1.0 REASONABLY AVAILABLE CONTROL MEASURE (RACM) 

ANALYSIS 

New Jersey reviewed control measures that if implemented, could help alleviate its Fine 

Particulate Matter (PM2.5) nonattainment problem. The measures would need to be 

reasonably available and advance the attainment date for the 1997 annual PM2.5 National 

Ambient Air Quality Standards (NAAQS) by at least one year. This appendix provides 

an analysis of both potential transportation control measures (TCMs) for onroad mobile 

sources and potential non-TCM control measures for point, area, onroad and nonroad 

source categories. 

In accordance with 42 U.S.C. §7502(c)(1) (Section 172(c)(1) of the Clean Air Act), 

states, as part of their effort to attain the NAAQS, are required to implement all RACMs 

as expeditiously as practicable. Specifically, the Clean Air Act states: 

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

reasonably available control measures as expeditiously as practicable (including 

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

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

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

standards.”

1.1 What is a RACM? 

A Reasonably Available Control Measure, or RACM, is defined by the USEPA as any 

potential control measure for application to point1, area, onroad and nonroad emission 

source categories that meets the following criteria: 

• The control measure is technologically feasible 

• The control measure is economically feasible 

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

adverse impacts” 

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

• The control measures, if considered collectively, could advance the attainment 

date by at least one year 

Each of these criteria is more fully discussed in Section 1.2.1 

 

1

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

Control Technology (RACT) analysis. The USEPA’s PM2.5 Implementation Rule (72 Fed. Reg. 20586 

(April 25, 2007)) considers RACT a part of RACM, and not an independent requirement, which is how 

RACT is considered in the Ozone Implementation Rule (70 Fed. Reg. 71611 – 705 (November 29, 2005)). 

However, New Jersey is conducting these two analyses separately, consistent with the approach used to 

address RACT and RACM requirements for 8-hour ozone. New Jersey’s separate RACT analysis for PM2.5

is contained in Appendix A7. 
2

1.1.1 USEPA RACM Requirements 

In its Final Rule to implement the fine particle National Ambient Air Quality Standard 

(NAAQS),2

 the USEPA established the following requirements for RACM: 

 

(a) For each PM2.5 nonattanment area, the State shall submit with the attainment 

demonstration, a SIP revision demonstrating that it has adopted all RACM 

(including reasonably available control technology (RACT)) necessary to 

demonstrate attainment as expeditiously as practicable and to meet any reasonable 

further progress (RFP) requirements. The SIP revision shall contain the list of the 

potential measures considered by the state, and information and analysis sufficient 

to support the state’s judgment that it has adopted all RACM, (including RACT). 

(b) In determining whether a particular emission reduction measure or set of 

measures must be adopted as RACM under section 172(c)(1) of the Act, the state 

must consider the cumulative impact of implementing the available measures. 

Potential measures that are reasonably available considering technical and 

economic feasibility must be adopted as RACM if, considered collectively, they 

would advance the attainment date by one year or more. 

Because New Jersey can demonstrate that both its 1997 annual PM2.5 nonattainment areas 

will attain by their required attainment dates (April 5, 2010), no RFP milestones are 

required.3 As such, RACM analysis is only needed to demonstrate advancement of the 

attainment date. 

1.2 PM2.5 RACM Analysis (by precursor) 

The USEPA requires that states address not only direct PM2.5, but also the gaseous 

precursors to the formation of PM2.5 in their RACM analysis.4 The main precursor gases 

associated with fine particle formation are SO2 and NOx, and to a lesser extent, volatile 

organic compounds (VOC) and ammonia.5

 However, as discussed in Chapter 3, the 

USEPA requires that RACM analysis only address the following PM2.5 precursors: 

- Direct emissions of PM2.5 

- SO2

- NOx, unless a state makes a finding that NOx emissions from sources in the state 

do not significantly contribute to the PM2.5 problem in a given nonattainment area. 

