Jersey, including the PSEG-Hudson facility. An amended CD extended 

the compliance date to December 31, 2010. The CD is the basis for New Jersey’s BART 

determination for reducing emissions of NOx, SO2 and PM from this unit. 

NOx 

As a result of the July 2002 CD, PSEG is required to install selective catalytic reduction 

(SCR) control technology using ammonia to reduce NOx emissions. This is in addition to 

the existing pre-BART low NOx burner (LNB) controls installed in 2008. When 

combusting coal, Unit 2 must be in compliance, by December 31, 2010, with an emission 

limit of 0.15 lb NOx /MMBTU, measured on a 24-hr average, and 0.10 lb NOx/MMBTU, 

as measured on a 30-day average. New Jersey reports that initial CEMS results for the 

first few months of operation have been approximately 0.09 lbs NOx /MMBTU on a 24-

hr average. This compares to EPA’s “presumptive” level of 0.39 lb/MMBTU (see Table 

1 of EPA’s Appendix Y BART Guidelines) for the same type boiler as Unit 2 (drybottom wall-fired unit that combusts bituminous coal). Therefore, initial operating 

 

9

http://www.epa.gov/compliance/resources/cases/civil/caa/psegfs.pdf
26

results indicate that the BART controls for limiting NOx emissions are better than EPA’s 

presumptive level. 

SO2

As a result of the July 2002 CD, PSEG is required to reduce SO2 emissions by installing a 

spray dryer absorber with baghouse, using lime as the alkali, and to limit the sulfur 

content of the coal to ≤ 2.00%. When combusting coal, Unit 2 must be in compliance, by 

December 31, 2010, with an emission limit of 0.25 lb SO2/MMBTU, measured on a 24-hr 

average, and 0.15 lb/MMBTU, as measured on a 30-day average. New Jersey indicates 

that initial CEMS results for the first few months of operation have been about 0.132 lb 

SO2/MMBTU on a 24-hr average. PSEG indicates that initial results indicate SO2

reductions of approximately 92%. EPA’s “presumptive” level for an EGU greater than 

200 MW that is uncontrolled and located at a 750 MW power plant, is an SO2 emission 

limit of either 0.15 lb/MMBTU or 95% reduction. Therefore, initial operating results 

indicate that the BART controls for reducing SO2 emissions are slightly better than 

EPA’s presumptive level. 

PM

As a result of the July 2002 CD, PSEG is required to reduce PM emissions by installing a 

baghouse. This baghouse is installed in conjunction with the installation of the spray

dryer absorber for controlling emissions of SO2. An existing electrostatic precipitator 

removes fly ash upstream of the spray dryer absorber/baghouse combination. When 

combusting coal, Unit 2 must be in compliance, by December 31, 2010, with a BART 

emission limit of 0.015 lb PM/MMBTU. PM emission limits for BART when 

combusting natural gas and No. 6 Fuel Oil are summarized in Table 25 (p 38) of New 

Jersey’s TSD. 

(c) Coal Handling System (E22 and E23)

The coal receiving system (E22) and the coal reclaim system (E23) are support systems 

for the Unit 2 (E2) coal fired boiler. The Coal Handling System does not have any

emissions of NOx or SO2 but does emit PM when there are wind conditions at the facility. 

Since the potential to emit PM is low (2.7 tpy for E22 and 1.2 tpy for E23), New Jersey

has determined that BART for the Coal Handling System is the continued use of PSEG’s 

existing controls including a water dust suppression system and covers on the conveying 

systems to minimize PM emissions. PM emission limits for BART are the existing title 

V permit conditions as summarized in Table 25 (p 38) of New Jersey’s TSD. 

(d) EPA’s Evaluation of New Jersey’s BART Determination for PSEG

EPA agrees with New Jersey’s determinations for establishing BART requirements on 

the four units subject to BART at the PSEG-Hudson facility. New Jersey did not conduct 

a 5-factor analysis for determining BART for any of the units subject to BART since 

maximum control technology or control measures have already been implemented as 

BART on the two boilers and the PM emissions from the Coal Handling Systems have 

very low potential to emits (PTEs) and have adequate existing PM control systems. 

Since EPA guidance10 does not require a 5-factor analysis whenever maximum controls 

are determined to be BART, EPA agrees with New Jersey’s BART determinations. New 

Jersey has included the BART requirements in final title V permits and the State’s SIP 

 

10 See EPA’s document “Additional Regional Haze Questions” August 24, 2006. See Q&A # 15. 
27

supplement will includes a summary of BART compliance requirements for monitoring, 

reporting and recordkeeping. New Jersey plans to submit this SIP supplement during 

November 2011. Since New Jersey has established BART requirements, including 

enforceable permit limits, in accordance with EPA guidance EPA recommends proposed 

approval of New Jersey’s BART determination for the PSEG-Hudson Station. 

Chevron Products Co. – Perth Amboy

New Jersey identified two units that are subject to BART at the Chevron petroleum refinery

located in the city of Perth Amboy, Middlesex County. The two units are both fuel gas-fired 

furnaces (E1501 and E1502), also referred to as process heaters, serving the petroleum refinery. 

The following summarizes New Jersey’s determination of BART for the two units and EPA’s 

evaluation. For additional details concerning New Jersey’s BART determination, the reader is 

referred to pp 8-10 and 17-18 of New Jersey’s March 2011 TSD located in EPA’s electronic 

docket for this rulemaking. New Jersey approved the Significant Modifications to PSEG’s title 

V permit for BART on March 4, 2011.

