1

SECTION 2

2007 Attainment and 2017 and 2025 Projection Inventories

for the

Northern and Southern New Jersey 

PM2.5 Redesignation Full Maintenance Plan SIP

Technical Support Document 
2

A. Background

The maintenance demonstration must demonstrate effective safeguards of the NAAQS for at least 10 years 

following the redesignation showing that future year PM2.5 and associated precursors emissions will not exceed 

the level of the attainment year. For the Northern New Jersey (NNJ) and Southern New Jersey (SNJ) PM2.5 

nonattainment areas, 2007 emissions were projected to 2017 and 2025. New Jersey must demonstrate, with the 

control programs identified in this SIP, that total 2017 or 2025 projected emissions do not exceed the 2007 

emission levels. Below are EPA=s review and evaluation of the maintenance demonstration for the two areas.

Inventory Requirements for a Redesignation/Full Maintenance Plan

Sections 110(a)(1) and 175A of the CAA, coupled with page 10, paragraphs 1-3, of the March 2, 2012, memo 

entitled Implementation Plan Guidance for the 2006 24-hour PM2.5 NAAQS from Stephen D. Page, Director, 

OAQPS, to Regional Air Directors require that the State submit following inventory elements to satisfy 

redesignation/maintenance plan inventory requirements. 

Maintenance Plan Attainment Inventory

Maintenance plan provisions include a comprehensive, accurate, and current emission inventory from all 

sources of relevant pollutants in the nonattainment area. States are required to develop an attainment inventory 

to identify the level of emissions in the area which is sufficient to attain the NAAQS. This inventory should be 

consistent with EPA=s most recent guidance and should include the emissions during the time period associated 

with the monitoring data showing attainment.

Maintenance Plan Interim Year Inventory

At a minimum, emissions should be projected to a midpoint year between the attainment year and the 

endpoint/10-year inventory. This is the interim inventory. Provide summary of controlled emissions for point, 

area, nonroad and onroad mobile sources for the PM2.5 nonattainment area for the interim year inventory.

Maintenance Plan Projected Final Year Inventory

Emissions should be projected from the attainment year to at least 10 years into the future. Provide summary of 

controlled emissions for point, area, nonroad and onroad mobile sources. This is the endpoint/10-year 

inventory.

B. Selection of 2007 Base Year as the Maintenance Plan Attainment Year Inventory

For the NNJ and SNJ PM2.5 nonattainment areas, air quality monitoring data shows that for 2007-2009 was not 

in violation of the PM2.5 annual standard. For 2007-2010, monitoring data shows that NNJ PM2.5 

nonattainment area was not in violation of the PM2.5 daily standard. For 2008-2010, monitoring data shows 
3

that SNJ PM2.5 nonattainment area was not in violation of the PM2.5 daily standard. However, for 2007, the 

SNJ was in violation of the PM2.5 daily standard. Historically, for the attainment inventory the state would 

select an attainment year inventory based on the year in which an area is not in violation of the standard. This 

means for the SNJ PM2.5 nonattainment area, that New Jersey should have selected 2008 or 2009 as the 

attainment year inventory for the PM2.5 daily standard. However, the State believes that the 2007 inventory is 

an appropriate and representative inventory to use as a surrogate attainment inventory for the 2008 inventory for 

the SNJ PM2.5 nonattainment area for the daily standard for several reasons discussed as follows:

• The 2007 inventory is the most comprehensive inventory developed by states in the region for SIP 

purposes.

• The monitors in the SNJ nonattainment area showed compliance with the 35 μg/m3 daily standard during 

the 2007-2009 monitoring period. However, sampling errors resulted in incomplete data for 2007 in the 

SNJ area, which was not able to be addressed through data substitution and statistical analysis. 

Incomplete data also existed for the 2008-2010 monitoring period, but was able to be addressed through 

data substitution and statistical analysis.

• The monitors in the New Jersey portion of the SNJ nonattainment area showed compliance with the 35 

μg/m3 daily standard during the 2007-2009 monitoring period. 

• The 2007 and 2008 emission inventories are comparable, as demonstrated by a comparison of New 

Jersey’s 2007 inventory with USEPA’s 2008 National Emissions Inventory (NEI).