The USEPA generally presumes that a RACM analysis does not need to address 

ammonia and/or VOC unless the state or USEPA determines that ammonia and/or VOC 

significantly contribute to the PM2.5 problem in a given nonattainment area, and thus 

finds that control of ammonia and/or VOC would help address the PM2.5 problem. 

 

2

 72 Fed. Reg. 20666, §51.1010 (April 25, 2007). 3

 72 Fed. Reg. 20633 (April 25, 2007). 4

 72 Fed. Reg. 20629 (April 25, 2007). 5

 72 Fed. Reg. 20589 (April 25, 2007). 
3

Therefore this PM2.5 RACM analysis reviewed potential control measures that addressed 

direct PM2.5, SO2 and NOx. 

NOx measures were reviewed in the 8-hour ozone RACM analysis,6

 and this analysis 

satisfies the requirement to address NOx as a precursor to the formation of PM2.5 in the 

PM2.5 RACM analysis. New Jersey’s 8-hour ozone RACM analysis is included in 

Attachment A1 to this appendix. In addition, NOx measures included in the USEPA’s list 

of potential control measures7 were reviewed since this list was provided to the states 

after they had already submitted their 8-hour ozone RACM analysis. A VOC RACM 

analysis was completed for 8-hour ozone (submitted to the USEPA on October 29, 2007), 

and concluded that no reasonable measures were available for implementation to advance 

8-hour ozone attainment date. 

 

1.2.1 Methodology 

Potential control measures for mobile (both onroad and nonroad), stationary area, and 

stationary point (not already subject to PM2.5 RACT analysis) emission source categories 

were evaluated using the following criteria: The control measure is technologically 

feasible, economically feasible, does not cause “substantial widespread and long-term 

adverse impacts,” is not “absurd, unenforceable, or impracticable,” and the control 

measures, if considered collectively, could advance the attainment date by at least one 

year. 

The New Jersey Department of Transportation (NJDOT) conducted the RACM analysis 

for onroad mobile Transportation Control Measures (TCMs). The remainder of this 

section discusses the evaluation criteria used for these analyses. 

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

determine feasibility of timely implementation: 

• Relevant technology must exist or be reasonably expected to exist within the 

schedule allotted, be sufficiently available, and be applied to achieve a stated 

result. For transportation control measures, this item includes technological 

changes to vehicles, fuels, necessary infrastructure and similar considerations 

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

determine feasibility of timely implementation: 

• The cost of reducing emissions (i.e., cost per ton of emission reduced, cost per 

ton of emission reduced on high ozone days, capital costs and operating costs. 

The costs associated with a measure must be justifiable relative to benefits, and 

6

 NJDEP. Chapter 7 of “The State of New Jersey Department of Environmental Protection State 

Implementation Plan (SIP) Revision for the Attainment and Maintenance of the Ozone National Ambient 

Air Quality Standard - 8-Hour Ozone Attainment Demonstration, Final.” New Jersey Department of 

Environmental Protection. October 29, 2007. 

7

 The USEPA’s list of potential control measures for PM2.5 and Precursors is available at 

http://www.epa.gov/pm/measures/pm_control_measures_tables_ver1.pdf (accessed November 28, 2007). 
4

compare favorably with other potential emissions control measures (of all types 

on all emissions sources). Operating costs include both direct or variable costs 

and indirect or fixed costs. 

• No fixed $/ton was considered for reasonableness in this analysis; instead 

measures were justified on a case by case basis. 

• For some measures, feasibility depends on availability of funding and resources. 

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

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

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

following to determine feasibility of implementation: 

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

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

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

issues and energy requirements must be minimized. 

• Must be legally enforceable and legal under Federal and state law. 

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

emissions reductions. 

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

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

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

results. 

