The State of New Jersey

Department of Environmental Protection

State Implementation Plan (SIP) Revision for the Attainment 

and Maintenance of the Fine Particulate Matter (PM2.5) 

National Ambient Air Quality Standard

PM2.5 Attainment Demonstration

Final

March 24, 2009
ii

Preface

New Jersey is finalizing this revision to its State Implementation Plan to demonstrate how the 

State’s two shared multi-state nonattainment areas will come into attainment with the 1997 

health-based annual fine particulate matter (PM2.5) National Ambient Air Quality Standards 

(NAAQS) by their attainment date of April 5, 2010. The plan for attainment contained in this 

document conforms to the United States Environmental Protection Agency’s (USEPA’s) 

guidance and rulemaking with respect to PM2.5 attainment.

Acknowledgements

The New Jersey Department of Environmental Protection (NJDEP) acknowledges the efforts and 

assistance of the many agencies and individuals whose contributions were instrumental in the 

preparation of this State Implementation Plan (SIP) revision. First, the NJDEP would like to 

thank the many participants of the NJDEP’s Reducing Air Pollution Together (RAPT) Initiative, 

whose insight into the prospective control measures and their implementation was most valuable.

The NJDEP would like to acknowledge the many individuals within the New Jersey Department 

of Transportation, the North Jersey Transportation Planning Authority, the Delaware Valley 

Regional Planning Commission, the United States Environmental Protection Agency Region 2, 

the Connecticut Department of Environmental Protection, the New York State Department of 

Environmental Conservation, the Pennsylvania Department of Environmental Protection, the 

Delaware Department of Natural Resources and Environmental Control, the Virginia Department 

of Environmental Protection, the New Hampshire Department of Environmental Quality, the 

Maryland Department of the Environment, the University of Maryland, the Ozone Transport 

Commission, the Mid-Atlantic Region for Air Management Association, Mid-Atlantic/Northeast 

Visibility Union, the Ozone Research Center at the University of Medicine and Dentistry of New 

Jersey/Rutgers University, Northeast States for Coordinated Air Use Management, and the staff 

within the NJDEP for their assistance and guidance. 
iii

Table of Contents

Preface............................................................................................................................... ii

Acknowledgements............................................................................................................. ii

Table of Contents...............................................................................................................iii

List of Tables ..................................................................................................................... vi

List of Figures.................................................................................................................. viii

List of Appendices.............................................................................................................. x

Acronyms and Abbreviations ........................................................................................... xii

Executive Summary........................................................................................................ xvii

1.0 INTRODUCTION AND BACKGROUND .................................................... 1

1.1 Fine Particulate Matter and its Associated Health Standards............................. 1

1.2 Health and Welfare Impacts of PM2.5 and PM2.5 Precursors .............................. 6

1.2.1 Fine Particulate Matter........................................................................................ 6

1.2.2 Sulfur Dioxide (SO2) .......................................................................................... 9

1.2.3 Oxides of Nitrogen (NOx)................................................................................. 10

1.2.4 Other PM2.5 Precursors – Volatile Organic Compounds and Ammonia .......... 11

1.3 Integrating PM2.5 with Other Air Quality Goals............................................... 12

1.3.1 Environmental Justice in New Jersey ............................................................... 13

1.3.2 Air Toxics......................................................................................................... 14

1.3.3 Greenhouse Gases and Climate Change ........................................................... 16

1.3.4 8-Hour Ozone ................................................................................................... 17

1.3.5 Regional Haze................................................................................................... 17

2.0 AIR QUALITY AMBIENT AND EMISSION INVENTORY DATA....... 19

2.1 Measuring Fine Particle Pollution in the Atmosphere – An Introduction to 

PM2.5 Monitoring .............................................................................................. 19

2.2 USEPA NAAQS for Fine Particle Pollution: Annual PM2.5 ........................... 20

2.2.1 Annual PM2.5 Mean Concentrations and Design Values.................................. 20

2.3 USEPA NAAQS for Fine Particle Pollution: Daily (24-Hour) PM2.5 ............. 26

2.3.1 Daily PM2.5 98th Percentile Average Concentrations and Design Values ........ 26

2.4 Composition of Fine Particle Pollution – Speciated Monitoring Data and 

Trends ............................................................................................................... 32

2.5 PM2.5 Source Apportionment............................................................................ 35

2.6 Emission Inventory ........................................................................................... 42

2.7 Conclusions....................................................................................................... 51

3.0 REQUIREMENTS FOR THE 1997 PM2.5 NAAQS .................................... 53

3.1 USEPA PM2.5 Implementation Rule................................................................. 53

3.2 Summary of this SIP Revision.......................................................................... 58

4.0 CONTROL MEASURES............................................................................... 59

4.1 Terminology...................................................................................................... 59

4.2 On the Books Controls...................................................................................... 59

4.2.1 New Jersey........................................................................................................ 60
iv

4.2.2 Federal............................................................................................................... 62

4.3 Beyond On The Way Controls.......................................................................... 68

4.3.1 Identifying Measures ........................................................................................ 68

4.3.1.1 Regional Activities ........................................................................................... 68

4.3.1.2 Ozone Transport Commission (OTC)............................................................... 69

4.3.1.3 Mid-Atlantic Regional Air Management Association (MARAMA)................ 72

4.3.1.4 Mid-Atlantic/Northeast Visibility Union (MANE-VU) ................................... 74

4.3.1.5 State Specific Efforts ........................................................................................ 75

4.3.1.5.1 New Jersey Workgroup Efforts ........................................................................ 76

4.3.1.5.2 New Jersey Board of Public Utilities (NJBPU) Energy Master Plan Efforts... 77

4.3.1.5.3 Reasonably Available Control Technology (RACT)........................................ 78

4.3.1.5.4 Reasonably Available Control Measures (RACM) Analysis........................... 78

4.3.1.5.5 Additional Measures......................................................................................... 79

4.3.1.5.6 Federal .............................................................................................................. 83

4.3.1.5.7 Additional Actions............................................................................................ 84

4.4 VOC Measures.................................................................................................. 87

4.5 Conclusions on Control Measures.................................................................... 89

5.0 ATTAINMENT DEMONSTRATION.......................................................... 93

5.1 Introduction....................................................................................................... 93

5.2 Photochemical Modeling .................................................................................. 94

5.2.1 Introduction....................................................................................................... 94

5.2.2 “One-Atmosphere” Air Quality Model............................................................. 95

5.2.2.1 Meteorology Data ............................................................................................. 96

5.2.2.2 Regional Emission Inventories......................................................................... 96

5.2.2.2.1 Base Emission Inventory .................................................................................. 97

5.2.2.2.2 Emission Control Inventories ........................................................................... 99

5.2.2.3 Emissions Processor Selection and Configuration ......................................... 100

5.2.2.4 Regional Modeling Coordination ................................................................... 100

5.2.2.5 Domain and Data Base Issues......................................................................... 100

5.2.2.5.1 Episode Selection............................................................................................ 100

5.2.2.5.2 Size of the Modeling Domain......................................................................... 100

5.2.2.5.3 Horizontal Grid Size ....................................................................................... 101

5.2.2.5.4 Vertical Resolution ......................................................................................... 101

5.2.2.5.5 Initial and Boundary Conditions..................................................................... 102

5.2.2.6 Quality Assurance........................................................................................... 102

5.2.2.7 Model Performance Evaluation ...................................................................... 103

5.2.2.7.1 Summary of Model Performance.................................................................... 103

5.2.3 Control Measures Modeled............................................................................. 104

5.2.4 Photochemical Modeling Results ................................................................... 109

5.3 Demonstrations............................................................................................... 116

5.3.1 Introduction..................................................................................................... 116

5.3.2 Supplemental Analysis/Weight-of-Evidence.................................................. 117

5.3.2.1 Monitoring Data Shows Trend toward Attainment of the Annual PM2.5 NAAQS 

and a Downward Trend in Ambient Air Concentrations................................ 117
v

5.3.2.2 Monitoring Data Shows Progress towards Attainment of the New Daily PM2.5

NAAQS of 35 μg/m3 ...................................................................................... 118

5.3.2.3 Discussion of Monitoring Results Collected at P.S. 59, Manhattan, New York

........................................................................................................................ 128

5.3.2.4 The Contribution of Transport to Nonattainment........................................... 129

5.3.2.5 SO2 CAIR Reductions May Provide Early Reductions in PM2.5 .................... 129

5.3.2.6 Additional Measures Not Included in the 2009 BOTW Attainment Modeling

........................................................................................................................ 131

5.3.2.6.1 Introduction..................................................................................................... 131

5.3.2.6.2 Additional Measures to Improve Air Quality................................................. 132

5.4 Emission Reduction Credits from Shutdowns and Curtailments.................... 137

5.5 Results............................................................................................................. 138

5.6 Unmonitored Area Analysis ........................................................................... 139

5.7 Conclusions..................................................................................................... 140

6.0 CONTINGENCY MEASURES................................................................... 142

6.1 Background..................................................................................................... 142

6.2 Contingency Measures for the Attainment Demonstration ............................ 143

6.3 Contingency Measure Implementation Schedule ........................................... 147

6.4 Conclusions..................................................................................................... 147

7.0 TRANSPORTATION CONFORMITY ..................................................... 148

7.1 Introduction..................................................................................................... 148

7.2 Transportation Conformity for PM2.5.............................................................. 151

7.2.1 Interim Tests to be used Prior to the Establishment of Budgets..................... 151

7.2.2 PM2.5 Precursors.............................................................................................. 151

7.2.3 Road Dust and Construction Related Fugitive Dust....................................... 152

7.2.4 Early Budgets for PM2.5 .................................................................................. 153

7.3 Budgets for Attainment of the Annual PM2.5 NAAQS ................................... 154

8.0 SECTION 110 INFRASTRUCTURE REQUIREMENTS ....................... 156

8.1 Introduction and Background ......................................................................... 156

8.2 Interstate Transport (§ 110(a)(2)(D)).............................................................. 158

8.2.1 Significant Contribution to Nonattainment, or Interference with Maintenance, 

of a NAAQS in Another State ........................................................................ 158

8.2.2 The Regional Haze and Visibility Interference Requirement......................... 159

8.2.3 Prevention of Significant Deterioration/Nonattainment New Source Review 

(PSD/NNSR) Requirement............................................................................. 162

8.3 Conclusion ...................................................................................................... 163

9.0 COMMITMENTS AND REQUESTS FOR FUTURE ACTION............. 165

9.1 Control Measure Commitments...................................................................... 165

9.2 Transport-Related Requirements.................................................................... 168

9.3 State Requests of the USEPA ......................................................................... 169

10.0 CONCLUSION ............................................................................................. 170
vi

List of Tables

Table 1.1: 1997 and 2006 PM2.5 Standards......................................................................... 5

Table 2.1: Northern New Jersey/New York/Connecticut Nonattainment Area Annual 

PM2.5 Means for the Two Consistently Highest Monitors by State, 1999-2006

......................................................................................................................... 22

Table 2.2: Southern New Jersey/Philadelphia Nonattainment Area Annual PM2.5 Means 

for the Two Consistently Highest Monitors by State, 1999-2006 .................. 23

Table 2.3: Northern New Jersey/New York/Connecticut Nonattainment Area Annual 

PM2.5 Design Values for the Two Consistently Highest Monitors by State, 

2001-2006 ....................................................................................................... 25

Table 2.4: Southern New Jersey/Philadelphia Nonattainment Area Annual PM2.5 Design 

Values for the Two Consistently Highest Monitors by State, 2001-2006 ...... 26

Table 2.5: PM2.5 98th Percentile 24-Hour Averages for the Two Consistently Highest 

Monitors in the 1997 PM2.5 Northern New Jersey/New York/Connecticut 

Nonattainment Area, 1999-2006..................................................................... 28

Table 2.6: PM2.5 98th Percentile 24-Hour Averages for the Two Consistently Highest 

Monitors in the 1997 PM2.5 Southern New Jersey/Philadelphia Nonattainment 

Area, 1999-2006 ............................................................................................. 29

Table 2.7: Northern New Jersey/New York/Connecticut Nonattainment Area Daily PM2.5

Design Values for the Two Consistently Highest Monitors by State, 2001-

2006................................................................................................................. 31

Table 2.8: Southern New Jersey/Philadelphia Nonattainment Area Daily PM2.5 Design 

Values for the Two Consistently Highest Monitors by State, 2001-2006 ...... 31

Table 2.9: Study Results from the Potential Source Contribution Function (PSCF) and 

Conditional Probability Function (CPF) Analyses, Kim and Hopke (2004).. 37

Table 4.1: Summary of Emission Standards for Recreational Vehicles........................... 66

Table 4.2: Final OTC Control Measure Source Categories, ............................................. 70

Table 4.3: Summary of MANE-VU Planning Targets ..................................................... 75

Table 4.4: VOC Control Measures ................................................................................... 88

Table 4.5: PM2.5 Control Measure Summary.................................................................... 89

Table 5.1: Modeled Control Measures Included in the 2009 BOTW Model Run.......... 106

Table 5.2: Ozone Transport Region-Wide Modeling Assumptions for the 2009 BOTW 

Model Run .................................................................................................... 108

Table 5.3: 2009 Modeled PM2.5 Design Values for the Northern New Jersey/New 

York/Connecticut Nonattainment Areas....................................................... 113

Table 5.4: 2009 Modeled PM2.5 Design Values for the Southern New 

Jersey/Philadelphia/Delaware Nonattainment Area ..................................... 115

Table 5.5: Annual Ambient PM2.5 Levels in the Northern New Jersey/New 

York/Connecticut Nonattainment Area ........................................................ 119

Table 5.6: Ambient PM2.5 Design Values in the Northern New Jersey/New York 

Connecticut Nonattainment Area.................................................................. 121

Table 5.7: Annual Ambient PM2.5 Levels in the Southern New Jersey/Philadelphia 

Nonattainment Area ...................................................................................... 123

Table 5.8: Ambient PM2.5 Design Values in the Southern New Jersey/Philadelphia 

Nonattainment Area ...................................................................................... 124
vii

Table 5.9: Averaged Daily PM2.5 Ambient Levels in the Northern New Jersey/New 

York/Connecticut Nonattainment Area (μg/m3)........................................... 125

Table 5.10: Averaged Daily PM2.5 Ambient Levels in the Southern New 

Jersey/Philadelphia Nonattainment Area (μg/m3) ........................................ 127

Table 5.11: Reductions from CAIR in 2010 in States that Significantly Contribute to 

Ozone or Fine Particulate Levels in New Jersey and the Modeled Contribution 

to NYC from those States............................................................................. 130

Table 6.1: PM2.5 Attainment Contingency Measures for 2009, New Jersey Portion of the 

Northern New Jersey/New York/Connecticut Nonattainment Area (tons per 

year) .............................................................................................................. 145

Table 6.2: PM2.5 Attainment Contingency Measures for 2009, New Jersey Portion of the 

Southern New Jersey/Philadelphia Nonattainment Area (tons per year)...... 146

Table 7.1: Existing and Updated Transportation Conformity Emission Budgets for PM2.5 

Attainment..................................................................................................... 155

Table 9.1: PM2.5 State Control Measure Commitments Not Yet Adopted and Contingency

Measures....................................................................................................... 166

Table 9.2: Additional Control Measures......................................................................... 167
viii

List of Figures

Figure 1.1: New Jersey-Associated 1997 PM2.5 Nonattainment Areas .............................. 4

Figure 2.1: Particulate Monitoring Network in New Jersey............................................. 20

Figure 2.2: Northern New Jersey/New York/Connecticut Nonattainment Area Annual 

PM2.5 Mean Concentrations for the Two Consistently Highest Monitors in 

Each Associated State, 1999-2006.................................................................. 21

Figure 2.3: Southern New Jersey/Philadelphia Nonattainment Area Annual PM2.5 Mean 

Concentrations for the Consistently Highest Monitors in Each Associated 

State, 1999-2006 ............................................................................................. 22

Figure 2.4: Northern New Jersey/New York/Connecticut Nonattainment Area Annual 

PM2.5 Design Values for the Two Consistently Highest Monitors in each 

Associated State, 2001-2006........................................................................... 24

Figure 2.5: Southern New Jersey/Philadelphia Nonattainment Area Annual PM2.5 Design 

Values for the Consistently Highest Monitors in each Associated State, 2001-

2006................................................................................................................. 25

Figure 2.6: PM2.5 98th Percentile 24-Hour Averages for the Two Consistently Highest 

Monitors in each Associated State in the 1997 PM2.5 Northern New 

Jersey/New York/Connecticut Nonattainment Area, 1999-2006 ................... 27

Figure 2.7: PM2.5 98th Percentile 24-Hour Averages for the Consistently Highest 

Monitors in each Associated State in the 1997 PM2.5 Southern New 

Jersey/Philadelphia Nonattainment Area, 1999-2006..................................... 28

Figure 2.8: Daily PM2.5 Design Values for the Two Consistently Highest Monitors in 

each Associated State in the Northern New Jersey/New York/Connecticut 

Area, 2001-2006 ............................................................................................. 30

Figure 2.9: Daily PM2.5 Design Values for the Consistently Highest Monitors in each 

Associated State in the Southern New Jersey/Philadelphia Area, 2001-2006.30

Figure 2.10: PM2.5 Species that Recorded the Highest Concentrations for 2002 and 2006 

in New Jersey.................................................................................................. 32

Figure 2.11: Speciated Data from 2002-2006 with the Highest Concentrations at Camden, 

New Jersey...................................................................................................... 33

Figure 2.12: Speciated Data from 2002-2006 with the Highest Concentrations at Chester, 

New Jersey...................................................................................................... 33

Figure 2.13: Speciated Data from 2002-2006 with the Highest Concentrations at 

Elizabeth, New Jersey..................................................................................... 34

Figure 2.14: Speciated Data from 2002-2006 with the Highest Concentrations at New 

Brunswick, New Jersey................................................................................... 34

Figure 2.15: PM2.5 Sources Identified at the Monitoring Site in Brigantine, New Jersey 

Contributing to the Mean Daily PM2.5 Mass Concentrations Averaged over 

1992 – 2001 using PMF.................................................................................. 36

Figure 2.16: Seasonal Variations in Source Contributions to Average Seasonal PM2.5

Mass Concentrations from 2001-2004 at Four Speciation Monitors in New 

Jersey, Hopke and Gildemeister (2006).......................................................... 39

Figure 2.17: Major Constituents of PM2.5 Mass at the Elizabeth, New Jersey Monitoring 

Site from 2001-2003 ....................................................................................... 41
ix

Figure 2.18: Comparison of Total PM2.5, NOx, and SO2 Emissions by State in the 

Northern New Jersey/New York/Connecticut Nonattainment Area, 2002-2009

......................................................................................................................... 43

Figure 2.19: Comparison of Total PM2.5, NOx, and SO2 Emissions by State in the 

Southern New Jersey/Philadelphia Nonattainment Area, 2002-2009............. 44

Figure 2.20: Comparison of PM2.5 Emissions by Sector in the Northern New Jersey/New 

York/Connecticut Nonattainment Area, 2002-2009....................................... 44

Figure 2.21: Comparison of PM2.5 Emissions by Sector in the Southern New 

Jersey/Philadelphia Nonattainment Area, 2002-2009..................................... 45

Figure 2.22: Comparison of NOx Emissions by Sector in the Northern New Jersey/New 

York/Connecticut Nonattainment Area, 2002-2009....................................... 45

Figure 2.23: Comparison of NOx Emissions by Sector in the Southern New 

Jersey/Philadelphia Nonattainment Area, 2002-2009..................................... 46

Figure 2.24: Comparison of SO2 Emissions by Sector in the Northern New Jersey/New 

York/Connecticut Nonattainment Area, 2002-2009....................................... 46

Figure 2.25: Comparison of SO2 Emissions by Sector in the Southern New 

Jersey/Philadelphia Nonattainment Area, 2002-2009..................................... 47

Figure 2.26: 2002 MANE-VU Region PM2.5 Inventory Top 15 ...................................... 47

Figure 2.27: 2009 MANE-VU Region PM2.5 Inventory Top 15 ...................................... 48

Figure 2.28: 2002 MANE-VU Region NOx Inventory Top 15 ........................................ 48

Figure 2.29: 2009 MANE-VU Region NOx Inventory Top 15 ........................................ 49

Figure 2.30: 2002 MANE-VU Region SO2 Inventory Top 15 ......................................... 49

Figure 2.31: 2009 MANE-VU Region SO2 Inventory Top 15 ......................................... 50

Figure 5.1: Mid-Atlantic/Northeast Visibility Union 12-Kilometer CMAQ Modeling 

Domain.......................................................................................................... 101

Figure 5.2: Map of the 1997 PM2.5 Northern New Jersey/New York/Connecticut 

Nonattainment Area ...................................................................................... 115

Figure 5.3: Map of Grid Cells Used in Photochemical Modeling Associated With New 

Jersey Fine Particulate Matter Monitors....................................................... 140

Figure 7.1: USEPA Designations of Nonattainment Areas for the PM2.5 National Ambient 

Air Quality Standard..................................................................................... 149

Figure 7.2: Metropolitan Planning Organizations in New Jersey................................... 150

Figure 8.1: States Identified as Contributing toVisibility Impairment in New Jersey’s 

Class I Area................................................................................................... 160
x

List of Appendices

Appendix A1*: Memorandum of Understanding Among the States of the Ozone 

Transport Commission Concerning the Incorporation of High 

Electrical Demand Day Emission Reduction Strategies into Ozone 

Attainment State Implementation Planning

Appendix A2*: Resolution 06-02 of the Ozone Transport Commission Concerning 

Coordination and Implementation of Regional Ozone Control 

Strategies for Certain Source Categories

Appendix A2*: Attachment 1: Addendum to Resolution 06-02 of the Ozone Transport 

Commission Concerning Coordination and Implementation of 

Regional Ozone Control Strategies for Various Sources

Appendix A3*: Identification and Evaluation of Candidate Control Measures Final 

Technical Support Document

Appendix A4*: Assessment of Control Technology Options for Petroleum Refineries 

in the Mid-Atlantic Region

Appendix A5*: Resolution of the Commissioners of States with Mandatory Class I

Federal Areas within the Mid-Atlantic Northeast Visibility Union 

(MANE-VU) Regarding Principles for Implementing the Regional 

Haze Rule

Appendix A6-1*: Statement of the Mid-Atlantic Northeast Visibility Union (MANEVU) Concerning a Course of Action within MANE-VU toward 

Assuring Reasonable Progress

Appendix A6-2*: Statement of the Mid-Atlantic Northeast Visibility Union (MANEVU) Concerning a Course of Action by States Outside of MANE-VU 

toward Assuring Reasonable Progress

Appendix A6-3*: Statement of the Mid-Atlantic Northeast Visibility Union (MANEVU) Concerning a Course of Action by the U.S. Environmental 

Protection Agency (EPA) toward Assuring Reasonable Progress

Appendix A7: Reasonably Available Control Technology (RACT)

Appendix A8: Reasonably Available Control Measures (RACM)

Appendix A8*: Attachment 1: 8-Hour Ozone RACM Analysis

Appendix A8*: Attachment 2: RACM Analysis Tables

Appendix A8*: Attachment 3: NJDOT Project Analysis

Appendix A8*: Attachment 4: NJDOT Political Feasibility Analysis

Appendix B1*: TSD-2c: PM2.5 Modeling Using the SMOKE/CMAQ System over the 

Ozone Transport Region (OTR)

Appendix B2*: USEPA Modeling Guidance (2007)

Appendix B2-1*: TSD-5: Baseline and Future PM2.5 Design Values in the New York 

City Metropolitan Non-Attainment Area

Appendix B3*: TSD-1a: Meteorological Modeling using Penn State/NCAR 5th 

Generation Mesoscale Model (MM5)

Appendix B4*: Technical Support Document for 2002 MANE-VU SIP Modeling 

Inventories, Version 3

*Note: These appendices and attachments are only available electronically
xi

Appendix B5-1*: TSD-1f: Future Year Emissions Inventory for 8-Hr OTC Ozone 

Modeling

Appendix B5-1*: Attachment 1: Comparison of CAIR and CAIR Plus Proposal using the 

Integrated Planning Model (IPM®)

Appendix B5-1*: Attachment 2: Development of MANE-VU Mobile Source Projection 

Inventories

Appendix B5-2*: Development of Emission Projections for 2009, 2012, and 2018

for NonEGU Point, Area, and Nonroad Source in the MANE-VU 

Region, Final Report

Appendix B6*: TSD-4: Future Year Emissions Inventory for Regional and Urban 

Modeling over the Ozone Transport Region (OTR)

Appendix B7*: TSD-2a: Processing of 2002 Biogenic Emissions for OTC / MANEVU Regional and Urban Modeling

Appendix B8*: TSD-2b: Processing of 2002 Anthropogenic Emissions: OTC Regional 

and Urban 12km Base Year Simulation

Appendix B9*: TSD-1e: CMAQ Model Performance and Assessment 8-Hr OTC 

Ozone Modeling

Appendix B10*: Analysis of the RRF’s in the Grid Cell Containing the Monitor and the 

Nine-Grid Cell Average

Appendix B11-1*: TSD-3a: Analysis of Ambient PM2.5 Mass Speciation for the New 

 York Metropolitan Area through 2006 

Appendix B11-2*: TSD-3b: Analysis of Ambient PM2.5 Mass: CT and NJ portions of 

 the New York City Metropolitan Non-attainment Area through 2006

Appendix B12*: New York’s Weight-of-Evidence Discussion for the P.S. 59 Monitor

Appendix B13: Emission Reduction Credits from Shutdowns and Curtailments

Appendix C: Contingency Measure Calculations

Appendix C*: Attachment 1: Onroad Fleet Turnover Calculation Details and 

 MOBILE6 Runs

Appendix C*: Attachment 2: Nonroad Fleet Turnover Calculation Details and NNEM 

 Runs

Appendix C*: Attachment 3: Coastal Eagle Point Oil Company Consent Decree

Appendix C*: Attachment 4: Valero Refining Company Consent Decree

Appendix C*: Attachment 5: Conoco Phillips Consent Decree

Appendix D: Updated Early PM2.5 Transportation Conformity Emission Budgets

Appendix E*: 2008 Infrastructure SIP Letter from New Jersey to the USEPA Region 

2

Appendix F: Public Participation

Attachment 1: Notice of Availability

Attachment 2: Documentation of the Notices that Appeared in the 

Newspapers and the New Jersey Register

Attachment 3: Response to Comment Document

*Note: These appendices and attachments are only available electronically
xii

Acronyms and Abbreviations

μg/m3 Micrograms per meter cubed

ACT Alternative Control Techniques

AEL Alternative Emission Limit

AIM Architectural and Industrial Maintenance

ANSI American National Standards Institute

APA Administrative Procedures Act

APCA Air Pollution Control Act

AQPP Air Quality Permitting Program

AQS Air Quality System

ASHRAE The American Society of Heating, Refrigerating and Air-Conditioning 

Engineers

ATPZEV Advanced Tech Partial Zero Emission Vehicle

ATSDR Agency for Toxic Substances and Disease Registry

ATV All Terrain Vehicle

BACT Best Available Control Technology

BAM Bureau of Air Quality Monitoring

BART Best Available Retrofit Technology

BMPs Best Management Practices

BPU New Jersey Board of Public Utilities

BOTW Beyond on the Way

CAA Clean Air Act 

CAAAC Clean Air Act Advisory Committee

CAEPA California Environmental Protection Agency

CAIR Clean Air Interstate Rule 

CARB California Air Resources Board

CASAC Clean Air Scientific Advisory Committee

CERR Consolidated Emissions Reporting Rule

CECA Consumer Energy Council of America

C.F.R. Code of Federal Regulations

CM Control Measures

CMAQ Congestion Mitigation and Air Quality

CO Carbon monoxide

CO2 Carbon dioxide

CPF Conditional Probability Function

CT Connecticut

CTGs Control Technique Guidelines

DAQ Division of Air Quality

DE Delaware

DON Degree of Neutralization 

DV Design Value

DVB-I Average Annual Baseline Design Value

DVF-I Projected 2009 Annual Design Value

DVMT Daily Vehicle Miles Traveled

DVRPC Delaware Valley Regional Planning Commission
xiii

ECPA Energy Conservation and Production Act

EGAS Economic Growth Analysis System

EGU Electric Generating Unit

EMP Energy Master Plan

FCC Fluid Catalytic Cracking

FCCU Fluid Catalytic Cracking Unit

FGR Flue Gas Recirculation

FIP Federal Implementation Plan

FMVCP Federal Motor Vehicle Control Program

FNL Federal Direct Final Rule

Fed. Reg. Federal Register

FRM Federal Reference Method

FSEL Facility-Specific Emission Limit

GACT Generally Available Control Technology

GHG Greenhouse Gas

GMF Glass Manufacturing Furnace

HAP Hazardous Air Pollutant

HC Hydrocarbon

HDDE Heavy Duty Diesel Engine

HDDV Heavy Duty Diesel Vehicle

HEDD High Electrical Demand Day

hp Horsepower

IAQR Interstate Air Quality Rule

ICE Internal Combustion Engine

ICI Industrial/Commercial/Institutional

IECC International Energy Conservation Code

IESNA The Illuminating Engineering Society of North America

I/M Inspection and Maintenance

kW Kilowatt

LAER Lowest Achievable Emission Rate 

lbs Pounds

LDAR Leak Detection and Repair

LEV Low Emission Vehicle

LNB Low NOx Burner

MACT Maximum Available Control Technology

MANE-VU Mid-Atlantic/Northeast Visibility Union

MARAMA Mid-Atlantic Regional Air Management Association

MATS Modeled Attainment Test Software

MDH Minnesota Department of Health

MERR Mobile Equipment Repair and Refinishing

mg/m3 Milligrams per meter cubed

MM5 Mesoscale Meteorological Model

MMBtu Million British Thermal Units

MOA Memorandum of Agreement

MOU Memorandum of Understanding 

MPO Metropolitan Planning Organization
xiv

MSW Municipal Solid Waste

MW Megawatt

MWC Municipal Waste Combustor

MWRPO Midwest Regional Planning Organization

MY Model Year

NAA Nonattainment Area

NAAQS National Ambient Air Quality Standards

NACAA National Association of Clean Air Agencies

NEI National Emissions Inventory

NESCAUM Northeast States for Coordinated Air Use Management

NH3 Ammonia

NJ New Jersey

N.J.A.C. New Jersey Administrative Code

NJBPU New Jersey Board of Public Utilities

NJCEP New Jersey Clean Energy Program

NJDCA New Jersey Department of Community Affairs

NJDEP New Jersey Department of Environmental Protection

NJDHSS New Jersey Department of Health and Senior Services

NJDOA New Jersey Department of Agriculture

NJDOT New Jersey Department of Transportation

NJEMP New Jersey Energy Master Plan

NJEMS New Jersey Environmental Management System

NJLEV New Jersey Low Emission Vehicle

N.J.R. New Jersey Register

N.J.S.A. New Jersey Statutes Annotated

NJTPA North Jersey Transportation Planning Authority

NLEV National Low Emission Vehicle Program

NMHC Non-methane Hydrocarbon

NMOG Non-methane Organic Gases

NNJ/NY/CT Northern New Jersey/New York/Connecticut

NNSR Nonattainment New Source Review

NO Nitric oxide

N2O Nitrous oxide

NO2 Nitrogen dioxide

NOx Oxides of Nitrogen

NSPS New Source Performance Standard

NSR New Source Review

NTE Not-To-Exceed

NY New York

NYSDEC New York State Department of Environmental Conservation

NYSERDA New York State Energy Research and Development Authority

OBD On-Board Diagnostics

OH Hydroxyl radical

ORVR Onboard Refueling Vapor Recovery

OTAG Ozone Transport Assessment Group

OTB On the Books
xv

OTC Ozone Transport Commission

OTR Ozone Transport Region

OTW On the Way

PA Pennsylvania

PAMS Photochemical Assessment Monitoring Station

PFC Portable Fuel Container

PM Particulate Matter

PM2.5 Fine Particulate Matter (particles with an aerodynamic diameter less than 

or equal to a nominal 2.5 micrometers)

PM10 Particles with an aerodynamic diameter less than or equal to a nominal 10 

micrometers

PMF Positive Matrix Factorization

POTW Publicly Owned Treatment Works

PPAQ Post Processor of Air Quality

Pb Lead

ppb Parts per billion

ppm Parts per million

ppmvd Parts per million by volume dry basis

PSCF Potential Source Contribution Function

PSD Prevention of Significant Deterioration

PSE&G Public Service Electric and Gas Company

PTE Potential to Emit

PZEV Partial Zero Emission Vehicle

QA/QC Quality Assurance/Quality Control

RACM Reasonably Available Control Measure

RACT Reasonably Available Control Technology

RFG Reformulated Gasoline

RFP Reasonable Further Progress

RGGI Regional Greenhouse Gas Initiative

ROP Rate of Progress

RPO Regional Planning Organization

RRF Resource Recovery Facility

RRF Relative Reduction Factor

RRF Relative Response Factor

SCC Source Classification Code

SCR Selective Catalytic Reduction

SIC Standard Industrial Classification

SIP State Implementation Plan

SJTPO South Jersey Transportation Planning Organization

SMAT Speciated Modeled Attainment Test

SMOKE Sparse Matrix Operator Kernel Emissions

SNCR Selective Non-Catalytic Reduction

SNJ/Phila. Southern New Jersey/Philadelphia

SO2 Sulfur Dioxide

SO4 Sulfate

SOx Oxides of Sulfur
xvi

SOA Secondary Organic Aerosol

SOTA State of the Art

STN Speciation Trends Network

SUV Sport Utility Vehicle

TBD To Be Determined

TCM Transportation Control Measure

TDM Travel Demand Model

TEA-21 Transportation Equity Act for the Twenty-first Century 

TEOM Tapered Element Oscillating Microbalance

TEU Twenty-foot Equivalent Container Units

TOC Technical Oversight Committee

tpd Tons per day

tpy Tons per year

TSD Technical Support Document

UCAMPP Urban Community Air Toxics Monitoring Project in Paterson City, New 

Jersey

UMD University of Maryland

UMDNJ/ORC University of Medicine and Dentistry of New Jersey’s Ozone Research 

Center

USEPA United States Environmental Protection Agency

USDOE United States Department of Energy

USDOT United States Department of Transportation

U.S.C. United States Code

VISTAS Visibility Improvement State and Tribal Association of the Southeast

VMT Vehicle Miles Traveled

VOC Volatile Organic Compound

WOE Weight of Evidence

XRF X-Ray Fluorescence

ZEV Zero Emission Vehicle
xvii

Executive Summary

Fine particulate matter (PM2.5) is a 

serious health problem in New 

Jersey. Exposure to PM2.5 can 

cause a variety of health 

problems, such as premature 

mortality, decreased lung 

function and difficulty 

breathing, and

asthma attacks, and other 

effects, such as reduced 

visibility, loss of biodiversity, 

and damage to manmade 

structures, sensitive forests, 

and farm crops, and 

contributes to global warming 

and the formation of acid rain. 

PM2.5 is referred to as 

“primary” if it is directly 

emitted into the air. PM2.5

that is formed by chemical 

reactions of gases in the atmosphere is referred to as “secondary” PM2.5. These PM2.5

precursors can include sulfur dioxide 

(SO2), oxides of nitrogen (NOx), 

volatile organic compounds (VOCs),1

and ammonia. 

In 1997, the United States 

Environmental Protection Agency 

(USEPA) revised the national 

health-based standard for PM, 

establishing new health-based 

standards for PM2.5 that were 

more protective of human health 

and welfare. Figures ES.1 and 

ES.2 show that New Jersey and its 

associated multi-state 

nonattainment areas are close to 

meeting the 1997 annual PM2.5

standard even with its highest 

monitors. These figures 

 1 According to the USEPA, the VOC policy in the implementation rule for PM2.5 addresses volatile (the 

lightest organic molecules with fewer than 6 carbon atoms) and semivolatile (the intermediate organic 

molecules with 7 to 24 carbon atoms) organic compounds (72 Fed. Reg. 20592 (April 25, 2007)).