• Most important, comparison of the 2008 to the 2017and 2025 inventories, shows that emissions will 

continue to decrease and will be well below the 2007 and 2008 PM2.5 levels for PM2.5 and its 

precursors, NOx, and SO2, in the SNJ PM2.5 nonattainment area.

For these reasons, the State selected the 2007 inventory as a surrogate for the 2008 inventory and will be used as 

the attainment inventory for the SNJ and NNJ PM2.5 nonattainment areas for the PM2.5 daily and annual 

standard. Thus, the 2007 base year emissions inventory will used as the attainment year inventory for the 

PM2.5 redesignation maintenance plan. The emission estimates were prepared in accordance with EPA 

guidance. 

EPA is approving the 2007 PM2.5 inventory for the Northern and Southern New Jersey PM2.5 nonattainment 

areas. Detailed evaluation of the 2007 inventory is located in Section 1 of EPA’s TSD. Tables 1A-B below 

shows the 2007 base year PM2.5, NOx and SO2 emission inventories for the NNJ and SNJ PM2.5 

nonattainment areas.
4

Table 1A

2007 Northern New Jersey PM2.5 Nonattainment Area

Base Year Inventory (in Tons/Year)

Pollutant Point Area Nonroad Mobile Onroad Mobile Total

PM 2.5 4,937 5,498 2,497 3,677 16,610

NOX 15,828 16,122 39.457 93,385 164,793

SOX 20,360 4,983 5,761 586 31,690

Table 1B

2007 Southern New Jersey PM2.5 Nonattainment Area 

Base Year Inventory (in Tons/Year)

Pollutant Point Area Nonroad Mobile Onroad Mobile Total

PM 2.5 800 2,837 560 1,055 5,159

NOX 4,453 3,483 6,790 26,992 41,718

SOX 2,034 1,128 1,642 161 4,965

C. 2017 and 2025 Projection Inventories

There are general and specific components for an acceptable 2017 and 2025 projection. 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 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. For the projection inventories to 

be acceptable they must pass the following acceptance criteria: 

1. Were the 2017 and 2025 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? 
5

D. Calculation of 2017 and 2025 Projection Year Emission Inventories

A projection of 2007 PM2.5, NOx, and SO2 anthropogenic emissions to 2017 and 2025 is required to determine 

the emission reductions needed for inventory maintenance plan. The 2017 and 2025 projection year emission 

inventories are calculated by multiplying the 2007 base year inventory by factors which estimate growth from 

2007 to 2017 and 2025. A specific growth factor for each source type in the inventory is required since sources 

typically grow at different rates. 

Projection Methodology

Major Point Sources

Electric Generating Units (EGU) and 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 2007 emissions inventory was used as the base for applying 

factors to account for inventory growth. The point source inventory was grown from the 2007 inventory to 2017 

and 2025 for each facility using growth factors utilized in New Jersey’s Emissions Statement Program, US 

Department of Energy’s (USDOE) Annual Energy Outlook projections, and NJ Department of Labor statistics.

The reader is referred to Appendix VI of New Jersey’s document entitled SIP Revision for the Attainment and 

Maintenance of the PM2.5 NAAQS (NJ PM2.5 SIP), dated July 18, 2012. This document provides further 

details and references on how projections were performed. 

Since these methodologies and growth indicators are some of the preferred growth indicators to use as outlined 

in EPA Guidance, 1,3,4,6,7EPA finds New Jersey’s methodology for projecting point sources to be 

acceptable.

Area Sources

For the area source category, New Jersey projected emissions from 2007 to 2017 and 2025 using growth factors 

generated from USDOE AEO 2011, state supplied population and employment data, where appropriate. 

The reader is referred to Appendix VI and Appendix V, Attachment 6 of NJ’s PM2.5 SIP dated July 18, 2012. 

These documents provide further details and references on how projections were performed. 

Since these methodologies 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 area sources to be 

acceptable.
6

Non-Road Mobile Sources

Nonroad Vehicle Equipment Emissions

Non-road vehicle equipment emissions were projected from 2007 to 2017 and 2025 using the EPA’s 

NONROAD Model2008a (July 2009 Version) This model 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. 