(a) Gas-Fired Furnaces (E1501 and E1502)

For the two BART-subject units, the pre-BART PTEs are as follows: 40.5 tpy SO2, 262.2 tpy

NOx, and 32.7 tpy PM. In addition, the annual emissions for these two units have been low (see 

p 17 of New Jersey’s TSD). From 2005-2008, the estimated annual emissions as a percentage of 

PTE for these two units are as follows: 55%-10.5% (35% average) for E1501; and 16.8%-2.5% 

(11.7% average) for E1502. In 2009, both units did not operate at all. Chevron submitted its 

BART proposal to New Jersey in March 2009 (see Appendix G8 of New Jersey’s July 2009 RH 

SIP revision) but subsequently decided to ”cap-out” the emissions of NOx to below the BARTeligible threshold of 250 tpy. Thus, each visibility impairing pollutant (SO2, NOx and PM) from 

the two furnaces were scheduled to be below the BART-eligible PTE threshold of 250 tpy by the 

effective compliance date of March 4, 2011. Since the modification to the title V permit allowed 

the facility to avoid becoming subject to a Federal rule, it was considered a “significant” 

modification and was subject to public notice and a 30-day comment period. New Jersey reports 

that no comments were received during this 30-day comment period. The title V permit requires 

Chevron to limit heat input to each furnace and to monitor and report annual emissions to limit 

the PTE of each pollutant to below 250 tpy. New Jersey requires Chevron to report the amount 

of fuel burned and actual emission rates in accordance with its Emissions Statements program 

adopted by the State at Subchapter 21 (N.J.A.C. 7:27-21). 

(b) EPA’s Evaluation of New Jersey’s BART Determination for Chevron

EPA agrees with New Jersey’s BART determination for the two BART-eligible units at the 

Chevron facility located in the city of Perth Amboy. Chevron has proposed and New Jersey has 

approved limiting the PTE of each visibility impairing pollutant from units E1501 and E1502 to 

below 250 tpy thereby satisfying BART requirements. Since the two units at Chevron have 

approved and effective title V permits that will result in limiting the emissions of each visibility

impairing pollutants to less than 250 tpy, the two units no longer meet the criteria for 

establishing a unit as being BART eligibility. Therefore the two units are not subject to BART 

and are not required to implement any BART requirements to further limit emissions of visibility

impairing pollutants. It should be noted that should Chevron request to operate the two units 

such that the cumulative PTE of the two units equals or exceeds 250 tpy, then E1501 and E1502 

shall be subject to BART and the facility’s title V permit would need to be revised to include 

new applicable requirements. New Jersey’s BART analysis and determination meets the criteria 
28

in EPA’s BART Guidelines (70 FR 39158-39161; July 6, 2005) and is therefore acceptable to 

EPA. New Jersey has included the BART requirements in final title V permits which will be 

submitted to EPA in a November 2011 SIP supplement along with a summary of BART 

compliance requirements for monitoring, reporting and recordkeeping. Since New Jersey has 

established BART requirements, including enforceable permit limits, in accordance with EPA 

guidance and the CAA, EPA recommends proposed approval of New Jersey’s BART 

determination for the two process heaters located at the Chevron facility in the city of Perth

Amboy. 

ConocoPhillips Bayway Refinery

New Jersey identified eleven units that are subject to BART at the ConocoPhillips (CP) 

petroleum refinery located in the city of Linden, Union County. The eleven units are all refinery

fuel gas-fired process heaters. The list of process heaters, as well as equipment descriptions, 

determined by the State to be subject to BART are listed in Table 16 on p 26 of New Jersey’s 

TSD. For additional details concerning New Jersey’s BART determination, the reader is referred 

to pp 10-13 and 19-29 of the State’s March 2011 TSD located in EPA’s electronic docket for this 

rulemaking. In addition, the reader is referred to CP’s proposal for BART submitted to New 

Jersey and located in Appendix G8 of the State’s July 2009 RH SIP. 

It should also be noted that, on January 27, 2005, the US Department of Justice (DOJ), EPA and 

New Jersey Department of Environmental Protection (NJDEP) entered into a national 

enforceable consent decree11 (CD) with CP, including its Bayway refinery. The CD identifies 

“boilers and heaters,” as well as other equipment categories, as affected units requiring 

reductions in NOx and SO2, precursors of fine PM. The eleven process heaters subject to BART 

are also subject to the requirements of the CD. On January 27, 2005, CP discontinued the use of 

fuel oil combustion in the eleven process heaters. In addition, the CD obliges CP to upgrade the 

refinery fuel gas system by December 31, 2010 and to comply with the hydrogen sulfide (H2S) 

requirements of the NSPS for petroleum refineries (40 CFR Part 60,Subpart J) by June 30, 2011. 

Absorbers are used as control technology to reduce H2S emissions from the refinery fuel gas. 

Combustion of H2S in the process heaters results in the formation of SO2 emissions. The NSPS 

Subpart J requires that the H2S concentration of refinery fuel gas to be combusted in process 

heaters is to be less than 0.10 grains/dry standard cubic feet (gr/dscf) which is equivalent to 162 

parts per million dry (ppmd). The SO2 emission concentration resulting from the combustion of 

refinery fuel gas containing 162 ppmd H2S would also be 162 ppmd. 

CP submitted an application for Significant Modifications to its title V permit for the eleven 

units subject to BART and New Jersey has provided for a 30-day public comment period that 

ends on July 30, 2011. New Jersey is expected to approve and submit those elements of the title 

V permits to EPA, as a supplement to the July 2009 RH SIP, in November 2011. The following 

summarizes New Jersey’s determination of BART for the eleven units and EPA’s evaluation.