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

measures advance the attainment date by at least one year. The USEPA requires that 

states conduct an air quality modeling analysis to determine the attainment date of 

identified potential control measures.8

 The modeling analysis would be conducted for the 

year 2009. In order to advance the attainment by one year, the potential RACM measures 

would have to be implemented by 2008. 

 

8

 72 Fed. Reg. 20613 (April 25, 2007). 
5

1.2.2 Potential Control Measure Evaluation for Non-Transportation Control 

Measures 

Step 1 - Identification of Potential Control Measures

A list of 628 potential non-transportation control measures was compiled through review 

of various sources, including the USEPA, other states, Regional Planning Organizations 

(RPOs), New Jersey State Organizations, and existing NJDEP documents. 

Measures that addressed a top 15 direct PM2.5 or SO2 emitting category in the State 2002 

base year inventory or the 2009 projected regional inventory were included in this 

analysis. Measures that had the potential to achieve high emission reductions regardless 

of whether or not they addressed a top inventory category (either State or regional) were 

also included in the analysis. The top 15 direct PM2.5 and SO2 emitting categories in the 

New Jersey 2002 Periodic Emission Inventory and the 2009 Regional inventory are 

shown in Figures B1, B2, B3 and B4. 

Potential PM2.5 RACT measures were deleted from the list of measures to be evaluated in 

the RACM analysis because these measures are addressed in the PM2.5 RACT analysis 

(see Appendix A7), and TCMs were separated out because the NJDOT conducted the 

PM2.5 TCM analysis. 

Any measures that are already in place in New Jersey or are more stringently addressed at 

the Federal level were not included in the analysis. Measures whose potential emission 

reduction benefits were not quantifiable and measures that had no net emission reduction 

benefit in New Jersey were also excluded from the analysis and identical measures were 

combined. 
6

Figure A1: 2002 New Jersey PM2.5 (with Fugitive Dust*) Emission Inventory Top 15 by SCC

9,363

2,226

2,100

1,005

887

836

823

783

758

605

530

336

334

328

301

0 1,000 2,000 3,000 4,000 5,000 6,000 7,000 8,000 9,000 10,000

RESIDENTIAL WOOD COMBUSTION

RESTAURANT OPERATIONS

HEAVY DUTY DIESEL VEHICLES

EXTERNAL COMBUSTION - ELECTRIC BOILER BITUMINOUS COAL MISC.

WILDFIRE

RESIDENT IAL NATURAL GAS COMBUSTION

OUTBOARD PLEASURE CRAFT - 2 STROKE, GASOLINE

COMMERCIAL MARINE

PAVED ROADS - (F)

LIGHT DUTY GAS VEHICLE

COMMERCIAL NATURAL GAS COMBUSTION

LIGHT DUTY GASOLINE TRUCK (<6K lbs.)

MANAGED BURNING

PERSONAL WAT ER CRAFT - 2 STROKE, GASOLINE

RESIDENTIAL DISTILLAT E OIL COMBUSTION

Tons per Year

Area

Point

OnRoad

NonRoad

Figure A2: 2002 New Jersey SO2 Emission Inventory Top 15 by SCC

32,595

16,260

11,444

6,484

3,758

2,035

1,917

1,845

1,593

1,304

1,168

774

657

610

569

0 5,000 10,000 15,000 20,000 25,000 30,000 35,000

EXTERNAL COMBUSTION - ELECTRIC BOILER BIT UMINOUS COAL MISC.

EXTERNAL COMBUSTION - ELECTRIC BOILER PULVERIZED BITUMINOUS COAL

COMMERCIAL MARINE

RESIDENTIAL DISTILLATE OIL COMBUSTION

INDUSTRIAL PROCESSES - FLUID CATALYTIC CRACKING UNITS

LIGHT DUTY GAS VEHICLE

COMMERCIAL DISTILLATE OIL COMBUSTION 

INDUSTRIAL PROCESSES - CHEMICAL MANUFACT URING SULFURIC ACID

HEAVY DUTY DIESEL VEHICLE

LIGHT DUTY GASOLINE TRUCK (<6K LBS.)