Figure ES.1: Northern New Jersey/New 

York/Connecticut Nonattainment Area Annual PM2.5

Design Values for the Two Consistently Highest 

Monitors in each Associated State, 2001-2006

0.0

5.0

10.0

15.0

20.0

1999-2001 2000-2002 2001-2003 2002-2004 2003-2005 2004-2006

Year

PM2.5 Annual Design Value (μg/m3

)

36 061 0056 PS 59, 288 E. 57th Street, Manhattan, NY 36 061 0062 Post Office, 350 Canal Street, NY

9 009 0018 Stiles Street, CT 9 009 1123 715 State Street, CT

34 017 2002 Union City, NJ 34 039 0004 Elizabeth Turnpike Primary, NJ

Annual PM2.5 NAAQS = 15.0 μg/m3

0.0

5.0

10.0

15.0

20.0

1999-2001 2000-2002 2001-2003 2002-2004 2003-2005 2004-2006

Year

PM2.5 Annual Design Value (μg/m3

)

34 007 0003 Camden Lab Primary, NJ 34 007 1007 Pennsauken, NJ 34 015 5001 Gibbstown, NJ

42 101 0047 500 South Broad Street, PA 42 045 0002 Front St. & Norris St., PA 10 003 2004 MLK Blvd. & Justison St., DE

10 003 1012 Univ. DE North Campus, DE

Annual PM2.5 NAAQS = 15.0 μg/m3

Figure ES.2: Southern New Jersey/Philadelphia 

Nonattainment Area Annual PM2.5 Design Values 

for the Consistently Highest Monitors in each 

Associated State, 2001-2006
xviii

demonstrate that New Jersey and the multi-state nonattainment areas are on the right path 

toward cleaner air but still face the challenge of meeting the 1997 annual PM2.5 standard. 

Although New Jersey and the other states that share New Jersey’s 1997 PM2.5 multi-state 

nonattainment areas have always met the 1997 daily PM2.5 health-based standard of 65 

μg/m3, and the levels continue to decrease since 2001, New Jersey and the other states 

still face the challenge of meeting the new 2006 daily PM2.5 standard of 35 μg/m3

, as seen 

by the monitoring trends at the consistently highest monitors in each nonattainment area 

shown in Figures ES.3 and ES.4. This State Implementation Plan (SIP) revision will 

simultaneously help the State meet a number of other particulate matter (PM)-related 

goals that compliment the efforts to not only attain the 1997 annual PM2.5 national 

ambient air quality standards (NAAQS) by 2010 but improve air quality beyond these 

standards. These other goals include: 

o Reducing Greenhouse Gas emissions in an effort to help New Jersey meet its 

obligations under the State’s Global Warming Response Act; 

o Continuing to reduce PM2.5 emissions in an effort to meet the new 2006 daily 

PM2.5 standard of 35 μg/m3 and the State’s internal annual goal of 12 μg/m3; 

o Supporting the State’s efforts to meet the commitments in its 8-hour ozone 

attainment demonstration SIP, submitted to the United States Environmental 

Protection Agency (USEPA) in October 2007; 

o Continuing the State’s on-going efforts to reduce air toxic emissions throughout 

New Jersey;

o The submittal of a Regional Haze SIP to establish reasonable progress goals to 

address visibility in the State’s only Class I area; and, 

o Supporting the State’s overarching Environmental Justice initiatives.

Figure ES.3: Daily PM2.5 Design Values for the 

Two Consistently Highest Monitors in each 

Associated State in the Northern New Jersey/New 

York/Connecticut Area, 2001-2006

25.0

30.0

35.0

40.0

45.0

50.0

55.0

60.0

65.0

70.0

1999-2001 2000-2002 2001-2003 2002-2004 2003-2005 2004-2006

Year

PM2.5 24-Hour Design Value (μg/m3

)

36 061 0056 PS59, 288 E. 57th Street, Manhattan, NY 36 061 0062 Post Office, 350 Canal Street, NY

9 009 0018 Stiles Street, CT 9 009 1123 715 State Street, CT

34 017 2002 Union City, NJ 34 017 1002 Jersey City Primary, NJ

Former Daily PM2.5 NAAQS = 65.0 μg/m3

New Daily PM2.5 NAAQS = 35.0 μg/m3

Figure ES.4: Daily PM2.5 Design Values for the 

Consistently Highest Monitors in each 

Associated State in the Southern New 

Jersey/Philadelphia Area, 2001-2006

20.0

25.0

30.0

35.0

40.0

45.0

50.0

55.0

60.0

65.0

70.0

1999-2001 2000-2002 2001-2003 2002-2004 2003-2005 2004-2006

Year

PM2.5 24-Hour Design Value (μg/m3

)

34 007 0003 Camden Lab Primary, NJ 34 007 1007 Pennsauken, NJ

34 015 5001 Gibbstown, NJ 42 101 0004 1501 E. Lycoming Ave. Ams Lab, PA

42 101 0136 Amtrak, 5917 Elmwood Ave., PA 10 003 2004 MLK Blvd. & Justison St., DE

10 003 1012 Univ. DE North Campus, DE

Former Daily PM2.5 NAAQS = 65.0 μg/m3

New Daily PM2.5 NAAQS = 35.0 μg/m3
xix

For the 1997 PM2.5 standards, 

New Jersey is part of two multistate nonattainment areas. Figure 

ES.5 shows New Jersey’s two 

1997 PM2.5 multi-state 

nonattainment areas. Both of 

New Jersey’s associated PM2.5

nonattainment areas have an 

attainment date of April 5, 2010, 

requiring that their attainment 

demonstrations be submitted to 

the USEPA by April 5, 2008. 

The core of this SIP revision is 

New Jersey’s demonstration that 

its two multi-state PM2.5

nonattainment areas will attain 

the PM2.5 National Ambient Air 

Quality Standard (NAAQS) by 

April 5, 2010. The remainder of 

the SIP revision addresses the 

other mandatory SIP elements 

for PM2.5.

Specifically, the primary components of the SIP revision include:

Attainment Demonstration:

New Jersey and the other states that share New Jersey’s 1997 PM2.5 multi-state 

nonattainment areas have always met and are in attainment with the 1997 daily PM2.5

health-based standard of 65 μg/m3. According to the USEPA’s modeling guidance,2

since these levels are well below the standard and have continued to improve since 2001, 

the modeled attainment test for the 1997 daily PM2.5 standard is not needed nor is 

included in this attainment demonstration. This SIP revision demonstrates that the two 

multi-state nonattainment areas for the 1997 PM2.5 NAAQS associated with New Jersey 

will attain the annual health-based standard of 15.0 μg/m3 by the required April 5, 2010 

attainment date. The core of this attainment demonstration is the photochemical air 

quality simulation modeling relied upon for the State’s 8-hour ozone attainment 

demonstration.3 This ozone season (May 1 – September 30) photochemical modeling 

was supplemented by additional months of air quality modeling to predict attainment of 

 2 USEPA. Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air 

Quality Goals for Ozone, PM2.5, and Regional Haze. United States Environmental Protection Agency, 

Office of Air Quality Planning and Standards, Air Quality Analysis Division, Air Quality Modeling Group, 

Research Triangle Park, NC, EPA-454/B-07-002, April 2007, pg. 56. 3 NJDEP. 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.

BERKS

PIKE

ORANGE

SUFFOLK

LUZERNE

KENT

BUCKS

OCEAN

CHESTER

LANCASTER

MONROE

SUSSEX

FAIRFIELD

BURLINGTON

MORRIS

SCHUYLKILL

CECIL

WAYNE

ATLANTIC

NEW HAVEN

SALEM

KENT

COLUMBIA

CARBON

HARFORD

LEHIGH

WARREN

SULLIVAN

WYOMING

MONMOUTH

LEBANON

CUMBERLAND

HUNTERDON

WESTCHESTER

NASSAU

MIDDLESEX

BERGEN

PUTNAM

MERCER

PASSAIC

ESSEX

LITCHFIELD

UNION

NEW CASTLE

MONTGOMERY

LACKAWANNA

SOMERSET

MIDDLESEX

CAMDEN

GLOUCESTER

NORTHAM PTON

QUEEN ANNES

CAPE MAY

ROCKLAND

DELAWARE

ULSTER

QUEENS

CAROLINE

PHILADELPHIA

HARTFORD

KINGS

HUDSON

BRONX

RICHMOND

NEW YORK

In Attainment 

NY_NJ_LI_CT_nonattainment_area

PA_NJ_DE_nonattainment_area

Geographic Areas

DE

NJ

CT

NY

PA

MD

In Attainment

NNJ/NY/CT Nonattainment Area 

SNJ/Phila. Nonattainment Area

Figure ES.5: New Jersey-Associated 1997 PM2.5

Nonattainment Areas
xx

the 1997 annual PM2.5 NAAQS. This modeling is dependent upon the implementation of 

numerous additional control measures, referred to as Beyond on the Way (BOTW) 

measures, prior to 2009. Since this attainment demonstration will show attainment of the 

PM2.5 standard within five years of the date of designation, the State is not required to 

submit a separate Reasonable Further Progress Plan.4 

This modeling demonstration shows that all but one of the monitors in the two multi-state 

PM2.5 nonattainment areas will be in attainment of the 1997 annual standard by April of 

2010. Furthermore, the attainment demonstration projects that the one outstanding 

monitor in New York City will be within the Weight of Evidence (WOE) range as 

defined by the USEPA,5 and provides additional analyses that show that the air quality is 

projected to attain the 1997 annual PM2.5 NAAQS in New York City. Therefore, this 

attainment demonstration provides additional support that the outstanding New York City 

monitor, as well as the other monitors in both nonattainment areas, will attain the 1997 

annual PM2.5 standard by their required attainment date. These additional WOE analyses 

include:

o Ambient monitoring trends and emission inventory analyses;

o Additional control measures (with quantifiable and non-quantifiable 

benefits) not included in the attainment demonstration modeling that 

deliver air quality benefits; and,

o A discussion of the contribution of transport to nonattainment.

Although this attainment demonstration clearly shows that both of the multi-state 

nonattainment areas associated with New Jersey will attain the 1997 annual health 

standard of 15.0 μg/m3, it does not show that the air quality at all the New Jersey 

monitors will meet New Jersey’s internal annual PM2.5 health-based goal of 12 μg/m3 by 

the April 5, 2010 attainment date. Also, although all New Jersey’s monitors currently, 

and will continue to, meet the 1997 24-hour health-based PM2.5 standard of 65 μg/m3, 

almost half of New Jersey’s monitors are exceeding the 2006 24-hour health-based PM2.5

standard of 35 μg/m3. In order to meet New Jersey’s internal annual PM2.5 goal of 12 

μg/m3 as soon as possible and the 2006 24-hour PM2.5 standard by April 2015, 

improvements in air quality are still needed. New Jersey is required to submit a SIP for 

the 2006 24-hour PM2.5 standard three years after the effective date of designations. 

Currently, the USEPA is on track for an expected effective designation date of April 

2009. The SIPs would then be due April 2012 (tentative and subject to change).

 4 72 Fed. Reg. 20666 (April 25, 2007). 5 The USEPA defines the WOE range for PM2.5 as between 14.5 and 15.5 μg/m3

. See the USEPA 

Modeling Guidance for more information about WOE (USEPA. Guidance on the Use of Models and Other 

Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM2.5, and Regional Haze. United 

States Environmental Protection Agency, Office of Air Quality Planning and Standards, Air Quality 

Analysis Division, Air Quality Modeling Group, Research Triangle Park, NC, EPA-454/B-07-002, April 

2007.).
xxi

Analyses of Reasonable Measures:

42 U.S.C. § 7502(c)(1) (Section 172(c)(1) of the Clean Air Act) requires states with 

nonattainment areas to submit SIPs implementing all reasonably available control 

measures (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, as expeditiously as practicable. In order to satisfy this requirement, New 

Jersey conducted two separate control measure analyses; a Reasonably Available Control 

Technology (RACT) analysis of emission control technologies for major stationary 

sources and a Reasonably Available Control Measures (RACM) analysis of emission 

control technologies from all other sources (mobile and area sources). 

New Jersey’s PM2.5 RACT analysis demonstrates that reductions of direct PM2.5

emissions and its precursors, SO2 and NOx, from certain major stationary source 

categories are reasonable. New Jersey also intends to implement a long-term regional 

strategy to reduce the sulfur content of fuel oil consistent with the Mid-Atlantic/Northeast 

Visibility Union (MANE-VU) statement.6

RACM measures, either alone or in combination, must advance the attainment date by at 

least one year. Following the USEPA’s criteria, this SIP revision provides both a RACM 

and a RACT analysis for direct PM2.5 and SO2. The analyses completed for NOx were 

submitted to the USEPA as part of the State’s 8-hour ozone SIP submitted in 20077 and 

are included as attachments to this SIP revision. While New Jersey’s RACM analysis did 

identify several “reasonable” measures, implementation of those measures would not 

advance the nonattainment areas’ attainment date by one year, to April 5, 2009 (which 

would require demonstration of attainment by 2008). However, several of the measures 

identified as part of this analysis are being proposed for implementation by either New 

Jersey or the federal government to ensure the protection of public health. 

Contingency Plans:

Pursuant to 42 U.S.C. §§ 7502(c)(9) and 7511a(c)(9), New Jersey developed contingency 

plans that in the event that New Jersey fails to attain the 1997 annual PM2.5 NAAQS by 

April 5, 2010, control measures will be implemented to ensure attainment of the NAAQS. 

Each contingency plan must provide for actions to reduce one (1) year of the projected 

emission reductions from the 2002 base year to the attainment year. The USEPA does 

not require a separate Reasonable Further Progress (RFP) submittal for areas with 2010 

attainment dates and a demonstration that shows attainment (72 Fed. Reg. 20633 (April 

25, 2007). Thus, New Jersey does not need to submit a separate contingency plan related 

to RFP due to its submittal of an attainment demonstration that satisfies the 2010 

 6 MANE-VU. Statement of the Mid-Atlantic/Northeast Visibility Union (MANE-VU) Concerning a 

Course of Action within MANE-VU toward Assuring Reasonable Progress. Adopted June 20, 2007. 7 NJDEP. 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.
xxii

deadline. To meet the 2009 attainment contingency milestone, New Jersey relies on 

those additional measures that were not included in the attainment demonstration 

modeling, but will result in emission reductions in 2009 and beyond. 

Conformity:

The SIP revision addresses transportation conformity requirements for the 1997 annual 

PM2.5 NAAQS. New Jersey establishes onroad vehicle emission budgets for use by the 

Metropolitan Planning Organizations. Each of the two Metropolitan Planning 

Organizations that have planning areas that include counties that are located within 

nonattainment areas8 must meet these budgets (once they are approved by the USEPA) in 

order to ensure that their plans and programs are in conformance with the SIP. 

New Source Review (NSR):

With respect to the PM2.5 standard, New Jersey has both attainment and nonattainment 

areas throughout the State, necessitating both a Prevention of Significant Deterioration

(PSD) and Nonattainment New Source Review (NNSR) program with respect to this 

pollutant. The USEPA finalized its implementation rule for the 1997 PM2.5 NAAQS on 

April 25, 20079 No final PM2.5 requirements for the NSR program were included. The 

USEPA issued a portion of the NNSR rule for PM2.5 on May 16, 2008.10 

Prior to the implementation of that rule, the USEPA issued interim guidance11,12 calling 

for use of coarse particulate matter (PM10) as a surrogate for PM2.5 in the PSD and NNSR 

programs until NSR rules were finalized. However, because of the lack of NSR 

guidance, PM10 was used as a surrogate in both attainment and nonattainment areas. 

Under the surrogate approach, compliance with applicable requirements for PM10 was 

assumed to satisfy PM2.5 requirements. Between July 15, 2008 and the effective date of 

New Jersey’s NSR rules for PM2.5 (expected in 2011), the USEPA’s Appendix S (40 

C.F.R. pt. 51) applies.

The PM2.5 NSR rule allows up to three years for states to revise their regulations and SIP.

New Jersey expects the three year clock to be triggered once the USEPA adopts the 

remaining components of its PM2.5 NSR implementation rules, which are expected by the 

summer of 2009. The NJDEP expects to develop NNSR rule strategies in 2009, propose 

a NNSR rule revision in 2010, and adopt a revised NSR rule in 2011. 

 8 The two Metropolitan Planning Areas affected are the North Jersey Transportation Planning Authority 

(NJTPA) and the Delaware Valley Regional Planning Commission (DVRPC). 9 72 Fed. Reg. 20586-667 (April 25, 2007). 10 73 Fed. Reg. 28321-350 (May 16, 2008). 11 USEPA Memorandum from Stephen D. Page, Director, Office of Air Quality Planning and Standards, to 

Regional Air Directors, “Implementation of New Source Review Requirements in PM-2.5 Nonattainment 

Areas,” April 5, 2005. 

12 USEPA Memorandum from John S. Seitz, Director, Office of Air Quality Planning and Standards, to 

Regional Air Directors, “Interim Implementation of New Source Review for PM2.5,” October 23, 1997.
xxiii

The NJDEP also expects to adopt New Jersey specific PSD rules in the same timeframe. 

Currently, NJDEP implements most of the Federal PSD rules under a delegation 

agreement and will continue to do so until New Jersey PSD rules are effective.

Other Components of the SIP Revision:

- Background and introductory information on direct PM2.5 and its precursors;

- How New Jersey’s PM2.5 initiatives support the State’s other PM-related air 

quality challenges;

- A summary of PM2.5 ambient air quality and inventory trends data for New 

Jersey and its associated multi-state nonattainment areas;

- Detailed descriptions of all the control measures used throughout the SIP 

revision;

- A reaffirmation of New Jersey’s actions and commitments with respect to 

transported emissions, as required by Section 110 (a)(2)(D)(i) of the Clean Air 

Act (and commonly referred to as the transport SIP requirement); and, 

- A summary of all New Jersey’s commitments and requests of the USEPA. 
1

1.0 INTRODUCTION AND BACKGROUND

The primary purpose of this state implementation plan (SIP) revision is to demonstrate that New 

Jersey and its associated multi-state nonattainment areas will attain the 1997 fine particulate 

matter (PM2.5) national ambient air quality standards (NAAQS) by April 5, 2010. While New 

Jersey plans to fulfill its obligations under the Federal Clean Air Act and the State’s Air 

Pollution Control Act with respect to both the 1997 and 2006 PM2.5 standards (see discussions of 

these standards in this Section 1.1), the State faces several other air quality related challenges, 

including meeting other criteria pollutant NAAQS (such as 8-hour ozone), reducing diesel and 

other air toxic emissions, and improving visibility, that are interrelated with the PM2.5 initiative. 

In determining air quality management plans, the State must not only meet federal and state 

requirements, it must also address the local needs and requirements. These needs and 

requirements are embodied in the State’s Energy Master Plan, New Jersey Department of 

Environmental Protection (NJDEP) Action Plan, the State Development/Redevelopment Plan, 

and the State’s Environmental Justice Plan, to name a few. See Section 1.3 for more information 

on how this PM2.5 SIP revision helps meet these air quality related challenges. Significant

progress has been made in improving New Jersey’s air quality. Even more needs to be done to 

meet all of these requirements, and it is important that the State coordinate to work toward 

consistency in implementing the most efficient and effective emission reduction strategies. The 

remainder of this chapter includes:

• An explanation of PM2.5 and its associated health standards 

• A discussion of the health and welfare impacts associated with PM2.5 and its likely 

precursors

• A discussion of how this SIP revision relates to the State’s other air quality goals

1.1 Fine Particulate Matter and its Associated Health Standards 

Fine particulate matter in the atmosphere is composed of a complex mixture of particles: sulfate, 

nitrate, and ammonium particles; particle-bound water; black carbon (also known as elemental 

carbon); a great variety of organic compounds (or volatile organic compounds (VOCs)); and 

crustal material. Fine particulate matter, also known as PM2.5, is referred to as “primary” if it is 

directly emitted into the air as a solid or liquid particle and its chemical form is stable. PM2.5

formed near its source by condensation processes in the atmosphere is also considered primary 

PM2.5. Primary PM2.5 includes soot from diesel engines, a wide variety of organic compounds 

condensed from incomplete combustion, and compounds such as arsenic, selenium, and zinc that 

condense from vapor formed during combustion or smelting. The concentration of primary 

PM2.5 in the air depends on source emission rates, transport and dispersion, and removal rate 

from the atmosphere. 

PM2.5 that is formed by chemical reactions of gases in the atmosphere is referred to as 

“secondary” PM2.5. These reactions form condensable matter that either form new particles or 

condense onto other particles in the air. Most of the sulfate and nitrate and a portion of the 

organic particles in the atmosphere are formed by such chemical reactions. As such, sulfur 
2

dioxide (SO2), oxides of nitrogen (NOx), some VOC,

13 and ammonia can be considered PM2.5

precursors.

14 Secondary PM2.5 formation depends on numerous factors including the 

concentrations of precursors; the concentrations of other gaseous reactive species such as ozone, 

hydroxyl radicals, peroxy radicals, or hydrogen peroxide; atmospheric conditions including solar 

radiation and relative humidity; and the interactions of the precursors and pre-existing particles 

with cloud or fog droplets or with the liquid film on solid particles. The United States 

Environmental Protection Agency (USEPA) recognizes that NOx, SO2, VOCs, and ammonia are

precursors of PM2.5 from a scientific perspective because these pollutants can contribute to the 

formation of PM2.5 in the ambient air. The USEPA has established a policy regarding PM2.5

precursors for planning and regulatory purposes in its PM2.5 Implementation Rule,

15 which 

focuses on NOx and SO2 in the Eastern United States. For more information on this policy, see 

Chapter 3. The health and welfare impacts of PM2.5 and its precursors are described in Section 

1.2 of this Chapter.

 

The USEPA, under the authority of the Federal Clean Air Act, identified PM2.5 as a criteria air 

pollutant, and established National Ambient Air Quality Standards (NAAQS), for PM2.5. 

Specifically, the Clean Air Act (42 U.S.C. § 7409(b)(1) (Section 109(b)(1)) requires the USEPA

to set primary NAAQS “the attainment and maintenance of which..., based on such criteria and 

allowing an adequate margin of safety, are requisite to protect the public health.” The Clean Air 

Act (42 U.S.C. § 7409(b)(2) (Section 109(b)(2)) further requires the USEPA to set secondary 

NAAQS “requisite to protect the public welfare from any known or anticipated adverse effects 

associated with the presence of such air pollutant in the ambient air.” When an area does not 

meet the established NAAQS for a criteria pollutant, the area is subject to a formal designation

process by the USEPA, which establishes the area as nonattainment for that pollutant. 

1997 PM2.5 NAAQS:

On July 18, 1997, the USEPA established two new primary NAAQS for fine particles:

o an annual PM2.5 health-based standard of 15 micrograms per cubic meter (μg/m3

) (annual 

arithmetic mean); and 

o a daily (24-hour) PM2.5 health-based standard of 65 micrograms per cubic meter (μg/m3

) 

(24-hour average).16,17 (This has since been revised to 35 μg/m3

).

Simultaneously, the USEPA established secondary (welfare-based) PM2.5 standards identical to 

the primary standards. These standards are hereafter referred to as the 1997 PM2.5 standards. 

The USEPA set the PM2.5 standards with 24-hour and annual averaging times to protect against 

 13 According to the USEPA, high molecular weight organic compounds (typically 25 carbon atoms or more) are 

emitted directly as primary organic particles and exist primarily in the condensed phase at ambient temperatures. 

Accordingly, high molecular weight organic compounds are considered a primary PM2.5 emission for the purposes 

of the PM2.5 implementation program (72 Fed. Reg. 20592 (April 25, 2007)). 14 72 Fed. Reg. 20586-667 (April 25, 2007). 15 72 Fed. Reg. 20586-667 (April 25, 2007). 16 62 Fed. Reg. 38652-760 (July 18, 1997). 17 The USEPA also revised the PM10 NAAQS by revising the 24-hour form of the PM10 standard to the 99th

percentile averaged over 3 years but retaining the 24-hour PM10 level (i.e., 150 mg/m3

) (62 Fed. Reg. 38652 (July 

18, 1997)). In 2006, the USEPA revoked the annual PM10 standard (71 Fed. Reg. 61144 (October 17, 2006)). New 

Jersey was not designated in nonattainment of the PM10 NAAQS and continues to meet the revised PM10 standards.
3

effects from short- and long-term exposure identified by a number of published epidemiological 

studies.

A number of events delayed implementation of the 1997 PM2.5 standard.18 Specifically, the 

USEPA’s 1997 standards were challenged by the American Trucking Association, the U.S. 

Chamber of Commerce, and other state and business groups. The Transportation Equity Act for 

the Twenty-first Century (TEA-21) revised the deadline to publish nonattainment designations in 

order to provide additional time to collect three years of air quality monitoring data. In February 

2001, the Supreme Court upheld the USEPA’s authority under the Clean Air Act to set NAAQS

that protect the American public from the harmful effects of air pollution. The Supreme Court 

also sent the case back to the D.C. Circuit Court of Appeals to resolve several additional issues.

In March 2002, the D.C. Circuit Court rejected all remaining legal challenges to the USEPA’s 

1997 ambient air quality standards for PM2.5.

Clear of all legal challenges, on December 17, 2004, the USEPA finalized 

attainment/nonattainment designations for the 1997 PM2.5 standards, which became effective on 

April 5, 2005.19 Thirteen of New Jersey’s 21 counties were designated as nonattainment for the 

1997 PM2.5 standards, and are associated with two multi-state nonattainment areas (the Northern 

New Jersey/New York/Connecticut (NNJ/NY/CT) PM2.5 nonattainment area and the Southern 

New Jersey/Philadelphia (SNJ/Phila.) PM2.5 nonattainment area). Figure 1.1 shows New 

Jersey’s 1997 PM2.5 multi-state nonattainment areas.

 18 USEPA. Fact Sheet: Areas Designated Nonattainment for the Fine Particle National Air Quality Standards. 

United States Environmental Protection Agency, December 17, 2004, 

http://www.epa.gov/pmdesignations/documents/final/factsheet.htm, accessed June 28, 2007.

19 72 Fed. Reg. 20586-667 (April 25, 2007).
4

Figure 1.1: New Jersey-Associated 1997 PM2.5 Nonattainment Areas

These designations triggered the Clean Air Act (CAA) requirement, 42 U.S.C. § 7410(a)(1) 

(Section 110(a)(1)), that states submit attainment demonstrations for their nonattainment areas to 

the USEPA by no later than three years after the promulgation of a NAAQS. However, given 

the delays in finalizing the implementation of the 1997 PM2.5 standards, the USEPA provided 

supplemental guidance requiring states to submit attainment demonstrations for their 1997 PM2.5

nonattainment areas to the USEPA by no later than three years from the effective date of 

designation (that is, April 5, 2008).20 The primary purpose of this SIP revision is to meet that 

requirement for the 1997 annual PM2.5 standard by presenting New Jersey’s plan for attaining the 

annual PM2.5 NAAQS by its attainment date of April 5, 2010. 

2006 PM2.5 Standards:

42 U.S.C. § 7409(d)1 (Section 109(d)) requires the USEPA to review and, if appropriate, revise 

the NAAQS for each criteria air pollutant every five years. On October 16, 2006, the USEPA 

promulgated a revised PM2.5 NAAQS, which became effective December 18, 2006.21 This 

revised NAAQS did not result in any changes to the annual standard established in 1997 but 

resulted in a more stringent daily standard of 35 μg/m3. The 2006 PM NAAQS retained the level 

of the annual standard of 15.0 μg/m3

. These standards are hereafter referred to as the 2006 PM2.5

standards. Table 1.1 compares the 1997 and 2006 PM2.5 standards.

 20 USEPA. Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals 

for Ozone, PM2.5, and Regional Haze. United States Environmental Protection Agency, Office of Air Quality 

Planning and Standards, Air Quality Analysis Division, Air Quality Modeling Group, Research Triangle Park, NC, 

EPA-454/B-07-002, April 2007. 21 71 Fed. Reg. 61144-233 (October 17, 2006).

BERKS

PIKE

ORANGE

SUFFOLK

LUZERNE

KENT

BUCKS

OCEAN

CHESTER

LANCASTER

MONROE

SUSSEX

FAIRFIELD

BURLINGTON

MORRIS

SCHUYLKILL

CECIL

WAYNE

ATLANTIC

NEW HAVEN

SALEM

KENT

COLUMBIA

CARBON

HARFORD

LEHIGH

WARREN

SULLIVAN

WYOMING

MONMOUTH

LEBANON

CUMBERLAND

HUNTERDON

WESTCHESTER

NASSAU

MIDDLESEX

BERGEN

PUTNAM

MERCER

PASSAIC

ESSEX

LITCHFIELD

UNION

NEW CASTLE

MONTGOMERY

LACKAWANNA

SOMERSET

MIDDLESEX

CAMDEN

GLOUCESTER

NORTHAM PTON

QUEEN ANNES

CAPE MAY

ROCKLAND

DELAWARE

ULSTER

QUEENS

CAROLINE

PHILADELPHIA

HARTFORD

KINGS

HUDSON

BRONX

RICHMOND

NEW YORK

In Attainment 

NY_NJ_LI_CT_nonattainment_area

PA_NJ_DE_nonattainment_area

Geographic Areas

DE

NJ

CT

NY

PA

MD

In Attainment

NNJ/NY/CT Nonattainment Area 

SNJ/Phila. Nonattainment Area
5

Table 1.1: 1997 and 2006 PM2.5 Standards

1997 PM2.5 Standards 2006 PM2.5 Standards

Primary Annual 15 μg/m3 15 μg/m3 *

Primary Daily 65 μg/m3 35 μg/m3

Secondary Annual 15 μg/m3 15 μg/m3 *

Secondary Daily 65 μg/m3 35 μg/m3

*The form of the annual standards changed with respect to the criteria for spatial averaging. 

Although fine particulate concentrations have improved since December 2004, New Jersey 

recommended that the annual nonattainment boundaries for the 2006 annual standard remain the 

same as previously designated for the 1997 annual standard since the State continued to either 

exceed the 2006 annual PM2.5 standard (which remained the same as the 1997 annual PM2.5

standard) or contribute to an exceedance of that standard in an upwind area at the time these 

recommendations were due (see Figure 1.1). 

As with the 1997 PM2.5 standards, the USEPA must designate areas that are not attaining the 

2006 PM2.5 standards. In accordance with 42 U.S.C. § 7407(d)(1)(A) (Section 107(d)(1)(A)), of 

the Clean Air Act, each state is allowed to make recommendations to the USEPA on which areas 

of their state should be designated nonattainment with respect to any new NAAQS. For the 2006 

PM2.5 standards, states were required to submit their attainment/nonattainment recommendations 

by December 18, 2007. Although fine particulate concentrations have improved since December 

2004, the air quality in several areas of New Jersey does not meet the 2006 24-hour PM2.5

NAAQS (see Chapter 2) or contribute to an exceedance of that standard in an upwind area at the 

time these recommendations were due (see Figure 1.1). New Jersey recommended that the 

nonattainment boundaries designated for the 1997 annual PM2.5 standard also apply for the 2006 

24-hour PM2.5 standard with one addition.22 The State requested Knowlton Township in Warren 

County be designated nonattainment and be associated with the Allentown-Bethlehem-Easton 

PM2.5 nonattainment area in Pennsylvania (which Pennsylvania has recommended include 

Lehigh and Northampton counties).23 The final daily PM2.5 designations will be issued by the 

USEPA by the Spring of 2009.

As the USEPA goes through the process of officially designating these areas as nonattainment 

for that new standard, New Jersey need not wait for those designations to address that new 

standard, particularly since it is the State’s obligation to meet NAAQS as expeditiously as 

practical to protect human health and welfare. Therefore, New Jersey considered its need to 

meet this additional 2006 Federal standard in the near future when developing the action plan 

included in this SIP revision to meet the 1997 PM2.5 NAAQS. Hence, this SIP revision, while 

 22 For more information on New Jersey’s nonattainment area recommendations, see the letter from NJDEP 

Commissioner Lisa P. Jackson to USEPA Regional Administrator Steinberg dated December 18, 2007. The letter is 

posted on the NJDEP’s website at http://www.nj.gov/dep/baqp/pm25desig2007.pdf. 23 PADEP. Recommendations to the U.S. EPA for 24-Hour Fine Particulate (PM2.5) Attainment/Nonattainment 

Areas. Bureau of Air Quality, Pennsylvania Department of Environmental Protection, December 2007. Accessible 

at http://www.dep.state.pa.us/dep/deputate/airwaste/aq/attain/pm25des/2007_PM2.5_Attain-Non.pdf.
6

focused on achieving the annual PM2.5 NAAQS, will also make progress toward achieving the 

24-hour PM2.5 NAAQS. 

In addition to the USEPA, some states, including New Jersey, have the authority to establish air 

quality standards. These state standards must either be equivalent to or more stringent than those 

established by the USEPA. While New Jersey has not taken official steps to establish its own air 

quality standards for PM2.5, the NJDEP’s air quality goal for an annual PM2.5 standard is 12 

μg/m3

. A goal of 12 μg/m3 is a 20 percent reduction from the Federal annual PM2.5 NAAQS

established in 1997. New Jersey, in commenting on the USEPA’s proposal for revising the 

PM2.5 standard, argued that, given the preponderance of health studies cited in the USEPA Staff 

Paper, peer-reviewed and supported by the Clean Air Scientific Advisory Committee (CASAC), 

that suggest that significant segments of the Unites States population are experiencing adverse 

health effects from exposures to ambient concentrations of PM2.5, even at levels below the 

annual standard of 15 μg/m3, the USEPA should act decisively on this critical public health issue 

by decreasing the annual PM2.5 health standard to 12 μg/m3.

24 The USEPA subsequently 

decided to retain the annual standard of 15 μg/m3. This goal also acknowledges that the 

California Air Resources Board’s (CARB) revised California’s annual PM2.5 standard to 12 

μg/m3 (annual mean), which is more stringent than the Federal NAAQS established in 1997, and 

retained in 2006.

25,26 The CARB’s establishment of a more stringent annual PM2.5 health-based

standard to provide greater public health protection gives reason to re-evaluate whether or not the 

Federal standard of 15 μg/m3 is protective enough, given that no threshold had been established 

below which there are no health effects from exposure to particulate emissions. Achieving the 

NJDEP’s goal of 12 μg/m3 will provide greater protection of its citizens than would be achieved 

at 15 μg/m3 ambient levels. The implication of adopting such a goal requires that New Jersey 

take aggressive action to ensure that PM2.5 health and welfare impacts are alleviated as soon as 

possible.

1.2 Health and Welfare Impacts of PM2.5 and PM2.5 Precursors

1.2.1 Fine Particulate Matter

The health effects associated with exposure to fine particles are significant, mainly due to the 

fact that particles of this size can easily reach into the deepest regions of the lungs. Significant 

health effects associated with fine particle exposure include: 

• premature mortality;

• aggravation of respiratory and cardiovascular disease;

• decreased lung function and difficulty breathing;

• asthma attacks; and 

 24 Letter dated December 16, 2005 from then NJDEP Commissioner Bradley M. Campbell to USEPA Region II 

Administrator Stephen L. Johnson. 

25 CAEPA. Staff Report: Public Hearing to Consider Amendments to the Ambient Air Quality Standards for 

Particulate Matter and Sulfates. Prepared by the Staff of the Air Resources Board and the Office of Environmental 

Health Hazard Assessment, California Environmental Protection Agency (CAEPA), May 3, 2002. 26 Adopted in 2002, pursuant to the Children’s Environmental Health Protection Act (Senate Bill 25, Senator Martha 

Escutia; Stats. 1999, Ch. 731, Sec. 3).
7

• serious cardiovascular problems, such as heart attacks and cardiac arrhythmia.27,28,29 

The USEPA has estimated that attainment of the 1997 annual and daily PM2.5 standards 

nationally would prolong tens of thousands of lives and prevent tens of thousands of hospital 

admissions each year.30 In addition, attainment of these standards would prevent hundreds of 

thousands of doctor visits, absences from work and school, and respiratory illnesses in children. 

Individuals particularly sensitive to fine particle exposure include older adults, people with heart 

and lung disease, and children. The elderly have been shown to be particularly at risk for 

premature death from the effects of particulate matter. Health studies have shown that there is 

no clear threshold below which adverse effects are not experienced by at least certain segments 

of the population. Thus, some individuals particularly sensitive to fine particle exposure may be 

adversely affected by fine particle concentrations below those for even the revised 2006 annual 

and daily standards. Hence, the NJDEP intends to achieve cleaner air than the current NAAQS 

to increase health benefits.