NOx

New Jersey considered seven control measures as potentially BART applicable for control of 

NOx emissions and determined that ultra low NOx burners (ULNB) with internal flue gas 

recirculation (FGR), the control measure currently being implemented on each of the eleven 

process heaters, is BART. For details, the reader is referred to Table 7 on p 16 of New Jersey’s 

TSD and to CP’s analysis found in Appendix G8 of the State’s July 2009 RH SIP. New Jersey

determined that SCR was not cost effective and that SNCR was not feasible due to temperature 

 

11 http://www.epa.gov/compliance/resources/cases/civil/caa/conocophillips.html
29

variations in the process heaters. In addition, process heaters combusting refinery fuel gas with a 

heat input of 50 million BTU or greater, are subject to the State’s NOx regulation at N.J.A.C. 

7:27-19.7(h) requiring NOx emissions of 0.20 lb/MM BTU. Also, New Jersey’s State of the Art 

(SOTA) Manual for Petroleum Refineries requires process heaters with replacement burners to 

meet a NOx performance emission limit of not more than 0.07 lb/MM BTU. New Jersey reports 

that the process heaters at CP’s Bayway refinery have a measured average overall NOx emission 

rate of approximately 0.04 lb/MM BTU (see p 20 of New Jersey’s TSD). New Jersey has 

established BART NOx emission limits, expressed in pounds per hour for any 60-minute period, 

for the eleven process heaters and are summarized in Table 16 on p 26 of the State’s TSD. The 

BART requirements for the process heaters are already included in CP’s title V permit.

SO2

New Jersey considered three control measures as potentially BART applicable for control of SO2

emissions and determined that CP’s compliance with the January 2005 CD is BART. The CD 

requires upgrading the existing gas system to comply with the NSPS Subpart J that requires 

limiting the H2S concentration in the refinery fuel gas combusted in the process heaters to less 

than 0.10 gr/dscf (162 ppmd). For details, the reader is referred to Table 7 on p 16 of New 

Jersey’s TSD and to CP’s analysis found in Appendix G8 of the State’s July 2009 RH SIP. In its 

BART analysis, New Jersey determined that scrubbers were not technically feasible and fuel 

processing was not practically applicable to individual process heaters. As indicated above, CP 

is obligated by the CD to upgrade the fuel gas system (that provides fuel to the process heaters) 

to comply with the NSPS Subpart J that requires reducing the H2S concentration to not more than 

162 ppmd. Section 60.104 of Subpart J provides the standards for SO2 emissions at petroleum 

refineries. Subpart J also requires continuous monitoring of the H2S concentration and the State 

is requiring H2S concentration measurements on a 3-hour rolling average. CP’s current title V 

permit already requires monitoring the H2S concentration of the refinery fuel gas. 

New Jersey estimates that when CP’s refinery fuel gas system is fully upgraded, the SO2

emissions from the process heaters will be approximately 0.033 lb/MM BTU (see Table 15 on p 

25 of New Jersey’s TSD). EPA’s RH guidance does not have any presumptive limits for 

petroleum refineries but, for comparative purposes, EPA’s presumptive SO2 limit for a large 

(200 MW at a 750 MW facility) uncontrolled coal-fired EGU is either 95% removal or 0.15 

lb/MM BTU. EPA’s presumptive limit for oil-fired boilers is that the sulfur content should be 

limited to 1% (equivalent to about 1.0 lb/MM BTU) or less. Therefore, CP’s SO2 emission limit 

of 0.033 lb/MM BTU compares very favorably to EPA’s presumptive limits for oil and coal fired 

boilers. 

For BART, New Jersey has established SO2 emission limits, expressed in pounds per hour for 

any 60-minute period, and H2S emission limits in the refinery fuel gas, expressed as ppmd for a 

three hour rolling average, for the eleven process heaters, as summarized in Table 16 on p 26 of 

the State’s TSD. New Jersey is requiring CP to be in full compliance with Subpart J 

requirements by June 30, 2011. One of the process heaters (E258), the largest of the 11 BART 

subject heaters, was already in compliance with Subpart J. As stated earlier, New Jersey is 

expected to approve and submit the BART elements of the title V permits to EPA, as a 

supplement to the July 2009 RH SIP, in November 2011. 

PM

New Jersey considered three control measures as potentially BART applicable for control of PM 

emissions and determined that the continued requirement of “good combustion practices” and the 

upgrade to the refinery fuel gas system represents BART for the eleven process heaters. For 
30

details, the reader is referred to Table 7 on p 16 of New Jersey’s TSD and to CP’s analysis found 

in Appendix G8 of the State’s July 2009 RH SIP. New Jersey determined that implementation of 

either wet scrubbers or ESPs were not technically feasible with refinery fuel gas that already has 

low sulfur concentrations. In addition, New Jersey’s NOx regulation, Subchapter 19, requires 

annual adjustment of the process heaters in accordance with manufacture’s recommended 

procedure and maintenance schedule to ensure complete combustion through “good combustion 

practices.” Annual adjustment to the combustion practice is expected to limit NOx and also PM 

emissions. Furthermore, the upgrade to the refinery fuel gas system will lower SO2 emissions, a 

precursor of fine PM, from the process heaters. New Jersey expects PM emissions to be in the 

approximate range of 0.01 to 0.02 lb/MM BTU (see Table 16 on p 26 of New Jersey’s TSD). 

EPA does not have any BART presumptive limits for PM. 

New Jersey has established BART PM emission limits, expressed in pounds per hour, for the 

eleven process heaters and are summarized in Table 16 on p 26 of the State’s TSD. As stated 

above, New Jersey is expected to approve and submit the BART elements of the title V permits 

to EPA, as a supplement to the July 2009 RH SIP, in November 2011.