EXTERNAL COMBUSTION - ELECTRIC BOILER RESIDUAL GRADE 6 OIL

COMMERCIAL KEROSENE OIL COMBUSTION

INDUSTRIAL PROCESSES - PET ROLEUM INDUST RY PROCESS HEATERS

EXTERNAL COMBUSTION - ELECTRIC BOILER NATURAL GAS MISC.

Light Duty Gasoline T ruck (>6K lbs. <8.5K lbs.)

Tons per Year

Area

Point

OnRoad

NonRoad

12/6/07
7

Figure A3: 2009 MANE-VU Region PM2.5 Inventory Top 15

105,229

47,979

37,367

25,470

25,012

18,931

17,331

14,452

13,090

10,149

9,359

8,056

7,831

7,822

7,128

0 20,000 40,000 60,000 80,000 100,000 120,000

Stationary Source Fuel Combustion - Wood

Mobile Sources - Unpaved Roads

Mobile Sources - Paved Roads

Industrial Processes - Construction

Waste Disposal, Treatment, and Recovery - Open burning

Miscellaneous Area Sources - Agricultural production

Mobile Sources - Off-highway Diesel

Industrial Processes - Food and Kindred Products

Stationary Source Fuel Combustion - Coal

External Combustion Boilers - Industrial

Industrial Processes - Mining and Quarrying

Stationary Source Fuel Combustion - Natural Gas

Industrial Processes - Mineral Products

Stationary Source Fuel Combustion - Distillate Oil

Mobile Sources - Off-highway vehicle gasoline

Tons per Year

Area

Point

OnRoad

NonRoad

Figure A4: 2009 MANE-VU Region SO2 Emission Inventory Top 15

165,328

115,253

88,325

56,587

34,643

26,088

22,731

20,414

18,716

7,974

6,684

5,554

4,750

4,709

4,163

0 20,000 40,000 60,000 80,000 100,000 120,000 140,000 160,000 180,000

Stationary Source Fuel Combustion - Distillate Oil

External Combustion Boilers - Industrial

Stationary Source Fuel Combustion - Coal

Industrial Processes - Mineral Products

Stationary Source Fuel Combustion - Residual Oil

Mobile Sources - Commercial Marine Vessels

Mobile Sources - Off-highway Diesel

Internal Combustion Engines - Industrial

Industrial Processes - Metal Production

Industrial Processes - Petroleum Industry

Stationary Source Fuel Combustion - Kerosene

Waste Disposal - Solid Waste Disposal

Stationary Source Fuel Combustion - Wood

Industrial Processes - In-process Fuel Use

Mobile Sources - Railroad Equipment

Tons per Year

Area

Point

OnRoad

NonRoad

For a number of years, it has been recognized that fugitive dust emission inventories, 

when used in air quality models, substantially over-estimate PM2.5 ambient crustal 

emissions when compared to crustal material found in ambient samples. Various efforts 

12/6/07 
8

which include work done by the Desert Research Institute (DRI) and USEPA,9 the AP-42 

study,10 and NESCAUM’s Pilot Study11 reached a consensus opinion that over-estimates 

in the fugitive dust categories (i.e. paved and unpaved roads, dust from highway, 

commercial and residential construction, agricultural tilling, windblown dust from 

agricultural and other exposed land, quarrying, and other earth moving) need correction 

to compensate for inaccuracies in the inventories. Fugitive dust emissions in Figure A1 

are adjusted to correct for this over-estimate. 