Incorporating new scientific literature on premature mortality due to PM2.5 exposure, an analysis 

of the relative risk of premature death in California attributed to PM2.5 conducted by the 

California Air Resources Board demonstrated that 14,000 to 24,000 premature deaths 

(uncertainty range: 4,300 – 41,000) occur statewide each year.31 These estimations were based 

upon the revised relative risk factor, a 10 percent increase in premature death per 10 mg/m3

increase in PM2.5 exposures (uncertainty interval: 3 to 20 percent), and the lowest threshold of 

ambient PM2.5 which is associated with premature death, 7 mg/m3 in a general population. 

A particular concern for New Jersey with respect to PM2.5 is its ability to aggravate asthma. The 

NJDEP has estimated that approximately 1,900 deaths and 53,000 cases of asthma in the State 

each year are attributable to exceedances of the PM2.5 annual standard, with associated medical 

costs of approximately $15 billion.32 According to the last Federal estimate (1998),

33 more than 

600,000 New Jersey residents have asthma. In 2001, asthma sufferers in New Jersey accounted 

for nearly 14,000 hospital admissions, roughly one out of every one hundred hospitalizations. In 

1999, the deaths of 80 New Jersey residents were attributed to asthma. The Centers for Disease 

Control and Prevention estimate that 4.5 million children in the United States have asthma. 

According to the Pediatric/Adult Asthma Coalition of New Jersey (Coalition), “approximately 

 27 62 Fed. Reg. 38652-690 (July 18, 1997). 28 72 Fed. Reg. 20586-87 (April 25, 2007).

29 USEPA. Air Quality Criteria for Particulate Matter. United States Environmental Protection Agency, Research 

Triangle Park, North Carolina: National Center for Environmental Assessment—RTP, Office of Research and 

Development; report no. EPA/600/P–99/002aF and EPA/600/P–99/002bF. October 2004. 30 62 Fed. Reg. 38652-690 (July 18, 1997). 31 CARB. Methodology for Estimating Premature Deaths Associated with Long-term Exposures to Fine Airborne 

Particulate Matter in California, Draft Staff Report. California Air Resources Board, May 22, 2008. Available at 

http://www.arb.ca.gov/research/health/pm-mort/pm-mortdraft.pdf. 32 State of New Jersey. Diesel Retrofit Program Rule Proposal. New Jersey Department of Environmental 

Protection, Office of Air Quality Management, Motor Vehicle Commission, and Department of the Treasury, 

December 18, 2006. Proposal Number: PRN 2006-409, DEP Docket Number: 22-06-11/559. Available at 

http://www.nj.gov/dep/aqm/Diesel%20Retrofit%20Program%20Rule%20Proposal.pdf. 33 NJDHSS. Asthma in New Jersey. New Jersey Department of Health and Senior Services, February 2003.
8

10-13% of New Jersey’s students have asthma.”34 According to the New Jersey Department of 

Health and Senior Services, “children are more likely to be hospitalized with asthma than 

adults.”35 The risk of death from asthma increases considerably with age, with the 65-plus 

population having the highest rates.36 

In addition to asthma, a recent report by the New Jersey Clean Air Council states that only 

smoking and obesity outrank particulate matter in the estimated number of premature deaths 

caused every year.37 These statistics show that asthma is a significant health risk in the State but 

there are other serious health impacts from PM2.5.

Although fine particulate matter generated from all sources can cause serious health impacts, 

particulate matter generated from diesel combustion is particularly harmful. The concern over 

diesel particulate matter is two-fold. First, while diesel engines collectively are large sources of 

NOx and direct fine particle emissions, they also emit significant amounts of other toxic air 

pollutants.38 Diesel exhaust contains many of the hazardous air pollutants that are prevalent in 

urban areas, such as acetaldehyde, acrolein, benzene, 1,3-butadiene, formaldehyde, and 

polycyclic aromatic hydrocarbons. The USEPA has recently identified diesel particulate matter 

and diesel exhaust organic gases as a Mobile Source Air Toxic and has classified diesel exhaust 

as a likely human carcinogen when inhaled at environmental exposures. The State of California 

also identified diesel particulate matter as a toxic air contaminant in 1998, based on its potential 

carcinogenicity and other health impacts.39 Therefore, in addition to the premature mortality

associated with the inhalation of fine particulate matter in general, diesel exhaust has an added 

cancer risk that makes exposure to it more detrimental to human health. In New Jersey, exposure 

to diesel PM poses the most cancer risk statewide by an order of magnitude; formaldehyde, 

which is also emitted by engines, poses the next most cancer risk.40

 34 State of New Jersey. Diesel Retrofit Program Rule Proposal. New Jersey Department of Environmental 

Protection, Office of Air Quality Management, Motor Vehicle Commission, and Department of the Treasury, 

December 18, 2006. Proposal Number: PRN 2006-409, DEP Docket Number: 22-06-11/559. Available at 

http://www.nj.gov/dep/aqm/Diesel%20Retrofit%20Program%20Rule%20Proposal.pdf. 35 NJDHSS. Asthma in New Jersey Annual Update 2005. New Jersey Department of Health and Senior Services, 

September 2005. Available at http://www.state.nj.us/health/fhs/asthma/documents/asthma_update2005.pdf. 36 State of New Jersey. Diesel Retrofit Program Rule Proposal. New Jersey Department of Environmental 

Protection, Office of Air Quality Management, Motor Vehicle Commission, and Department of the Treasury, 

December 18, 2006. Proposal Number: PRN 2006-409, DEP Docket Number: 22-06-11/559. Available at 

http://www.nj.gov/dep/aqm/Diesel%20Retrofit%20Program%20Rule%20Proposal.pdf. 37 Clean Air Council of New Jersey. Public Hearing – Fine Particulate Matter in the Atmosphere: Health Impacts in 

NJ & Need for Control Measures, April 2004. Available at http://www.state.nj.us/dep/cleanair. 38 USEPA. Health Assessment Document for Diesel Engine Exhaust. United States Environmental Protection 

Agency, Office of Research and Development, National Center for Environmental Assessment, Washington, DC, 

EPA/600/8-90/057F, May 1, 2002.

39 CARB. Summary of Adverse Impacts of Diesel Particulate Matter. Air Resources Board, California 

Environmental Protection Agency, July 2005. 

http://www.arb.ca.gov/research/diesel/diesel_health_effects_summary_7-5-05-1.pdf, accessed December 19, 2007. 40 NJDEP. New Jersey Statewide Average 1999 NATA Modeled Air Concentrations Compared to Health 

Benchmarks. New Jersey Department of Environmental Protection, November 21, 2006, 

http://www.nj.gov/dep/airtoxics/nj.htm, accessed January 18, 2008.
9

Second, the size of diesel particulate matter may add to its health impacts. Almost all of the 

particles produced by diesel exhaust are fine particulate matter (between 0 and 2.5 μg/m3

), much 

in the ultra-fine range (that is, particles with an aerodynamic diameter of less than 0.1 

micrometer). Since both fine and ultra-fine particles are respirable, many of these particles are 

not captured by the human respiratory system’s defense mechanisms and these small particles 

enter deeply into the lung. Studies have shown that ultra-fine particles are so small that they are 

capable of penetrating the lungs and other tissue all the way to a cellular level, where they may 

induce structural damage in the body’s core building blocks. 

In addition to health effects, particulate matter is the major cause of reduced visibility in many 

parts of the United States. Visibility impairment caused by the collection of air pollutants 

(primarily PM2.5) emitted by sources over a broad geographic area is known as regional haze.41 

See Section 1.3.5 for more information on visibility and regional haze initiatives. Other welfare 

impacts from direct PM2.5 pollution include harmful effects to vegetation and ecosystems (e.g.,

sedimentation and loss of biodiversity), contributions to the formation of acid rain (e.g., making 

soils, lakes and streams more acidic), aesthetic damage to manmade structures, and damages to 

sensitive forests and farm crops.

42 Excessive fine particles in the air also alter the amount of 

radiation that penetrates the Earth’s atmosphere, affecting the Earth’s climate.43 Of special 

concern, black carbon increases global warming.

1.2.2 Sulfur Dioxide (SO2)

Sulfur dioxide, or SO2, contributes to the formation of fine particulates. SO2 belongs to the 

family of sulfur oxide gases (SOx). Sulfur is prevalent in raw materials such as crude oil, coal,

and metal ores. SOx gases are formed when fuels containing sulfur, such as coal and oil, are 

burned, when gasoline is extracted from oil, or when metals are extracted from ore. The sulfur is 

then oxidized and emitted as SOx gases. SO2 can be oxidized to form sulfuric acid in three ways: 

by the hydroxyl radical (OH) to form sulfuric acid, by dissolving in cloud water and oxidized by 

various oxidants to form sulfuric acid, or by the reactions that take place in the particle-bound 

water in the aerosol particles.44 Sulfate can exist in particles as sulfuric acid, and sulfate is an 

important contributor to increased concentrations of PM2.5 around the country.

SO2 dissolves in water vapor to form acid and interacts with other gases and particles in the air to 

form sulfate particles and other products that can be harmful to people and the environment. SO2

and the pollutants formed from SO2, such as sulfate particles, can be transported over long 

distances and deposited far from the point of origin, contributing to air quality problems far 

beyond the areas where they were emitted. The associated health effects with exposure to SO2

include increased respiratory disease, aggravated existing heart disease, and temporary breathing 

 41 64 Fed. Reg. 35714 (July 1, 1999). 42 USEPA. Health and Environment, Particulate Matter. United States Environmental Protection Agency, 

http://www.epa.gov/air/particlepollution/health.html, accessed November 8, 2007. 43 71 Fed. Reg. 61203 (October 17, 2006). 44 72 Fed. Reg. 20594-20595 (April 25, 2007).
10

difficulty, particularly for people with asthma.

45 The elderly and children are at highest risk of 

health effects from exposure to SO2. 

With respect to environmental effects, SO2 harms vegetation and ecosystems, contributes to the 

formation of acid rain (e.g., making soils, lakes, and streams more acidic), and damages trees, 

crops, buildings, and monuments.

1.2.3 Oxides of Nitrogen (NOx)

NOx is a gas-phase precursor that contributes to the formation of PM2.5. Oxides of nitrogen 

consist of a mixture of gases comprised mostly of nitric oxide (NO) and nitrogen dioxide 

(NO2).46 These gases are emitted from the exhaust of motor vehicles, the burning of coal, oil or 

natural gas, and during industrial processes such as welding, electroplating, and dynamite 

blasting. Although most NOx is emitted as NO, it is readily converted to NO2 in the atmosphere. 

The primary processes developed in the past century that convert unreactive nitrogen to reactive 

nitrogen are the manufacture of fertilizer, the combustion of fossil fuels, and the planting of 

nitrogen-harnessing croplands.47 The oxidation of atmospheric N2 during combustion is the 

source of most of the atmospheric NOx (i.e., NO, nitrous oxide (N2O), and NO2).48 NO2 is a 

reddish-brown, highly reactive gas that is formed in the air through the oxidation of NO. In the 

troposphere, near the Earth’s surface, NO2, provides the primary source of the oxygen atoms 

required for ozone formation. 

In addition to contributing to the formation of PM2.5 and ozone, NOx is also harmful if directly 

inhaled. Long-term exposure to elevated levels of NOx causes damage to the mechanisms that 

protect the human respiratory tract and can increase a person’s susceptibility to, and the severity 

of, respiratory infections and asthma.49 Long-term exposure to high levels of NOx can cause 

chronic lung disease and may also affect sensory perception. Other health effects of exposure to 

NOx include shortness of breath and chest pains. 

In addition to harmful health impacts, NOx is also harmful to the environment. It combines with 

other pollutants to form ozone and acid rain that harms vegetation and ecosystems.50 Acid rain 

causes deterioration of cars, buildings, and historical monuments and causes lakes and streams to 

become acidic and unsuitable for many fish. NOx contributes to nutrient overload that impairs 

 45 USEPA. Health and Environmental Impacts of SO2. United States Environmental Protection Agency, 

http://www.epa.gov/oar/urbanair/so2/hlth1.html, accessed November 9, 2007. 46 NJDEP. 2005 Nitrogen Dioxide Summary, 2005 Air Quality Monitoring Report. New Jersey Department of 

Environmental Protection, Bureau of Air Monitoring, 2006. 47 Aber et al. Nitrogen pollution: sources and consequences in the U.S. Northeast. High Beam Encyclopedia from 

Environment, September 1, 2003. Accessed at http://www.encyclopedia.com/doc/1G1-107217746.html. 48 Hemond, H. F. and Fechner-Levy, E. J. Chemical Fate and Transport in the Environment, Second Edition. 

Academic Press: New York, 2000, pg. 292.

49 Queensland Government EPA. Nitrogen Oxides. Queensland Government Environmental Protection Agency, 

Queensland Parks and Wildlife Service, December 31, 2006, 

http://www.epa.qld.gov.au/environmental_management/air/air_quality_monitoring/air_pollutants/nitrogen_oxides/, 

accessed January 2, 2007.

50 USEPA. Health and Environmental Impacts of NOx. United States Environmental Protection Agency, 

http://www.epa.gov/air/urbanair/nox/hlth.html, accessed November 8, 2007.
11

water quality, leads to oxygen depletion, and reduces fish and shellfish populations. It also 

contributes to global warming.

1.2.4 Other PM2.5 Precursors – Volatile Organic Compounds and Ammonia

On April 25, 2007, the USEPA established a policy for which PM2.5 precursors needed to be 

considered for PM2.5 planning and regulatory purposes at this time. This policy specifically 

exempts volatile organic compounds (VOCs) and ammonia (NH3) from consideration as 

precursors unless a state can make a compelling argument for including either of these 

precursors. For more information on the USEPA’s precursor policy, see Chapter 3. Even though 

New Jersey and the states that share its associated nonattainment areas agree with the USEPA’s 

precursor policy regarding VOC and ammonia, the NJDEP is providing a discussion of the 

health effects associated with VOCs and ammonia.

The NJDEP is already regulating VOC emissions as a precursor to ozone. Additionally, high 

molecular weight organic compounds (typically 25 carbon atoms or more) are emitted directly as 

primary organic particles and exist primarily in the condensed phase at ambient temperatures. 

Accordingly, high molecular weight organic compounds are not volatile in nature, and are 

regulated as primary PM2.5 emissions for the purposes of the PM2.5 implementation program. 

The low molecular weight organic compounds are VOCs, as they are chemicals or mixtures of 

chemicals that evaporate easily at room temperature. They include compounds known as 

hydrocarbons, which only contain carbon and hydrogen, and carbonyls, which contain a carbon 

atom double-bonded to an oxygen atom. VOCs can be found in both indoor and outdoor 

environments, and some VOCs are more harmful than others. Sources of VOCs include vehicle 

and industrial exhaust; the evaporation of gasoline; and a variety of consumer products from 

paints, solvents, and adhesives to carpeting, deodorants, cosmetics, hair products, and cleaning 

fluids; as well as biogenic (naturally occurring) emissions. 

In addition to contributing to the formation of PM2.5 and ozone, many VOCs are also considered 

air toxics and are harmful if directly inhaled, depending upon the concentration. Long-term 

exposure to low concentrations of some VOCs includes elevation of serum enzyme levels, mild 

cellular changes, and changes in lipid metabolism. At higher concentrations, breathing VOCs 

may cause irritation of the respiratory tract.51 Acute effects include eye irritation/watering, nose 

irritation, throat irritation, headaches, nausea/vomiting, dizziness and asthma exacerbation. 

Chronic effects include cancer, liver damage, kidney damage and central nervous system 

damage.52 In addition, some VOCs are substances that cause serious health effects, including 

cancer, birth defects, nervous system problems and death due to massive accidental releases.53 

See Section 1.3 for more information about New Jersey initiatives to address air toxics.

 51 CDPHE. Volatile Organic Compounds Health Effects Fact Sheet. Colorado Department of Public Health and 

Environment, November 2000, http://www.cdphe.state.co.us/hm/schlage/vocfactsheet.pdf. 52 MDH. Volatile Organic Compounds – VOCs Fact Sheet. Minnesota Department of Health (MDH), 

http://www.health.state.mn.us/divs/eh/indoorair/voc/, September 2005.

53 USEPA. The Plain English Guide to the Clean Air Act. United States Environmental Protection Agency, Air and 

Radiation (ANR-443), EPA 400-K-93-001, April 1993.
12

VOCs also negatively impact the environment. The most significant environmental impact of 

VOCs is their contribution to the formation of ozone. VOCs can also form PM (specifically, 

secondary organic aerosol (SOA)).54 The significance of organic compounds to the formation of 

SOA depends upon emissions from local sources, atmospheric chemistry, and the season. 

Studies have shown that SOA can be a major component of carbonaceous PM in the summer due 

to the warmer temperatures increasing the chemical reaction rates. The environmental impacts 

of PM2.5 are discussed earlier in this Section. In addition, vegetation is a source of biogenic 

VOCs, and these naturally occurring VOCs contribute to the haze aerosols formed over forested 

areas.55 VOCs from emission sources can accumulate in plants and have detrimental impacts to 

protective mechanisms, which then can affect the entire ecosystem.

Ammonia (NH3) is a gaseous pollutant that can also contribute to the formation of PM2.5. 

Ammonia emissions come from natural and anthropogenic sources. Emission inventories for 

ammonia are considered to be among the most uncertain of any species related to PM. In 

addition, though recent studies have improved our understanding of the role of ammonia in 

aerosol formation, ongoing research is required to better describe the relationships between 

ammonia emissions, particulate matter concentrations, and related impacts. The control 

techniques for ammonia and the analytical tools to quantify the impacts of reducing ammonia 

emissions on atmospheric aerosol formation are both evolving. Area-specific data are needed to 

evaluate the effectiveness of reducing ammonia emissions on reducing PM2.5 concentrations in 

different areas, and to determine where ammonia decreases may increase the acidity of particles 

and precipitation.56 For instance, reducing ammonia emissions where sulfate concentrations are 

high may increase the acidity of particles and precipitation, which can be associated with adverse 

health effects and increased concentrations of secondary organic compounds. 

Exposure to high levels of ammonia in the air may cause skin, eye, throat, and lung irritation, 

and may also cause burns and coughing.57 Extremely high concentrations of ammonia may lead 

to lung disease and death. Individuals with asthma are more sensitive to ammonia exposure. 

Ammonia serves an important role in neutralizing acids in clouds, precipitation and particles. In 

particular, ammonia neutralizes sulfuric acid and nitric acid, the two key contributors to acid 

deposition (acid rain), forming sulfates and nitrates in the process. Deposited ammonia also can 

contribute to problems of eutrophication in water bodies, and deposition of ammonium particles 

may effectively result in acidification of soil as ammonia is taken up by plants. 

1.3 Integrating PM2.5 with Other Air Quality Goals 

As discussed in Section 1.0, attaining and maintaining the 1997 PM2.5 standards is one of many 

interrelated air quality goals that New Jersey is striving to achieve. The actions included in this 

SIP revision are part of the State’s overall plan for reducing PM-related emissions. The 

remainder of this Section discusses in detail other PM-related actions anticipated in the near 

 54 72 Fed. Reg. 20592-93 (April 25, 2007). 55 USEPA. Air Quality Criteria for Particulate Matter, Volume I of II. United States Environmental Protection 

Agency, October 2004, EPA/600/P-99/002aF. 56 72 Fed. Reg. 20591 (April 25, 2007). 57 ATSDR. ToxFAQsTM: Ammonia. Agency for Toxic Substances and Disease Registry, September 2004, accessed 

June 27, 2007.
13

future or already in place that comprise the rest of the State’s overall plan for reducing PMrelated emissions.

1.3.1 Environmental Justice in New Jersey

While unhealthy air quality can negatively impact human health throughout the northeastern 

United States and New Jersey, these health risks are higher for populations living near roadways 

and in urban areas. Improving air pollution in these affected areas is one of the NJDEP’s greater 

challenges, particularly since many of the areas that are currently targeted for redevelopment 

throughout the State are located in New Jersey’s urban communities. New Jersey is committed 

to revitalizing these urban areas by mitigating a legacy of environmental degradation, including 

air pollution, and the resulting adverse consequences to public health and the environment to 

ensure that all people, regardless of race, color, national origin, or income, live in vibrant 

communities that are safe from environmental pollution. The actions outlined in this SIP 

revision will help New Jersey meet this commitment by working to reduce PM2.5 emissions from 

the mobile and industrial sources impacting New Jersey’s urban areas. 

As stated in Section 1.2.1, the health effects associated with exposure to fine particulate matter

are significant, and epidemiological studies have shown a significant correlation between 

elevated fine particle levels and premature mortality. Other significant health impacts include 

aggravating existing heart and lung diseases, increasing asthma attacks, and emergency room 

visits. Urban residents in particular are regularly exposed to greater amounts of PM2.5 from 

multiple local sources, including heavy-duty diesel truck traffic, congested roads, industrial and 

commercial operations, airports, marine ports, trains, and, junk yards. These sources all 

contribute to the formation of localized high levels of air pollution.

New Jersey’s 2009 Environmental Justice Executive Order (EO) #13158 recognizes these 

significant health impacts, especially the disproportionate increase in childhood asthma for Black 

and Latino/Hispanic children in urban communities, and the link of this increase, in part, to poor 

air quality. Further, the Executive Order #131 charges the NJDEP and other state agencies 

“involved in decisions that affect environmental quality and public health to provide 

opportunities for input by representatives of low-income and minority groups.” The NJDEP 

reviews and considers all recommendations submitted by the Advisory Council, in fulfillment of 

the Executive Order, including recommendations for policy and regulatory changes that the 

NJDEP can undertake to consider and incorporate cumulative impacts into its decision-making.

As discussed further in Section 1.3.2, the NJDEP is working with the USEPA on a number of 

national air toxic reduction programs. To address disproportionate impacts of air toxic hazards 

across urban areas on highly exposed population subgroups, and predominately minority and 

low-income communities,

59 the NJDEP is developing methods and strategies to assess air 

 58 NJDEP. Environmental Justice Program. New Jersey Department of Environmental Protection, 

http://www.nj.gov/dep/ej/policy.html, accessed March 17, 2009. EO #131 replaced EO#96 (2004) as of February 

17, 2009.

59 USEPA. Fact Sheet, The Air Toxics Strategy. United States Environmental Protection Agency, 

http://www.epa.gov/ttn/uatw/urban/strategyfs0303.pdf, accessed November 28, 2007.
14

impacts from multiple sources at the community scale. These strategies build upon the pilot 

projects that were initiated in Camden and Paterson, two of New Jersey’s most urbanized areas, 

which assessed community scale air impacts. The NJDEP is also committed to assessing 

technical and policy options to address the cumulative impact of multi media exposure (beyond 

air pollution exposure) at the local level. Reducing PM2.5 concentrations in urban areas will help 

address environmental justice.

1.3.2 Air Toxics 

The efforts to reduce PM2.5 and its precursors in this SIP revision will benefit the efforts to 

reduce the concentrations of air toxics, e.g., diesel particulates, in the State. Sources of 

particulate air toxics are the same as some of the sources of PM2.5 and PM2.5 precursors, i.e., 

traditional industrial and utility sources, smaller manufacturing and commercial sources, mobile 

sources (e.g., cars, trucks, buses, and trains), residential activities (such as oil burning for home

heating), and construction equipment.60 Several State and federal initiatives to reduce the 

public’s exposure to the health impacts of air toxics have multi-pollutant benefits. New Jersey is 

taking action in local communities to address severe air quality issues.

The NJDEP generally divides air pollutants that it regulates into two broad categories: criteria 

pollutants and air toxics. The USEPA has established National Ambient Air Quality Standards 

(NAAQS) for six criteria pollutants (ozone, particulate matter, carbon monoxide, sulfur dioxide, 

nitrogen dioxide and lead). For the State’s regulatory purposes, other air pollutants that are not 

criteria pollutants, and that are emitted into the air in quantities that may cause cancer or other 

adverse health effects, are classified as air toxics.61 These broad categories are not mutually 

exclusive, as there is overlap between air toxics and criteria pollutants. For example, many of 

the VOCs that contribute to the formation of ozone and, as discussed later in this Section, can 

also contribute to the formation of PM2.5, are also air toxics. Additionally, particulate matter can 

be air toxics or a “carrier” for certain air toxics that adhere to the particle itself, as is the case 

with diesel emissions. Lead (Pb) is considered both an air toxic and a criteria pollutant. Given 

this overlap, efforts to reduce the concentrations of PM2.5 and its precursors in this SIP revision 

will also benefit the efforts to reduce many air toxics. 

Supporting the effort to achieve lower emissions of PM2.5 and its precursors, the NJDEP has a 

multi-pronged approach to decreasing air toxic emissions, including PM and PM precursors in 

the State:

 60 In addition to these sources, diesel engines emit a complex mixture of air pollutants, composed of both solid and 

gaseous material, the visible portion of which is known as particulate matter. Diesel particulate matter includes 

many carbon particles (also called soot), as well as gases that become visible as they cool. The major sources of 

diesel particulate matter are onroad and nonroad vehicles powered by diesel engines; however, diesel engines are 

also used in construction vehicles, agricultural equipment, trains, marine vessels, and stationary diesel electric 

generators. 

61 The USEPA also refers to air toxics as hazardous air pollutants (HAPS), which are listed under 42 U.S.C. § 7412 

(Section 112). (USEPA. About Air Toxics. United States Environmental Protection Agency, June 6, 2007, 

http://www.epa.gov/ttn/atw/allabout.html, accessed January 4, 2008.)
15

1. Permit Review: A combination of control technology (e.g., maximum achievable control 

technology (MACT) standards) and risk assessment requirements employed in the air 

permitting process. 

2. Voluntary Reductions: Initiatives that encourage facilities to reduce air toxics emissions 

through Pollution Prevention opportunities, Right-to-Know, and similar disclosure and 

compliance assistance programs. 

3. Traditional Pollutant Control Programs: Air toxics reductions that result from direct 

regulation or as a side-benefit of control programs that address ozone precursors, 

particulate matter, and other pollutants (e.g., point, area, and mobile source controls).

4. Air Toxics Initiatives: Risk assessments, dry cleaners, other projects.

Several of these programs address direct PM2.5 and PM2.5 precursors, and can be found in 

Chapter 4 (Control Measures); specifically, the National Low Emission Vehicle Program 

(NLEV), Nonroad Diesel Engine Standards, and New Jersey’s Enhanced Inspection and 

Maintenance (I/M) Program. The projects conducted by the NJDEP Air Toxics Program also 

help to reduce PM2.5 emission levels in New Jersey. The Camden Waterfront South Air Toxics 

Pilot Project, a project that began in 2002, was designed to develop tools to assess air quality 

problems in a community (with a focus on air toxics). In addition, the Urban Community Air 

Toxics Monitoring Project in Paterson City, New Jersey (UCAMPP) is a multi-faceted air quality 

monitoring and modeling project.

On a national level, under the Federal Clean Air Act Amendments of 1990, the USEPA is 

required to adopt a number of national air toxic reduction programs. The NJDEP works with 

USEPA to implement these programs in New Jersey. Two of these programs are the adoption of 

MACT standards for large sources (such as chemical manufacturing), and the Integrated Urban 

Air Toxics Strategy and generally available control technology (GACT) for small sources (such 

as hospital sterilizers). To date, the USEPA has promulgated 96 MACT emission standards, 

some of which were included in the photochemical modeling used to demonstrate attainment of 

the 1997 PM2.5 NAAQS (SeeChapter 5). The USEPA is under a court ordered schedule to 

promulgate standards for 50 area source categories by June 15, 2009, which will also help to 

reduce direct PM2.5 and PM2.5 precursor emissions. Released by the USEPA in July 1999 and 

discussed in Section 1.3.1, the Integrated Urban Air Toxics Strategy is a framework for 

addressing air toxics in urban areas from stationary, mobile, and indoor sources.

62 It 

complements the MACT and GACT standards and other aspects of national air toxics initiatives.

With respect to mobile sources, the USEPA finalized the rule “Control of Hazardous Air 

Pollutants from Mobile Sources in early 2007.”63 This program will lower emissions of air

toxics by lowering the benzene (a potential ozone and PM2.5 precursor) content of gasoline. The 

USEPA has required or proposed controls for new construction vehicles, agricultural equipment, 

trains, and marine vessels (see Chapter 4). The USEPA conducts voluntary programs for 

 62 USEPA. Urban Strategy. States Environmental Protection Agency, August 9, 2007, 

http://www.epa.gov/ttn/atw/urban/urbanpg.html, accessed January 4, 2008. 63 USEPA. Mobile Source Air Toxics. United States Environmental Protection Agency, 

http://www.epa.gov/otaq/toxics.htm, accessed November 5, 2007.
16

reduction of diesel emissions, which include Clean School Bus USA, the Voluntary Diesel 

Retrofit Program, and the National Clean Diesel Campaign. 

1.3.3 Greenhouse Gases and Climate Change

New Jersey is planning to reduce New Jersey’s carbon footprint and is pushing for mandatory 

federal action to combat global climate change. All of the measures currently planned to combat 

Global Warming (and discussed in this section) will not only reduce greenhouse gas emissions, 

but will also have supplemental benefits of reducing PM2.5 and PM2.5 precursor emissions, 

including NOx and SO2, as well as other air contaminants. Reducing atmospheric PM2.5 levels 

could also help to slow global warming, because some particles result in darkening effects on 

snow and ice, which causes those areas to absorb sunlight rather than reflect it. 

On February 13, 2007, Governor Jon S. Corzine signed an Executive Order to adopt proactive 

goals for the reduction of greenhouse gas emissions in New Jersey. 64 The order calls for 

reducing greenhouse gas emissions to 1990 levels by 2020, an approximately 20 percent 

reduction from 2006, followed by a further reduction of emissions to 80 percent below 2006 

levels by 2050. These provisions were enacted into law under the Global Warming Response 

Act in New Jersey on July 6, 2007, making New Jersey the third state in the nation to make 

greenhouse gas reduction goals law.65 On December 15, 2008, the State released the Draft 

Global Warming Response Act Recommendations Report for stakeholder input as required by 

the New Jersey Global Warming Response Act. On January 6, 2009, the State initiated a series 

of six stakeholder meetings to solicit input on the report.

New Jersey is playing a leadership role in the Regional Greenhouse Gas Initiative (RGGI), a 

ten-state cooperative effort to implement a regional mandatory cap-and-trade program in the 

Northeast and Mid-Atlantic, addressing CO2 emissions from power plants. As the first 

mandatory market-based program to reduce carbon emissions in the U.S., the program will cap 

regional power plant CO2 emissions. 

Other New Jersey greenhouse gas initiatives include standards for new automobiles and light 

trucks, the implementation of renewable portfolio standards, and an Energy Master Plan. New 

Jersey is continuing its interagency planning process that will culminate in the Energy Master 

Plan, a long-term energy vision for the state that plans for the State’s energy needs through 

2020.66 Goals include 20 percent of the electricity used in the State to come from Class One 

renewable energy sources by the Year 2020 and to reduce future electricity consumption by 20 

percent from projected 2020 consumption levels. 

 64 State of New Jersey Office of the Governor. Governor Calls for Sweeping Reduction of Greenhouse Gas 

Emissions in New Jersey. Available at http://www.nj.gov/governor/news/news/approved/20070213a.html. 

February 13, 2007.

65 State of New Jersey Office of the Governor. Governor Signs Global Warming Response Act. Available at 

http://www.nj.gov/globalwarming/home/news/approved/070706.html. July 7, 2007. 66 State of New Jersey Office of the Governor. Governor Corzine Announces Initial Phase of Energy Master Plan. 

Available at http://www.nj.gov/governor/news/news/approved/20061003.html. October 3, 2006.
17

1.3.4 8-Hour Ozone

Given the fact that both NOx and VOCs have the potential to generate ozone and PM2.5,

67 the 

Northeastern states and associated regional agencies considered the impact on all four ozone and 

PM2.5 related pollutants (NOx, VOC, SO2, and direct PM2.5) in selecting control measures. These 

control measures were considered for inclusion in the modeling analysis used in New Jersey’s 

(and the other states’) attainment demonstration of the 8-hour ozone NAAQS,68 anticipating the 

need for a comprehensive modeling analysis that could be used in both the 8-hour ozone and 

1997 PM2.5 attainment demonstrations. For example, a control measure that reduces NOx will 

achieve the benefit of reducing both ozone and PM2.5 concentrations since NOx is a precursor for 

both pollutants. The control measures used in this modeling analysis are listed in Table 4.5, and 

discussed in detail in Chapter 4. For more information about the overlap and impact of the 

implementation of “ozone measures” on PM2.5 levels throughout the region, see Chapter 5. For 

more information about New Jersey’s efforts to attain the 8-hour ozone NAAQS, refer to its 8-

Hour Ozone Attainment Demonstration SIP.69

1.3.5 Regional Haze

The Federal Clean Air Act protects Class I areas, which are usually large parks and wilderness 

areas,70 from visibility impairment due to anthropogenic (manmade) sources (42 U.S.C. § 7491 

(Section 169A)).71 The Clean Air Act requires the USEPA to establish regulations to abate 

regional haze and increase visibility in those areas to protect the scenic vistas. Visibility 

impairment caused by the collection of air pollutants emitted by sources over a broad geographic 

area is known as regional haze. Some particles and gases can either absorb or scatter light 

causing an effect known as “light extinction.” A hazy condition is created as a result of these 

processes. The USEPA first promulgated regulations for regional haze in 1980. These 

regulations were updated and took effect on August 30, 1999.72 The regional haze regulations 

were promulgated to accomplish the integration of air quality management planning for multiple 

pollutants, i.e., particulate matter (PM) and ozone,73 recognizing that these pollutants have 

common precursors, emission sources, atmospheric processes, transport issues, and geographical 

 67 Ozone is a highly reactive gas. In the troposphere, it is formed by complex chemical reactions involving oxides of 

nitrogen (NOx) and volatile organic compounds (VOCs) in the presence of sunlight. Similar to the PM2.5 precursors, 

NOx and VOC are precursors to ozone. 68 On October 29, 2007, New Jersey submitted its 8-hour ozone SIP revision to the USEPA for approval. Refer to 

the letter dated October 29, 2007 from then NJDEP Commissioner Lisa P. Jackson to USEPA Region II 

Administrator Alan J. Steinberg. Available at http://www.nj.gov/dep/baqp/8hrsip/commissioner's%20letter.pdf . 69 NJDEP. 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.

70 64 Fed. Reg. 35715 (July 1, 1999): Areas designated as mandatory Class I Federal areas are those national parks 

exceeding 6,000 acres, wilderness areas and national memorial parks exceeding 5000 acres, and all international 

parks which were in existence on August 7, 1977. 

71 Other sections of the Federal Clean Air Act that are part of the visibility protection program include 42 U.S.C. §§

7492 and 7410(a)(2)(J) (Sections 169B and 110(a)(2)(J)). 72 On June 15, 2005, the USEPA published its final amendments to its July 1999 Regional Haze Rule (70 Fed. Reg.

39104-72 (July 6, 2005)). 73 64 Fed. Reg. 35714-74 (July 1, 1999).
18

areas of concern. The regional haze regulations require that states develop plans to protect 156 

Class I areas. New Jersey is home to a federally protected Class I area, which is the Brigantine 

Wilderness Area of the Edwin B. Forsythe National Wildlife Refuge. The control measures 

contained within the State’s regional air quality protection plan, designed to improve visibility in 

New Jersey’s Class I area and other downwind Class I areas, will also help to reduce direct PM2.5

and PM2.5 precursors, since PM2.5 is the primary component of regional haze. 

The plans for regional haze occur in phases to achieve periodic goals. The first regional haze air 

quality protection plan for New Jersey will be completed this year. This first regional haze air 

quality protection plan must establish progress goals and control strategies through 2018. New 

Jersey must supplement its regional haze air quality protection plan to show reasonable progress 

every five years beginning in 2013. Beginning in 2018 and every 10 years thereafter, the State 

must reevaluate and revise its regional haze air quality protection plan and submit the revised 

plan to the USEPA. The final goal of the federal regional haze regulations is to achieve natural 

visibility conditions by 2064. New Jersey proposed its Regional Haze SIP on September 15, 

2008. This proposal is based on control measures and modeling developed through the MidAtlantic/Northeast Visibility Union (MANE-VU) regional organization. The MANE-VU 

process and control measure development is discussed in detail in Chapters 4 and 5. 
19

2.0 AIR QUALITY AMBIENT AND EMISSION INVENTORY DATA

This chapter provides an analysis of the fine particulate matter and precursor ambient air quality 

data for the entire State of New Jersey, as well as for both the Northern New Jersey/New 

York/Connecticut and Southern New Jersey/Philadelphia nonattainment areas. The data was 

obtained from the United States Environmental Protection Agency’s (USEPA’s) online database, 

AirData,74 which provides data summaries using the Air Quality System (AQS) data subsystem. 