EPA’s Evaluation of New Jersey’s BART Determination for ConocoPhillips

EPA agrees with New Jersey’s determinations for establishing BART requirements on the eleven 

process heaters subject to BART at the ConocoPhillips Bayway Refinery. Since the State 

determined that the existing control measures are BART, New Jersey conducted a limited rather 

than a full 5-factor analysis for determining BART. In its analysis, New Jersey examined 

applicable control technologies and established that SCR technology was not cost effective for 

controlling NOx emissions. For SO2 and PM, New Jersey determined that that the evaluated 

control technologies were not practically feasible. In its March 2011 TSD, and as noted above, 

New Jersey also established that either the actual or permitted emission limits are as follows: 

NOx (0.04 lb/MM BTU measured average; and approximately 0.09 lb/MM BTU permit), SO2

(0.033 lb/MM BTU equivalent permitted) and PM (0.01-0.02 lb/MM BTU permit). EPA 

considers that these emissions are equivalent to or better than what could be achieved on a coal 

fired boiler using maximum controls, i.e. SCR, scrubber and a baghouse (see discussion above 

for the PSEG Hudson Unit 2 that has the SCR, scrubber and baghouse configuration that EPA 

considers as maximum controls). EPA is in agreement with New Jersey’s limited evaluation for 

determining BART for the eleven process heaters at CP for the following reasons: (1) emission 

levels of the three visibility impairing pollutants at CP are low and equivalent to emissions levels 

at coal-fired EGUs that implement maximum control technology; and (2) in accordance with 

EPA guidance, a state is not required to include a five factor analysis for a BART source that 

implements maximum controls; and (3) New Jersey evaluated alternative control technologies 

that were determined to be not feasible. 

New Jersey will be including the BART requirements in a SIP supplement including final title V 

permits and a summary of BART compliance requirements for monitoring, reporting and 

recordkeeping. New Jersey plans to submit this SIP supplement during November 2011. Since 

New Jersey has establishing BART requirements and is including these requirements in 

enforceable permits, in accordance with EPA guidance, EPA recommends proposed approval of 

New Jersey’s BART determination for the ConocoPhillips Bayway Refinery. 

Determination of BART – Additional BART Eligible Facilities in New Jersey

During EPA’s review of New Jersey’s July 2009 and March 2011 RH SIP, EPA discovered that 

two other facilities within the State had units that were BART eligible. These two facilities were 

not originally identified by New Jersey as BART eligible since the facilities indicated they
31

planned to shut down but later withdrew this request. EPA has worked closely with New Jersey

in determining BART for these two facilities. As a result, in a letter dated July 25, 2011 from the 

State addressed to EPA, New Jersey provides an addendum to its March 2011 TSD that discusses 

its BART determination for the two additional facilities that are BART eligible. For additional 

details, the reader is referred to New Jersey’s July 2011 letter to EPA that is located in the 

electronic docket for this rulemaking. In the July 2011 letter, New Jersey has indicated that its 

BART determination, as summarized in a new addendum to the March 2011 TSD, will be 

submitted to EPA in November for approval as a supplement to the State’s July 2009 RH SIP, 

after the opportunity for public comment. 

Following is New Jersey’s determination of BART for the two facilities, Vineland Municipal 

Electric Utility and BL England Generating Station, as indicated in New Jersey’s July 2011 letter 

to EPA, as well as EPA’s evaluation of New Jersey’s BART determination. 

Vineland Municipal Electric Utility

The first BART eligible source, Unit 10 at Vineland Municipal Electric Utility’s Howard M. 

Down Station is under a Federal consent decree12 to either install additional pollution control 

measures or to permanently shut down by September 1, 2012. On July 1, 2011, Vineland’s 

Director submitted written certification to EPA and New Jersey that Unit 10 will be retired from 

service by September 1, 2012. Vineland is required to submit a permit application by July 30, 

2011 and New Jersey plans to submit this element of the permit to EPA as a supplement to the 

RH SIP by November 2011. It should be noted that after Unit 10 is permanently shut down, the 

facility, in accordance with EPA’s Guidelines, will no longer be BART eligible since the PTE of 

each visibility impairing pollutant will be less than 250 tpy. An additional BART eligible unit at 

this facility is a distillate fuel oil-fired emergency generator, rated at 2.3 MM BTU/hr, that has 

not operated for more than 10 years. Since this emergency generator is small and rarely used, 

New Jersey and EPA consider the current operation as BART and therefore does not need to 

implement additional controls. New Jersey requires that the facility maintain records of 

emergency use and report any annual emissions. Furthermore, as previously stated, once Unit 10 

is permanently shut down, the facility, including the emergency generator, will no longer be 

BART eligible. EPA is in agreement with New Jersey’s BART determination for the two units 

at Vineland because it conforms to EPA’s BART Guidelines. Therefore, EPA proposes approval 

of New Jersey’s BART determination for Vineland. 