NJDEP Workgroup White Paper Measures

In June of 2005, the NJDEP launched its “Reducing Air Pollution Together Initiative” 

designed to open a dialogue between the NJDEP and interested and affected parties about 

reducing emissions in order to improve air quality in New Jersey. As part of this 

Initiative, six workgroups were formed to focus on different sources of emissions (i.e., 

emissions from diesel vehicles, gasoline cars and trucks, homes and restaurants, 

stationary combustion sources, processes and consumer products, and non-automobile 

gasoline engines) that contributed to New Jersey’s key air quality problems and to 

recommend control strategies to reduce these emissions. These workgroups developed 

and submitted to the Department a total of 250 potential control measures 

recommendations to the NJDEP for consideration, and ranked the measures from highest 

to lowest potential based on the measures’ environmental benefits, technical feasibility, 

implementation feasibility, economic feasibility, social benefits/Environmental Justice, 

and ease of enforcement. More information on the NJDEP’s “Reducing Air Pollution 

Together Initiative” can be found on the NJDEP’s website at 

http://www.nj.gov/dep/airworkgroups/index.html. 

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

were further evaluated by NJDEP and re-ranked using a common scale (High, Medium, 

Low, and Not Ranked) so that every measure could be compared equally. The NJDEP 

Air Quality Management Team determined which of the 250 workgroup recommended 

strategies should be further evaluated for possible inclusion in the SIP and/or considered 

further for implementation. As a result of these discussions, sixty draft white papers 

addressing 60 measures were developed by the NJDEP staff, and presented to the public 

for their review and consideration.12

The majority of the white papers were written for VOC and NOx measures. Ten of the 

white paper measures were for PM2.5 and/or SO2 measures. Two of the ten white papers 

 

9

 A Conceptual Model to adjust Fugitive Dust Emissions to Account for Near Source Particle Removal in 

Grid Model Application, Thompson G. Pace, USEPA 8/22/2003 available form USEPA’s website at 

http://www.epa.gov/. 

10 Analysis of Fine Particulate Matter Near Urban Roadways”, Balogh, Larson, and 

Mannering,Transportation Research Record 1416, page 25. 

11 Spatial and Temporal Assessment of Mobile Source Aerosol Indicator During Winter in Boston, Ma.: A 

Pilot Study; Allen and Johnson, April, 2003. 

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

http://www.nj.gov/dep/airworkgroups/docs/wp_summary_table_web_2007.xls (Accessed November 28, 

2007). 
9

were RACT measures and the remaining eight were fully evaluated according to the 

RACM criteria. The concepts from all eight white paper measures that were evaluated 

advanced to the final stage of the analysis (advance the attainment date). The eight white 

paper measures are listed below: 

- Increasing the Rate of Small Engine Turnovers and Portable Fuel Container Turnovers 

 through the Use of Incentive-Based Initiatives 

- Regional Sulfur Fuel Oil Controls 

- Wood Stove and Fireplace Insert Change-out Programs 

- A Multi-Stage Approach to Outdoor Wood Burning Equipment 

- A Multi-Stage Approach for Wood Burning Issues at the Local Level 

- Increasing Public Relations/Outreach/Education and Extending BPU Programs that 

 Address Energy-Efficiency and Renewable Energy 

- Restaurant Controls 

- Require Owners of Wood Burning Fireplaces to Change-over to Natural Gas Fireplaces 

 and Allow Only Natural Gas Fireplaces in New Construction 

NOx measures from 8-hour ozone RACM analysis

There were five NOx measures that made it to the final step of the in the 8-hour ozone 

RACM analysis (advance the ozone attainment date). Two of these measures overlapped 

with the workgroup white paper measures. Three were added to the non-TCM measures 

for PM2.5 RACM analysis. One of these measures advanced to the final stage of the 

analysis (advance the attainment date) (see “Step II – RACM Criteria Analysis” section). 

Step II – RACM Criteria Analysis 

After this careful review of the initial 628 non-TCM control measures, 60 non-TCM 

control measures advanced to Step II of the analysis. 