AirData was also used to obtain data for the other states that share a nonattainment area with 

New Jersey. This USEPA data was updated with data provided by the other state agencies, 

where available.75 In general, the pollutant concentrations presented in this chapter are 

expressed as micrograms per cubic meter (μg/m3) unless otherwise stated.

2.1 Measuring Fine Particle Pollution in the Atmosphere – An Introduction to PM2.5

Monitoring

In order to monitor the levels of PM2.5 and compare those levels to the National Ambient Air 

Quality Standards (NAAQS), the USEPA established criteria for ambient air quality networks 

for PM2.5 at 40 C.F.R. Pt. 58. Figure 2.1 shows the New Jersey Fine Particulate Monitoring 

Network. Some locations have multiple samplers. There are 19 monitoring sites in New Jersey 

where the Federal Reference Method sampler (FRM) routinely collects 24-hour PM2.5 samples. 

All sites collect a sample once every three days, with the exception of Elizabeth Lab which 

samples daily. Ambient air quality monitoring of PM2.5 began in 1999. As of 2006, nine sites 

also continuously monitor fine particle concentrations and transmit the data every minute to the 

Bureau of Air Monitoring’s (BAM’s) central computer, where the data is made available on the 

BAM’s public website (www.state.nj.us/dep/airmon). In addition, the NJDEP has a Speciation 

Network which consists of four sites at which filters are collected and analyzed to determine 

their chemical characteristics. Speciation monitoring is conducted to determine the chemical 

characteristics of the fine particles. Samples are collected once every three days concurrent with 

FRM sampling. 

 

 74 USEPA. AirData: Access to Air Pollution Data, United States Environmental Protection Agency, 

http://www.epa.gov/air/data/index.html.

75 The New Haven/Stiles St., CT monitor was designated as a “special purpose” monitor, and as such cannot be used 

to make an attainment or nonattainment designation. The site was found to be overly influenced by micro-scale 

phenomena, including heavy duty truck exhaust from trucks leaving the New Haven Terminal area and accelerating 

uphill on the Interstate-95 on-ramp. The monitor was less than twenty feet from the traffic lane. Following a 

special, multi-site monitoring study conducted by CTDEP, the Stiles Street monitor was deemed unrepresentative of 

population exposure in the City of New Haven. In 2006, it was shut down as part of the I-95 bridge reconstruction 

project. The information on this site, therefore, is for informational purposes only and should not be used to assess 

attainment of the standard.
20

Figure 2.1: Particulate Monitoring Network in New Jersey

2.2 USEPA NAAQS for Fine Particle Pollution: Annual PM2.5 

2.2.1 Annual PM2.5 Mean Concentrations and Design Values

A nonattainment area demonstrates compliance with the 1997 annual PM2.5 standard when the 3-

year average of the exceeding sites’ annual arithmetic mean PM2.5 concentrations from a monitor 

is 15.0 μg/m3 or less. Each 3-year average is commonly referred to as the design value for that 

monitoring site. The design value for the nonattainment area is the highest value from all the 

sites in the nonattainment area. A design value is only valid if minimum data completeness 

criteria for the monitoring site are met. With regard to the annual PM2.5 standard, a site meets 

National Ambient Air Quality Standard (NAAQS) completeness criteria if it registered 75 

percent or more data capture each quarter of the three year period in question.76 PM2.5 annual 

means are calculated from the four calendar quarterly averages at each monitoring site. Refer to 

the USEPA guidance issued in 1999 for more details on calculations and data handling for 

 76 For the purposes of presenting the current state of air quality in New Jersey, data that did not meet the 75 percent 

completeness requirement were included in this chapter and should not be used to make formal determinations about 

meeting the NAAQS.
21

PM2.5.

77 In the multi-state 1997 PM2.5 Southern New Jersey/Philadelphia nonattainment area, 

there are three New Jersey monitors, and all are plotted in the figures for this section.

Figures 2.2 and 2.3 show the annual PM2.5 mean concentrations for the two consistently highest 

monitoring sites in each of the states that make up the multi-state Northern New Jersey/New 

York/Connecticut and the Southern New Jersey/Philadelphia nonattainment areas.78 In 2006, all 

the monitors in both annual PM2.5 nonattainment areas were below the NAAQS level of 15.0 

μg/m3 in 2006,79 as seen in Tables 2.1 and 2.2. 

Figure 2.2: Northern New Jersey/New York/Connecticut Nonattainment Area Annual 

PM2.5 Mean Concentrations for the Two Consistently Highest Monitors in Each Associated 

State, 1999-200680

0.0

5.0

10.0

15.0

20.0

1999 2000 2001 2002 2003 2004 2005 2006

Year

PM2.5 Annual Mean (μg/m3

)

36 061 0056 PS 59, 288 E. 57th Street, Manhattan, NY 36 061 0062 Post Office, 350 Canal Street, NY

9 009 0018 Stiles Street, CT 9 009 1123 715 State Street, CT

34 017 2002 Union City, NJ 34 039 0004 Elizabeth Turnpike Primary, NJ

Annual PM2.5 NAAQS = 15.0 μg/m3

 77 USEPA. Guidance on Data Handling Conventions for the PM NAAQS. United States Environmental Protection 

Agency, Office of Air Quality, Planning and Standards, Research Triangle Park, NC, EPA-454/R-99-008, April 

1999.

78 The monitoring data used to develop this chapter include periods when the monitors were shut down. Monitoring 

problems that occurred with the monitor that was used to designate the Northern New Jersey/New York/Connecticut 

nonattainment area, monitor # 360610056, invalidated the data collected for 2003 and were not included in this 

analysis. Monitoring problems that occurred with the monitor that was used to designate the Southern New 

Jersey/Philadelphia nonattainment area, i.e., monitor # 421010047, invalidated the data collected for 2005 and 2006

and were not included in this analysis.

79 2007 data were undergoing quality assurance and not available for inclusion in this final SIP revision. The 

preliminary data indicates the ambient air quality data in the two multi-state nonattainment areas is below the 

NAAQS threshold of 15.0 μg/m3

. 80 See note 76.
22

Figure 2.3: Southern New Jersey/Philadelphia Nonattainment Area Annual PM2.5 Mean 

Concentrations for the Consistently Highest Monitors in Each Associated State, 1999-

200681

0.0

5.0

10.0

15.0

20.0

1999 2000 2001 2002 2003 2004 2005 2006

Year

PM2.5 Annual Mean (μg/m3

)

34 007 0003 Camden Lab Primary, NJ 34 007 1007 Pennsauken, NJ 34 015 5001 Gibbstown, NJ

42 101 0047 500 South Broad Street, PA 42 045 0002 Front St. & Norris St., PA 10 003 2004 MLK Blvd. & Justison St., DE

10 003 1012 Univ. DE North Campus, DE

Annual PM2.5 NAAQS = 15.0 μg/m3

Table 2.1: Northern New Jersey/New York/Connecticut Nonattainment Area Annual PM2.5

Means for the Two Consistently Highest Monitors by State, 1999-200682

New York Connecticut New Jersey

1st Highest 2nd Highest 1st Highest 2nd Highest 1st Highest 2nd Highest

AQS Monitor 

ID, Site Name 

and Location

36-061-0056 

PS 59, New 

York City

36-061-0062 

Canal Street, 

New York City

9-009-0018 

Stiles Street, 

New Haven

9-009-1123

715 State 

Street, New 

Haven

34-017-2002 

Union City

34-039-0004 

Elizabeth 

Turnpike 

Primary

Year of 

Highest 2000 2000 2005 2001 1999 2000

Concentration 

of Highest 

(μg/m3)

18.5 17.6 18.9 14.3 19.6 16.9

Below 1997 

Annual PM2.5 

NAAQS in 

2006?

Yes Yes No data 

available Yes Yes Yes

 81 See note 76. 82 See note 76.
23

Table 2.2: Southern New Jersey/Philadelphia Nonattainment Area Annual PM2.5 Means for 

the Two Consistently Highest Monitors by State, 1999-2006

New Jersey Pennsylvania Delaware

1st Highest 2nd Highest 1st Highest 2nd Highest 1st Highest 2nd Highest

AQS Monitor 

ID, Site Name 

and Location

34-007-0003 

Camden Lab 

Primary, 

Camden

34-007-1007 

Pennsauken 

Township, 

Pennsauken

42-101-0047 

500 South 

Broad Street, 

Philadelphia

42-045-0002

Front Street & 

Norris Street, 

Chester

10-003-2004 

MLK Blvd. & 

Justison Street, 

Wilmington

10-003-1012 

University of 

Delaware, 

Newark

Year of 

Highest 2003 2000 2000 2005 2001 2001

Concentration 

of Highest 

(μg/m3)

16.3 15.5 17.0 16.5 17.6 15.8

Below 1997 

Annual PM2.5 

NAAQS in 

2006?

Yes Yes No data 

availablea Yes Yes Yes

a Monitoring problems that occurred with the monitor that was used to designate the Southern New Jersey/Philadelphia 

nonattainment area, i.e., monitor # 421010047, invalidated the data collected for 2005 and 2006 and were not included in this 

analysis. 

Three years of annual mean concentrations for PM2.5 are used to calculate the design value at a 

monitor.83 Figures 2.4 and 2.5 show the PM2.5 design values for the two consistently highest 

monitoring sites in each of the states that make up the multi-state Northern New Jersey/New 

York/Connecticut and the Southern New Jersey/Philadelphia nonattainment areas.84 They show 

much progress has been made to attain the 2007 annual PM2.5 NAAQS, but more reductions are 

necessary to attain the NAAQS as some sites remain out of compliance. Tables 2.3 and 2.4 show 

the maximum PM2.5 design values at these sites, which were included in Figures 2.4 and 2.5, 

respectively. 

 83 The design value for a nonattainment area is the maximum monitor design value for all monitors for each 3-year 

period. 

84 See note 79. 
24

Figure 2.4: Northern New Jersey/New York/Connecticut Nonattainment Area Annual 

PM2.5 Design Values for the Two Consistently Highest Monitors in each Associated State,

2001-200685

0.0

5.0

10.0

15.0

20.0

1999-2001 2000-2002 2001-2003 2002-2004 2003-2005 2004-2006

Year

PM2.5 Annual Design Value (μg/m3

)

36 061 0056 PS 59, 288 E. 57th Street, Manhattan, NY 36 061 0062 Post Office, 350 Canal Street, NY

9 009 0018 Stiles Street, CT 9 009 1123 715 State Street, CT

34 017 2002 Union City, NJ 34 039 0004 Elizabeth Turnpike Primary, NJ

Annual PM2.5 NAAQS = 15.0 μg/m3

 85 See note 76.
25

Figure 2.5: Southern New Jersey/Philadelphia Nonattainment Area Annual PM2.5 Design 

Values for the Consistently Highest Monitors in each Associated State, 2001-2006

0.0

5.0

10.0

15.0

20.0

1999-2001 2000-2002 2001-2003 2002-2004 2003-2005 2004-2006

Year

PM2.5 Annual Design Value (μg/m3

)

34 007 0003 Camden Lab Primary, NJ 34 007 1007 Pennsauken, NJ 34 015 5001 Gibbstown, NJ

42 101 0047 500 South Broad Street, PA 42 045 0002 Front St. & Norris St., PA 10 003 2004 MLK Blvd. & Justison St., DE

10 003 1012 Univ. DE North Campus, DE

Annual PM2.5 NAAQS = 15.0 μg/m3

Table 2.3: Northern New Jersey/New York/Connecticut Nonattainment Area Annual PM2.5

Design Values for the Two Consistently Highest Monitors by State, 2001-200686

New York Connecticut New Jersey

1st Highest 2nd Highest 1st Highest 2nd Highest 1st Highest 2nd Highest

AQS Monitor 

ID, Site Name 

and Location

36-061-0056 

PS 59, New 

York City

36-061-0062 

Canal Street, 

New York City

9-009-0018 

Stiles Street, 

New Haven

9-009-1123

715 State 

Street, New 

Haven

34-017-2002 

Union City

34-039-0004 

Elizabeth 

Turnpike 

Primary

Year of 

Highest 2002 2002 2005 2001 2001 2001

Concentration 

of Highest 

(μg/m3)

17.6 17.0 17.1 14.1 17.5 16.3

Below 1997 

Annual PM2.5 

NAAQS in 

2006?

No Yes 2006 data not 

available Yes No Yes

 86 See note 76.
26

Table 2.4: Southern New Jersey/Philadelphia Nonattainment Area Annual PM2.5 Design 

Values for the Two Consistently Highest Monitors by State, 2001-2006

New Jersey Pennsylvania Delaware

1st Highest 2nd Highest 1st Highest 2nd Highest 1st Highest 2nd Highest

AQS Monitor 

ID, Site Name 

and Location

34-007-0003 

Camden Lab 

Primary, 

Camden

34-007-1007 

Pennsauken 

Township, 

Pennsauken

42-101-0047 

500 South 

Broad Street, 

Philadelphia

42-045-0002

Front Street & 

Norris Street, 

Chester

10-003-2004 

MLK Blvd. & 

Justison Street, 

Wilmington

10-003-1012 

University of 

Delaware, 

Newark

Year of 

Highest 2003 and 2005 2001 2002 2005 2001 2002

Concentration 

of Highest 

(μg/m3)

14.7 14.6 16.6 15.6 16.5 15.2

Below 1997 

Annual PM2.5 

NAAQS in 

2006?

Yes Yes Not availablea No Yes Yes

a Monitoring problems that occurred with the monitor that was used to designate the Southern New Jersey/Philadelphia 

nonattainment area, i.e., monitor # 421010047, invalidated the data collected for 2005 and 2006 and were not included in this 

analysis. 

2.3 USEPA NAAQS for Fine Particle Pollution: Daily (24-Hour) PM2.5

2.3.1 Daily PM2.5 98th Percentile Average Concentrations and Design Values 

The former 24-hour (daily) NAAQS for PM2.5 was 65 μg/m3 and the current daily PM2.5 standard 

is 35 μg/m3. To attain these standards, the 3-year average of the 98th percentile of 24-hour 

concentrations at each monitor within an area must not exceed 65 μg/m3 or 35 μg/m3.

87 Refer to 

the USEPA guidance issued in 1999 for more details on calculations and data handling for 

PM2.5.

88 In the Southern New Jersey/Philadelphia nonattainment area, there are three New 

Jersey monitors, and all are plotted in the figures for this section.

Figures 2.6 and 2.7 show that the concentrations in the multi-state nonattainment areas are well 

below the former 65 μg/m3 standard, but near and above the newer 35 μg/m3 NAAQS. New 

Jersey and the other states that share New Jersey’s 1997 PM2.5 multi-state nonattainment areas 

have always met and are in attainment with the 1997 daily PM2.5 health-based standard of 65 

μg/m3.

89 

 87 The entire state of New Jersey was in attainment of the 24-hour PM2.5 standard of 65 μg/m3 in 2004 when USEPA 

finalized designations. 

88 USEPA. Guidance on Data Handling Conventions for the PM NAAQS. United States Environmental Protection 

Agency, Office of Air Quality, Planning and Standards, Research Triangle Park, NC, EPA-454/R-99-008, April 

1999.

89 The attainment demonstration in this final SIP revision addresses the 1997 annual PM2.5 standard. According to 

the USEPA’s modeling guidance (USEPA. Guidance on the Use of Models and Other Analysesfor Demonstrating 

Attainment of Air Quality Goals for Ozone, PM2.5, and Regional Haze. United States Environmental Protection 

Agency, Office of Air Quality Planning and Standards, Air Quality Analysis Division, Air Quality Modeling Group, 

Research Triangle Park, NC, EPA-454/B-07-002, April 2007, pg. 56), since these levels are well below the standard 
27

Figure 2.6: PM2.5 98th Percentile 24-Hour Averages for the Two Consistently Highest 

Monitors in each Associated State in the 1997 PM2.5 Northern New Jersey/New 

York/Connecticut Nonattainment Area, 1999-200690

25.0

30.0

35.0

40.0

45.0

50.0

55.0

60.0

65.0

70.0

1999 2000 2001 2002 2003 2004 2005 2006

Year

PM2.5 24-Hour Average (μg/m3

)

36 061 0056 PS59, 288 E. 57th Street, Manhattan, NY 36 061 0062 Post Office, 350 Canal Street, NY

9 009 0018 Stiles Street, CT 9 009 1123 715 State Street, CT

34 017 2002 Union City, NJ 34 017 1002 Jersey City Primary, NJ

Former Daily PM2.5 NAAQS = 65.0 μg/m3

New Daily PM2.5 NAAQS = 35.0 μg/m3

 

and have continued to improve since 2001, the modeled attainment test for the 1997 daily PM2.5 standard is not 

needed nor is included in the attainment demonstration.

90 See note 76.
28

Figure 2.7: PM2.5 98th Percentile 24-Hour Averages for the Consistently Highest Monitors 

in each Associated State in the 1997 PM2.5 Southern New Jersey/Philadelphia 

Nonattainment Area, 1999-2006

20.0

25.0

30.0

35.0

40.0

45.0

50.0

55.0

60.0

65.0

70.0

1999 2000 2001 2002 2003 2004 2005 2006

Year

PM2.5 24-Hour Average (μg/m3

)

34 007 0003 Camden Lab Primary, NJ 34 007 1007 Pennsauken, NJ

34 015 5001 Gibbstown, NJ 42 101 0004 1501 E. Lycoming Ave. Ams Lab, PA

42 101 0136 Amtrak, 5917 Elmwood Ave., PA 10 003 2004 MLK Blvd. & Justison St., DE

10 003 1012 Univ. DE North Campus, DE

Former Daily PM2.5 NAAQS = 65.0 μg/m3

New Daily PM2.5 NAAQS = 35.0 μg/m3

Table 2.5: PM2.5 98th Percentile 24-Hour Averages for the Two Consistently Highest 

Monitors in the 1997 PM2.5 Northern New Jersey/New York/Connecticut Nonattainment 

Area, 1999-200691

New York Connecticut New Jersey

1st Highest 2nd Highesta 1st Highest 2nd Highest 1st Highest 2nd Highest

AQS Monitor 

ID, Site Name 

and Location

36-061-0056 

PS 59, New 

York City

36-061-0062 

Canal Street, 

New York City

9-009-0018 

Stiles Street, 

New Haven

9-009-1123

715 State 

Street, New 

Haven

34-017-2002 

Union City

34-017-1002 

Jersey City 

Primary

Year of 

Highest 2000 2003 2003 and 2005 2003 1999 1999 and 2003

Concentration 

of Highest 

(μg/m3)

42 46 44 44 50 46

Below 1997 

Daily PM2.5 

NAAQS in 

2006?

Yes Yes 2006 data not 

available Yes Yes Yes

Below 2006 

Daily PM2.5 

NAAQS in 

2006?

No No 2006 data not 

available No No No

 91 See note 76.
29

a Monitors #36-061-0010 and #36-085-0055 also had high 98th percentile 24-hour averages twice during the 1999-2006 time period 

but were not shown, as monitor #36-061-0062 had the highest average in 2006 and was chosen to be highlighted in this analysis.

Table 2.6: PM2.5 98th Percentile 24-Hour Averages for the Two Consistently Highest 

Monitors in the 1997 PM2.5 Southern New Jersey/Philadelphia Nonattainment Area, 1999-

2006

New Jersey Pennsylvania Delaware

1st Highest 2nd Highest 1st Highest 2nd Highest 1st Highest 2nd Highest

AQS Monitor 

ID, Site Name 

and Location

34-007-0003 

Camden Lab 

Primary, 

Camden

34-007-1007 

Pennsauken 

Township, 

Pennsauken

42-101-0004

AMS Lab, 

Philadelphia

42-101-0136

Amtrak, 

Philadelphia

10-003-2004 

MLK Blvd. & 

Justison Street, 

Wilmington

10-003-1012 

University of 

Delaware, 

Newark

Year of 

Highest 2003 2006 2000 2001 2001 2002

Concentration 

of Highest 

(μg/m3)

43 38 41 46 43 42

Below 1997 

Annual PM2.5 

NAAQS in 

2006?

Yes Yes Yes Yes Yes Yes

Below 2006 

Daily PM2.5 

NAAQS in 

2006?

No No No No No No

The design value for the 24-hour NAAQS for a monitor is calculated by taking the three year 

average of the 98th percentile of 24-hour concentrations for PM2.5.

92 Figures 2.8 and 2.9 show 

the multi-state nonattainment areas are well below the former 65 μg/m3 NAAQS, and above the 

newer 35 μg/m3 NAAQS. Tables 2.7 and 2.8 show the maximum daily PM2.5 design values at 

these sites, which were included in Figures 2.8 and 2.9, respectively. 

 92 The design value for a nonattainment area is the maximum monitor design value for all monitors for each 3-year 

period. 
30

Figure 2.8: Daily PM2.5 Design Values for the Two Consistently Highest Monitors in each 

Associated State in the Northern New Jersey/New York/Connecticut Area, 2001-200693

25.0

30.0

35.0

40.0

45.0

50.0

55.0

60.0

65.0

70.0

1999-2001 2000-2002 2001-2003 2002-2004 2003-2005 2004-2006

Year

PM2.5 24-Hour Design Value (μg/m3

)

36 061 0056 PS59, 288 E. 57th Street, Manhattan, NY 36 061 0062 Post Office, 350 Canal Street, NY

9 009 0018 Stiles Street, CT 9 009 1123 715 State Street, CT

34 017 2002 Union City, NJ 34 017 1002 Jersey City Primary, NJ

Former Daily PM2.5 NAAQS = 65.0 μg/m3

New Daily PM2.5 NAAQS = 35.0 μg/m3

Figure 2.9: Daily PM2.5 Design Values for the Consistently Highest Monitors in each 

Associated State in the Southern New Jersey/Philadelphia Area, 2001-2006

20.0

25.0

30.0

35.0

40.0

45.0

50.0

55.0

60.0

65.0

70.0

1999-2001 2000-2002 2001-2003 2002-2004 2003-2005 2004-2006

Year

PM2.5 24-Hour Design Value (μg/m3

)

34 007 0003 Camden Lab Primary, NJ 34 007 1007 Pennsauken, NJ

34 015 5001 Gibbstown, NJ 42 101 0004 1501 E. Lycoming Ave. Ams Lab, PA

42 101 0136 Amtrak, 5917 Elmwood Ave., PA 10 003 2004 MLK Blvd. & Justison St., DE

10 003 1012 Univ. DE North Campus, DE

Former Daily PM2.5 NAAQS = 65.0 μg/m3

New Daily PM2.5 NAAQS = 35.0 μg/m3

 93 See note 76.
31

Table 2.7: Northern New Jersey/New York/Connecticut Nonattainment Area Daily PM2.5

Design Values for the Two Consistently Highest Monitors by State, 2001-200694

New York Connecticut New Jersey

1st Highest 2nd Highest 1st Highest 2nd Highest 1st Highest 2nd Highest

AQS Monitor 

ID, Site Name 

and Location

36-061-0056 

PS 59, New 

York City

36-061-0062 

Canal Street, 

New York City

9-009-0018 

Stiles Street, 

New Haven

9-009-1123

715 State 

Street, New 

Haven

34-017-2002 

Union City

34-017-1002 

Jersey City 

Primary

Year of 

Highest 2006 2001 2003 2005 2005 2005

Concentration 

of Highest 

(μg/m3)

41 43 42 40 44 41

Below 1997 

Annual PM2.5 

NAAQS in 

2006?

Yes Yes 2006 data not 

available Yes Yes Yes

Below 2006 

Daily PM2.5 

NAAQS in 

2006?

No No 2006 data not 

available No No No

Table 2.8: Southern New Jersey/Philadelphia Nonattainment Area Daily PM2.5 Design 

Values for the Two Consistently Highest Monitors by State, 2001-2006

New Jersey Pennsylvania Delaware

1st Highest 2nd Highest 1st Highest 2nd Highest 1st Highest 2nd Highest

AQS Monitor 

ID, Site Name 

and Location

34-007-0003 

Camden Lab 

Primary, 

Camden

34-007-1007 

Pennsauken 

Township, 

Pennsauken

42-101-0004

AMS Lab, 

Philadelphia

42-101-0136

Amtrak, 

Philadelphia

10-003-2004 

MLK Blvd. & 

Justison Street, 

Wilmington

10-003-1012 

University of 

Delaware, 

Newark

Year of 

Highest 2005 2005 and 2006 2001-2003 2002 2002 2002

Concentration 

of Highest 

(μg/m3)

39 37 40 41 41 41

Below 1997 

Annual PM2.5 

NAAQS in 

2006?

Yes Yes Yes 2006 data not 

available Yes Yes

Below 2006 

Daily PM2.5 

NAAQS in 

2006?

No No No 2006 data not 

available No Yes

 94 See note 76.
32

2.4 Composition of Fine Particle Pollution – Speciated Monitoring Data and Trends

New Jersey has four monitoring sites that collect PM2.5 speciated data. Speciation is the process 

of separating PM2.5 particle mass into individual chemical species components or groups of 

species. These sites are located in Camden, Chester, Elizabeth, and New Brunswick, New 

Jersey. The first full year of speciated data collection was 2002. Data were collected in 2001 but 

only for part of the year. The data for each monitor, including each monitoring site’s speciation 

profile for the eight highest PM2.5 components from 2002 through 2006, is presented in Figures

2.10 through 2.14. The total mass is presented in the figures and does not equate to the sum of 

all of the components.95 The trends for each monitor consistently show that sulfate, organic 

carbon, nitrate, ammonium, sulfur, and elemental carbon are the largest components of total 

PM2.5 mass. These charts show that organic carbon and sulfate comprise the majority of the 

PM2.5 mass measured at all four sites in both 2002 and 2006. Since the signatures of both 

organic carbon and sulfate are the highest compounds measured at each monitoring site from 

2002 through 2006, the NJDEP is confident that these signatures are regional, rather than local, 

in nature. 

Figure 2.10: PM2.5 Species that Recorded the Highest Concentrations for 2002 and 2006 in 

New Jersey

Total Mass, 14.7

Total Mass, 13.8

Total Mass, 16.0

Total Mass, 11.5

Total Mass, 14.1

Total Mass, 9.3

Total Mass, 18.2

Total Mass, 10.3

0.0

5.0

10.0

15.0

20.0

2002 2006 2002 2006 2002 2006 2002 2006

Camden Chester Elizabeth New Brunswick

Concentration (μg/m3

)

Others

Iron

Silicon

Sodium

Elemental Carbon

Sulfur

Nitrate

Ammonium

Sulfate

Organic Carbon

Total Mass

 95 Data are collected on three different filters that run independently of each another. The flow rates may vary 

slightly between the three sample channels. The total mass that is reported is measured from the Teflon filter. 

There are also some redundancies in data reporting. For example, sodium and potassium are measured both by XRay Fluorescence (XRF) and Ion Chromatography. The XRF results were used in this analysis. Carbon is reported 

as Elemental Carbon, Organic Carbon, and total Carbon (sum of organic and elemental). If redundancies are 

removed, the reported total mass and sum of all species are relatively close. 
33

Figure 2.11: Speciated Data from 2002-2006 with the Highest Concentrations at Camden, 

New Jersey

Total Mass, 16.4

Total Mass, 16.0

Total Mass, 16.1

Total Mass, 14.7

Total Mass, 14.7

0.0

5.0

10.0

15.0

20.0

2002 2003 2004 2005 2006

Concentration (μg/m3

)

Others

Iron

Silicon

Sodium

Elemental Carbon

Sulfur

Nitrate

Ammonium

Sulfate

Organic Carbon

Total Mass

Figure 2.12: Speciated Data from 2002-2006 with the Highest Concentrations at Chester, 

New Jersey

Total Mass, 11.1

Total Mass, 10.3

Total Mass, 12.0

Total Mass, 9.3

Total Mass, 10.8

0.0

5.0

10.0

15.0

20.0

2002 2003 2004 2005 2006

Concentration (μg/m3

)

Others

Potassium

Iron

Silicon

Sodium

Elemental Carbon

Sulfur

Nitrate

Ammonium

Sulfate

Organic Carbon

Total Mass
34

Figure 2.13: Speciated Data from 2002-2006 with the Highest Concentrations at Elizabeth, 

New Jersey

Total Mass, 17.4 Total Mass, 18.2

Total Mass, 17.8

Total Mass, 14.1

Total Mass, 15.7

0.0

5.0

10.0

15.0

20.0

2002 2003 2004 2005 2006

Concentration (μg/m3

)

Others

Iron

Silicon

Sodium

Elemental Carbon

Sulfur

Nitrate

Ammonium

Sulfate

Organic Carbon

Total Mass

 

Figure 2.14: Speciated Data from 2002-2006 with the Highest Concentrations at New 

Brunswick, New Jersey

Total Mass, 13.9

Total Mass, 13.8 Total Mass, 13.8

Total Mass, 11.5

Total Mass, 12.5

0.0

5.0

10.0

15.0

20.0

2002 2003 2004 2005 2006

Concentration (μg/m3

)

Others

Iron

Silicon

Sodium

Elemental Carbon

Sulfur

Nitrate

Ammonium

Sulfate

Organic Carbon

Total Mass
35

2.5 PM2.5 Source Apportionment 

Another way to look at the data is to attribute the composition of the particle mass to its source. 

This is accomplished using “source apportionment” modeling.96 For air quality management 

purposes, source apportionment is complimentary to photochemical modeling and other air 

quality analyses. In this SIP revision, one rural and one urban source apportionment study for 

New Jersey were selected to highlight major sources of PM2.5. 

Using the Brigantine monitoring site (a rural location and Class I area), Kim and Hopke

(2004)

97,98 showed that over 60 percent of the PM2.5 mass was associated with sulfate aerosol 

formation from electric generating units outside of New Jersey, 13 percent of the mass was from 

gasoline vehicles, and 4 percent was from diesel vehicles for sources in New Jersey or the nearby 

Philadelphia metropolitan area. Results are presented in Figure 2.15. Table 2.9 summarizes the 

results of additional analyses conducted in this study that provide an estimation of the geographic 

location/pathway and/or origin of the PM2.5 sources identified through the positive matrix 

factorization (PMF) analysis.

 96 USEPA. Receptor Modeling, Air Quality Management Online Portal, United States Environmental Protection 

Agency, http://www.epa.gov/air/aqmportal/management/modeling/receptor.htm, accessed October 22, 2007.

97 Kim, E. and Hopke, P. K. Improving Source Identification of Fine Particles in a Rural Northeastern U.S. Area 

Utilizing Temperature-resolved Carbon Fractions. Journal of Geophysical Research, 109, D09201, doi: 

10.1029/2003JD004199, 2004.

98 Data from March 1992 - May 2001 was used in the positive matrix factorization (PMF) model, conditional 

probability function (CPF), and potential source contribution function (PSCF) analyses to identify sources of PM2.5

and their locations contributing to concentrations at the Brigantine monitoring site.
36

Figure 2.15: PM2.5 Sources Identified at the Monitoring Site in Brigantine, New Jersey 

Contributing to the Mean Daily PM2.5 Mass Concentrations Averaged over 1992 – 2001 

using PMF*

3% 2% 1%

4%

4%

5%

6%

7%

8%

13%

48%

Sulfate-rich Secondary

Aerosol I

Gasoline Vehicle

Aged Sea Salt

Sulfate-rich Secondary

Aerosol II 

Nitrate-rich Secondary

Aerosol

Sulfate-rich Secondary

Aerosol III

Sea Salt

Airborne Soil

Diesel Emission

Incinerator 

Oil Combustion 

Source: Kim and Hopke, 

*The percentages are from Table 2 (Kim and Hopke, 2004) and 

are the estimated average source contribution (percent) to PM2.5

mass (11.24 μg/m3

, measured over the 1992-2001 time period) 

using PMF. The relative contributions in μg/m3 were not 

provided in the paper.
37

Table 2.9: Study Results from the Potential Source Contribution Function (PSCF) and 

Conditional Probability Function (CPF) Analyses, Kim and Hopke (2004)

Analysis PM2.5 Source(s) 

Identifieda

Source Contributor(s)b Source Location(s)/Pathway(s) 

(with respect to the Brigantine monitor)

PSCFc Sulfate-rich secondary 

aerosols I and III

Coal-fired power plants • Midwest (i.e., Ohio River Valley)

• Southern Indiana

• Northern Kentucky

Petrochemical industry • Louisiana

Not identified • Southern Mississippi

Sulfate-rich secondary 

aerosol II

Biogenic emissions from 

Canadian forest fires

• Hudson Bay, Canada region

Volatile organic carbon 

(VOC) emissions from 

biogenic sources

• Eastern Tennessee

• Northeastern Georgia

• Western South Carolina

Sulfur emissions • Southern Louisiana

• Mississippi

• Alabama

Airborne soil Dust storms • Asia

• Africa (Sahara)

CPFd Organic carbon Gasoline vehicles North and southwest: close to Highway 9 

in New Jersey

Elemental carbon Diesel vehicles Northwest: an area containing 

Philadelphia, Pennsylvania and major 

highway traffic between Washington, D.C. 

and New York City. 

Nitrate-rich secondary 

aerosol

Not identified West and Northwest – Philadelphia, 

Pennsylvania

Aged and fresh sea salt N/A Atlantic Ocean

Airborne soil Crustal particles from 

onroad traffic

Northwest and southwest

Dust storms • Asia

• Africa (Sahara)

Municipal solid waste 

incinerator emissions

N/A West and northwest

Oil combustion Utilities and industries • New York City (north)

• Atlantic City (southeast)

• Northeastern urban corridor between 

Washington, D.C. and Boston, 

Massachusetts a For clarification, researchers also sometimes refer to sources as factors and these terms may be used interchangeably in some

instances. A factor could be associated with a source, source type, or source region (Lee, J. H., Poirot, R. L., Lioy, P. J., and 

Oxley, J. C. Identification of Sources Contributing to Mid-Atlantic Regional Aerosol. Journal of Air and Waste Management, 

52, 1186-1205, 2002.). b A ‘source contributor’ identifies the specific category or source type that is the assumed cause of the pollution. c The PSCF analysis was performed only for the sulfate-rich secondary aerosols using the PMF estimations and backward 

trajectories using the HYSPLIT model. d The CPF analysis combined the PMF results with wind direction values measured at the Brigantine monitoring site. 
38

Building on the PMF analysis conducted in 2004,99 Hopke and Gildemeister (2006) used PSCF 

and back trajectory analyses to determine the seasonal variation in source contributions to PM2.5

mass measured at the four speciation monitors in New Jersey from 2001-2005.100 These 

monitors are in urban areas compared to the rural location of the Brigantine monitor discussed in 

the previous study. Figure 2.16 shows the results of the study by monitor and by season. 

Significant findings of the study were as follows:

• Similar types of transported aerosols were seen amongst all four sites, notably, secondary 

sulfate and nitrate, biomass burning, and aged sea salt. 

• Secondary sulfate was the largest contributor to PM2.5, especially during the summer.

• Secondary nitrate concentrations reach their highest in the winter. 

• Secondary sulfate and nitrate were transported from sources in other states. 

• The sulfate factor was estimated to be from regions with large coal-fired power plants. 

• Elevated nitrate concentrations were shown to be from areas with increased ammonia and 

some oxides of nitrogen (NOx) emissions. 

• Automotive emissions were the second highest contributor among most of the sites.

• Biomass burning was thought to be due to transport of wood smoke from Canadian 

boreal forest fires during the summers. 

• Railroad traffic was estimated to be the source of iron and steel at New Brunswick.

• Compared to the summer source contributions, the automotive, nitrate, mixed 

industrial/Fe and steel, and sea salt factors increase during the winter.

 99 Hopke, P. K. and Kim, E. Application of Advanced Factor Analysis Modeling to Apportion PM2.5 in New Jersey. 

Center for Air Resources Engineering and Science, Clarkson University, March 2005.