BL England Generating Facility

The second BART eligible facility is the BL England Generating Station, located in Cape May

County, owned/operated by RC Cape May Holding. This facility has three electric generating 

units that are BART eligible - Units 1, 2 and 3 - as well as three miscellaneous units including a 

coal handling system that supports Units 1 and 2; a cooling tower that supports Unit 3; and an 

emergency fire water diesel engine. Units 1 and 2 are currently under an administrative 

compliance order13 (ACO), as amended in January 2010, with New Jersey to either repower or 

meet performance requirements for NOx, SO2 and PM. The ACO requirements for Units 1 and 

 

12 US District Court in New Jersey, Civil Action 1:11-cv-1826(RMB-JS), see paragraph 14. 

13 See Attachment 5 and 6 to New Jersey’s TSD dated July 25, 2011. 
32

2 are already included in the title V permit. New Jersey has determined that the required future 

controls on Units 1 and 2, both coal-fired boilers, and the current and future controls on Unit 3, 

an oil-fired boiler, are BART. New Jersey defines “repowering” to mean the replacement of an 

existing coal-fired boiler with a new heat source (e.g., natural gas or distillate oil) or new coalcombustion technology (e.g., circulating fluidized bed boilers or integrated gasification 

combined-cycle (IGCC) technology. RC Cape May Holding has indicated to New Jersey that it 

is evaluating the conversion of Units 1, 2 and 3 to either natural gas or No. 2 fuel oil. It should 

be noted that the State’s Sulfur in Fuel Oil regulation, Subchapter 9, limits the sulfur content of 

No. 2 Fuel Oil to not more than 0.015% effective July 1, 2016. To the extent that RC Cap May

decides to convert one or all of the units, New Jersey anticipates that RC Cape May would 

submit a specific proposal that addresses applicable requirements including BART. For the 

reasons stated in the discussion below, EPA is proposing approval of New Jersey’s BART 

determination for the BL England facility.

Following are additional details for each unit. 

Unit 1

Unit 1 is a 129 MW cyclone wet bottom coal fired boiler and permitted to combust up to 8% tire 

derive fuel (TDF) or No. 6 Fuel Oil. Under the amended ACO, this unit must either repower by 

December 15, 2011 or meet performance standards by December 15, 2013. The new 

performance standards are as follows: (1) for NOx, the existing SNCR will be replaced with 

SCR and the existing over fire air (OFA) control system will remain - to lower NOx emissions 

from 0.60 lb/MM BTU (seasonal) to 0.11 lb/MM BTU on a 30-day average and 0.15 lb/MM 

BTU on a 24-hr average; (2) for SO2, install a circulating dry scrubber to meet an emission limit 

of 0.15 on a 30-day rolling average and 0.25 lb/MM BTU on a 24-hr average; for PM, upgrade 

the electrostatic precipitator, and meet an emission limit of 0.03 lb/MM BTU. As a result, New 

Jersey’s TSD indicates that NOx emissions will be reduced by about 85% and SO2 emissions will 

be reduced by about 97% (see Table 9A in New Jersey’s TSD). EPA considers that, by

December 15, 2013, Unit 1 will be implementing maximum control measures for limiting 

emissions of NOx, SO2 and PM that meet EPA’s BART guidance14 and therefore EPA agrees 

with New Jersey’s determination. If the owners decide to repower, New Jersey requires the 

owners to incorporate advances in the art of air pollution control and EPA expects that emissions 

will be at least equal to or lower than the performance standards indicated above. 

It should be noted that RC Cape May, the owner/operator, has indicated to New Jersey that there 

is some uncertainty as to the start-up date of Unit1 and therefore they believe that this Unit may

possibly not be BART eligible. However, New Jersey has indicated that until RC Cape May can 

provide proper documentation as to the start-up date, Unit 1 will be considered BART eligible. 

Unit 2

Unit 2 is a 160 MW cyclone wet bottom coal-fired boiler and permitted to combust up to 8% 

TDF or No. 6 Fuel Oil. In accordance with the amended ACO, Unit 2 must repower by 

December 15, 2011 or meet performance standards for SO2 and PM by May 1, 2010, and NOx 

 

14 See EPA’s document “Additional Regional Haze Questions” August 24, 2001. See Q&A # 15.
33

performance standards by May 1, 2012. The required performance standards are as follows: (1) 

for NOx, upgrade the current controls (selective non-catalytic reduction (SNCR) by installing

selective catalytic reduction (SCR) and continue to implement the existing over fire air (OFA) 

controls to achieve an emission limit of 0.11 lb/MM BTU on a 30-day rolling average and 0.15 

lb/MM BTU on a 24-hr average; (2) for SO2, continue utilizing (compliance as of May 1, 2010) 

wet flue gas desulfurization (FGD) controls for limiting emissions to 0.15 lb/MM BTU on a 30-

day rolling average and 0.25 on a 24-hr average; (3) for PM, continue (compliance as of May 1, 

2010) the use of an electrostatic precipitator (ESP) for controlling emissions to 0.030 lb/MM 

BTU on a 3-hr average. EPA considers that, by May 1, 2012, Unit 2 will be implementing 

maximum control measures for limiting emissions of NOx, SO2 and PM that meet EPA’s BART 

guidance and therefore EPA agrees with New Jersey’s BART determination. If the owners 

decide to repower, New Jersey requires the owners to incorporate advances in the art of air 

pollution control and EPA expects that emissions will be at least equal to or lower than the 

required amended ACO performance standards indicated above. 

Unit 3 

Unit 3 is a 160 MW oil-fired tangential boiler that combusts No. 6 Fuel Oil and primarily 

operates during the summer season on days when the demand for electricity is high (high electric 

demand days (HEDD)). Since 2008, the annual operating capacity factor has averaged about 3% 

and has not been more than 32% since 1999. This unit annually employs SNCR controls and 

must meet a NOx permit limit of 2.0 lb/MW-hr (equivalent to 0.20 lb/MM BTU) by May 1, 

2015. For controlling SO2 emissions this unit combusts No. 6 fuel oil with a sulfur limit of 

0.70% which is lower than EPA’s presumptive limit for an oil fired boiler. In accordance with 

New Jersey’s Sulfur in Fuels regulation, Subchapter 9, this unit will be required to combust No. 