Technological Feasibility, Economic Feasibility and Other Local Considerations: 

The 60 potential non-TCM control measures were analyzed according to the RACM 

criteria discussed in Section 1.2.1 for technological feasibility, economic feasibility and 

other local considerations. The analysis for these criteria was done simultaneously on all 

60 measures. If sufficient information was not available for a determination to be made 

under any criteria, an “N/A” determination was made, and the measure was evaluated for 

the remaining criteria. In addition, if a measure failed any of the criteria, no further 

evaluation was conducted on that measure. Table A2.1 in Attachment A2 lists these 60 

measures and the determinations for each measure. 

A total of 15 viable non-TCM measures listed in Table A1 advanced to the final stage of 

the analysis (advance the attainment date). 
10

Table A1: List of 15 Potential Non-TCM RACMs 

 

Measure Name

Area

Voluntary wood stove and fireplace retrofit/change-out programs 

Mandatory wood stove and fireplace retrofit/change-out programs

Amend the Air Pollution control Act to allow counties to regulate outdoor wood 

Establish moratorium through Governor's Executive Order or Legislation on sale and 

distribution of new OWBs until implementation of USEPA's regulations

Establish provisions on minimum chimney height and distances to houses/property 

lines for outdoor wood boilers

Commitment to adopt State rules in the absence of Federal action 

Implement standards for chain driven charbroilers 

Energy conservation and "green building" for residential and commercial building 

Enhance New Jersey's open burning permit requirements

PM-efficient units for street sweeping

New Jersey to lower the Sulfur content in Fuel Oil 

OnRoad

New Jersey to update and strengthen existing opacity requirements

NonRoad

Emission Testing and repair/maintenance program for nonroad heavy duty equipment

Reduce ship speeds near the coast

Voluntary Lawn Mower Replacement Program 

1.2.3 NJDOT Potential Control Measure Analysis for Transportation Control 

Measures and Other Onroad Mobile Measures 

TCMs are transportation strategies specific to onroad mobile sources, which reduce 

emissions by reducing the number and/or length of vehicle trips and/or improve traffic 

flow. After the passage of the Clean Air Act Amendments of 1990, New Jersey made a 

full-scale commitment to TCMs.13 The State’s transportation capital program continues 

to stress transit projects, system preservation, and systems management over the 

provision of new highway capacity. The NJDOT is committed to continue the support 

and implementation of air quality-friendly transportation projects programs. The 

remainder of this section outlines the NJDOT’s evaluation of PM2.5-related TCMs for 

RACM purposes. 

 

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

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

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

programs. 
11

Step I – Evaluation Criteria for Potential Transportation Control Measures 

Twenty-six (26) TCMs were identified by NJDOT, in consultation with the NJDEP, for 

consideration in this RACM evaluation. Detailed summaries of each of the 26 measures 

identified by NJDOT are located in Attachment A3. 

Step II – Identification of Potential Transportation Control Measures

The 26 onroad TCMs were evaluated by the NJDOT based on the criteria outlined in 

Section 1.2.1. These criteria include technological and economic feasibility, other local 

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

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

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

advance the attainment date in each PM2.5 nonattainment area from 2010 to 

2009, meaning that the measures must be in place by 2008 to achieve reductions in 

2008. 

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

the measures as “high,” “medium,” or “low.” The political feasibility analysis is located 

in Attachment A4. The NJDEP evaluated the rationale for measures that were ranked 

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

described in Section 1.2.1. There were 11 measures that ranked “high” for political 

feasibility. Many of the potential TCMs are already in place and therefore not considered 

a RACM. Only one of the 11 measures advanced to the final stage of the RACM 

analysis. This measure is listed below 

School Bus Replacement – All model year 2002 and older buses will be replaced with 

model year 2007 diesel buses. 
12

1.3 Potential Measures Identified 

A total of 16 measures (one TCM and 15 Non-TCM) passed the technological feasibility, 

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

B5). 