100 Hopke, P. K. and Gildemeister, A. Application of Trajectory Ensemble Analysis to Locate PM2.5 Sources. 

Center for Air Resources Engineering and Science, Clarkson University, November 2006.
39

Figure 2.16: Seasonal Variations in Source Contributions to Average Seasonal PM2.5 Mass Concentrations from 2001-2004 at Four 

Speciation Monitors in New Jersey, Hopke and Gildemeister (2006)

Chester, Summer Chester, Winter

Chester Summer

0.5 μg/m3

, 4%

0.4 μg/m3

, 3%

6.2 μg/m3

, 54% 

1.9 μg/m3

, 17%

1.0 μg/m3

, 9%

0.6 μg/m3

, 5%

0.4 μg/m3

, 4%

0.5 μg/m3

, 4%

Secondary Sulfate

Automotive

Biomass Burning

Diesel

Nitrate

Mixed Industrial

Soil

Sea Salt Total Seasonal Av erage (estimated sum of all components):

Summer = 11.48 μg/m3 

Chester Winter

0.3 μg/m3

, 3%

1.1 μg/m3

, 11%

0.7 μg/m3, 7%

0.5 μg/m3, 5%

0.7, μg/m3

, 7%

1.8 μg/m3

, 18%

0.5 μg/m3

, 5%

4.3 μg/m3

, 44%

Secondary Sulfate

Automotive

Biomass Burning

Diesel

Nitrate

Mixed Industrial

Soil

Sea Salt

Total Seasonal Average (estimated sum of all components):

Winter = 9.68 μg/m3

Camden, Summer Camden, Winter

Camden Summer

2.2 μg/m3, 13%

0.6 μg/m3, 3%

1.0 μg/m3, 6%

1.2 μg/m3, 7%

1.3 μg/m3, 7%

1.2 μg/m3, 7% 0.4 μg/m3

, 2%

9.0 μg/m3, 55%

Secondary Sulfate

Gasoline

Biomass Burning

Diesel

Nitrate

Mixed Industrial

Soil

Sea Salt

Total Seasonal Average (estimated sum of all components):

Summer = 16.76 μg/m3

 

Camden Winter

2.4 μg/m3, 15%

0.5 μg/m3

, 3%

0.6 μg/m3 1.0 μg/m , 4% 3

, 6%

1.0 μg/m3

, 6%

3.0 μg/m3

, 19%

2.8 μg/m3, 17%

4.8 μg/m3

, 30%

Secondary Sulfate

Gasoline

Biomass Burning

Diesel

Nitrate

Mixed Industrial

Soil

Sea Salt

Total Seasonal Average (estimated sum of all components):

Winter = 16.0 μg/m3
40

(continued) Figure 2.16: Seasonal Variations in Source Contributions to Average Seasonal PM2.5 Mass Concentrations from 2001-2004 at 

Four Speciation Monitors in New Jersey, Hopke and Gildemeister (2006)

Elizabeth, Summer Elizabeth, Winter

Elizabeth Summer

0.5 μg/m3, 4%

0.5 μg/m3

, 4%

0.5 μg/m3, 4%

0.6 μg/m3, 5%

1.0 μg/m3

, 9%

1.9 μg/m3, 17%

6.0 μg/m3, 54%

0.4 μg/m3

, 3%

Secondary Sulfate

Automotive

Biomass Burning

Diesel

Nitrate

Mixed Industrial

Soil

Sea Salt

Total Seasonal Average (estimated sum of all components):

Summer = 11.28 μg/m3

 

Elizabeth Winter

0.3 μg/m3

, 3%

1.0 μg/m3

, 11%

0.7 μg/m3

, 7%

0.4 μg/m3, 4%

0.6 μg/m3

, 7%

1.7 μg/m3, 19%

4.0 μg/m3

, 44%

0.4 μg/m3

, 5%

Secondary Sulfate

Automotive

Biomass Burning

Diesel

Nitrate

Mixed Industrial

Soil

Sea Salt

Total Seasonal Average (estimated sum of all components):

Winter = 9.11 μg/m3

New Brunswick, Summer New Brunswick, Winter

New Brunswick Summer

2.1 μg/m3, 15%

0.4 μg/m3, 3%

1.4 μg/m3, 11%

0.8 μg/m3, 6%

0.8 μg/m3, 6%

7.5 μg/m3, 56%

0.3 μg/m3, 3% Secondary Sulfate

Biomass Burning

Diesel

Nitrate

Fe and Steel

Soil

Sea Salt

Total Seasonal Average (estimated sum of all components):

Summer = 13.26 μg/m3

 

New Brunswick Winter

0.8 μg/m3, 6%

0.6 μg/m3, 5%

1.7 μg/m3, 15%

0.4 μg/m3, 4%

3.1 μg/m3

, 27% 0.6 μg/m3

, 5%

4.5 μg/m3, 38%

Secondary Sulfate

Biomass Burning

Diesel

Nitrate

Fe and Steel

Soil

Sea Salt

Total Seasonal Average (estimated sum of all components):

Winter = 11.63 μg/m3

 
41

In a regional analysis101of PM2.5, the chemical composition measured at the monitor in Elizabeth, 

New Jersey is shown in Figure 2.17. This analysis was not a source apportionment study but an 

analysis of the ambient data, which also showed that organic carbon (identified as gasoline 

emissions in Hopke and Gildemeister (2006)) and sulfate were the largest contributors to the 

total PM2.5 mass with sulfate concentrations significantly higher in the summer compared to the 

winter. Back trajectories used in the Mid-Atlantic Regional Air Management Association

(MARAMA) (2006) analysis showed air parcels on the cleanest days (i.e., lowest PM2.5

concentrations) originating from western Canada, Ontario, Canada, and the ocean. On the 

dirtiest days showed air trajectories mostly from U.S. regions in the South, Midwest, or 

Northeast and Mid-Atlantic states.

Figure 2.17: Major Constituents of PM2.5 Mass at the Elizabeth, New Jersey Monitoring 

Site from 2001-2003102

6.9 μg/m3

, 36%

2.2 μg/m3, 11%

2.3 μg/m3, 12%

1.8 μg/m3

, 9%

0.8 μg/m3

, 4%

 0.3 μg/m3

, 2%

0.1 μg/m3, 1%

4.8 μg/m3

, 25%

Sulfate

Organic Carbon Mass

(1.6)

Ammonium

Nitrate

Elemental Carbon

Geological

Trace Elements

Salt

The ambient data analyses consistently show a fairly large sulfate contribution to the PM2.5 mass 

collected at the speciation monitors throughout New Jersey, demonstrating that these signatures 

are regional, rather than local, in nature. The source apportionment modeling studies 

demonstrate that the major source of this sulfate is primarily from coal-fired electric generating 

units in regions west of New Jersey. The contribution of local sources from gasoline and dieselpowered vehicles and industries in the area are also important contributors to the PM2.5 mass in 

New Jersey. 

 101 MARAMA. An Analysis of Speciated PM2.5 Data in the MARAMA Region. Prepared by Gillepsie, W G. and 

Davis, P. of the Mid-Atlantic Regional Air Management Association, Baltimore, MD, May 31, 2006. 102 Figure 5-65 modified from MARAMA, 2006 (see note 101).

Average reconstructed total PM2.5 mass 

= 19.1 μg/m3 (percentages are based 

upon this total mass)

Average gravimetric total PM2.5 mass = 

18.0 μg/m3
42

2.6 Emission Inventory

An emission inventory is an estimate of the emissions from anthropogenic (human-made) and

biogenic (natural) sources. New Jersey developed an emission inventory for 2002, which is 

defined as the base year for future attainment planning purposes with respect to 8-hour ozone, 

PM2.5, and regional haze State Implementation Plans (SIPs), as required by the USEPA.103 The 

2002 base year inventory included the pollutants: VOC, NOx, carbon monoxide, particulate 

matter less than 10 micrometers in diameter (PM10), PM2.5, sulfur dioxide (SO2),

104 and ammonia 

(NH3). The inventory divided the sources into five sectors, each making up one component of 

the inventory: point sources, area sources, onroad sources, nonroad sources, and biogenic 

sources. The emission inventories from all the states in the Northeastern and Mid-Atlantic states 

were compiled by the Mid-Atlantic/Northeast Visibility Union (MANE-VU), which then created 

a regional inventory. MANE-VU consists of the District of Columbia and 11 states: 

Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New 

York, Pennsylvania, Rhode Island, and Vermont. This regional inventory was used to perform 

the regional modeling analysis used in the State’s air quality management planning efforts to 

attain the 8-hour ozone NAAQS, the PM2.5 NAAQS, and the regional haze plans. MANE-VU, 

through its contractor, MARAMA, projected the 2002 base year emission inventory to various 

future years. For the purposes of this PM2.5 SIP revision, the 2009 future projections were used 

in the regional modeling exercises to demonstrate attainment of the 1997 annual PM2.5

NAAQS.105 The regional 2002 and 2009 emission inventories were used as the basis of this SIP 

revision. 

Comparisons of the 2002 and 2009 PM2.5, SO2, and NOx inventories developed by MANE-VU 

are discussed in this section. Detailed information about the emission inventories is included in 

the attainment demonstration summary in Chapter 5. Figures 2.18 and 2.19 compare the total 

emissions of direct PM2.5, NOx, and SO2 from 2002 and 2009 for each state in the Northern New 

Jersey/New York/Connecticut and Southern New Jersey/Philadelphia nonattainment areas, 

respectively. Figures 2.20 through 2.26 compare the direct PM2.5, NOx, and SO2 emissions from 

each sector (i.e., point, area, onroad, and nonroad) in all the states associated with New Jersey’s 

PM2.5 nonattainment areas from 2002 and 2009. The top 15 direct PM2.5, NOx, and SO2 emitting 

categories in the 2002 and 2009 inventories for the MANE-VU region are compared in Figures 

2.27 through 2.31. In general, for both nonattaiment areas, total emissions for each pollutant are 

projected to decrease, with emissions from the area source sector increasing while emissions 

from the other sectors are projected to decrease. Stationary source emissions are projected to 

increase for direct PM2.5. The 2009 projections assume the implementation of BOTW measures 

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

Monoxide National Ambient Air Quality Standard, 1-Hour Ozone National Ambient Air Quality Standard, and Fine 

Particulate Matter National Ambient Air Quality Standard; and the 2002 Periodic Emission Inventory. New Jersey 

Department of Environmental Protection, May 2006. 104 SO2 has been reported in the inventory instead of SOx as required in the Consolidated Emissions Reporting Rule 

because the USEPA MOBILE and NON-ROAD models and the majority of USEPA guidance on emission factors is 

based on SO2, not SOx. In addition, the USEPA National Emissions Inventory reports SO2. 105 While New Jersey did complete a state-specific 2002 inventory (submitted to the USEPA February 28, 2006, and 

approved by the USEPA May 2006), this inventory was not used for this analysis, as a comparable 2009 inventory 

was not grown in state.
43

(see Chapter 4).

Figure 2.18: Comparison of Total PM2.5, NOx, and SO2 Emissions by State in the Northern 

New Jersey/New York/Connecticut Nonattainment Area

2002-2009

0

100000

200000

300000

400000

500000

600000

2002 2009 2002 2009 2002 2009

PM2.5 NOx SO2

Emissions (tpy)

New York

New Jersey

Connecticut
44

Figure 2.19: Comparison of Total PM2.5, NOx, and SO2 Emissions by State in the Southern 

New Jersey/Philadelphia Nonattainment Area

2002-2009

0

50000

100000

150000

200000

250000

2002 2009 2002 2009 2002 2009

PM2.5 NOx SO2

Emissions (tpy)

Pennsylvania

New Jersey

Delaware

Figure 2.20: Comparison of PM2.5 Emissions by Sector in the Northern New Jersey/New 

York/Connecticut Nonattainment Area

2002-2009

0

3000

6000

9000

12000

15000

18000

21000

24000

27000

30000

Point Area Onroad Nonroad

Sector

Emissions (tpy)

2002 2009
45

Figure 2.21: Comparison of PM2.5 Emissions by Sector in the Southern New 

Jersey/Philadelphia Nonattainment Area

2002-2009

0

3000

6000

9000

12000

15000

18000

21000

24000

27000

30000

Point Area Onroad Nonroad

Sector

Emissions (tpy)

2002 2009

Figure 2.22: Comparison of NOx Emissions by Sector in the Northern New Jersey/New 

York/Connecticut Nonattainment Area

2002-2009

0

30000

60000

90000

120000

150000

180000

210000

240000

270000

300000

Point Area Onroad Nonroad

Sector

Emissions (tpy)

2002 2009
46

Figure 2.23: Comparison of NOx Emissions by Sector in the Southern New 

Jersey/Philadelphia Nonattainment Area

2002-2009

0

30000

60000

90000

120000

150000

180000

210000

240000

270000

300000

Point Area Onroad Nonroad

Sector

Emissions (tpy)

2002 2009

Figure 2.24: Comparison of SO2 Emissions by Sector in the Northern New Jersey/New 

York/Connecticut Nonattainment Area

2002-2009

0

10000

20000

30000

40000

50000

60000

70000

80000

90000

100000

110000

120000

130000

Point Area Onroad Nonroad

Sector

Emissions (tpy)

2002 2009
47

Figure 2.25: Comparison of SO2 Emissions by Sector in the Southern New 

Jersey/Philadelphia Nonattainment Area

2002-2009

0

10000

20000

30000

40000

50000

60000

70000

80000

90000

100000

110000

120000

130000

Point Area Onroad Nonroad

Sector

Emissions (tpy)

2002 2009

Figure 2.26: 2002 MANE-VU Region PM2.5 Inventory Top 15

161,137

69,550

60,426

46,127

23,763

21,492

21,016

18,951

15,505

14,016

13,436

10,873

8,721

8,485

8,295

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

Stationary Source Fuel Combustion-Residential

Mobile Sources-Unpaved Roads

Mobile Sources-Paved Roads

Industrial Processes-Construction

Waste Disposal, Treatment, and Recovery-Open Burning

Stationary Source Fuel Combustion-Industrial

Mobile Sources-Off-highway Vehicles Diesel

External Combustion Boilers-Electric Generation

Miscellaneous Area Sources-Agricultural Production-Crops

Industrial Processes-Food and Kindred Products

Mobile Sources-Highway Vehicles-Diesel

External Combustion Boilers-Industrial

Mobile Sources-Highway Vehicles-Gasoline

Industrial Processes-Mining and Quarrying

Stationary Source Fuel Combustion-Commercial/Institutional

Tons per Year

Area

Point

OnRoad

NonRoad
48

Figure 2.27: 2009 MANE-VU Region PM2.5 Inventory Top 15

105,229

66,253

47,979

37,367

25,470

25,012

18,931

17,331

14,452

13,577

13,090

10,149

9,359

8,056

7,831

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

Stationary Source Fuel Combustion - Wood

Electric Generating Units (Total Emissions)

Mobile Sources - Unpaved Roads

Mobile Sources - Paved Roads

Industrial Processes - Construction

Waste Disposal, Treatment, and Recovery - Open Burning

Miscellaneous Area Sources - Agricultural production-Crops

Mobile Sources - Off-highway Vehicles Diesel

Industrial Processes - Food and Kindred Products

Mobile Sources - All Onroad (Total Emissions)

Stationary Source Fuel Combustion - Coal

External Combustion Boilers - Industrial

Industrial Processes - Mining and Quarrying

Stationary Source Fuel Combustion - Natural Gas

Industrial Processes - Mineral Products

Tons per Year

Area

Point

OnRoad

NonRoad

Figure 2.28: 2002 MANE-VU Region NOx Inventory Top 15

798,279

492,533

434,308

224,113

121,124

71,535

57,533

55,775

53,852

52,718

51,966

43,701

33,554

22,042

21,419

0 100,000 200,000 300,000 400,000 500,000 600,000 700,000 800,000 900,000

Mobile Sources-Highway Vehicles-Gasoline

Mobile Sources-Highway Vehicles-Diesel

External Combustion Boilers-Electric Generation

Mobile Sources-Off-highway Vehicle Diesel

Stationary Source Fuel Combustion-Residential

Stationary Source Fuel Combustion-Commercial/Institutional

Industrial Processes-Mineral Products

External Combustion Boilers-Industrial

Mobile Sources-Railroad Equipment

Mobile Sources-LPG

Mobile Sources-Marine Vessels, Commercial

Stationary Source Fuel Combustion-Industrial

Mobile Sources-Off-highway Vehicle Gasoline, 4-Stroke

Internal Combustion Engines-Industrial

Internal Combustion Engines-Electric Generation

Tons per Year

Area

Point

OnRoad

NonRoad
49

Figure 2.29: 2009 MANE-VU Region NOx Inventory Top 15

745,736

219,523

182,587

107,211

84,965

66,495

59,455

51,966

51,352

44,121

35,600

34,927

24,485

24,391

22,024

0 100,000 200,000 300,000 400,000 500,000 600,000 700,000 800,000

Mobile Sources - All Onroad (Total Emissions)

Electric Generating Units (Total Emissions)

Mobile Sources - Off-highway Diesel

Stationary Source Fuel Combustion - Natural Gas

Stationary Source Fuel Combustion - Distillate Oil

Mobile Sources - Railroad Equipment

Industrial Processes - Mineral Products

Mobile Sources - Commercial Marine Vessels

Mobile Sources - LPG

External Combustion Boilers - Industrial

Mobile Sources - Off-highway vehicle gasoline

Internal Combustion Engines - Industrial

Stationary Source Fuel Combustion - Coal

Stationary Source Fuel Combustion - Wood

Waste Disposal - Solid Waste Disposal

Tons per Year

Area

Point

OnRoad

NonRoad

Figure 2.30: 2002 MANE-VU Region SO2 Inventory Top 15

1,633,336

156,095

145,518

83,170

66,138

47,627

29,674

27,265

26,087

17,173

17,154

15,817

12,191

11,750

4,574

0 200,000 400,000 600,000 800,000 1,000,000 1,200,000 1,400,000 1,600,000 1,800,000

External Combustion Boilers-Electric Generation

External Combustion Boilers-Industrial

Stationary Source Fuel Combustion-Residential

Stationary Source Fuel Combustion-Commercial/Institutional

Stationary Source Fuel Combustion-Industrial

Industrial Processes-Mineral Products

Mobile Sources-Off-highway Vehicle Diesel

Mobile Sources-Highway Vehicles-Gasoline

Mobile Sources-Marine Vessels, Commercial

External Combustion Boilers-Commercial/Institutional

Industrial Processes-Petroleum Industry

Industrial Processes-Primary Metal Production

Mobile Sources-Highway Vehicles-Diesel

Stationary Source Fuel Combustion-Electric Utility

Industrial Processes-In-process Fuel Use

Tons per Year

Area

Point

OnRoad

NonRoad
50

Figure 2.31: 2009 MANE-VU Region SO2 Inventory Top 15

519,618

165,328

115,253

88,325

56,587

34,643

26,088

22,731

20,414

18,716

7,974

7,457

6,684

5,554

4,750

0 100,000 200,000 300,000 400,000 500,000 600,000

Electric Generating Units (Total Emissions)

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

Mobile Sources - All Onroad (Total Emissions)

Stationary Source Fuel Combustion - Kerosene

Waste Disposal - Solid Waste Disposal

Stationary Source Fuel Combustion - Wood

Tons per Year

Area

Point

OnRoad

NonRoad

Addressing Condensables

Certain commercial or industrial activities involving high temperature processes (fuel 

combustion, metal processing, cooking operations, etc.) emit gaseous pollutants into the ambient 

air which rapidly condense into particle form. The constituents of these condensed particles 

include, but are not limited to, organic material, sulfuric acid, and metals.106 States are required 

under the consolidated emissions reporting rule (CERR)107 to report condensable emissions in 

each inventory revision. For New Jersey’s 2002 PM2.5 inventory, filterable PM2.5 and 

condensable PM2.5 emissions were calculated, and then these emissions were added together to 

produce the final PM2.5 emissions.108

Addressing Fugitive Dust

There has been some controversy over state inventory estimates for fugitive dust sources, which 

primarily consist of dust from paved and unpaved roadways, stock/storage piles, landfill activity, 

quarry/mining activity, raw material handling, construction and agricultural tilling. Fugitive 

 106 72 Fed. Reg. 20586 (April 25, 2007). 107 67 Fed. Reg. 39602 (June 10, 2002). 108 NJDEP. State Implementation Plan (SIP) Revisions for the Attainment and Maintenance of the

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

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

Inventory. New Jersey Department of Environmental Protection. May 2006.
51

dusts are directly released air contaminants that do not pass through an exhaust pipe, stack, flue, 

vent, or chimney. Specifically, the concern is that the estimated numbers are significantly higher 

than is evidenced by the ambient data. This discrepancy is supported by a study of fine particle 

matter near urban roadways which found that emissions of resuspended particulate matter near 

urban roads calculated using the prescribed guidance would result in fine particle levels 9 to 20 

times higher than those observed.109 Further, the USEPA and other regional air quality modeling 

work have found it necessary to reduce calculated dust-related emissions by 75-90 percent in 

order to have the modeling results match monitored PM2.5 speciated data. In the regional 

inventory, the states each submitted unadjusted fugitive dust emission numbers to the National 

Emissions Inventory (NEI)/MARAMA. However, these numbers were adjusted prior to 

modeling, as documented in the inventory section of the Technical Support Document for 

modeling (see Appendix B4). In order for the calculated inventory values to more closely match 

the actual measured levels in New Jersey air quality monitors, and match their true proportional 

impacts to human health, New Jersey multiplied its estimated fugitive dust emissions by a dust 

adjustment factor of 20 percent in its State-generated base inventory (submitted to USEPA on 

February 28, 2006, and approved by the USEPA May 2006).

110 

2.7 Conclusions

Ambient air monitoring networks are in place to measure the levels of fine particulate matter in 

order to communicate the quality of the air to the public and to track the progress toward meeting 

the NAAQS. PM2.5 has been measured in New Jersey and its associated multi-state 

nonattainment areas since 1999. A summary of the observations and conclusions from the 

analyses in this Chapter are as follows:

1) The air quality data in New Jersey and surrounding states indicates attainment of the former 

daily PM2.5 standard (65 μg/m3) and nonattainment of the new daily standard (35 μg/m3).

2) PM2.5 levels are decreasing.

3) Ambient PM2.5 speciated data from the New Jersey speciation monitors in Camden, Chester, 

Elizabeth, and New Brunswick show that sulfate and organic carbon are the largest 

components of total PM2.5 mass.

4) Analyses of the PM2.5 speciated data collected at ambient monitors using source 

apportionment techniques demonstrate that common sources that contribute to PM2.5 mass 

included a combination of local and regional sources and biogenic and anthropogenic 

sources, specifically coal-fired power plants in regions west of New Jersey, crustal matter, oil 

combustion sources in Northeast urban areas, sea salt, and motor vehicles (diesel/gasoline 

and local/highway).

 109 NJDEP. Attachment 2: Fugitive Dust Inventory Discussion and Summary, State Implementation Plan (SIP) 

Revisions for the Attainment and Maintenance of the 8-Hour Carbon Monoxide National Ambient Air Quality 

Standard, 1-Hour Ozone National Ambient Air Quality Standard, and Fine Particulate Matter National Ambient Air 

Quality Standard; and the 2002 Periodic Emission Inventory. New Jersey Department of Environmental Protection. 

May 2006.

110 See note 108.
52

5) In addition to the ambient monitoring network, emission inventories quantify the sources of 

PM2.5. In general, for both nonattaiment areas associated with New Jersey, total emissions 

for each pollutant are projected to decrease, with emissions from the area source sector 

increasing, direct PM2.5 emissions from stationary sources are increasing, and emissions from 

the other sectors are decreasing by 2009.
53

3.0 REQUIREMENTS FOR THE 1997 PM2.5 NAAQS

The primary purpose of this State Implementation Plan (SIP) revision is to demonstrate that New 

Jersey and its associated multi-state nonattainment areas will attain the 1997 annual fine 

particulate matter (PM2.5) national ambient air quality standards (NAAQS) by April 5, 2010. 

New Jersey plans to fulfill its obligations under the federal Clean Air Act and the State’s Air 

Pollution Control Act with respect to both the 1997 and 2006 PM2.5 standards (see discussions of 

these standards in Section 1.1). The State faces several other air quality related challenges, 

including meeting other criteria pollutant NAAQS (such as 8-hour ozone), reducing air toxic 

emissions to reduce cumulative risk, and improving visibility, that are interrelated with the PM2.5

initiatives. See Chapter 1 for more information on the PM2.5 reductions from this SIP revision 

relate to the State’s other air quality related challenges.

As required by 42 U.S.C. § 7410(a)(1) (Section 110(a)(1)), the states are required to demonstrate 

attainment of the NAAQS by submitting revised State Implementation Plans (SIPs). As 

discussed in Chapter 1, on July 18, 1997, the United States Environmental Protection Agency 

(USEPA) established two new primary NAAQS for fine particles:

o an annual fine particulate matter (PM2.5) health-based standard of 15 micrograms per 

cubic meter (μg/m3

) (annual arithmetic mean) and 

o a daily (24-hour) PM2.5 health-based standard of 65 micrograms per cubic meter (μg/m3) 

(24-hour average).111,112 

On October 16, 2006, the USEPA promulgated a revised PM2.5 NAAQS, which became effective 

December 18, 2006.113 The USEPA retained the existing annual standard established in 1997 

and established a more stringent daily standard of 35 μg/m3. This SIP revision does not meet the 

requirements for the 2006 PM2.5 NAAQS but provides progress toward attainment of the 35 

μg/m3 standard.

3.1 USEPA PM2.5 Implementation Rule

The USEPA published its final rule to implement the 1997 PM2.5 NAAQS on April 25, 2007.114 

A state or tribe must develop an implementation plan for any areas that are designated in 

nonattainment of a NAAQS. For the 1997 daily PM2.5 standard, New Jersey continues to meet 

that level as demonstrated by the most current air monitoring data presented in Chapter 2. 

Thirteen of New Jersey’s 21 counties were designated as nonattainment for the 1997 PM2.5

standards, and are associated with two multi-state nonattainment areas (the Northern New 

Jersey/New York/Connecticut (NNJ/NY/CT) PM2.5 nonattainment area and the Southern New 

Jersey/Philadelphia (SNJ/Phila.) PM2.5 nonattainment area), as shown in Figure 1.1 (see Chapter 

1).

 111 62 Fed. Reg. 38652-760 (July 18, 1997). 112 The USEPA also revised the PM10 NAAQS by revising the 24-hour form of the PM10 standard to the 99th

percentile averaged over 3 years but retaining the 24-hour PM10 level (i.e., 150 mg/m3

) (62 Fed. Reg. 38652 (July 

18, 1997)). In 2006, the USEPA revoked the annual PM10 standard (71 Fed. Reg. 61144 (October 17, 2006)). New 

Jersey was not designated in nonattainment of the PM10 NAAQS and continues to meet the revised PM10 standards. 113 71 Fed. Reg. 61144-233 (October 17, 2006). 114 72 Fed. Reg. 20586-667 (April 25, 2007).
54

The SIP requirements and elements of the implementation rule are described briefly in this 

section. Please refer to the associated SIP chapters for additional details.

PM2.5 Precursor Policy 

As discussed in Chapter 1, sulfur dioxide (SO2), oxides of nitrogen (NOx), volatile organic 

compounds (VOCs), and ammonia can all contribute to the formation of PM2.5. Under the 

UESPA’s final implementation rule for PM2.5,

115 the precursor that nonattainment areas must 

evaluate for control measures to reduce PM2.5 is SO2. Sulfate has a significant regional impact 

on PM2.5 concentrations and is a large component of air quality problems in all areas of the 

country. Studies show that sulfate is also the largest component of total PM2.5 mass 

concentrations in New Jersey, as discussed in Section 2.5. There are presumptive policies for 

NOx, ammonia, and VOC regarding whether or not these pollutants need to be addressed in SIPs; 

states have the option of reversing these policies for these precursors for an area but states must 

provide a technical demonstration to do so. The presumption is that NOx should be evaluated in 

a SIP and for control measures, whereas ammonia and VOC are not required to be evaluated for 

strategies that will reduce PM2.5 unless a state demonstrates that either or both of these pollutants 

are significant contributors to the PM2.5 problem in an area. New Jersey and the states in its 

shared nonattainment areas agree with the USEPA’s final policies for PM2.5 precursors and did 

not conduct technical demonstrations to reverse these policies. Hence, New Jersey focuses on 

SO2, NOx, and direct emissions of PM2.5 in this SIP revision.

The USEPA developed similar but not identical precursor policies for other PM-related programs 

under the federal Clean Air Act (e.g., New Source Review (NSR), regional haze, transportation 

conformity, and general conformity).116 NSR and regional haze are discussed in Chapter 4 and 

transportation and general conformity are discussed in Chapter 7. For transportation conformity, 

a different approach for a precursor was adopted under the final regulation (i.e., 71 Fed. Reg.

12468). The federal Clean Air Act (42 U.S.C. § 7506(c) (Section 176(c))) requires 

transportation plans, programs, and projects to conform with a state’s SIP. This requirement 

ensures that these activities will not contribute to or create any new air quality problems or delay 

the attainment of a NAAQS. For transportation conformity, four transportation related PM2.5

precursors –NOx, VOCs, SOx, and ammonia – must be considered in the conformity process in 

PM2.5 nonattainment areas.117 The USEPA requirements for the consideration of PM2.5

precursors are:

 

• Regional emissions analysis must include NOx as a PM2.5 precursor in all PM2.5

nonattainment areas, unless the head of the state air agency and the USEPA Regional 

Administrator make a finding that NOx is not a significant contributor to the PM2.5 air 

quality problem in a given area. 

• Regional emissions analyses are not required for VOC, SOx, or NH3 before an approved 

SIP budget for such precursors is established, unless the head of the state air agency or 

the USEPA Regional Administrator makes a finding that onroad emissions of any of 

 115 72 Fed. Reg. 20586-667 (April 25, 2007). 116 72 Fed. Reg. 20590 (April 25, 2007). 117 70 Fed. Reg. 24280-92 (May 6, 2005).
55

these precursors is a significant contributor.

Details of the criteria for the consideration of PM2.5 precursors are explained in Chapter 7.

Reasonably Available Control Technology (RACT)

The Clean Air Act, the implementation plan must provide for the adoption of RACT, at a 

minimum, as expeditiously as practicable, in addition to any other plan provisions to attain the 

NAAQS. New Jersey determined that there are RACT measures that can be reasonably 

implemented, and expects these emission reduction strategies to also help with future attainment 

efforts for the more stringent 24-hour PM2.5 standard, reduction of air toxics, and other air 

quality improvement purposes. Refer to Chapter 4 and Appendix A7 for additional details.

Reasonably Available Control Measures (RACM)

Control measures that would advance the attainment date are considered RACMs that must be 

included in the SIP. 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.”

The purpose of the RACM analysis is to determine whether or not reasonably available control 

measures for all mobile and non-RACT stationary sources exist that would advance the 

attainment date for nonattainment areas by one year. Refer to Chapter 4 and Appendix A8 for 

additional details.

Emission Inventory

Emission inventories for criteria pollutants, including PM2.5, and their precursor pollutants are 

required by the USEPA through its authority under the federal Clean Air Act. The USEPA 

requirements are codified at 40 C.F.R. Pt. 51, Subpart Q. States need these emission inventories 

for demonstrating attainment and maintenance of NAAQS. New Jersey submitted its 2002 

emission inventory to the USEPA in May 2006 and the USEPA approved it on July 10, 2006.118 

New Jersey’s 2002 emission inventory was provided to the regional organizations for 

photochemical modeling exercises for the attainment demonstrations of the 8-hour ozone and 

1997 annual PM2.5 NAAQS and a regional 2002 baseline modeling emission inventory was 

developed for all of the states, incorporating the states’ data, and projected to 2009. The regional 

2002 and 2009 modeling emission inventories were used as the basis of this SIP revision. As 

 118 “The State of New Jersey Department of Environmental Protection 2002 Periodic Emission Inventory May 2006” 

submitted to the USEPA as Appendix D of the “The State of New Jersey NJDEP of Environmental Protection State 

Implementation Plan (SIP) Revisions for the Attainment and Maintenance of the 8-Hour Carbon Monoxide National 

Ambient Air Quality Standard, 1-Hour Ozone National Ambient Air Quality Standard, and Fine Particulate Matter 

National Ambient Air Quality Standard; and the 2002 Periodic Emission Inventory May 2006.” The USEPA 

approved the 2002 Emission Inventory effective July 10, 2006.
56

discussed in Chapter 2, Figures 2.20 and 2.21 show a comparison of PM2.5 emissions by sector in 

the Northern New Jersey/New York/Connecticut and Southern New Jersey/Philadelphia 

nonattainment areas, respectively. Refer to Chapter 2 and Chapter 5 for additional details.

Reasonable Further Progress (RFP)

RFP is a requirement that ensures a nonattainment area is progressing toward attaining a standard 

in a timely fashion. For nonattainment areas with 2010 or earlier PM2.5 attainment dates (like 

New Jersey’s associated PM2.5 nonattainment areas, which both have an attainment date of April 

2010), no RFP submittal is necessary, as the due date of the SIP, April 5, 2008, is within two 

years of the attainment date.119 

Attainment Demonstration

States with nonattainment areas are required to show through technical analyses that the standard 

will be met by the attainment date of April 5, 2010. Refer to Chapter 5 for additional details.

Contingency Measures

Contingency measures are required to further reduce emissions in the event an area fails to attain 

by its attainment date or meet a RFP milestone, as required by 42 U.S.C. § 7502(c)(9) of the 

Clean Air Act (Section 172(c)(9)). These contingency measures must be fully adopted rules or 

measures that are ready for implementation quickly without further action by the State or the 

USEPA upon failure to meet an RFP milestone or reach attainment.120 By following the 

USEPA’s guidance that encourages early implementation of contingency measures and relying 

on measures already implemented or under development, New Jersey is ensuring that no 

additional contingency measures will need to be developed and implemented beyond those 

identified, and is safeguarding itself against failure to meet attainment. Refer to Chapter 6 for 

additional details.

Section 110(a) Requirements

Under 42 U.S.C. § 7410(a)(1) and (2) (Section 110(a)(1) and (2) of the federal Clean Air Act), 

states are required to submit an implementation plan to the USEPA Administrator that 

demonstrates states’ ability and authority to implement, maintain, and enforce the NAAQS. The 

USEPA refers to these plans as the infrastructure elements of the SIP. New Jersey submitted its 

proposed PM2.5 infrastructure SIP to the USEPA on December 7, 2007.121 42 U.S.C. § 

7410(a)(2) (Section 110(a)(2)) lists the elements that are to comprise the implementation plan. 

42 U.S.C. § 7410(a)(2)(D)(i) (Section 110(a)(2)(D)(i)) (hereafter referred to as Section 110 

(a)(2)(D)(i)) is commonly referred to as the transport State Implementation Plan (SIP) 

requirement. New Jersey submitted its transport SIP letter on December 22, 2006.122 The public 

hearing on New Jersey’s proposed Clean Air Interstate Rule (CAIR),123 held on March 28, 2007, 

included a discussion of interstate transport as outlined in the December 22, 2006 NJDEP letter 

 119 72 Fed. Reg. 20633 (April 25, 2007). 120 72 Fed. Reg. 20642-43 (April 25, 2007). 121 Letter from NJDEP Commissioner Lisa P. Jackson to USEPA Regional Administrator Steinberg dated December 

7, 2007. The letter is posted on the NJDEP’s website at http://www.state.nj.us/dep/baqp/sip/siprevs.htm.

122 Letter from NJDEP Commissioner Lisa P. Jackson to USEPA Regional Administrator Steinberg dated December 

22, 2006. The letter is posted on the NJDEP’s website at http://www.state.nj.us/dep/baqp/sip/siprevs.htm.

123 39 N.J.R. 300(a) (February 5, 2007). 
57

to the USEPA. New Jersey’s CAIR was adopted on June 19, 2007, became effective on July 16, 

2007, became operative on August 17, 2007,124 and the USEPA approved these rules on October 

1, 2007.125 Refer to Chapter 8 for additional details. 

Transportation Conformity and General Conformity

The Clean Air Act (42 U.S.C. § 7506) (Section 176) requires that federal actions conform to a 

state’s SIP. To implement this requirement the Clean Air Act directed the USEPA to issue rules 

that governed how conformity determinations would be conducted for two categories of 

actions/activities; a) those dealing with transportation plans, programs, and projects 

(Transportation Conformity), and b) all other actions, e.g., projects requiring federal permits. 