6 Fuel Oil with a sulfur content of not more than 0.50% by July 1, 2014. PM emissions are 

controlled with a mechanical cyclone and permitted at 505 lb/hr (equivalent to 0.29 lb/MM 

BTU). Since this is an HEDD unit that operates for very limited periods and includes SNCR 

control and low sulfur fuel oil, emissions are relatively low. EPA considers that, by May 1, 

2015, Unit 3 will be implementing maximum control measures for limiting emissions of NOx, 

SO2 and PM that meet EPA’s BART guidance and therefore EPA agrees with New Jersey’s 

BART determination. 

Coal Handling System

There are nine units in the coal handling system that provides support to the two coal-fired units. 

These units emit PM but not NOx or SO2. To minimize PM emissions, these unloading, 

processing and transfer units are covered and any fugitive PM emission are controlled with 

surfactant-based wet suppression (with the exception of 3 of the 9 units). New Jersey has 

indicated that the cumulative PTE for these nine units is 6.1 tpy. As with the PSEG coal 

handling system (see previous PSEG discussion for BART in this TSD), New Jersey and EPA 

consider these fugitive emissions to be minimal and therefore the existing controls are BART. 

Emergency Fire Water Diesel Engine

When in operation, this diesel engine emits NOx, SO2 and PM. New Jersey notes that this unit 

typically operates for less than two hours per year and, by July 1, 2016, will be required to 

combust oil with a sulfur content not more than 0.015% (15 ppm). This lower sulfur oil is much 

lower than EPA’s presumptive limit (1.0% sulfur) for an oil fired boiler. Because of limited use, 

the implementation of any control on this emergency engine is most probably not cost effective. 

Therefore, New Jersey and EPA conclude that this engine does not need additional controls 
34

because its emissions are small and it operates very infrequently. For these reasons, EPA agrees 

with New Jersey’s BART determination. 

Unit 3 Cooling Tower

PM are the only emissions from this unit. This natural draft cooling tower circulates treated sea 

water in a closed loop system and is equipped with high efficiency mist eliminators. The use of 

a high efficiency mist eliminator minimizes PM emissions and therefore this control measure is 

considered BART. 

Recommendation 

In summary, EPA should propose approval of New Jersey’s BART eligibility determinations and 

BART requirements as they provide for maximum controls where feasible. EPA agrees with 

New Jersey’s evaluation of those units which are not eligible for BART or are too small for 

control.
35

 Attachment

Review of New Jersey State-wide 2002 and 2018 Projection Modeling Inventories 

and Reasonable Progress Goal Inventory Demonstration 

for the Regional Haze SIP, December 7, 2010

PREFACE

This document is to support EPA's evaluation of the 2018 projection inventories and Reasonable 

Progress Goal (RPG) Plan included in New Jersey’s Regional Haze State Implementation Plan 

(SIP) for the entire State of New Jersey. The intended effect of this action is to evaluate 

inventory components required by the Clean Air Act (Act) to summarize the emission reductions 

needed from 2002 to 2018 to meet the goal of improving visibility at Class I areas affected by

New Jersey. However, detailed evaluation of the 2002 inventory will not be addressed in this 

document. The reader is referred to Region 2’s document entitled New Jersey State 2002 Base 

Year Inventory SIP Technical Support Documentation for details on the approval of New 

Jersey’s 2002 base year inventory. EPA proposed to approve New Jersey’s 2002 Base Year 

inventories on May 9, 2006, (71 FR 26895) and approved the emission inventories on July 10, 

2006 (71 FR 38770). 

This document contains a detailed review of the New Jersey’s submittal. Among the topics 

discussed below are: background and criteria for approval and EPA’s final recommendation.

BACKGROUND

REASONABLE PROGRESS GOALS 

Section 51.308(d)(4)(v) of EPA’s Regional Haze Rule (RHR), 40 CFR 51.308, requires the 

establishment of a statewide emissions inventory of pollutants that are reasonably anticipated to 

cause or contribute to visibility impairment in any mandatory Class I area. The pollutants 

inventoried by New Jersey include VOC, NOx, PM2.5, PM10, SO2 and NH3. In addition, 

Section 51.308(d)(3)(iii) of RHR requires the State to identify a baseline emissions inventory

upon which future projections will be based and from which necessary emission reductions for 

meeting reasonable progress goals can be determined. This document provides information on 

the development of a projected inventory for 2018 from the 2002 base year.

The 2018 Reasonable Progress Goal Plans Inventory Demonstration

The State is required to submit a Regional Haze SIP that includes a Reasonable Progress Goal 

(RPG) Plan inventory demonstration for pollutants that contribute to Regional Haze. The SIPs 

must demonstrate that the 2002 base year inventory, projected to 2018 with growth and including

control measures incorporated in rules that are adequate to provide for the timely reasonable 

progress in reducing emissions to reach 2018 projected emissions inventory control levels.
36

There are general and specific components for an acceptable 2018 projection inventory and RPG 

inventory demonstration. In general, the State must submit a revision to its SIP and the 

aforementioned components must meet certain minimum requirements for reporting by source 

category. Specifically, the source requirements are detailed below.

A review process is used to determine that all components of the projection inventories and RPG

inventory demonstration are present. The review also evaluates the level of supporting 

documentation provided by the State and assesses whether the emissions were developed 

according to current EPA or acceptable alternative guidance. 

CRITERIA FOR APPROVAL

Projection and RPG Inventory Demonstration

There are several points that the projection inventories and RPG inventory demonstration must 

adequately address. For the projection inventories and RPG inventory demonstration to be 

acceptable they must pass the following acceptance criteria: 

1. Were the 2018 projection inventories developed in accordance with the procedures 

outlined EPA’s latest guidance 1,3,4,6,7? 