Figure B5: Identification of Potential Control Measures 

 

15 Non-TCM Measures

pass technological, 

economic, other local 

considerations criteria 

TO 

612 Non TCM Measures 

5 NOx Measures from 

8- hr O3 RACM 10 PM Specific 

Workgroup White Paper 

Measures 

Discuss Strategies for 

possible SIP Inclusion 

26 TCMs 

49 Measures 

Pass pre screening and Advance to 

RACM Analysis 

8 White Paper Measures 

Advance to RACM

Analysis

60 Non-TCM Measures

Advance to 

RACM Analysis 

2 NOx Measures from 8- 

hr O3 RACM 

Overlap with White Paper 

Measures (three additional 

Measure Advance to 

RACM Analysis

1 TCM 

Pass 

Technological, 

economic, other 

local

considerations 

criteria 

628 Original Potential 

Control Measures 
13

1.4 Advancement of Attainment Date 

The 16 TCMs and non-TCMs that passed all previously discussed (technological, 

economic, other local considerations) RACM criteria were analyzed to determine 

whether or not they had the potential to advance the attainment date. NJDEP determined 

that none of these 16 measures could be implemented by 2008, and therefore would not 

achieve any reduction benefits in 2008. As a result, these measures, alone or collectively, 

would not advance the attainment date. No additional modeling was needed (per USEPA 

requirement, see Section § 51.1007 in 72 Fed. Reg. 20585 (April 25, 2007)) to make this 

determination). 

1.5 RACM Conclusion 

New Jersey reviewed over 600 potential control measures to determine if these measures 

should be implemented to assist with attaining the health standard and also help improve 

the air quality in New Jersey. The control measures were also evaluated based on the 

RACM criteria discussed in Section 1.2.1 and it was determined that none could be 

implemented by 2008 in order to provide emission benefits by 2009. Therefore, none of 

the potential control measures are considered RACM for the purposes of the 1997 annual 

PM2.5 NAAQS and it is unnecessary to include any of these measures in the State’s 1997 

annual PM2.5 attainment plan. 

Even though none of these potential measures could be implemented by 2008, they 

include some promising measures that New Jersey considered implementing to assist in 

attaining the health standards and for future strategies. In addition, New Jersey is already 

addressing some of the source categories addressed by these measures, as well as other 

significant contributing sources to reduce PM2.5 emissions. The remainder of this Section 

discusses the most promising of these source categories and what New Jersey is currently 

doing and/or plans to do to address these sources in the future. 

a. Open burning/Outdoor wood burning – Smoke Management Plans 

New Jersey already has a regulation in place to control emissions from open burning at 

N.J.A.C. 7:27-2, Control and Prohibition of Open Burning14, and is considering changes 

to agricultural burning portion of these requirements. This source category is also 

addressed in the “Smoke Management” Section of the proposed Regional Haze SIP 

(including the agricultural and forestry smoke management, prescribed burning, and 

agricultural management discussions in that SIP proposal).15 

 

14 Available at http://www.state.nj.us/dep/aqm/Sub%2002%20v1994-06-20.pdf (Accessed November 19, 

2007). 

15 The first regional haze air quality protection plan for New Jersey was proposed September 15, 2008 (see 

Chapter 1 for further details). 
14

b. Change-out programs 

Control measures include wood stove and fireplace change-out programs, and lawn 

mower replacement programs. Financial incentives would be necessary to ensure a 

productive program. New Jersey would consider implementing a change-out program in 

the future if funds become available. 

c. Control fugitive dust emissions 

The New Jersey Municipal Stormwater Regulation program16 requires the streets in the 

State to be swept on a regular basis. This measure also has air quality benefits by the 

removal of a source of fugitive dust such as dust from tire and break wear. 