This latter category is referred to as General Conformity. De minimis levels for PM2.5 were 

published in 2006 (71 Fed. Reg. 40420 (July 17, 2006)). Projects whose direct and indirect 

emissions exceed the de minimis levels are required to offset their emissions. The Federal 

Transportation Conformity Rule (40 C.F.R. Sect. 93.100-160) provides the process by which the 

air quality impact of transportation plans, transportation improvement programs, and projects are 

analyzed. Refer to Chapter 7 for additional details.

Enforcement and Compliance

Enforceable SIP regulations must include specific elements. These elements include the sources 

or source types subject to the requirements, the requirements, (e.g., emission limits), time frames 

for compliance, recordkeeping and monitoring requirements, test methods for compliance,126 and 

performance and ongoing monitoring of the control measures for those regulations with an 

applicable emissions limit. The State expects to propose and adopt measures it needs to attain 

the 1997 annual PM2.5 standard in accordance with the New Jersey Administrative Procedures 

Act (APA) (N.J.S.A. 52:14B-1 et seq.) and the Air Pollution Control Act (APCA) (N.J.S.A. 

26:2C-1 et seq.) (Refer to Chapter 8). Once adopted, these regulations will be fully enforceable 

by the State.

Ambient Monitoring

Federal PM2.5 monitoring regulations at 40 C.F.R. Pt. 58 that apply to the states’ ambient air 

quality monitoring programs were revised in 2006 with the revised PM NAAQS. No new 

requirements or revisions were promulgated with the final implementation rule. 

Nonattainment New Source Review (NNSR)

The final 1997 implementation rule did not include final PM2.5 requirements for the NNSR 

program. The USEPA issued a portion of its NNSR rule on May 16, 2008.127 Refer to Chapter 4 

for additional details on this program in New Jersey.

 124 39 N.J.R. 2637(a) (July 16, 2007). Also, see N.J.A.C. 7:27-30. 125 72 Fed. Reg. 55666-72 (October 1, 2007). 126 There is no final test method for direct PM2.5 emissions at this time. The USEPA is collecting information from 

stakeholders on such test methods described in the implementation rule and established a period of transition for 

establishing PM2.5 emission limits (72 Fed. Reg. 20651-55 (April 25, 2007)). 127 73 Fed. Reg. 28321-350 (May 16, 2008).
58

3.2 Summary of this SIP Revision 

The remainder of this SIP revision includes the following:

• A discussion of control measures

• A demonstration of attainment for the year 2010 for both PM2.5 nonattainment areas 

associated with New Jersey 

• A Reasonably Available Control Technology (RACT) analysis

• A Reasonably Available Control Measures (RACM) analysis

• A discussion of contingency measures

• A discussion of the State’s obligations in Section 110 of the Clean Air Act 

• Transportation conformity budgets 

• New Jersey specific declarations and commitments
59

4.0 CONTROL MEASURES

This chapter discusses the particulate matter related control measures implemented, or expected 

to be implemented in New Jersey, in the Northeast/Mid-Atlantic Regions, and nationally. As 

discussed in detail in Chapter 1, oxides of nitrogen (NOx) and sulfur dioxide (SO2), in addition to 

direct fine particulate matter (PM2.5), are the precursors of concern for PM2.5 SIP-related activity. 

This chapter focuses on those measures designed to decrease one or more of these pollutants 

specifically. This section explains the terminology related to control measures used throughout 

Chapter 5 (the PM2.5 attainment demonstration chapter); provides a summary of how the control 

measures were identified; and gives a brief synopsis of each control measure considered in 

Chapter 5. A summary of the identified control measures is shown in Table 4.5. The benefits 

from the implementation of these measures, and the benefit calculations, are discussed in the 

State’s attainment demonstration in Chapter 5, contingency plan in Chapter 6, and appendix to 

Chapter 6. Note that this chapter only provides a discussion of control measures not included in 

the baseline (2002) emission inventory. Existing controls, such as the New Jersey inspection and 

maintenance (I/M) program for gasoline vehicles prior to the initiation of mandatory on-board 

diagnostic inspections and pre-2002 reasonably available control technology (RACT) rules are 

not included in this chapter. Those controls are included in the 2002 baseline inventory. In 

addition to addressing PM2.5 emissions, the measures discussed in this chapter are also expected 

to have an impact on controlling regional haze, the primary constituent of which is PM2.5.

4.1 Terminology

On The Books (OTB) – “On the Books (OTB)” control measures (State or Federal) are control 

measures that were a) adopted before 2002, but have implementation dates after 2002, or obtain 

additional benefits after 2002, due to turnover of products, equipment, or vehicles (the benefits 

from these measures are not included in the State’s 2002 base year emissions inventory); or b) 

adopted and implemented after 2002. An example of an OTB measure for New Jersey is the 

NOx Budget Program, which went into effect May 1, 1999; a lower NOx emission cap was 

required effective May 1, 2003.

Beyond On The Way (BOTW) – These control measures (state, regional, or Federal) are 

proposed by New Jersey as part of the effort to reach attainment by April 5, 2010.128

4.2 On the Books Controls

The following section provides descriptions of the New Jersey and Federal OTB measures that 

are included in the State’s attainment demonstration.

 128 According to USEPA guidance, areas that have an attainment date of no later than April 5, 2010 must implement 

the emission reductions needed for attainment no later than 2009. Source: USEPA. Guidance on the Use of Models 

and Other Analyses in Attainment Demonstrations for the 8-hour Ozone NAAQS, United States Environmental 

Protection Agency, October 2005.
60

4.2.1 New Jersey

Pre-2002 with benefits achieved Post-2002 – On the books

New Jersey NOx Budget Program (SIP Call): On September 27, 1994, the Ozone Transport 

Commission (OTC) agreed to develop a regional program to achieve significant reductions in 

NOx emissions from large combustion sources. This program called for the establishment of a 

NOx cap and trade program, as well as the establishment of an emissions cap or “budget” for all 

affected sources that in total must not be exceeded during each control period, beginning in 

1999. The NOx SIP Call is a similar regional NOx reduction measure designed by the USEPA, in 

part, as a result of the Ozone Transport Assessment Group’s (OTAG) final recommendation 

report addressing ozone transport over the Eastern United States.129 New Jersey adopted its NOx

Budget Program130 in 1998. The base emission budget of 17,340 tons of NOx was established 

for the years 1999-2002. This was approximately 65 percent less than 1990 emission levels and 

was termed Phase II. In 2003, the NOx SIP Call replaced Phase III of the OTC’s program with a 

reduction of the base emission budget to 8,200 tons. The NOx SIP Call also expanded the 

geographical area beyond the Ozone Transport Region to the south and the west. The NOx SIP 

Call will continue through the ozone season of 2008, at which point it will be superseded by the 

Clean Air Interstate Rule (CAIR). The NOx Budget Program covers primarily electric generating 

units (EGUs) and some non-EGUs. The equipment covered by the NOx Budget Program include 

fossil fuel fired indirect heat exchangers with a maximum rated heat input capacity of at least 

250 million British thermal units (MMBtu) per hour and electric generating units with a rated 

output of at least 15 megawatts (MW). The USEPA approved the State’s NOx SIP Call program 

on May 22, 2001.131

Nonattainment New Source Review (NNSR): The Clean Air Act (CAA), 42 U.S.C. § 7503, 

requires new or modified major sources to install the Lowest Achievable Emission Rate (LAER) 

control equipment and obtain greater than one for one emission offsets in order to locate in a 

nonattainment area. Thus, the NNSR program provides for continual emission reductions to help 

improve the air quality in the nonattainment area and further downwind. In New Jersey, any 

significant new, reconstructed, or modified significant source is also required to install state of 

the art (SOTA) control technology (similar to Best Available Control Technology (BACT) or 

LAER for major sources). SOTA, which is a minor NSR program, also results in reductions in 

the actual emissions from the facilities. New Jersey’s SOTA requirements, denominated in the 

New Jersey Air Pollution Control Act as “advances in the art of air pollution control,” mandate 

BACT or LAER, as appropriate, if the equipment or control apparatus is subject to Prevention of 

Significant Deterioration (PSD) or Nonattainment New Source Review (NNSR) regulations.

132

 129 USEPA. 1998 Ozone Transport Assessment Group (OTAG) Final Report. United States Environmental 

Protection Agency, Ozone Transport Assessment Group. Accessed from: 

http://www.epa.gov/ttn/naaqs/ozone/rto/otag/finalrpt/. 130 N.J.A.C. 7:27-31 131 66 Fed. Reg. 28063-66 (May 22, 2001). 132 New Jersey’s Air Pollution Control Act (1954). 
61

Post 2002 – On the books

New Jersey Measures Done Through a Regional Effort

NOx RACT Rule (2006): The NJDEP adopted amendments to N.J.A.C. 7:27-19, Control and 

Prohibition of Air Pollution from NOx, on September 8, 2005. The amendments were based on 

the OTC’s March 6, 2001 model rules to control NOx emissions tied to shortfall measures. The 

OTC model rules were created as the result of the agreement formally set forth in a 

“Memorandum of Understanding Among the States of the Ozone Transport Commission 

Regarding the Development of Specific Control Measures to Support Attainment and 

Maintenance of the Ozone National Ambient Air Quality Standards" (MOU), which was 

approved by the OTC on June 1, 2000. Specifically, the New Jersey amendments apply to 

owners and operators of certain stationary sources of NOx emissions, including 

industrial/commercial/institutional (ICI) boilers, combustion turbines, and reciprocating engines. 

Owners and operators of such sources are required to achieve the emission limit specified in the 

rules or to comply instead with alternative requirements, such as an emission averaging plan, an 

alternative maximum allowable emission rate or a plan for phased compliance (repowering or 

use of innovative technology). The amendments also regulate distributed generation133 of 

electricity, consistent with the OTC recommendation in its March 28, 2001 “Resolution of the 

States of the Ozone Transport Commission Concerning the Creation of incentives for Additional 

Distributed Generation of Electric Power.” The USEPA issued final approval of the New Jersey 

SIP revision, including these rule amendments on July 31, 2007.134 The rules became effective 

August 30, 2007.

New Jersey Only Measures

New Jersey Heavy Duty Diesel Rules, Including “Not-To-Exceed” (NTE) Requirements: The 

NJDEP adopted new rules and amendments on October 28, 2001 to N.J.A.C. 7:27-26 that added 

requirements for new heavy-duty diesel vehicles (HDDVs) equipped with model year 2005 and 

newer heavy-duty diesel engines (HDDEs) sold in New Jersey. Specifically, the rulemaking 

required these new HDDEs to be certified as meeting California’s HDDE requirements. These 

requirements include both the federal emission standards applicable to all model year 2004 and 

newer HDDEs, plus a number of testing procedures which the USEPA required for model year 

2007 and newer HDDEs. The NTE test procedure is so called because it is used to demonstrate 

that an engine does not exceed, under a wide variety of operating conditions, an emissions cap of 

1.25 times the Federal Test Procedure emission standard. For this reason, the California 

requirements are often referred to as the NTE requirements. California promulgated these NTE

requirements to address a temporal gap of two years between the end of the requirements set 

forth in the consent decrees entered into by seven major HDDE manufacturers and the effective 

date of equivalent federal testing requirements. It was anticipated that the adoption of the NTE 

 133 Distributed generation is a system composed of generation located near the energy consumer’s site that may be 

integrated with the electric grid to provide multiple benefits on both sides of the utility meter. Source: CECA. 

Distributed Generation Facts, Consumer Energy Council of America, 

http://www.cecarf.org/Programs/DG/DGFacts.html.

134 72 Fed. Reg. 41626-41629 (July 31, 2007).
62

requirements by states regulating the majority of HDDEs sold in the United States would 

encourage and provide incentive for engine manufacturers to produce only engines meeting the 

NTE requirements.

On October 25, 2005, the NJDEP adopted new rules, rule amendments, recodifications and 

repeals of rule provisions to clarify and supplement the existing requirements for the sale, for use 

or registration in New Jersey, of certain HDDVs and HDDEs, model years 2007 and later. The 

rulemaking did not impose any new standards for model year 2007 and later HDDEs per se; 

rather, it served to clarify the finer points of the application of CARB-certification requirements 

to model year 2007 and beyond, since CARB’s standards for those model years are significantly 

different from the NTE requirements and standards for model years 2005 and 2006, and were not 

discussed in the NJDEP’s 2001 rulemaking. In addition, a prohibition of the practice known as 

“stockpiling” was added. Stockpiling is the practice of purchasing vehicles and/or engines 

earlier than necessary in order to avoid more stringent emission standards. Finally, the NJDEP 

added provisions that would, in the event that the provisions of the Federal 2007 rule are not in 

effect, require recordkeeping and reporting of the sale, for use in New Jersey, of model year and 

later HDDEs. The Federal 2007 rule was promulgated by the USEPA on January 18, 2001 to 

take effect for model year 2007.

On-Board Diagnostics (I/M) Program for Gasoline Vehicles: A number of changes to New 

Jersey’s I/M program for gasoline vehicles were implemented after 2002. The two program 

changes that materially impacted vehicle emissions were the extension for the new vehicle 

emission inspection from one inspection cycle (i.e., 2 years) to two inspection cycles (i.e., 4 

years) and the initiation of mandatory on-board diagnostic (OBD) inspections for model year 

1996 and newer vehicles. The OBD test largely replaced the dynamometer based Acceleration 

Simulation Mode (ASM5015) exhaust test for these newer vehicles. New Jersey submitted a SIP 

revision that contained the results of performance standard modeling for these I/M program 

changes on November 27, 2002.135 The USEPA subsequently approved this SIP revision.136

4.2.2 Federal

Pre-2002 with benefits achieved Post 2002 – On the books

Residential Woodstove New Source Performance Standards (NSPS): The USEPA New Source 

Performance emission standards for new wood burning stoves137 and fireplace inserts were 

implemented in 1992. These standards are 7.5 grams of particulate matter per hour for noncatalytic controlled units and 4.1 grams of particulate matter per hour for catalytic controlled 

 135 NJDEP. Enhanced Inspection and Maintenance (I/M) Program for the State of New Jersey Revised Performance 

Standard Modeling SIP Revision. New Jersey Department of Environmental Protection. November 27, 2002. 

Available at http://www.state.nj.us/dep/baqp/sip/4year/4yrexempt_fin.doc. 136 68 Fed. Reg. 7704-06 (February 18, 2003). 137 A wood burning stove is defined as a free standing enclosed wood-burning unit, vented to the atmosphere, and 

designed to provide heat to a home. In contrast, a fireplace insert is defined as a self-enclosed unit that sits within a 

masonry structure, vented to the atmosphere, that is not designed as a primary heating source for a home. The 

USEPA emission standards do not cover masonry-constructed fireplaces without fireplace inserts, but these unique 

fireplaces are thought to account for a very small segment of the wood burning conducted in the New Jersey.
63

units. There are no control requirements for fireplace inserts or wood stove units manufactured 

prior to 1992, and these units emit from 30 to 70 grams of particulate matter per hour. The 

USEPA indicates that they do not have any plans to update the NSPS anytime soon. Instead, the 

USEPA is choosing to focus on voluntary wood stove change-out programs, rather than new 

standards.

Acid Rain: Title IV of the Clean Air Act set a goal of reducing annual SO2 emissions by 10 

million tons below 1980 levels. To achieve these reductions, the law required a two-phase 

tightening of the restrictions placed on fossil fuel-fired power plants. Phase I began in 1995, and 

affected 263 units at 110 mostly coal-burning electric utility plants located in 21 eastern and 

mid-western states. An additional 182 units joined Phase I of the program as substitution or 

compensating units, bringing the total of Phase I affected units to 445. Phase II, which began in 

the year 2000, tightened the annual emissions limits imposed on these large, higher emitting 

plants and also set restrictions on smaller, cleaner plants fired by coal, oil, and gas, 

encompassing over 2,000 units in all. The program affects existing utility units serving 

generators with an output capacity of greater than 25 megawatts and all new utility units.

The Clean Air Act also called for a two million ton reduction in NOx emissions by the year 2000. 

This has been superseded with the more stringent NOx caps in CAIR, discussed below.

The Acid Rain Program utilizes an allowance trading system where affected utility units are 

allocated allowances based on their historic fuel consumption and a specific emissions rate. 

Each allowance permits a unit to emit one ton of SO2 during or after a specified year. For each 

ton of SO2 emitted in a given year, one allowance is retired, that is, it can no longer be used. 

Allowances may be bought, sold, or banked. Anyone may acquire allowances and participate in 

the trading system. However, regardless of the number of allowances a source holds, it may not 

emit at levels that would violate Federal or state limits set under Title I of the Clean Air Act to 

protect public health including limits set by SIPs, such as this SIP. During Phase II of the 

program (now in effect), the Clean Air Act set a ceiling (or cap) of 8.95 million SO2 allowances 

for total annual allowance allocations to utilities. 

Tier 1 Vehicle Program: Pursuant to 42 U.S.C. §7521, the USEPA promulgated regulations 

which revised the tailpipe standards of the Federal Motor Vehicle Control Program (FMVCP) for 

light duty vehicles and light duty trucks.138 These standards, known as Tier 1, were implemented 

in phases beginning with the 1994 model year. The Tier 1 standards encompassed pollutants 

previously regulated (that is, carbon monoxide, nitrogen oxides, and particulate matter), as well 

as the addition of non-methane hydrocarbons (NMHC). The standards themselves are a function 

of vehicle class, pollutant, useful life, engine cycle, and fuel. The Tier 1 rulemaking also 

established new intermediate and full useful life139 levels for air pollution control devices on 

light-duty vehicles and light-duty trucks, as well as new vehicle weight classes. The regulation 

affected petroleum and methanol-fueled motor vehicles. 

 138 56 Fed. Reg. 25724 (June 5, 1991).

139 Useful life is the number of years that the vehicle is expected to be in use.
64

National Low Emission Vehicle Program (NLEV): The NLEV140 program required automobile 

manufacturers to meet more stringent new car standards, starting with the 1999 model year in the 

OTC states and starting with the 2001 model year in the remainder of the nation, except for 

California. New Jersey participated in the NLEV program for the model year 2006, after which 

New Jersey came under the Federal Tier 2 program. New Jersey subsequently adopted the Low 

Emission Vehicle II (LEV II) program, which becomes effective for vehicles delivered for sale 

in New Jersey on and after January 1, 2009. 

Tier 2 Vehicle Program/Low Sulfur Fuels: On February 10, 2000, the USEPA promulgated rules 

for its comprehensive Tier 2/Low Sulfur Gasoline program.141 These regulations are designed to 

treat a vehicle and its fuel as a system, resulting in multiple efforts to reduce highway source 

emissions. In addition to requiring new tailpipe emissions standards for all passenger vehicles, 

sport utility vehicles (SUVs), minivans, vans and pick-up trucks, the USEPA simultaneously 

promulgated regulations to lower the sulfur standard in gasoline. These regulations phased in 

between 2004 and 2007.

Heavy Duty Diesel Vehicle (HDDV) Defeat Device Settlement: On October 22, 1998, the U.S. 

Department of Justice and the USEPA announced a settlement with seven major diesel engine 

manufacturers to resolve claims that they installed computer software on 1993 through 1998 

model year heavy-duty diesel engines which was designed to disengage the engine’s emission 

control system during highway driving.142 The settlement, involving Caterpillar, Inc., Cummins 

Engine Company, Detroit Diesel Corporation, Mack Trucks, Inc., Navistar International 

Transportation Corporation, Renault Vehicles Industries, S.A., and Volvo Truck Corporation, 

included an $83.4 million total penalty. The settlement also required the manufacturers to offer 

software updates (chip reflash) at no cost to the truck owners at the time of engine rebuild. 

Heavy Duty Diesel Vehicle (HDDV) Engine Standards:

143 On July 31, 2000, the USEPA issued 

a final rule for the first phase of its two-part strategy to significantly reduce harmful diesel 

emissions from heavy-duty trucks and buses. This rule finalized new diesel engine standards 

beginning in 2004, for all diesel vehicles over 8,500 pounds. Additional diesel standards and test 

procedures in this final rule began in 2007. This new rule required heavy-duty gasoline engines 

to meet new, more stringent standards starting no later than the 2005 model year. According to 

the USEPA, these new standards require gasoline trucks to emit 78 percent less NOx and 

hydrocarbons, and diesel trucks to emit 40 percent less NOx and hydrocarbons, than current 

models. The second phase of the program required cleaner diesel fuels and cleaner engines, 

reducing air pollution from trucks and buses by another 90 percent. The USEPA issued the final 

rule, to take effect in 2006-2007 on January 18, 2001.144 

 140 For more information on NLEV, see USEPA website at http://www.epa.gov/otaq/lev-nlev.htm. 141 65 Fed. Reg. 6698-746 (February 10, 2000). 142 For more information, see USEPA’s web page on Heavy Duty Diesel Engine Consent Decree Documents at

www.epa.gov/Compliance/resources/cases/civil/caa/diesel/condec.html. 143 For more information, see the USEPA’s Office of Transportation and Air Quality web site at

http://www.epa.gov/otaq/hd-hwy.htm. 144 66 Fed. Reg. 5002-50 (January 18, 2001).
65

Nonroad Diesel Engines: In June 1994, the USEPA promulgated regulations to control volatile 

organic compounds (VOCs), NOx and carbon monoxide (CO) emissions from diesel-powered 

compression ignition engines at or greater than 50 horsepower (hp), i.e., bulldozers.145 These 

Tier 1 standards phased in from 1996 to 2000. In October 1998, the United States 

Environmental Protection Agency (USEPA) promulgated regulations to control VOC, NOx and 

carbon monoxide emissions from diesel-powered compression ignition engines for all engine 

sizes.146 This rule includes Tier 1 standards for engines under 50 horsepower (hp) (i.e., lawn 

tractors), Tier 2 standards for all engine sizes, and more stringent Tier 3 standards for engines 

rated over 50 hp. The new Tier 3 standards are expected to lead to control technologies similar 

to those that will be used by manufacturers of highway heavy-duty engines to comply with the 

2004 highway engines standards.147 The new Tier 1 standards were phased in between the years 

1999 and 2000, Tier 2 standards between 2001 and 2006, and Tier 3 between 2006 and 2008. 

Large Industrial Spark-Ignition Engines over 19 kilowatts: Spark-ignition nonroad engines are 

mostly powered by liquefied petroleum gas, with others operating on gasoline or compressed 

natural gas. These engines are used in commercial and industrial applications, including 

forklifts, electric generators, airport baggage transport vehicles, and a variety of farm and 

construction applications. 

In September 2002, the USEPA adopted new standards to regulate these engines.148 The 

emission standards are two-tiered. The Tier 1 standards, which started in 2004, are based on a 

simple laboratory measurement using steady-state procedures. The Tier 2 standards, starting in 

2007, are based on transient testing in the laboratory, which ensures that the engines will control 

emissions when they operate under changing speeds and loads in the different kinds of 

equipment. 

Also included is an option for manufacturers to certify their engines to different emission levels 

to reflect the fact that decreasing NOx emissions tend to increase carbon monoxide emissions 

(and vice versa). In addition to these exhaust-emission controls, manufacturers must take steps 

starting in 2007 to reduce evaporative emissions, such as using pressurized fuel tanks. Tier 2 

engines are also required to have engine diagnostic capabilities that alert the operator to 

malfunctions in the engine’s emission-control system. The rule also includes special standards to 

allow for measuring emissions without removing engines from equipment.

Recreational Vehicles: Recreational vehicles include snowmobiles, off-highway motorcycles, 

and all-terrain-vehicles (ATVs). In September 2002, the USEPA adopted new standards to 

regulate nonroad recreational engines and vehicles.149 The standards that affect PM2.5 emissions 

are presented in Table 4.1. As shown by this table, only the new standards for off-highway 

motorcycles and ATVs will reduce NOx, a PM2.5 precursor.

 145 59 Fed. Reg. 31306 (June 17, 1994). 146 63 Fed. Reg. 56968-7023 (October 23, 1998). 147 USEPA. Regulatory Announcement: New Emission Standards for Nonroad Diesel Engines. United States 

Environmental Protection Agency Office of Mobile Sources, EPA420-F-98-034, August 1998. 148 67 Fed. Reg. 68242-447 (November 8, 2002).

149 67 Fed. Reg. 68242-447 (November 8, 2002).
66

Table 4.1: Summary of Emission Standards for Recreational Vehicles

Vehicle Model year Emission standards Phase-in

HC*+NOx

g/km

CO

g/km

Off-highway 

Motorcycle

2006 2.0 25.0 50%

2007 and later 2.0 25.0 100%

ATV 2006 1.5 35.0 50%

2007 and later 1.5 35.0 100%

*HC = Hydrocarbon

Federal Compression Ignition Marine Engine Regulations (Commercial Marine Engines):

150,151

In 1999, the USEPA promulgated regulations for commercial marine diesel engines over 37 

kilowatts (kW), including engines with per cylinder displacement up to 30 liters.152 This rule 

established VOC and NOx emission standards, starting in 2004, for new engines with per 

cylinder displacement up to 2.5 liters. This rule also established standards in 2007 for engines 

with per cylinder displacement between 2.5 and 30 liters.153 The engines covered by this rule are 

divided into two categories: Category 1: rated power at or above 37 kW - specific displacement 

of less than 5 liters per cylinder. These engines are primarily found in fast ferries. Category 2: 

rated power at or above 37 kW - specific displacement greater than or equal to 5, but less than 

30, liters per cylinder. These engines are primarily found in tug and towboats.

Federal Small Spark Ignition Engine Regulations: In July 1995, the USEPA promulgated the first 

phase of its regulations to control emissions from new nonroad spark ignition engines.154 This 

regulation established VOC and carbon monoxide emission standards for all model year 1997155

and newer nonroad spark ignition engines that have a gross power output at or below 19 

kilowatts. These engines are used principally in lawn and garden equipment, including, but not 

limited to, lawn mowers, leaf blowers, trimmers, chainsaws, and generators. In March 1999, the 

USEPA promulgated Phase 2 regulations to control emissions from new nonroad spark ignition 

engines.156 These regulations established tighter VOC and NOx standards for non-handheld 

equipment such as lawn mowers and commercial turf equipment. The new standards were 

phased in between the years 2001 and 2007. In March 2000, the USEPA promulgated additional 

Phase 2 regulations to control emissions from new nonroad spark ignition engines.157 This 

regulation established tighter VOC, NOx, and carbon monoxide standards for handheld 

 150 For more information, see the USEPA’s regulatory announcement on Emission Standards for New Commercial 

Marine Diesel Engines at http://www.epa.gov/otaq/regs/nonroad/marine/ci/fr/f99043.pdf. 151 The USEPA has not finalized Tier 2 standards for Category 3 commercial marine engines. The USEPA will 

promulgate final Tier 2 standards for Category 3 engines on or before December 17, 2009. (“Category 3” means 

relating to a marine engine with a specific engine displacement greater than or equal to 30 liters per cylinder). 

Source: 40 C.F.R. §§ 94.1, 94.8; 72 Fed. Reg. 20948-52 (April 27, 2007). 152 64 Fed. Reg. 73300-73 (December 29, 1999). 153 USEPA. Technical Highlights: Organization of Gasoline and Diesel Marine Engine Emission Standards. United 

States Environmental Protection Agency Office of Mobile Sources, EPA420-F-99-046. December 1999. 154 60 Fed. Reg. 34582-657 (July 3, 1995). 155 Ibid; Model year 1997 is defined as “The 1997 model year will run from January 2, 1996 to December 31, 1997.” 156 64 Fed. Reg. 15208-55 (March 30, 1999). 157 65 Fed. Reg. 24268-314 (April 25, 2000).
67

equipment such as string trimmers (i.e., weed whackers), leaf blowers and chainsaws. The new 

standards were phased in between the years 2002 to 2007. 

Post 2002 – Federal On the Books

Industrial Boiler/Process Heater MACT: On September 13, 2004, the USEPA established a

Maximum Achievable Control Technology (MACT) that applies to industrial, commercial, and 

institutional units firing solid fuel (coal, wood, waste, biomass) which have a design capacity 

greater than 10 MMBtu/hr and are located at a major source of hazardous air pollutants 

(HAPs).158 See the discussion on HAPs under USEPA MACT Standards. This rule was 

subsequently vacated by the courts, triggering the Section 112(j) provisions of the Clean Air Act. 

NJDEP is participating in the National Association of Clean Air Agencies’ (NACAA) efforts to 

develop MACT guidance for use by states and expects to do case-by-case MACT in 2009.

Clean Air Interstate Rule (CAIR): The CAIR was the USEPA’s attempt to address the interstate 

transport of ozone and fine particulate precursors by requiring emission reductions of SO2 and 

NOx. The U.S. Court of Appeals for the D.C. Circuit ruled (see Chapter 8) that the CAIR does 

not meet these objectives within and the requirements of the Federal Clean Air Act and 

remanded it to the USEPA. While the USEPA is working on a replacement program, the 

existing CAIR program remains in place.

The CAIR expects to obtain these reductions from large electric generating units (EGUs greater 

than 25 MW) through three cap-and-trade programs: ozone season NOx, annual NOx and annual 

SO2. The CAIR ozone season NOx cap and trade program essentially replaces the NOx Budget 

Program with lower caps and an expanded geographical region to the south and west of the NOx

SIP Call region. The CAIR also creates new annual NOx and SO2 cap and trade programs. The 

annual NOx trading program is modeled after the NOx Budget Program, expanded for the entire 

year. New Jersey adopted the new rules for the CAIR NOx Trading Program on July 16, 2007, 

and the USEPA approved these rules on October 1, 2007.159 The new CAIR rules will allow 

New Jersey to allocate NOx allowances to New Jersey sources beginning 2009.

New Jersey did not take any action on the SO2 trading program. There is no allocation of SO2

allowances for CAIR, but instead, CAIR uses the SO2 allowances allocated under the Acid Rain 

Program. CAIR reduces the SO2 emissions from the Acid Rain Phase II level by applying 

increased retirement ratios to the Acid Rain SO2 allowances. Under the CAIR, pre-2010 vintage 

SO2 allowances are worth 1.0 ton of SO2 emission; 2010-2014 vintage SO2 allowances are worth 

0.5 ton of SO2 emissions; and post-2014 vintage SO2 allowances are worth 0.35 ton of SO2

emissions. This effectively reduces SO2 emissions further below the Title IV level without 

creating a new currency. 

Refinery Enforcement Initiative, Consent Decrees (Sunoco, Valero and ConocoPhillips): The 

USEPA and various state and local agencies have negotiated Consent Decrees with the major 

refineries to elicit emission reductions from five major refinery processes. The processes are 

 158 69 Fed. Reg. 55218-86 (September 13, 2004).

159 72 Fed. Reg. 55666-72 (October 1, 2007).
68

Fluid Catalytic Cracking Units (FCCUs) and Fluid Coking Units (FCUs), Process Heaters and 

Boilers, Flare Gas Recovery, Leak Detection and Repair (LDAR), and Benzene/Wastewater. 

The New Jersey refineries with settlements as of March 2008 include Sunoco, Valero and 

ConocoPhillips.

For FCCUs/FCUs, the Consent Decree control requirements generally require the installation of 

wet gas scrubbers for SO2 control, and selective catalytic reduction (SCR), selective noncatalytic reduction (SNCR), or other measures to reduce NOx emissions.

For process boilers/heaters, the control requirements for SO2 emissions generally require the 

elimination of burning solids/liquid fuels. For NOx emissions, the control requirements generally 

apply to units greater than 40 MMBtu per hour capacity or larger. In many cases, the Consent 

Decrees establish NOx emission reduction objectives across a number of refineries that are 

owned by the same firm. Therefore, the companies decide which individual boilers/heaters to 

control as well as the control techniques to apply.

The Consent Decrees also included enhanced leak detection and repair programs (e.g., reducing 

the defined leak concentration) and other VOC requirements. The settlements are expected to 

produce additional SO2, NOx, and VOC emissions reductions for flare gas recovery and 

wastewater operations. While the Consent Decrees have various phase-in dates, significant 

emission reductions are expected prior to the summer of 2009. 

4.3 Beyond On The Way Controls

The following sections discuss how beyond on the way (BOTW) measures (both regional 

initiatives and state only) were identified and provides descriptions of the BOTW measures 

included in the State’s attainment demonstration. 

4.3.1 Identifying Measures 

New Jersey participated in a wide variety of processes aimed at identifying viable control 

measures that could be implemented to help the State reach its PM2.5 attainment goals. The 

following section briefly discusses those processes, and the measures identified as viable through 

those processes that the State is moving forward to propose.

4.3.1.1 Regional Activities

New Jersey is an active member of four regional organizations, each with a unique focus with 

respect to either geographic area, air pollution concern or both. These organizations include:

The Ozone Transport Commission (OTC), a multi-state organization created under the Clean Air 

Act to advise the USEPA on ozone transport issues and develop and implement regional 

solutions to the ground-level ozone problem in the Northeast and Mid-Atlantic regions. 

Mid-Atlantic Regional Air Management Association (MARAMA), a non-profit association of 

ten state and local air pollution control agencies whose mission is to strengthen the skills and 
69

capabilities of member agencies and to help them work together to prevent and reduce air 

pollution in the Mid-Atlantic Region. 

Northeast States for Coordinated Air Use Management (NESCAUM), a nonprofit association of 

air quality agencies in the Northeast designed to provide scientific, technical, analytical, and 

policy support to the air quality programs of the eight Northeast states. 

The Mid-Atlantic/Northeast Visibility Union (MANE-VU), which was formed by the MidAtlantic and Northeastern states, tribes, and Federal agencies to coordinate regional haze 

planning activities for the region.

All of these organizations had an active role in the technical support work associated with this 

SIP revision. MANE-VU supported the regional inventory work that was utilized in the regional 

attainment modeling effort (see Chapter 5) and was responsible for coordinating the Regional 

Haze effort, which resulted in control measures that will yield PM2.5 reduction benefits (see 

Section 4.3.1.4). The efforts of the OTC and MARAMA identified control measures that would 

result in reductions of ozone, PM2.5, and regional haze. The ozone control measures identified by 

these processes are expected to result in PM2.5 and regional haze benefits due to either shared 

precursors (NOx) or tangent reduction benefits (controls would also result in direct PM2.5 and/or 

SO2 emission reductions). NESCAUM focused on control measures more closely linked with 

PM2.5 and regional haze reductions (mainly low sulfur fuel for industrial, commercial and 

residential facilities). The efforts of these regional organizations are summarized in the 

following sections.

4.3.1.2 Ozone Transport Commission (OTC)

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

control measures for potentially significant emission reductions. To accomplish this, the OTC 

staff and member jurisdictions formed workgroups to: 1) review mobile, point, and area source 

categories, 2) identify candidate source categories, and 3) consider potential control strategies for 

those source categories to reduce NOx, VOC, and SO2 emissions.

Each OTC workgroup focused on a different sector (mobile/point/area) and compiled a list of 

viable control measures from sources published by the USEPA and various regional associations, 

OTC member state-specific control strategies already in place, and emission control initiatives 

from states outside the Ozone Transport Region, such as California. Then using 2002 emission 

inventories as the base year, the workgroups determined projected 2009 emission reductions 

based on currently existing controls, including Federal rules, adoption of previous OTC model 

rules by member jurisdictions, enforcement settlements, and other state-specific control 

measures, and estimated growth of inventories. Based on the review of the list of control 

measures and the emission inventories, the workgroups developed a preliminary list160 of 

candidate control measures thought to be most effective in reducing emission levels throughout 

the Ozone Transport Region.

 160 To review the preliminary list of OTC-identified control measures that were further evaluated for potential 

emission reductions, see the OTC web site at http://www.otcair.org/document.asp?fview=Report.
70

From this preliminary list, the OTC workgroups developed white papers, summarizing key facts 

about the relevant control alternatives. The white papers provided information, such as 

descriptions of source categories and candidate control measures, 2002 base year emissions, 

2009 projected emissions after implementation, preliminary cost estimates, current federal and 

state regulations, methods of implementation, applicability, and geographic impact. Some of the 

papers reflected inter-regional efforts, such as those by the MARAMA for refineries, by the 

NESCAUM for heating oil, and by the super-regional discussions with the Midwest Regional 

Planning Organization (MWRPO) regarding Industrial, Commercial and Institutional (ICI) 

boilers and Electric Generating Units (EGUs). Using a scale of recommendations from one 

(definitely recommended) to five (not recommended), the member jurisdictions ranked the 

relative importance of the source categories and control strategies based on a qualitative 

assessment of the information presented in the white papers. After consideration of the 

estimated costs and magnitude of reductions potentially achievable for the selected emission 

sources, the OTC member jurisdictions identified reasonable control measures for a variety of 

source categories. Both during and after the ranking process, the OTC received written 

comments from stakeholders, held public meetings, and interfaced with impacted industries to 

better understand the source categories and how to regulate them effectively. The final list of 

source categories recommended by OTC for member jurisdictions to consider for emission 

reductions are presented in Table 4.2.