2. Were the Plans developed in accordance with EPA’s latest guidance for Growth 

Factors, Projections, and Control Strategies for Reasonable Progress Goal Plans

1,3,4,6,7? 

DETAILED ACTION AND EVALUATION

This portion of the report contains a discussion and summary of the review conducted by EPA 

for the 2018 projection inventories and RPG inventory demonstration.

Section 1: 2002 BASE YEAR INVENTORY

Calculation of 2002 Base Year Emission Inventory

The reader is referred to Region 2’s document entitled New Jersey State 2002 Base Year 

Inventory SIP Technical Support Documentation for details on the approval of New Jersey’s 

2002 base year inventory. EPA proposed to approve New Jersey’s 2002 Base Year inventories 

on May 9, 2006, (71 FR 26895) and approved the emission inventories on July 10, 2006 (71 FR 

38770). The reader is referred to these rulemakings for additional information concerning the 

emission inventories and EPA’s approval. 
37

Table 1 below shows the revised 2002 VOC, NOx, PM2.5, PM10, SO2 and NH3 state-wide 

modeling base year emission inventories for the New Jersey.

Table 1

2002 New Jersey 

Statewide Base Year Modeling Inventory (Tons/Year)

Pollutant

Major Point 

Sources Area Sources

Nonroad 

Mobile 

Sources

Onroad 

Mobile 

Sources Total

VOC 16,547 167,883 83,919 110,529 378,877

NOx 51,593 26,692 63,479 161,289 303,053

PM2.5 4,779 17,004 4,997 2,529 29,350

PM10 6,072 31,664 5,501 3,785 47,021

SO2 61,217 10,744 15,686 3,627 91,373

NH3 0 17,572 43 7,316 24,931

Section 2: Calculation of 2018 Projection Year Emission Inventories

A projection of 2002 VOC, NOx, PM2.5, PM10, SO2 and NH3 anthropogenic emissions to 2018

is required to determine the emission reductions needed for RPG inventory demonstration. The 

2018 projection year emission inventories are calculated by multiplying the 2002 base year 

inventory by factors which estimate growth from 2002 to 2018. A specific growth factor for 

each source type in the inventory is required since sources typically grow at different rates. 

Projection Methodology

Point Sources

Electric Generating Units (EGUs)

For the major point source category, the projected emissions inventories were first calculated by 

estimating growth in each source category. As appropriate, the 2002 emissions inventory was 

used as the base for applying factors to account for inventory growth. The point source 

inventory was grown from the 2002 inventory to 2018 for each facility using growth factors 

utilized in Integrated Planning Model to forecast growth based on the following 

variables/factors: electric demand; natural gas, oil and coal supply forecasts; pollution control 

and performance; capacity cost and performance, and replacement of older less efficient and 

polluting power plants with newer more efficient units to meet future growth and state by state 

NOx and SO2 caps.

The reader is referred to Section 5 of State of New Jersey Department of Environmental 

Protection SIP for Regional Haze Final, dated July 2009, and Documentation of 2018 Emissions 
38

from EGUs in the Eastern United States for MANE-VU’s Regional Haze Modeling, dated 

August 15, 2009. These documents provide further details and references on how projections 

were performed.

Non-Electric Generating Units (Non-EGUs)

For the major point source category, the projected emissions inventories were first calculated by 

estimating growth in each source category. As appropriate, the 2002 emissions inventory was 

used as the base for applying factors to account for inventory growth. The point source 

inventory was grown from the 2002 inventory to 2018 for each facility based on source 

classification codes using growth factors generated from EPA’s Economic Growth Analysis 

System (EGAS) version 5.0, United States Department of Energy’s (USDOE) Annual Energy

Outlook Projections (AEO) 2005, state supplied population and employment data, where 

appropriate. 

The reader is referred to Section 5 of State of New Jersey Department of Environmental 

Protection SIP for Regional Haze Final, dated July 2009 and Development of Emissions 

Projections for 2009, 2012 and 2018 for Non-EGU Point, Area and Nonroad Mobile Sources in 

the MANE-VU Region, Final Report, dated February 2007. These documents provide further 

details and references on how projections were performed. 

Since these methods and growth indicators are some of the preferred growth indicators to use as 

outlined in EPA Guidance, 1,3,4,6,7

EPA finds New Jersey’s methodology for projecting point sources to be acceptable.

Area Sources

For the area source category, New Jersey projected emissions from 2002 to 2018 using growth 

factors generated from EPA’s EGAS version 5.0, USDOE AEO 2005, state supplied population 

and employment data, where appropriate. 

This is in accordance with EPA’s recommended growth indicators for projecting emissions for 

area source categories as outlined in EPA Guidance. 1,3,4,6,7 

The reader is referred to Section 5 of State of New Jersey Department of Environmental 

Protection SIP for Regional Haze Final, dated July 2009 and Development of Emissions 

Projections for 2009, 2012 and 2018 for Non-EGU Point, Area and Nonroad Mobile Sources in 

the MANE-VU Region, Final Report, dated February 2007. These documents provide further 

details and references on how projections were performed. 

EPA finds New Jersey’s methodology for projecting area sources to be acceptable.
39

Non-Road Mobile Sources

Non-road vehicle equipment emissions were projected from 2002 to 2018 using the EPA’s 

National Mobile Inventory Model (NMIM) 2005. NMIM 2005 contains growth factors, which 

are based on the historical trends in nonroad equipment activity. This model was use to calculate 

past and future emission inventories for all nonroad equipment categories except commercial 

marine vessels, locomotives and aircrafts. Emissions were determined on a monthly basis and 

combined to provide annual emission estimates.