New Jersey also has standards that would reduce fugitive emissions from various sources 

such as tillage and construction. These standards have been adopted by NJDOT and New 

Jersey Department of Agriculture (NJDOA) under the “Soil Erosion and Sediment 

Control Standards: Standards for Dust Control.”17,18 

Control of fugitive dust at major industrial facilities throughout the State is a viable PM2.5 

RACT measure and will be addressed by a new rule expected to be proposed in 2009, in 

accordance with the New Jersey Administrative Procedures Act (APA) (N.J.S.A. 52:14B1 et. Seq.) and the Air Pollution Control Act (APCA) (N.J.S.A. 26:2C-1 et seq.). For 

more information, see the PM2.5 RACT analysis in Appendix A7. 

d. Energy conservation and “green building” 

New Jersey currently provides for rebates and other financial incentives to install energyefficiency measures in a home. The New Jersey Department of Community Affairs 

(NJDCA) has minimum design standards for some appliances. The New Jersey Clean 

Energy Program (NJCEP) and the New Jersey Energy Master Plan (NJEMP) are 

programs that encourage energy conservation. 

e. Train engines 

New Jersey Transit (NJ Transit) has voluntarily implemented an “Idling Reduction 

Policy” which says that there is no idling when the temperature is above zero degrees. 

 

16 NJDEP. 2006 Annual Report summary on New Jersey’s Stormwater Regulation program is available at 

http://www.state.nj.us/dep/dwq/pdf/2006msrpannualreportlong.pdf (Accessed November 19, 2007). 17 New Jersey Department of Transportation. Soil Erosion and Sediment Control Standards (Approved 

January 18, 1989). Standards for Dust Control, pg 2-10-1. 

18 New Jersey Department of Agriculture. Soil Erosion and Sediment Control Act Rules (July 1999) 

N.J.A.C 2:90-1. 
15

f. Truck Stop Electrification 

On October 20, 2004, the first Electrified Truck Stop in New Jersey was opened at the 

Travel Centers of America truck stop in Paulsboro, Gloucester County, New Jersey. The 

Truck stop has ninety-eight truck electrification bays equipped with IdleAire Service 

Modules. These modules mount on the cab's passenger window to provide heat, 

ventilation, air conditioning, power for the refrigeration unit and appliances as well as 

cable TV, telephone and Internet service. New Jersey encourages the use of this 

technology to reduce PM2.5 emissions from diesel trucks. New Jersey opened another 

electrified truck stop with ninety-two electrification bays at Petro Travel Center #382, in 

Bordentown, Burlington County, New Jersey on June 26, 2007. An electrified truck stop 

at the Vince Lombardi Rest Area in Ridgefield, Bergen County, New Jersey, is scheduled 

to begin construction within the next six months. New Jersey also has an electrified truck 

stop with sixty-three bays at Travel Centers of America #006, in Columbia, Warren 

County, New Jersey, and is considering other locations for electrification, as well. 

g. Idling Rule 

New Jersey has revised its Idling Rule at N.J.A.C. 7:27-14.3 (Effective July 25, 2007) to 

remove the sleeper berth exemption no later than April 30, 2010. 

 

h. Diesel Smoke Rule Changes 

New Jersey currently has opacity requirements for periodic and roadside inspections of 

emissions of diesel vehicles. New Jersey is in the process of updating and strengthening 

the existing requirements and updating the Pass/Fail Standards for the periodic and 

roadside inspections. 

i. Ports 

New Jersey is working with the Port of New York/New Jersey to develop a plan to 

reduce emissions, including fine particulate emissions. Some of these measures include 

replacing or upgrading all container trucks that frequently visit the port such that they 

meet or are cleaner than the USEPA 2007 onroad emission standard, conduct targeted 

enforcement sweeps for idling and smoke violations, require clean construction and 

operations at Port fields and encourage clean partners, non-road equipment upgrade to 

newer models with lower emissions, and fuel switching from diesel to electricity. 

j. Medium Duty Motor Vehicles 

New Jersey is piloting an effort to review measures that would help control particulate 

emissions from Medium Duty Motor Vehicle with a gross weight between 8,501 – 

17,999 pounds.