The OTC efforts focused on VOC and NOx reductions for the purpose of reducing ozone. New 

Jersey evaluated the control measures identified by the OTC for NOx measures that would have a 

PM2.5 reduction benefit. Although the OTC efforts did not have a primary focus on control 

strategies for direct PM2.5, New Jersey evaluated related direct PM2.5 reduction strategies through 

its Reasonably Available Control Technology (RACT) and Reasonably Available Control 

Measures (RACM) analyses discussed in Sections 4.3.1.5.3 and 4.3.1.5.4, respectively. 

Table 4.2: Final OTC Control Measure Source Categories161, 162

Sector Source Category

Area Adhesives, Sealants, Adhesive Primers, and Sealant Primers (Industrial)

Area Cutback and Emulsified Asphalt Paving

Area Consumer Products

Area Portable Fuel Containers

Point Asphalt Production Plants

Point ICI Boilers 100 MMBtu/hour or greater

Area and Point ICI Boilers <100 MMBtu/hour

 161 Measures that are shaded are expected to have a NOx emission reduction benefit in New Jersey. 162 The following programs that are listed in Table 4.3 are not discussed in New Jersey’s proposed SIP document: 1) 

Regional Fuel based on Reformulated Gasoline Options is not discussed because there is already a mandatory 

program required by Section 211(k) of the Clean Air Act in New Jersey. 2) Cement Plants are not discussed 

because there are no cement plants in New Jersey. 3) Diesel Chip Reflash is not discussed because the OTC states, 

including New Jersey, are considering possible actions to increase the number of chip reflash installations of 

HDDVs in the Northeast.
71

Point Glass Furnaces

Point Cement Plants

Onroad Mobile Diesel Truck Chip Reflash

Onroad Mobile Regional Fuel based on Reformulated Gasoline Options

The shaded categories in Table 4.2 are the OTC measures that have a PM2.5 precursor reduction 

benefit. NESCAUM developed a model rule for diesel chip reflash for state use, which was 

included in the OTC’s final Technical Support Document. New Jersey is still evaluating this 

program and seeks comments on how to best achieve the Federal emission limits. For three of 

the OTC measures (adhesives and sealant, consumer products and portable fuel containers), the 

OTC drafted model rules which NJDEP is using to achieve VOC emission benefits. For the 

remaining measures shown in Table 4.2, the OTC developed emission limits and rule 

specification guidance. The OTC member states signed a Memorandum of Understanding 

(MOU) (Appendix A1) that addresses emissions associated with high electrical demand days 

(HEDD) to compliment already existing and future cap-and-trade programs with respect to 

electrical generation. This regional HEDD program will address the peak load emissions from 

the electrical generation sector on a daily basis. 

New Jersey and other OTC member jurisdictions have resolved to pursue necessary and 

appropriate rulemakings to implement the emission reduction percentages, emission rates, or 

technologies for the categories listed in Table 4.2 that are consistent with guidelines found in 

OTC Resolution 06-02 adopted on June 7, 2006, and amended on November 15, 2006, found in 

Appendix A2, as well as the High Electrical Demand Days MOU found in Appendix A1. The 

NJDEP expects to implement most measures that are not already adopted starting May 1, 2009 or 

later. A brief summary of all the OTC-identified control measures that have a PM2.5 emission 

reduction benefit is included in the following subsection. For more information about the OTC 

control measure identification process, or the control measures identified for implementation 

through this process, please see Appendix A3.

OTC Identified Beyond on the Way (BOTW) Measures:

Asphalt Production: The NJDEP proposed amendments to its rules at N.J.A.C. 7:27-19.9 in order 

to lower NOx emissions from asphalt production facilities. The proposed amendments, based on 

an OTC model rule, would pursue control measures to achieve at least a 35 percent reduction of 

NOx emissions from asphalt production plants from current levels, with the inclusion of emission 

limits based on type of fuel combusted and implementation of Best Management Practices 

(BMP) requirements. The OTC guidance is based on emission rates and percent reductions 

typically achieved from the installation of low NOx burners (LNB) and flue gas recirculation 

(FGR) to reduce NOx emissions from asphalt plants. A low NOx burner reduces NOx by staged 

combustion. In flue gas recirculation, the flue gas is used to assist in cooling the combustion 

temperature, which in turn reduces the NOx generated. The implementation of Best Management 

Practices would allow for substantial reductions in fuel consumption and corresponding 

reductions in the products of combustion, including NOx. Best Management Practices include 

annual combustor tune-ups, effective stockpile management to reduce aggregate moisture 

content, lowering mix temperature, and other maintenance and operational best practices. For 

more details on this future rulemaking, see Appendix A3. 
72

Glass Manufacturing: New Jersey proposed amendments to its current glass manufacturing rules 

at N.J.A.C. 7:27-19.10. The proposed amendments, based on OTC guidance, would revise the 

NOx emission rates to reduce emissions consistent with the installation of oxy-fuel firing, or 

equivalent measures, at the time of the next furnace re-build. Although several alternative NOx

control technologies exist, including combustion modifications (low NOx burners, oxy-fuel 

firing, oxygen-enriched air staging), process modifications (fuel switching, batch preheat, 

electric boost), and post combustion modifications (fuel reburn, SNCR, SCR), oxyfiring is 

considered the most effective because it not only reduces NOx emissions by as much as 85 

percent, but also reduces energy consumption, increases production rates by 10-15 percent, and 

improves glass quality by reducing defects. In addition, oxyfiring is demonstrated technology 

for the glass industry. Of New Jersey’s 25 glass manufacturing furnaces, five are already 

equipped with oxy-fuel firing and nine are electric. For more details on this future rulemaking, 

see Appendix A3.

Industrial/Commercial/Institutional (ICI) Boiler Rule 2009:

163 ICI boilers combust fuel to 

produce heat and process steam for a variety of applications, including chemical, metals, paper, 

petroleum, and food production industries, and for space heating in office buildings, hotels, 

apartment buildings, hospitals, and universities. Industrial boilers are generally smaller than 

boilers in the electric power industry, and typically have heat inputs in the 10-250 MMBtu/hr 

range; however, industrial boilers can be as large as 1,000 MMBtu/hr or smaller than 1 

MMBtu/hr. Most commercial and institutional boilers have a heat input less than 100 

MMBtu/hr. In New Jersey, 70 percent of the population is smaller than 50 MMBtu/hr. 

Currently, New Jersey ICI boilers are regulated according to size, fuel and boiler type. New 

Jersey’s existing NOx limits generally apply only to ICI boilers at least 50 MMBtu/hr located at 

major sources (i.e., point sources). ICI boilers at minor sources (i.e., area sources) are not 

subject to the maximum allowable emission rates, but are required to adjust the combustion 

process annually in boilers as small as 5 MMBtu/hr, effective as of 2010.

New Jersey proposed amendments to its current ICI boiler rules at N.J.A.C. 7:27-19.7. The 

proposed amendments would revise the NOx emission limits for both point and area source ICI 

boilers. Under the proposed amendments, owners and operators of any ICI boilers as small as 25 

MMBtu/hr would be required to achieve emission limits specified in the rules. For more details 

on this future rulemaking, see Appendix A3.

4.3.1.3 Mid-Atlantic Regional Air Management Association (MARAMA)

The MARAMA states concentrated their efforts on identifying and analyzing emissions from all 

petroleum refinery processes to help states with refineries develop their SIPs for ozone, fine 

particles, and regional haze. The MARAMA Refinery Technical Oversight Committee (TOC), 

assisted by MACTEC Federal Programs, Inc., evaluated emissions and existing requirements for 

certain sources found at fourteen (14) petroleum refineries in the MARAMA area. Based on that 

preliminary review, the TOC selected catalytic and thermal cracking units, boilers and process 

 163 Some categories have 2009 compliance dates; remainder have 2012 compliance dates.
73

heaters, flares, equipment leaks, wastewater treatment, storage tanks, and sulfur recovery plants 

for further consideration.

MARAMA evaluated emissions, existing requirements, including recent Consent Decrees from 

10 of the 14 identified refineries, available control technology options, and typical installation 

costs for each category. As a result of this study, MARAMA, assisted by MACTEC Federal 

Programs, Inc., developed three Model Rules for fluid catalytic cracking units, flares and 

enhanced monitoring of equipment leaks at petroleum refineries. As part of its 8-hour ozone 

RACT committal SIP, the State of New Jersey proposed new rules based in part on MARAMA’s 

model rules.164 New Jersey expects that the NOx, SO2, PM, and VOC reductions from these 

measures will also result in PM2.5 reduction benefits. 

A brief summary of all the MARAMA-identified control measures is included in the following 

subsections. For more information about the MARAMA control measure identification process, 

or the control measures identified for implementation through this process, please see Appendix 

A4.

MARAMA-Identified Beyond on the Way (BOTW) Measures:

Refineries - Fluid Catalytic Cracking Units (FCCUs): Catalytic cracking units convert middle 

distillate, gas oil and residuum into primarily gasoline, jet and diesel fuels by using a series of 

processing steps that literally “crack” large, heavy molecules into smaller, lighter ones. Heat and 

catalyst are used to convert the heavier oils to lighter products. With fluid catalytic cracking, a 

fluidized catalyst is used in the cracking process. Fluid catalytic cracking unit systems are the 

most widely used cracking process in the MARAMA region and are the largest air contaminant 

emission sources at the refinery. New Jersey has four gasoline-producing refineries with fluid 

catalytic cracking units. These refineries are major facilities with Title V Operating Permits, and 

all emit large quantities of criteria pollutants (SO2, NOx, VOCs, carbon monoxide, and coarse 

particulate matter (PM10)), as well as HAPs. New Jersey currently regulates NOx emissions from 

fluid catalytic cracking units at N.J.A.C. 7:27-19.13. 

MARAMA’s model rule for FCCUs, includes emissions limits for particulate matter, SO2, NOx, 

and carbon monoxide. The MARAMA Technical Oversight Committee chose to recommend the 

most stringent limits in recent Consent Decrees or rules in other jurisdictions. Feasible control 

technologies are summarized in Table 2-6 of their Final Report. 

Refineries – Flares: Petroleum refinery flares are intended to be last-resort control devices used 

to safely dispose of flammable waste gases from emergency process upsets, as well as during 

start-up, shutdown and turnaround operations. The combustion of these gases can emit large 

quantities of NOx, SO2, and carbon monoxide into the atmosphere and are believed to be 

underestimated. New Jersey currently regulates VOC emissions from refinery flares at N.J.A.C. 

7:27-16.13.

 164 The MARAMA model rules are posted at http://www.marama.org for public review.
74

MARAMA’s model rule for petroleum refinery flares includes the control measures designed to 

reduce NOx, SO2, VOC, and carbon monoxide emissions. Specifically, the model rule includes 

requirements for the owner/operators of refinery flares to operate and maintain a flare gas 

recovery system and to eliminate the flaring of routinely generated refinery fuel gases. Other 

items included in MARAMA’s flare model rule include operational requirements, monitoring 

system requirements, and guidelines for calculating flare emissions. Control technology options 

for flares are summarized in Table 4-5 of the Final Report. 

4.3.1.4 Mid-Atlantic/Northeast Visibility Union (MANE-VU)

The MANE-VU was tasked with identifying reasonable control measures that would reduce 

emissions from within the MANE-VU region contributing to visibility impairment at Class I 

areas by 2018 or earlier. To accomplish this task, beginning in 2005, the MANE-VU reviewed a 

wide range of potential control measures to reduce emissions from sources contributing to 

visibility impairment in affected Class I areas, including a “master list” of some 900 potential 

control measures, originally developed for 8-hour ozone initiative by the OTC. From this 

extensive list, the MANE-VU developed an interim list of Regional Haze control measures, 

which for regional haze included: beyond-CAIR sulfate reductions from EGUs, low-sulfur 

heating oil (residential and commercial), ICI boilers (both coal and oil-fired), lime and cement 

kilns, residential wood combustion, and outdoor burning (including outdoor wood boilers).

The next step in the regional haze control measure selection process was to further refine the 

interim list. The beyond-CAIR EGU strategy continued to stay on the list since EGU sulfate 

emissions have, by far, the largest impact on visibility in the MANE-VU Class I areas. 

Likewise, a low-sulfur oil strategy, combining low-sulfur heating oil (residential and 

commercial) and the oil-fired ICI boiler sector control measures for #2, #4, and #6 residual oils, 

remained on the list after a NESCAUM-initiated conference with refiners and fuel-oil suppliers 

concluded that such a strategy could realistically be implemented. During MANE-VU’s internal 

consultation meeting in March 2007, member states reviewed the updated interim list of control 

measures to make further refinements. At that time, states determined, for example, that there 

may be too few coal-fired ICI boilers in the MANE-VU states for that to be considered as a 

“regional” strategy, but that could be a sector pursued by individual states. They also determined 

that lime and cement kilns, of which there are few in the MANE-VU region, would likely be 

handled via state BART determination processes. Residential wood burning and outdoor wood 

boilers remain on the list for those states where localized visibility impacts may be of concern. 

The Commissioners of the environmental agencies of the northeastern States with Class I areas 

met on June 7, 2007 and agreed on a Statement of Principles to guide the direction of the future 

consultation process for Regional Haze Planning that occurred during the summer of 2007. This 

Statement of Principles was designed to guide the consultation process, set forth the importance 

of Regional Haze long-range planning for all states, and highlighted the critical role that air 

pollutant transport plays in regional haze and interstate air pollution. The principles that New 

Jersey and the other MANE-VU States laid out in this document are included in Appendix A5.

The Commissioners of the MANE-VU States also agree upon certain long-range goals for the 

control of specific source categories within MANE-VU and agreed on certain specific targets to 
75

“ask” of other States outside of the MANE-VU planning region and to “ask” of the USEPA. 

These planning agreements are included in Appendix A6, and summarized in Table 4.3. New 

Jersey included these targets in its Regional Haze air quality planning document.165

Table 4.3: Summary of MANE-VU Planning Targets

Controls Inside of the MANEVU RegionControls Outside of MANE-VU 

Region

National Controls (to “ask” of 

the USEPA)

Timely implementation of BART 

requirements

Timely implementation of BART 

requirements

The MANE-VU states and tribes 

request that the USEPA work 

with the eastern Regional 

Planning Organizations to 

develop a proposal for tightening 

the CAIR program to achieve an 

additional reduction in SO2 by no 

later than 2018

A 90% or greater reduction in 

SO2 emissions from EGUs 

identified by MANE-VU

A 90% or greater reduction in 

SO2 emissions from EGUs 

identified by MANE-VU

Ultra Low sulfur fuel strategy in 

the inner zone states

Application of reasonable 

controls on non-EGU sources

Low sulfur fuel strategy in the 

outer zone states

Continued evaluation of other 

control measures, including 

energy efficiency, alternative 

clean fuels, and other measures to 

reduce SO2 and NOx emissions 

from all coal burning facilities by 

2018, and new source 

performance standards for wood 

combustion

Continued evaluation of other 

control measures, including 

energy efficiency, alternative 

clean fuels, and other measures to 

reduce SO2 and NOx emissions 

from all coal burning facilities by 

2018, and new source 

performance standards for wood 

combustion

Although emission reduction benefits from the MANE-VU efforts that are targeting PM2.5

precursors (SO2 and NOx) will occur after the 1997 PM2.5 NAAQS attainment date (April 5, 

2010), the reductions from the measures listed in Table 4.3 will help the State attain the new 

2006 24-hour PM2.5 standard, as well as all the other PM2.5-related air quality goals discussed in 

Chapter 1.

4.3.1.5 State Specific Efforts

In addition to New Jersey’s participation in the regional control measure identification efforts, 

the State implemented its own outreach initiative, entitled “Reducing Air Pollution Together.” 

“Reducing Air Pollution Together” was designed to gather control measure ideas and 

suggestions from the New Jersey public, regulated communities, and other interested parties. In 

addition, the NJDEP, as required by the Clean Air Act, completed its own internal RACT and 

Reasonably Available Control Measures (RACM) analyses, to identify viable controls for 

significant sources within the State. All of these efforts, as well as any control measures 

identified from them, are discussed in greater detail below.

 165 New Jersey proposed its Regional Haze SIP September 15, 2008. 
76

4.3.1.5.1 New Jersey Workgroup Efforts

The NJDEP began a collaborative effort to discuss the air quality challenges facing New Jersey 

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

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

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

environmental and civic groups attended. As a result of the “Reducing Air Pollution Together”

workshop, the following six air quality workgroups were formed and collaborated over several 

months to develop recommendations on how to reduce air emissions from their specific source 

categories:

 Diesel Initiatives 

 Gasoline Cars and Trucks 

 Homes and Restaurants 

 Non-Automobile Gasoline Engines

 Stationary Combustion Sources 

 Volatile Organic Compounds from Industrial Processes and Consumer

Products

The workgroups identified potential control measures to reduce NOx, VOC, PM2.5, and SO2

emissions for possible inclusion in the State’s upcoming SIP revisions. Through the cooperative 

efforts of the NJDEP, federal agencies, industry, consultants, environmental groups, and other 

members of the regulated community, the workgroups evaluated available emission inventories, 

technical information and field data to develop lists of potential air emission control strategies 

related to their topic area. The criteria used by the workgroups to prioritize control measures 

included technical feasibility, economic feasibility, environmental benefits, and implementation 

feasibility. The air quality workgroups compiled their recommendations into reports that were 

submitted to the NJDEP for further consideration on October 31, 2005. The workgroups 

presented a summary of their recommendations to the NJDEP’s Air Quality Management Team 

on November 14, 2005. This event was another opportunity for the NJDEP staff and workgroup 

members to discuss the workgroup recommendations.

The NJDEP’s workgroup leaders and facilitators met with the NJDEP’s Air Quality Management 

team to review the over 200 workgroup recommendations and identify those control strategies 

with significant potential emissions reductions. After culling that list down to 60 potential 

control measures, the NJDEP then generated white papers166 for each measure. These white 

papers were posted on the NJDEP’s website for public review and comment. The NJDEP made 

revisions to individual white paper where appropriate, based on comment and/or additional 

information. In addition, the NJDEP invited the public, representatives from local businesses, 

industry and environmental groups, and others to a follow-up workshop to discuss potential 

emission reduction strategies on May 17, 2006. The purpose of that workshop was for the 

NJDEP to provide an update on efforts during the past year to address air quality challenges 

 166 A complete list of white papers, with links to the actual papers, can be found at 

www.nj.gov/dep/airworkgroups/docs/wp_summary_table_web.xls.
77

facing New Jersey and to share preliminary regulatory and nonregulatory plans to reduce air 

emissions. Following the May 17, 2006 workshop, the public was asked to provide feedback on 

the workshop, and on the 60 white papers drafted by the NJDEP and discussed at the 

workshop.167

Many of the white paper measures are the same as those identified through the OTC and 

MARAMA efforts, and the State’s own RACT and RACM analyses for both ozone and PM2.5. 

The PM2.5 RACT and RACM analyses are discussed in more detail in Sections 4.3.1.5.4 and 

4.3.1.5.5, respectively. 

4.3.1.5.2 New Jersey Board of Public Utilities (NJBPU) Energy Master Plan Efforts

On October 3, 2006, Governor Jon S. Corzine announced the commencement of an interagency 

planning process that will culminate in an energy master plan, a long-term energy vision for the 

state that plans for the state’s energy needs through 2020.168 

The Energy Master Plan (EMP) will address three areas: security, safety, and reliability of prices 

of energy supply and services; economic impact of energy production, transportation, and end 

use; and environmental impact associated with the production of energy.169 The main goal of the 

EMP is to reduce projected energy use by 20 percent by 2020 and meet 20 percent of the State’s 

electricity needs with Class 1 renewable energy sources by 2020.170 Other goals of the EMP are 

described below:

Goal 1: Secure, Safe, and Reasonably Priced Energy Supplies and Services – To provide 

safe, secure, reasonably priced energy supplies and services to New Jersey’s commercial, 

industrial, transportation, and residential customers, while reducing dependence on 

traditional fossil fuels and fossil fuel generation, decreasing electric and natural gas 

transmission congestion, utilizing efficiency and renewable resources to supplement the 

State’s energy resources, proactively planning for in-state electricity generation retirements, 

and reducing the demand for energy.171

Goal 2: Economic Growth and Development – To encourage and maintain economic 

growth prospects for the State by recognizing and fostering the multiple functions of energy 

in the economy.172

Goal 3: Environmental Protection and Impact – To promote the achievement of Federal 

and State environmental requirements and objectives in an effective and low-cost manner 

and, where possible, provide market-based incentives to achieve those goals.173

 167 Comments received on the white papers are posted at www.nj.gov/dep/airworkgroups/comments.html. 168 State of New Jersey Office of the Governor. Governor Corzine Announces Initial Phase of Energy Master Plan. 

Available at http://www.nj.gov/governor/news/news/approved/20061003.html. October 3, 2006.

169 State of New Jersey Office of the Governor. Governor Corzine Announces Initial Phase of Energy Master Plan. 

Available at http://www.nj.gov/governor/news/news/approved/20061003.html. October 3, 2006.

170 State of New Jersey Energy Master Plan. Energy Master Plan Goals. Available at: 

http://www.nj.gov/emp/about/goals.html.

171 Ibid. 172 Ibid.
78

Public participation began October 2006, with a series of stakeholder meetings held throughout 

the State; that continued with the formation of External Working Groups for energy categories. 

More than 500 people have attended EMP meetings, offered input and ideas, and joined the 

listserv. The draft EMP was released in April of 2008 with public hearings held in July of 2008. 

The final EMP was released on October 22, 2008.

4.3.1.5.3 Reasonably Available Control Technology (RACT)

New Jersey’s PM2.5 reasonably available control technology (RACT) analysis was conducted 

pursuant to 42 U.S.C. § 7502(c)(1) (Section 172(c)(1) of the Clean Air Act), which requires 

states with nonattainment areas to submit State Implementation Plans (SIPs) implementing all 

reasonably available control measures (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) as expeditiously as practicable to attain the NAAQS.

New Jersey’s RACT analysis demonstrates that reductions of direct PM2.5 emissions and its 

precursors, SO2 and NOx, from major stationary source categories are reasonable. New Jersey’s 

full RACT analysis is included in Appendix A7.

4.3.1.5.4 Reasonably Available Control Measures (RACM) Analysis

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

control measure for application to point,174 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 measure can advance the attainment date by at least one year

New Jersey’s 2007 PM2.5 RACM analysis was conducted to fulfill the requirements of Section 

(c)(1) of the Clean Air Act. This analysis addressed the following PM2.5 precursors: direct 

PM2.5, SO2, and NOx. VOC and ammonia were not addressed, consistent with USEPA guidance.

A total of 628 potential non-transportation control measures175 were compiled and reviewed to 

determine whether or not any of these measures could be considered a RACM that would 

 173 Ibid. 174 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. 20585-667 (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 - 71705). However, New Jersey determined to 

conduct these two analyses separately, consistent with how it addressed its RACT and RACM requirements for 8-

hour ozone. New Jersey’s separate RACT analysis for PM2.5 is contained in Appendix A7.
79

advance the attainment date for the 1997 annual PM2.5 NAAQS by at least one year. In order to 

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

implemented by 2008. After pre-screening, 61 potential non-transportation control measures 

(TCMs) were further evaluated using the RACM criteria. Seventeen (17) non-TCMs passed all 

RACM criteria, but would not be implemented by 2008. 

The NJDOT conducted a separate PM2.5 RACM analysis for TCMs. Twenty-six TCMs were 

identified and evaluated based on the RACM criteria. One TCM passed all RACM criteria, but 

would not be implemented by 2008.

It was determined that none of these 18 potential measures could be implemented by 2008. The 

RACM analysis did identify several promising measures that New Jersey will consider 

implementing at a later date, and confirmed other measures that New Jersey is already 

addressing. 

New Jersey’s full RACM analysis is included in Appendix A8.

4.3.1.5.5 Additional Measures

There are additional State measures that, while not identified specifically in any of the regional 

or state control measure initiatives, have been, or will be, implemented in time to provide 

quantitative PM2.5 emission reductions prior to and during 2009. The remainder of this section 

discusses these measures:

Diesel Idling Rule Changes: Since diesel engines are significant contributors of ozone and fine 

particulate precursors in the State of New Jersey, any efforts to control and reduce those 

emissions contribute to the State’s attainment of the ozone and fine particulate matter NAAQS. 

On September 18, 2006, the NJDEP proposed amendments to the existing diesel idling rules.176 

The rules became effective July 25, 2007. These rules address the allowable idling duration for 

diesel-powered motor vehicles, and exemptions to that maximum idling limit. The changes 

reduce the allowable exemptions to a three-minute diesel idling standard. There were 

exemptions to the idling limit which allowed qualified vehicles to idle for an unlimited length of 

time under certain conditions. The revisions to the rule modify these exemptions to further limit 

idling in cold weather; limit the idling time for vehicles that transport people; clarify the idling 

rules regarding trucks waiting in line; clarify the type of vehicle which would be considered an 

“emergency motor vehicle,” and the times which would be considered “an emergency situation;” 

eliminate the exemption for idling while a vehicle is in for repairs that do not require the engine 

to be engaged to complete; eliminate the exemption for idling while attaching or detaching a 

trailer, should it take longer than the allowed three consecutive minutes; and phase out the 

exemption for sleeper berths. 

 175 Transportation Control Measures, or 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. 

176 Control and Prohibition of Air Pollution from Diesel-Powered Motor Vehicles Air Administrative Procedures 

and Penalties Proposed Amendments: N.J.A.C. 7:27-14.1, 14.3, 7:27A-3.10(m)14. New Jersey Department of 

Environmental Protection. September 18, 2006.
80

Diesel Smoke (I/M Cutpoint) Rule Changes: Like the diesel idling efforts, the NJDEP 

requirements for the inspection and maintenance (I/M) of diesel vehicles are designed to reduce 

the emissions from diesel engines, which are significant contributors to ozone, PM2.5 and its 

precursors. The NJDEP is currently working to propose amendments to its existing diesel I/M 

rules to reduce the allowable smoke from heavy-duty diesel vehicles. Smoke opacity, which is 

used as a surrogate for particulate matter, is the degree to which a plume of smoke will obstruct 

transmission of visible light. Smoke opacity is used as an indicator for mal-maintenance. 

Currently available technology allows diesel engines to emit smoke at rates much lower than the 

existing cutpoints, when operating in accordance with the manufacturers’ specifications.

Therefore, it is appropriate to revise the heavy-duty diesel vehicle inspection program standards 

to reflect the current diesel engine technology and ensure appropriate maintenance is performed.

Although newer diesel-powered vehicles and equipment usually operate more cleanly and may 

contribute less to air quality problems than their predecessors, diesel-powered trucks and buses 

tend to remain in service for 20 years or more. Unless the excess emissions due to malmaintenance or lack of repair are reduced, trucks and buses will continue to emit excess levels of 

exhaust particles and contribute to air pollution in the State for many years to come.

Implementing stricter opacity cutpoints for diesel-powered vehicles will result in appropriate 

maintenance and reduce emissions.

Case-by-Case NOx Limit Determinations (FSELs/AELs): Existing RACT rules set performance 

standards for many source categories. Major NOx facilities with emission sources having a 

potential to emit more than 10 tons of NOx per year where no previous NJDEP RACT limit has 

been established in the RACT Rules (N.J.A.C. 7:27-16 and N.J.A.C. 7:27-19), i.e., sources 

without performance standards, must apply to the NJDEP for a Facility-Specific Emission Limit 

(FSEL). When a performance standard exists and the source determines it is not reasonable, they 

apply to the NJDEP for an Alternative Emission Limit (AEL). FSELs and AELs are determined 

on a case-by-case basis.

Currently, New Jersey has about 40 of these case-by-case FSEL/AEL determinations for sources 

throughout the State. New Jersey’s FSEL and AEL provisions for oxides of nitrogen are found 

at N.J.A.C. 7:27-19.13. 

As part of its RACT analysis, the NJDEP reviewed all of its existing FSELs and AELs and found 

that many were approved as long ago as 1997. In many cases, control technologies have 

advanced sufficiently since that time, warranting the reevaluation of these case-by-case 

determinations. The NJDEP proposes to require all facilities with existing FSELs or AELs to 

either comply with the existing or revised RACT limits, where applicable, or demonstrate that a 

new FSEL/AEL is warranted. The NJDEP further proposes that the newly issued AELs will 

terminate after a certain number of years, requiring periodic re-evaluations and determinations, 

in an effort to keep these limits current until compliance with specific rule emission limits are 

achieved. 

Municipal Waste Combustors (Incinerators) NOx Rule: New Jersey has five resource recovery 

facilities (RRF) located in Essex, Union, Camden, Gloucester, and Warren Counties, 
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respectively. There are 13 municipal waste combustors (MWC) at these five facilities. The 

NJDEP approved facility specific emission limits (FSELs) pursuant to N.J.A.C. 7:27-19.13 for 

each of these MWCs to meet the 1-hour ozone NAAQS, because these facilities qualified as 

major facilities (i.e., those facilities with the potential to emit more than 25 tons of NOx per year 

containing a source operation that has the potential to emit greater than 10 tons per year) and the 

State did not establish specific RACT source requirements for MWCs. The USEPA has adopted 

Federal Plans for both large and small MWCs. New Jersey is the delegated state authorized to 

implement and enforce those plans, in accordance with Memoranda of Agreement (MOAs) 

between the State and the USEPA. The Federal standard for emissions of NOx from MWCs, as 

reflected in the Federal rules dated May 10, 2006, and previous Federal plans, is 205 ppm.177 

Currently, all New Jersey MWCs are in compliance with the Federal standard.

As part of its ozone RACT analysis, the NJDEP reviewed the Municipal Waste Combustor 

FSELs and determined that, when equipped with selective non-catalytic reduction (SNCR), NOx

controls are capable of more NOx reductions than are currently being achieved by some of the 

municipal solid waste facilities. The ozone RACT rulemaking proposal will eliminate the 

various MWC FSELs and set a more stringent source category NOx emission limit, which will 

result in further NOx emission reductions from this source category.

Refineries - Process Heaters and Boilers: Process heaters and boilers operating at petroleum 

refineries emit large amounts of NOx, carbon monoxide, SO2, and PM emissions. Boilers are 

designed to generate steam for use throughout the refinery, while process heaters burn fuels to 

transfer heat directly to process materials. Boilers and process heaters are similar in that they are 

indirect combustion devices that burn fuels such as natural gas, fuel oil, and refinery fuel gas. 

New Jersey currently regulates NOx emissions from indirect heat exchangers at N.J.A.C. 7:27-

19.7. 

Available control technologies for controlling NOx emissions from these units include Ultra Low 

NOx Burners (LNB) and Selective Catalytic Reduction (SCR). These control technologies have 

been successfully applied to both types of equipment achieving emission reductions up to 90 

percent. Recent enforcement settlements required some refineries to reduce NOx emissions to 

0.04 lbs NOx/MMBtu.

New Jersey Low Emission Vehicle Program: The NJDEP’s Low Emission Vehicle (LEV) 

program (or Clean Car Program) rule was adopted on November 28, 2005, with an operative date 

of January 27, 2006.178 The rule requires all new vehicles delivered for sale in New Jersey to be 

California certified for emissions beginning January 1, 2009. This rule also establishes a zero 

emission vehicle (ZEV) sales requirement for New Jersey and requires that each auto 

manufacturer’s sales fleet in New Jersey meet a declining fleet average non-methane organic gas 

(NMOG) emission standard.

The rule is designed, in part, to encourage auto manufacturers to offer the ultra-low emitting 

California certified models in New Jersey prior to the 2009 mandatory compliance start date.

 177 70 Fed. Reg. 75348-69 (May 10, 2006). 178 38 N.J.R. 497(b) (January 17, 2006).
82

Auto manufacturers delivering such vehicles to New Jersey can earn ZEV credits that can be 

used by manufacturers to help transition into the mandatory requirements in 2009 and beyond. 

Currently, 36 models are certified to the Partial ZEV (PZEV) or Advanced Tech PZEV 

(ATPZEV) standard, which will generate such credits if sold in New Jersey. There are 23,493 

vehicles that have either received or are currently receiving ZEV credits in New Jersey.

Distillate and Residual Fuel Strategies: Lowering the sulfur content in fuel oil is a part of the 

long-term strategy established by the MANE-VU states to reduce and prevent regional haze. 

The MANE-VU states in the inner zone (New Jersey, New York, Delaware and Pennsylvania) 

plan to reduce the sulfur content of distillate oil to 0.05 percent sulfur by weight (500 ppm) by 

2012, the sulfur content of No. 4 residual oil to 0.3 percent sulfur by weight by 2012, the sulfur 

content of No. 6 residual oil to 0.3 to 0.5 percent sulfur by weight by 2012, and to further reduce 

the sulfur content of distillate oil to 15 ppm by 2016. The MANE-VU states in the outer zone 

plan to reduce the sulfur content of distillate oil to 0.05 percent sulfur by weight by than 2014, 

the sulfur content of No. 4 residual oil to 0.25 to 0.5 percent sulfur by weight by 2018, the sulfur 

content of No. 6 residual oil to no greater than 0.5 percent sulfur by weight by 2018, and to 

further reduce the sulfur content of distillate oil to 15 ppm by 2018 (depending on supply 

availability).

The NJDEP is planning to propose to amend N.J.A.C. 7:27-9, Sulfur in Fuels, specifically 

section 9.2, which specifies sulfur content standards and maximum allowable sulfur dioxide 

emissions. The potential amendments will affect those who store, offer for sale, sell, deliver or 

exchange fuel for use in New Jersey, as well as the users of these fuels. The anticipated 

amendments will reduce 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. 

Currently, maximum allowable sulfur levels in No. 2 and lighter fuel oil in New Jersey are either 

2,000 parts per million (ppm) or 3,000 ppm. Maximum allowable sulfur levels in No. 4 fuel 

ranges from 3,000 ppm (0.3 percent) to 20,000 ppm (2.0 percent). Maximum allowable sulfur 

levels in No. 5 and No. 6 fuels also range from 3,000 to 20,000 ppm. The NJDEP is evaluating a 

proposal to reduce the maximum allowable sulfur content of No. 2 and lighter fuel oil to 500 

ppm (0.05 percent), then 15 ppm (0.0015 percent) statewide; reduce the maximum allowable 

sulfur content of No. 4 fuel oil to 3,000 ppm (0.3 percent) statewide; and reduce the maximum 

allowable sulfur content of No. 5, No. 6 and heavier fuel oils to 5,000 ppm (0.5 percent) in Zones 

1, 2, 3 and 5 (the standard will remain 3,000 ppm (0.3 percent) in Zones 4 and 6).

Fleet Turnover: The turnover of the onroad fleet of cars and trucks will result in additional NOx

and PM emission benefits in 2009 and beyond because the new vehicles have significantly lower 

emission standards than the vehicles they are replacing. The new vehicle emission standards are 

lower primarily because of a number of Federal rules such as the Tier 2 standards for 

automobiles and light trucks and the 2007 Heavy Duty Diesel standards for large diesel highway 

trucks. A number of post-2002 New Jersey rules also contribute to the fleet turnover emission 

benefits, such as the New Jersey Low Emission Vehicle (NJLEV) new vehicle program.
83

Controls from EGU Consent Decrees (PSE&G Mercer and Hudson): On November 30, 2006, the 

USEPA, U.S. Department of Justice, and the State of New Jersey reached a settlement with 

PSE&G related to failure to comply with a 2002 consent decree requiring installation of 

pollution controls at its coal-fired power plants in Jersey City (Hudson) and Hamilton (Mercer), 

New Jersey.179,180 The settlement required additional air pollution controls, lower sulfur coal, 

lower emissions, and environmental projects. At the Hudson plant, PSE&G was required to take 

interim steps to reduce emissions of NOx, SO2, and PM until the required pollution control 

equipment was installed as required by the original consent decree or the unit was shut down. 