Aircrafts, Locomotives and Commercial Marine Vessels (CMV)

Aircraft, locomotives and CMV emissions were projected based on combined growth and control 

factors from USEPA Clean Air Interstate Rule (CAIR) by determining the level of emissions and 

their associated ratios between 2002 base and 2025 projection year. From this point, the State 

determine the ratio of emissions between 2002 and 2018 projection year using linear 

interpolation. The ratios between 2002 and 2018 were determined and then multiplied by the 

2002 base year to determine 2018 projection year emissions.

The reader is referred to Section 5 of State of New Jersey Department of Environmental 

Protection SIP for Regional Haze Final, dated July 2009 and Development of Emissions 

Projections for 2009, 2012 and 2018 for Non-EGU Point, Area and Nonroad Mobile Sources in 

the MANE-VU Region, Final Report, dated February 2007. These documents provide further 

details and references on how projections were performed. 

EPA finds New Jersey’s methodology for projecting non-road mobile sources to be 

acceptable.

Onroad Mobile Sources

For the onroad mobile source category, the primary indicator and tool for developing on-road 

mobile growth and expected emissions are vehicle miles traveled (VMT) and US EPA’s mobile 

emissions model Mobile 6.2.03 (Mobile6.2). The 2018 pollutant emission factors were 

generated by Mobile6.2 (with the associated controlled measures applied, where appropriate) and 

applied to the monthly VMT projections provided by the State. Monthly emissions were then 

combined to develop annual emission estimates.

The reader is referred to Section 5 of State of New Jersey Department of Environmental 

Protection SIP for Regional Haze Final, dated July 2009 and Development of MANE-VU 

Mobile Source Projection Inventories for SMOKE/MOBILE6 Application, June 2006. This 

document provides further details and references on how projections were performed. 

Since these growth indicators are some of the preferred growth indicators to use, as outlined in 

EPA Guidance, 1,3,4,6,7 EPA finds New Jersey’s methodology for projecting on-road mobile 

sources to be acceptable.
40

Table 2A shows 2018 projection emission inventories controlled after 2002 using the 

aforementioned growth indicators/methodologies for the New Jersey State. Table 2B (attached, 

separately) shows the 2002-2018 control measures.

Table 2A

New Jersey State

2018 Projection Year Modeling Inventory (Controlled)

(Tons/Year)

Pollutant

Major Point 

Sources Area Sources

Nonroad 

Mobile 

Sources

Onroad Mobile 

Sources Total

VOC 20,267 134,089 53,625 31,415 239,396

NOx 31,100 21,684 41,166 30,150 124,100

PM2.5 7,745 15,220 3,143 1,140 27,247

PM10 8,969 31,874 3,489 1,232 45,564

SO2 23,421 1,781 832 735 26,819

NH3 564 21,435 52 8,555 30,606

Section 3: 2008 RPG Inventory Demonstration

Section 3A: Inventory Demonstration Requirements1,2,3,4,5,6,7

1. For the New Jersey, state-wide Regional Haze pollutant 

precursors’ annual emissions should be projected from the 

2002 base to the future 2018 year. Provide summary of 

statewide emissions for point, area, nonroad and onroad 

mobile sources.

2. State must provide a demonstration which shows that the 

2002 base projected to 2018 (with growth and controls) will 

reach 2018 controlled emission levels. Provide state-wide 

summary of emissions for point, area, nonroad mobile and 

onroad mobile sources.

3. Provide an explanation on how the 2018 point, area, nonroad 

mobile and onroad mobile source projection inventories are 
41

developed.

Section 3B: How New Jersey Meets the Criteria for the 2018 RPG Inventory

Demonstration

 For the New Jersey, state-wide Regional Haze pollutant 

precursors’ annual emissions should be projected from the 

2002 base to the future 2018 year. Provide summary of 

statewide emissions for point, area, nonroad and onroad 

mobile sources.

Sections 1 and 2, provide detailed answers to these questions. New Jersey has satisfied the 

criteria for 2002 base year projected to 2018 (controlled) projection inventory 

requirements.

 State must provide a demonstration which shows that the 2002 base projected to 

2018 (with growth and controls) will reach 2018 controlled emission levels. Provide 

state-wide summary of emissions for point, area, nonroad mobile and onroad mobile 

sources.

Sections 1 and 2 and Tables 2A and 2B provide detailed answers to these questions. New Jersey

has satisfied the criteria for 2002 base year projected to 2018 (controlled) projection 

inventory requirements.

 Provide an explanation on how the 2018 point, area, nonroad 

mobile and onroad mobile source projection inventories are 

developed.

Sections 1 and 2, provide detailed answers to these questions. New Jersey has satisfied the 

criteria for 2002 base year projected to 2018 (controlled) projection inventory 

requirements.
42

Emission Inventory Guidance Documents

1

Emission Inventory Improvement Program guidance document titled Volume X, Emission 

Projections, dated December 1999 

2

EPA Checklist for Regional Haze SIPs, dated August 4, 2006

3Guidance for Growth Factors, Projections, and Control Strategies for the 15 Percent Rate of 

Progress Plans, dated March 1993

4Guidance on the Post-1996 Rate of Progress Plan and Attainment Demonstration, dated January

1994?

5Emission Inventory Guidance for Implementation of ozone and Particulate Matter NAAQS and 

Regional Haze Regulation, dated August 2005

6

EPA’s follow-up memo “8-Hour Ozone National Ambient Air Quality Standards 

Implementation-Reasonable Further Progress (RFP), dated August 2006

7Guidance on the Use of Models and Other Analyses for Demonstration Attainment of Air 

Quality Goals for Ozone, PM2.5 and Regional Haze, dated April 2007