Revised inputs to the model by the State included meteorological, fuel oil, housing unit and population data 

where appropriate. Emissions were determined on a monthly basis and combined to provide annual emission

estimates.

Aircrafts, Locomotives and Commercial Marine Vessels (CMV)

CMV emissions were projected from 2002 to 2017 and 2025 using EPA’s regulatory impact assessment (RIA) 

May 2008 RIA report, for category 1 and 2 vessels and EPA’s April 2009 RIA proposal and December 2009 

RIA report for category 3 vessels based on combined growth and control factors. 

Aircraft emissions were projected from 2007 to 2017 and 2025 based on landing and takeoff growth factors 

from the Federal Aviation Administration Terminal Area Forecast System for 2009-2030. 

Locomotives emissions were projected from 2007 to 2017 and 2025 based on combined growth and control 

factors from EPA’s Regulatory Impact Analysis in May 2008 for control of locomotive engines and USDOE’s

2006 Annual Energy Outlook report.

For nonroad mobile inventory, the reader is referred to Appendix VI of NJ’s PM2.5 SIP dated July 18, 2012. 

These documents provide further details and references on how projections were performed. 

Since these methodologies 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 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 

MOVES2010a. Projection years 2017 and 2025 pollutant emission factors were generated by MOVES2010a
7

(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 Appendix VII of NJ’s PM2.5 SIP dated July 18, 2012. These documents provide 

further details and references on how projections were performed

Since these methodologies 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 on-road mobile sources to be 

acceptable.

Tables 2A-3B shows the 2017 and 2025 projection emission inventories controlled after 2007 using the 

aforementioned growth indicators/methodologies for the NNJ and SNJ PM2.5 nonattainment areas, 

respectively. 

A listing of the control strategies can be found in the document, which is available in the docket, Technical 

Support Document for EPA’s Notice of Proposed Rulemaking for the New Jersey State Implementation Plan 

Revision: Redesignation of Areas for Air Quality Planning Purposes and Approval of the Associated 

Maintenance Plan for the 1997 and 2006 Fine Particle (PM2.5) Standards, Appendix A.
8

Table 2A

2017 Northern New Jersey PM2.5 Nonattainment Area 

Projection Year Inventory (Controlled)

(in Tons/Year)

Pollutant Point Area Nonroad Mobile Onroad Mobile Total

PM2.5 3,131 5,496 1,725 1874 12,227

NOX 13,512 15,969 27,050 45,687 102,218

SOX 3,583 452 719 531 5,295

Table 2B

2017 Southern New Jersey PM2.5 Nonattainment Area 

Projection Year Inventory (Controlled)

(in Tons/Year)

Pollutant Point Area Nonroad Mobile Onroad Mobile Total

PM2.5 818 2,743 372 616 4,549

NOX 4,126 3,429 4,998 13,504 26,057

SOX 1,245 102 105 129 1,579
9

Table 3A

2025 Northern New Jersey PM2.5 Nonattainment Area 

Projection Year Inventory (Controlled)

(in Tons/Year)

Pollutant Point Area Nonroad Mobile Onroad Mobile Total

PM2.5 3,243 5,616 1,410 1.218 11.487

NOX 13,454 16,059 21,711 20,546 71,769

SOX 3,900 1,157 888 539 6,483

Table 3B

2025 Southern New Jersey PM2.5 Nonattainment Area 

Projection Year Inventory (Controlled)

(in Tons/Year)

Pollutant Point Area Nonroad Mobile Onroad Mobile Total

PM2.5 858 2,651 315 278 4,102

NOX 4,433 3,427 3,915 6,095 17,870

SOX 1,355 260 141 161 1,880
10

Emission Inventory Guidance Documents

1

Emission Inventory Improvement Program guidance document titled Volume X, Emission Projections, dated 

December 1999 

2

Draft Notice of Proposed Rulemaking for PM2.5 SIPs, dated August 2010

3

Guidance for Growth Factors, Projections, and Control Strategies for the 15 Percent Rate of Progress Plans, 

dated March 1993

4

Guidance on the Post-1996 Rate of Progress Plan and Attainment Demonstration, dated January 1994

5

Emission 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

7

Guidance 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