These interim measures included year-round operation of the existing NOx control equipment 

utilizing selective non-catalytic reduction (SNCR) to reduce NOx, use of ultra-low sulfur coal, 

compliance with interim annual emission caps for NOx and SO2, and operation of an electrostatic 

precipitator and a fly ash conditioning system to control PM. These additional emission control 

measures will improve air quality in the region. This agreement also included new fabric filters 

being installed on the PSE&G Mercer generating plant by December 31, 2008. For the period of 

the consent decree, PSE&G will significantly reduce its emissions of NOx, SO2, and PM in order 

to achieve the same reductions required under the 2002 Consent Decree. 

4.3.1.5.6 Federal

The Federal government plans to implement several measures that will provide quantitative 

emission reductions prior to the summer of 2009. The remainder of this section discusses these 

measures. 

Small Offroad Engine Rule: On May 18, 2007, the USEPA proposed new rules that would set 

stricter standards for most lawn and garden equipment and small recreational watercraft.181,182 

Specifically, the proposal would establish new exhaust emission standards that manufacturers are 

expected to meet using catalytic converters in many types of small watercraft, lawn, and garden 

equipment. This proposed rule also includes fuel evaporative standards for all the types of 

equipment and watercraft covered in the rulemaking. The new standards would apply as early as 

2011 for most lawn and garden equipment (under 25 horsepower) and 2009 for watercraft. 

Locomotive Engines and Marine Compression-Ignition Engines Less Than 30 Liters per 

Cylinder: On March 14, 2008, the USEPA adopted more stringent exhaust emission standards 

for locomotives and marine diesel engines.183 The standards include: tightening emission 

 179 USEPA. United States and New Jersey Announce Clean Air Act Settlement with PSE&G Fossil LLC for 

Violations of 2002 Consent Decree; Utility Required to Pay Significantly Increased Penalties and Reduce 

Emissions. Accessed from: 

http://yosemite.epa.gov/opa/admpress.nsf/1ef7cd36224b565785257359003f533f/c59ece80a8a072d1852572360065c

298!OpenDocument. November 30, 2006.

180 State of New Jersey v. PSEG Fossil LLC, Amendment to Consent Decree, Newark Division, New Jersey, U.S. 

District Court (November 30, 2006). Accessible at 

http://www.epa.gov/compliance/resources/decrees/amended/psegfossil-amended-cd.pdf. 181 72 Fed. Reg. 28098-146 (May 18, 2007). 182 For more information about the proposal, visit USEPA’s websites at Lawn and Garden 

http://www.epa.gov/otaq/equip-ld.htm for lawn and garden equipment and http://www.epa.gov/otaq/marinesi.htm 

for gasoline boats and personal watercraft. 183 73 Fed. Reg. 25097 (May 6, 2008).
84

standards for existing locomotives when they are remanufactured; setting near-term engine-out 

emission standards (Tier 3 standards) for newly-built locomotives and marine diesel engines; and 

setting longer-term standards (Tier 4 standards) for newly-built locomotives and marine diesel 

engines that reflect the application of high-efficiency aftertreatment technology. The USEPA is 

also proposing provisions to eliminate emissions from unnecessary locomotive idling. 

The standards for remanufactured locomotives will take effect as soon as certified remanufacture 

systems are available (as early as 2008). Tier 3 standards for newly-built locomotive and marine 

engines would phase in starting in 2009. Tier 4 standards for newly-built locomotives and

marine diesel engines would phase in beginning in 2014 for marine diesel engines and 2015 for 

locomotives.

Energy Conservation Standards for New Federal Commercial and Multi-Family High-Rise 

Residential Buildings and New Federal Low-Rise Residential Buildings: The United States 

Department of Energy (USDOE) has developed standards for all new Federal commercial and 

high-rise multi-family residential (over three stories in height above ground) buildings and all 

new low-rise residential buildings pursuant to the requirements of the Energy Conservation and 

Production Act (ECPA). The effective date of the rule is January 22, 2008. The rule establishes 

an energy efficiency baseline for new Federal commercial and multi-family high rise residential 

buildings based on referencing ASHRAE184 Standard 90.1-2004 and the 2004 IECC.185 The 

standards establish requirements for the structure and major systems of a building, and are 

mandatory for new Federal buildings. The rule establishes a requirement for new Federal 

buildings to achieve a level of energy efficiency 30 percent greater than that of the 

ANSI/ASHRAE/IESNA186 or the 2004 IECC levels when life-cycle cost-effective. This rule is 

expected to reduce NOx and SO2 emissions.

4.3.1.5.7 Additional Actions

The State is also taking the following additional actions to reduce PM2.5 emissions.

High Electrical Demand Days (HEDD) Program: In March 2007, following a year long process, 

six of the OTC states committed to pursue reductions in NOx emissions from electrical 

generating units that primarily operate on high electrical demand days (HEDD) starting with the 

2009 ozone season.187 On these high electric demand days, increased power generation is 

needed, usually on short notice. In Connecticut, Delaware, Maryland and Pennsylvania, boilers 

and turbines that primarily run to follow electrical load needs supply HEDD power generation. 

In New Jersey and New York, combustion turbines primarily supply HEDD power generation. 

The majority of the HEDD units in the six states are not controlled and produce significant NOx 

emissions on HEDDs. For example, on a typical summer day (June 4, 2005), NOx emissions for 

 184 The American Society of Heating, Refrigerating and Air-Conditioning Engineers 185 International Energy Conservation Code 186 American National Standards Institute/ The American Society of Heating, Refrigerating and Air-Conditioning 

Engineers/ The Illuminating Engineering Society of North America

187 Memorandum of Understanding Among the States of the Ozone Transport Commission Concerning the 

Incorporation of High Electrical Demand Day Emission Reduction Strategies into Ozone Attainment State 

Implementation Planning. Ozone Transport Commission, March 2, 2007.
85

the six states for all Electric Generating Units (EGUs) were 551 tons per day (tpd). On a HEDD 

(July 26, 2005), NOx emissions were 1,349 tpd. Most of this increase in emissions is due to 

power production from uncontrolled HEDD units.

As part of the HEDD initiative, New Jersey plans to reduce NOx emissions by 19.8 tpd on the 

nominal high electrical demand days. Specifically, power generators in New Jersey will be 

responsible for securing these reductions and will be required to submit a plan on how they will 

reduce NOx. The generators will have flexibility in securing the 2009 reductions. New Jersey 

also plans to require that all HEDD units meet performance standards that reflect modern low 

NOx technology by May 1, 2015.

Ports: The Port of New York/New Jersey is the largest port complex on the East Coast of North 

America. It is located at the hub of the most concentrated and affluent consumer market in the 

world, with immediate access to the most extensive interstate highway and rail networks in the 

region. The Port Authority directly oversees the operation of seven privately owned cargo 

terminals in the New York-New Jersey region (landlord tenant relationship). Each year, more 

than 25 million tons of oceanborne general cargo moves through this port, including 4.5 million 

TEUs (twenty-foot equivalent container units) of containerized cargo. The Port 

Newark/Elizabeth-Port Authority Marine Terminal complex (NJ), the Port Authority Auto 

Marine Terminal (NJ), Brooklyn Piers and Red Hook Container Terminal (NY), and Howland 

Hook Marine Terminal (NY) handle most of the cargo. In addition, there are private operators, 

such as Global Marine Terminal and a number of marine terminals, operated by private bulk 

cargo operators. The Passenger Ship Terminal known as The New York Cruise Terminal is 

operated by P&O Ports North America for the City of New York.

Containerized cargo volumes in the Port of New York and New Jersey rose nearly 8 percent in 

2006, to a new record high. The dollar value of all cargo moving through the port in 2006 

exceeded $149 billion for the first time, up 13 percent from 2005. In the next 10 years, nearly $2 

billion in infrastructure upgrades are planned for marine terminal facilities and for off-port roads 

and railways to improve the flow of cargo.

To minimize the impact that this tremendous growth has on our environment, the NJDEP 

Commissioner outlined the following action item in the document entitled “Priorities and Action 

Plan,” January 2007. This goal is reiterated in the draft document entitled “Environmental 

Justice Priorities for the NJDEP – May 2007.” 

“Target [NJ]DEP efforts to establish a coordinated effort on protecting the health of 

urban residents from environmental causes and ensure that [NJ]DEP’s efforts to support 

economic growth and redevelopment in urban areas results in improved urban 

environmental health. Specifically, [NJ]DEP will coordinate its efforts at NJ’s two major 

ports to deliver tangible environmental improvements.”

The NJDEP is working closely with the Port Authority of NY/NJ, the USEPA Region 2, the 

South Jersey Port Corporation, and the Northeast Diesel Collaborative to develop and implement 

a comprehensive diesel risk reduction strategy for the port areas. Some possibilities include 

requiring cleaner fuel for oceangoing vessels while at dock or near the port; upgrading the cargo 
86

handling equipment; reducing idling emissions from ships, trains and trucks doing business at the 

port; and modernizing the drayage truck fleet that calls on the port.

At the South Jersey Port Corporation in Camden, New Jersey, several specific projects are 

underway at the terminals that they own and operate. First, as part of an enforcement settlement, 

nearly $400,000 was spent on retrofitting both on-road and off-road vehicles in the Camden 

Waterfront South area. Second, Clean Air Communities in partnership with NJDEP, the South 

Jersey Port Corporation, and others received a $250,000 grant from the USEPA titled 

“Community Action for a Renewed Environment.” The grant will be used to work with the 

project partners to: establish a forum for dialogue with local businesses; and undertake 

community campaigns, such as publishing an environmental justice toolkit for high school 

students and educating children about environmental health. The NJDEP agreed to supplement 

the $250,000 grant with $500,000 from an enforcement settlement so that the South Jersey Port 

Corporation could undertake additional diesel emission reduction projects on the diesel 

equipment that they operate in Camden.

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 Burning,188 and is considering changes to agricultural burning portion of 

these requirements. This source category is also addressed in the “Smoke Management” section 

of New Jersey’s Regional Haze SIP (including the agricultural and forestry smoke management, 

prescribed burning, and agricultural management discussions in that SIP proposal).189 One 

particulate control measure has already been implemented, namely to limit air pollution control 

permits to prevent open burning on days forecast to be of unhealthful air quality. This permit 

condition requires the permit holder to delay open burning until forecast meteorological 

conditions and air quality have improved so that forecasted unhealthful conditions for that day 

will not be made worse by this activity. Similarly, New Jersey is considering a seasonal home 

wood heating advisory program to further curtail wood smoke emissions, similar to the program 

adopted in Lane County, Oregon.190 This program would advise homeowners when they could 

heat their homes with wood, according to the current air quality.

Change-out programs: Control measures might 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. 

Fugitive dust emissions: New Jersey has a control strategy in place for the control of stormwater 

runoff from streets under the New Jersey Municipal Stormwater Regulation program191 that also 

 188 Available at http://www.state.nj.us/dep/aqm/Sub%2002%20v1994-06-20.pdf (Accessed November 19, 2007).

189 The first regional haze air quality protection plan for New Jersey will be completed in 2008 (see Chapter 1 for 

further details).

190 LRAPA. Public Education: Home Wood Heating Programs. Lane Regional Air Protection Agency (LRAPA). 

http://www.lrapa.org/public_education/home_wood_heating_programs/, accessed May 14, 2008.

191 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).
87

has air quality benefits by the removal of fugitive dust. The strategy includes both mandated and 

voluntary street sweeping. Some streets are required to be swept monthly. 

New Jersey also has standards that reduce fugitive emissions from various sources such as tillage 

and construction. These standards have been adopted by the NJDOT and New Jersey 

Department of Agriculture (NJDOA) under the “Soil Erosion and Sediment Control Standards: 

Standards for Dust Control.”

This source category has also been identified as a potential PM2.5 RACT measure for certain 

facilities throughout the State. For more information, see the PM2.5 RACT analysis in Appendix 

A7.

Energy conservation and “green building”: New Jersey currently provides for rebates and other 

financial incentives to install energy-efficiency 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) encourage energy conservation.

Train engines: As of January 1, 2008, New Jersey Transit (NJ Transit) has voluntarily 

implemented an “Idling Reduction Policy” to shut down their diesel passenger locomotives 

within one hour of stopping to reduce idling at train yards by 70 percent to 90 percent. NJ 

Transit has also agreed to move forward with a New Jersey Transportation Planning Authority 

(NJTPA) proposal to evaluate idling reduction technologies.

Truck Stop Electrification: On October 20, 2004, the first Electrified Truck Stop in New Jersey 

was opened at Paulsboro, 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. Discussions are underway for an 

electrification project at the Vince Lombardi Rest Area in Ridgefield, Bergen County, New 

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

Medium Duty Motor Vehicle Inspection: New Jersey is evaluating an inspection program for 

medium duty vehicles with a gross weight between 8,501 – 17,999 pounds. The inspection 

program would be a combination of OBD and Smoke opacity inspections, and would help 

control particulate emissions. 

4.4 VOC Measures
88

The State is implementing several VOC control measures that were adopted as discussed in the 

2007 8-hour Ozone Attainment Demonstration SIP.192 Although the USEPA does not consider 

VOC as a PM2.5 precursor for SIP and conformity purposes, New Jersey anticipates a PM2.5 

benefit from the implementation of these measures. The proposed VOC measures are listed in 

Table 4.4.

Table 4.4: VOC Control Measures

Control Measures Sector

Pre-2002 with benefits achieved Post-2002 - On the Books

Federal

Onboard Refueling Vapor Recovery (ORVR) beyond Stage II Area/Onroad

Post-2002 - On the Books

New Jersey Measures Done Through a Regional Efforta

Consumer Products 2005 Area

Architectural Coatings 2005 Area

Portable Fuel Containers 2005 Area and Nonroad

Mobile Equipment Repair and Refinishing Area

Solvent Cleaning Point and Area

New Jersey Only Measures

Stage I and Stage II (Gasoline Transfer Operations) Area

Federal

USEPA MACT Standards Point

Post-2002 - Beyond on the Way

New Jersey Measures Done Through a Regional Effort

Consumer Products 2009 Amendments Area

Portable Fuel Containers 2009 Amendments Area and Nonroad

Asphalt Paving Area

Adhesives and Sealants Area and Point

Refineries – Fugitive Equipment Leaks Point

New Jersey Only Measures

VOC Stationary Storage Tank Measures Point and Area

USEPA CTGs (4 categories) Point and Area

 192 NJDEP. State Implementation Plan (SIP) Revision for the Attainment and Maintenance of the Ozone National 

Ambient Air Quality Standard: 8-Hour Ozone Attainment Demonstration Proposal. June 15, 2007. 
89

Control Measures Sector

Note: a. The VOC measures include On the Way (OTW) measures. The six “shortfall” measures discussed in the definition of the OTB 

were developed by the Ozone Transport Commission (OTC) specifically to address United States Environmental Protection Agency 

(USEPA)-identified deficiencies in the 1-hour ozone attainment demonstrations of several OTC states. This terminology does not 

apply to New Jersey, as all of the OTC shortfall rules were adopted in New Jersey prior to the development of the modeling inventory.

4.5 Conclusions on Control Measures

The control measures discussed in this section make up the core of the State’s PM2.5 attainment 

demonstration and contingency measures. The use of these measures in each of those 

demonstrations, as well as how the benefits from the implementation of those measures were 

calculated, is discussed in Chapters 5 and 6, respectively. Many of the benefits were determined 

from the USEPA MOBILE6 model and the USEPA Nonroad model. Most of the control 

measure benefits (quantitatively) were included in the attainment modeling. Those that were not 

included in the attainment modeling are listed and discussed in Chapter 5. 

There are a host of other measures that have been, or will be, implemented in and around New 

Jersey whose benefits cannot be accurately estimated or quantified. These measures are 

described in Chapter 5. These measures, while not quantified, are providing a benefit to the air 

quality in New Jersey, as well as its upwind states,193 and increase the likelihood that the State 

will attain the PM2.5 health standard by its attainment date of April 5, 2010.

Table 4.5 shows a summary of New Jersey’s control measures and how they are being used to 

meet SIP requirements.

Table 4.5: PM2.5 Control Measure Summary

Control Measures Sector Attainment 

2009 Modeling

Control Measures 

Not Captured in the 

2009 Regional 

Modeling

Attainment (2009) 

Contingency

Pre-2002 with benefits achieved 

Post-2002 – On the Books 

New Jersey

NOx Budget Program (SIP Call) Point X

Nonattainment New Source Review 

(NNSR)

Point X

Pre-2002 with benefits achieved 

Post-2002 – On the Books

Federal

Residential Woodstove NSPS Area X

Acid Rain Point X

Onboard Refueling Vapor Recovery 

(ORVR) beyond Stage II*

Area/Onroad X

 193 Please see Chapter 8 for a discussion of the impact of New Jersey control measures on upwind states.
90

Control Measures Sector Attainment 

2009 Modeling

Control Measures 

Not Captured in the 

2009 Regional 

Modeling

Attainment (2009) 

Contingency

Tier 1 Vehicle Program Onroad X

National Low Emission Vehicle 

Program (NLEV)

Onroad X

Tier 2 Vehicle Program/Low Sulfur 

Fuels

Onroad X

Heavy Duty Diesel Vehicle 

(HDDV) Defeat Device Settlement

Onroad X

Heavy Duty Diesel Vehicle 

(HDDV) Engine Standards

Onroad X

Nonroad Diesel Engines Nonroad X

Large Industrial Spark-Ignition 

Engines over 19 kW

Nonroad X

Recreational Vehicles (includes 

snowmobiles, off-highway 

motorcycles, and all-terrain 

vehicles)

Nonroad X

Diesel Marine Engines over 37 kW Nonroad X

Phase 2 Standards for Small SparkIgnition Handheld Engines at or 

below 19 kW

Nonroad X

Phase 2 Standards for New 

Nonroad Spark-Ignition 

Nonhandheld Engines at or below 

19 kW

Nonroad X

Post-2002 – On the Books

New Jersey Measures Done 

Through a Regional Effort

Consumer Products 2005* Area X

Architectural Coatings 2005* Area X

Portable Fuel Containers 2005* Area and 

Nonroad

X 

(Area Only)

Mobile Equipment Repair and 

Refinishing*

Area X

Solvent Cleaning* Point and Area X

NOx RACT Rule (2006) Point and Area X

New Jersey Heavy Duty Diesel 

Rules Including "Not-To-Exceed" 

(NTE) Requirements

Onroad X

Post-2002 – On the Books

New Jersey Only

Stage I and Stage II (Gasoline 

Transfer Operations)*

Area X

On-Board Diagnostics (OBD) –

(I/M) Program for Gasoline 

Vehicles

Onroad X

Post-2002 – On the Books

Federal
91

Control Measures Sector Attainment 

2009 Modeling

Control Measures 

Not Captured in the 

2009 Regional 

Modeling

Attainment (2009) 

Contingency

USEPA MACT Standards including 

Industrial Boiler/Process Heater 

MACT

Point X

Clean Air Interstate Rule (CAIR) Point X

Refinery Consent Decrees (Sunoco, 

Valero, and ConocoPhillips)

Point X

Refinery Consent Decrees (Sunoco, 

Valero)

Point X a X a

Post-2002 – Beyond on the Way

New Jersey Measures Done 

Through a Regional Effort

Consumer Products 2009 

Amendments*

Area X

Portable Fuel Containers 2009 

Amendments*

Area and 

Nonroad

X

(Area)

Asphalt Paving* Area X

Adhesives and Sealants* Area and Point X

Asphalt Production Plants Rule Point X X

Refineries – Fugitive Equipment 

Leaks*

Point X

Glass Manufacturing Point X

ICI Boiler Rule 2009 b Point X

High Electric Demand Day 

(HEDD) Program 

Point X

Post-2002 - Beyond on the Way

New Jersey Only

Fugitive Dust at Stationary Sources Point and Area X

#6 Fuel Oil-Fired Boilers Point X

Stationary Diesel Engines Point X

VOC Stationary Storage Tank 

Measures*

Point X

USEPA CTGs (4 categories)* Point X

Case by Case NOx Emission Limit 

Determinations (FSELs/AELs)

Point X

Municipal Waste Combustors 

(Incinerators) NOx portion

Point X X

Municipal Waste Combustors 

(Incinerators) PM portion

Point X

Refinery Rules (FCCUs, Flares, 

Process Heaters, and Boilers)

Point X

New Jersey Low Emission Vehicle 

(LEV) Program

Onroad X

Diesel Idling Rule Changes Onroad X X

Diesel Smoke (I/M Cutpoint) Rule 

Changes

Onroad X

Controls from EGU Consent 

Decrees (PSE&G Mercer)

Point X
92

Control Measures Sector Attainment 

2009 Modeling

Control Measures 

Not Captured in the 

2009 Regional 

Modeling

Attainment (2009) 

Contingency

Controls from EGU Consent 

Decrees (PSE&G Hudson NOx)

Point X

Controls from EGU Consent 

Decrees (PSE&G Hudson SO2)

Point X X

Post 2002 – Beyond on the Way

Federal

New Nonroad Engine Standards Nonroad X

Locomotive Engines and Marine 

Compression-Ignition Engines Less 

Than 30 Liters per Cylinder 

Nonroad X

Energy Conservation Standards for 

New Federal Commercial and 

Multi-Family High-Rise Residential 

Buildings and New Federal LowRise Residential Buildings

Area X

Additional 2009 Benefits c

Portable Fuel Containers – portion 

not modeled*

Area and 

Nonroad

X 

(Nonroad Only)

NOx RACT Rule 2006 (portion not 

modeled)

Point X X

ICI Boiler Rule 2009 (portion not 

modeled)

Point X X

Smoke Management Area X

Low Sulfur Distillate and Residual 

Fuel Strategies

Point and Area X

Ports Nonroad X

Onroad Motor Vehicle Control 

Programs (Fleet turnover 2010)

Onroad X X

Nonroad Motor Vehicle Control 

Programs (Fleet turnover 2010)

Nonroad X X

Notes: a. See modeling differential analysis in Appendix C

b. Some categories have 2009 compliance dates; remainder have 2012 compliance dates.

c. These measures are above and beyond what went into the modeling and do not necessarily constitute 

regulatory action, e.g., corrections to the modeling emissions inventory; these measures may also provide 

additional air quality benefits beyond the 2010 attainment date.

* = measures are VOC only measures
93

5.0 ATTAINMENT DEMONSTRATION

5.1 Introduction

As discussed in Section 1.0, states are required to submit State Implementation Plan (SIP) 

revisions that contain attainment demonstrations for their PM2.5 nonattainment areas within three 

years after the effective date of the nonattainment designation. The designation date for both the 

Northern New Jersey/New York/Connecticut nonattainment area and the Southern New 

Jersey/Philadelphia nonattainment area was December 17, 2004, with an effective date of April 

5, 2005.194 Therefore, the PM2.5 attainment demonstration SIP revision was due to the USEPA 

by April 5, 2008 (40 C.F.R. § 51.1002; 72 Fed. Reg. 20587, April 25, 2007). These SIPs must 

demonstrate that the measures and rules contained within them are adequate to provide for the 

timely attainment and maintenance of the PM2.5 National Ambient Air Quality Standard 

(NAAQS). In accordance with 40 C.F.R. § 51.112, each implementation plan must include:

• A summary of the computations, assumptions, and judgments used to determine the 

degree of reduction of emissions (or reductions in the growth of emissions) that will 

result from the implementation of the control strategy; 

• A presentation of emission levels expected to result from implementation of each 

measure of the control strategy; 

• A presentation of the air quality levels expected to result from implementation of the 

overall control strategy showing expected maximum pollutant concentration; 

• A description of the dispersion models used to project air quality and to evaluate 

control strategies; and 

• For interstate regions, the analysis from each constituent state must, where 

practicable, be based upon the same regional emission inventory and air quality 

baseline.

The attainment demonstration in this SIP revision addresses the 1997 annual PM2.5 standard. 

New Jersey and the other states that share New Jersey’s 1997 PM2.5 multi-state nonattainment 

areas have always met and are in attainment with the 1997 daily PM2.5 health-based standard of 

65 μg/m3. According to the USEPA’s modeling guidance,195 since these levels are well below 

the standard and have continued to improve since 2001 (see Chapter 2), the modeled attainment 

test for the 1997 daily PM2.5 standard is not needed nor is included in this attainment 

demonstration. 

 194 70 Fed. Reg. 944 (January 5, 2005).

195 USEPA. Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality 

Goals for Ozone, PM2.5, and Regional Haze. United States Environmental Protection Agency, Office of Air Quality 

Planning and Standards, Air Quality Analysis Division, Air Quality Modeling Group, Research Triangle Park, NC, 

EPA-454/B-07-002, April 2007, page 56.
94

Chapter 4 discussed and summarized Federal, New Jersey and regional efforts to identify control 

measures. This chapter presents the State’s analyses of the impact that the implementation of the 

control measures identified for attainment, in combination with existing and already on the way 

measures, have on the State’s air quality by 2009. Since this attainment demonstration will show 

attainment of the PM2.5 standard within five years of the date of designation, the State is not 

required to submit a separate Reasonable Further Progress Plan.196 Chapter 6 provides for 

contingencies in the event that either of New Jersey’s nonattainment areas fails to reach 

attainment. 

5.2 Photochemical Modeling

5.2.1 Introduction

The USEPA modeling guidance suggests the use of a photochemical model to determine 

attainment of the fine particulate NAAQS and has created a model which will predict 

concentrations of both ozone and fine particulate levels within the same modeling run.197 As 

such, New Jersey’s attainment demonstrations for both the Northern New Jersey/New 

York/Connecticut and the Southern New Jersey/Philadelphia nonattainment areas include the 

same parameters in the photochemical grid modeling as were used in the modeling runs used to 

demonstrate attainment of the ozone NAAQS. This analysis is also supplemented by other 

information to demonstrate that all the monitors in both nonattainment areas are predicted by the 

photochemical modeling to be in attainment of the PM2.5 annual health-based standard by 2010.

The objective of the photochemical modeling test is to enable New Jersey, to analyze the 

efficacy of various control strategies in reducing air pollution. The Ozone Transport 

Commission (OTC) on behalf of its member states (which include New Jersey, New York, 

Connecticut, Delaware, and Pennsylvania) undertook a photochemical modeling study to 

demonstrate compliance with the 8-hour ozone NAAQS for their multi-state nonattainment areas 

and built upon these efforts to demonstrate compliance with the annual PM2.5 NAAQS. The 

OTC Modeling Committee directed the 8-hour ozone attainment modeling study. The OTC 

Modeling Committee consisted of the following workgroups: OTC Photochemical Workgroup, 

OTC Meteorological Modeling Workgroup, OTC Emissions Inventory Development 

Workgroup, and the OTC Control Strategy Workgroup. The emissions inventory work was 

performed in conjunction with the Mid-Atlantic/Northeast Visibility Union (MANE-VU). The 

OTC Air Directors served on the OTC Oversight Committee and provided oversight of the 

process. Since the 8-hour ozone modeling was limited to the ozone season (May 1 through 

September 30), additional modeling was needed to demonstrate attainment of the annual PM2.5

NAAQS. This additional modeling was performed by the University of Medicine and Dentistry 

of New Jersey’s Ozone Research Center (UMDNJ/ORC), the Northeast States for Coordinated 

Air Use Management (NESCAUM) and the University of Maryland (UMD). 

 196 72 Fed. Reg. 20666 (April 25, 2007). 

197 USEPA. Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals 

for Ozone, PM2.5, and Regional Haze. United States Environmental Protection Agency, Office of Air Quality 

Planning and Standards, Air Quality Analysis Division, Air Quality Modeling Group, Research Triangle Park, NC, 

EPA-454/B-07-002, April 2007.
95

The remainder of this section discusses the model used in this regional modeling analysis, the 

specific modeling parameters, including inventory development, and the results of that modeling 

exercise.

5.2.2 “One-Atmosphere” Air Quality Model

The photochemical model selected for the attainment modeling demonstration was the USEPA’s 

Models-3/Community Multi-scale Air Quality (CMAQ) modeling system. The CMAQ 

modeling system was selected for the attainment demonstration primarily because it is a 

photochemical grid model capable of modeling a variety of pollutants over a range of time and 

space scales, i.e., a “one-atmosphere” photochemical grid model. Not only was CMAQ used to 

model ozone formation, but also was used to model the components that make up the particles 

with an aerodynamic diameter less than or equal to a nominal 2.5 micrometers (PM2.5) and 

Regional Haze in the Northeast. The model is capable of calculating the formation of secondary 

aerosols which are a prime component of fine particulate matter in the northeastern United 

States. The model is also recommended in the USEPA’s Modeling Guidance.198 All of the 

regional modeling was conducted in accordance with the USEPA’s Modeling Guidance.

Under the direction of the OTC Modeling Committee, several states and modeling centers 

performed the regional modeling runs and/or contributed to the preparation of technical 

information for the regional modeling effort. Those organizations included:

1) New York State Department of Environmental Conservation (NYSDEC),

2) Ozone Research Center at University of Medicine & Dentistry of NJ/Rutgers University 

(ORC),

3) University of Maryland (UMD),

4) Virginia Department of Environmental Quality,

5) Northeast States for Coordinated Air Use Management (NESCAUM)

6) Maryland Department of the Environment, 

7) New Hampshire Department of Environmental Services, and 

8) Mid-Atlantic Regional Air Management Agency (MARAMA).

The lead agency for coordinating the running of the CMAQ model and performing the modeling 

runs for the OTC was the NYSDEC.199 The NYSDEC ran the CMAQ model using the protocol 

in Appendix B1 for the May 1 through September 30 ozone season, which was supplemented by 

modeling runs performed by the UMDNJ/ORC (March and April), NESCAUM (October, 

November, December), and the University of Maryland (January, February) for the purposes of 

determining PM2.5 attainment. The four regional modeling centers were, therefore, able to model 

an entire year of meteorology and emissions. The NYSDEC was responsible for post-processing 

 198 USEPA. Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality 

Goals for Ozone, PM2.5, and Regional Haze. United States Environmental Protection Agency, Office of Air Quality 

Planning and Standards, Air Quality Analysis Division, Air Quality Modeling Group, Research Triangle Park, NC, 

EPA-454/B-07-002, April 2007.

199 New Jersey wishes to thank the NYSDEC for its leadership in the regional modeling effort.
96

the results for the Northern New Jersey/New York/Connecticut nonattainment area, including 

calculating the projected PM2.5 concentrations using the relative response factor (RRF) method 

specified in the USEPA’s Modeling Guidance, included in Appendix B2. The projected PM2.5

concentrations for the Southern New Jersey/Philadelphia nonattainment area were calculated by 

the UMDNJ/ORC. 

The CMAQ model requires specific inputs, including meteorological information and emissions 

information. The remainder of this section discusses, in general, the needed data inputs for the 

CMAQ model, the particular parameters of the CMAQ model chosen for the PM2.5 modeling 

runs, and the validation of the CMAQ model for use in the regional modeling effort. For more 

specific information, see Appendices B3, B4, B5, B6, and B7. 

5.2.2.1 Meteorology Data

As explained in the USEPA’s Emission Inventory Guidance,200 2002 was designated as the base 

year for 8-hour ozone SIPs, PM2.5 SIPs, and regional haze plans; therefore, wherever possible, 

2002 was used for baseline modeling for the PM2.5 standard. The Pennsylvania State 

University/National Center for Atmospheric Research Mesoscale Meteorological Model (MM5) 

version 3.6 was used to generate the annual 2002 meteorology for the modeling analysis. The 

MM5 model is a non-hydrostatic, prognostic meteorological model routinely used for urban- and 

regional-scale photochemical regulatory modeling studies. Professor Da-Lin Zhang (University 

of Maryland) performed the MM5 modeling in consultation with the NYSDEC and Maryland 

Department of the Environment staff. The analyses showed that in general, the performance of 

the MM5 is reasonable both at the surface and in the vertical, thereby providing confidence in

the use of these data in the CMAQ simulations. The documents supporting the MM5 modeling 

analysis are provided in Appendix B3. Based on model validation and sensitivity testing, the 

model results met the evaluation criteria and the MM5 configurations were used for the regional 

modeling effort.

5.2.2.2 Regional Emission Inventories

Both the nonattainment areas associated with New Jersey have an attainment date of no later 

than April 5, 2010. Since January through April represents only part of the year, attainment must 

be demonstrated for the last full year prior to the attainment date; in this case 2009.201 Emission 

reductions included in the regional modeling, therefore, should be implemented no later than the 

beginning of 2009 for the air quality benefits to have the greatest likelihood of improving air 

quality throughout the entire year and showing attainment of the annual standard. As such, the 

attainment modeling run is designed to show the incremental emission reductions associated with 

the implementation of control measures between the base year (2002) and the “attainment” year 

(2009). 

 200 USEPA. Emissions Inventory Guidance for Implementation of Ozone and Particulate Matter National Ambient 

Air Quality Standards (NAAQS) and Regional Haze Regulations. United States Environmental Protection Agency, 

Emissions Inventory Group, Emissions, Monitoring, and Analysis Division, Office of Air Quality Planning and 

Standards, Research Triangle Park, NC, EPA-454/R-05-001, August 2005, updated November 2005. 201 Success will be judged by three years of data, i.e., 2007, 2008, and 2009, to calculate the 2009 design value.
97

To complete this modeling exercise, two regional emission inventories were developed to 

represent the 2002 base case (see Appendix B4) and the 2009 control case (see Appendix B5). 

In addition, two other future control case emission inventories (for 2012 and 2018, respectively) 

were developed simultaneous with the 2009 control case emission inventory to allow for 

additional modeling exercises. These future year emission inventories were developed by 

projecting the 2002 base year emissions inventory using standard emissions projection 

techniques discussed in Appendix B5. These future year emission inventories include emissions 

growth due to projected increases in economic activity, as well as the emission reductions due to 

the implementation of control measures. All of the regional emission inventories in this chapter 

are hereafter referred to as the modeling inventories.

The 2002 emissions were first generated by the individual Ozone Transport Region states. 

MARAMA then coordinated and quality assured the 2002 inventory data, and projected it for the 

relevant control years. The 2002 emissions for non-Ozone Transport Region areas within the 

modeling domain were obtained from other Regional Planning Organizations for their 

corresponding areas. These Regional Planning Organizations included the Visibility 

Improvement State and Tribal Association of the Southeast (VISTAS), the Midwest Regional 

Planning Organization, and the Central Regional Air Planning Association. The documentation 

for the OTC base and control modeling inventories are presented in Appendices B4 and B5-1, 

respectively. The use of emission inventory data from the non-MANE-VU states is documented 

in Appendix B6.

As discussed in Chapter 4, the OTC member states selected several control strategies for 

inclusion in the attainment demonstration modeling. These strategies were selected from groups 

of measures developed by the technical subcommittees responsible for identifying and 

developing the regulations and/or control measures to attain the ozone health standard. 

Consideration was given to maintaining consistency with control measures likely to be 

implemented in other Regional Planning Organizations. Emission reduction requirements 

mandated by the Clean Air Act were also included in projecting future year emissions. 

Additional information on the emissions used in future year modeling is provided in Appendix 

B6. The following sections provide a more detailed discussion of base and control inventories 

used in the regional modeling. 

5.2.2.2.1 Base Emission Inventory

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

The technical support document for this inventory, which is included in Appendix B4, explains

the data sources, methods, and results for preparing this version of the 2002 base year criteria air 

pollutant and ammonia emissions inventories for point, area, onroad, nonroad, and biogenic 

sources for the MANE-VU Regional Planning Organization. In addition to relying on this base 

inventory for PM2.5 SIP-related activities, the MANE-VU states will use this base inventory to 

support air quality modeling, control measure development, and implementation activities for the 

Regional Haze SIP.

The inventory and supporting data include the following:
98

1) Comprehensive, county-level modeling inventories for 2002 emissions for criteria air 

pollutants and ammonia for the State and Local agencies included in the MANE-VU 

region; 

2) The temporal, speciation, and spatial allocation profiles for the MANE-VU region 

inventories; 

3) Inventories for wildfires, prescribed burning, and agricultural field burning for the 

southeastern provinces of Canada; and 

4) Inventories for other Regional Planning Organizations, Canada, and Mexico. 

The mass emissions inventory files were converted to the National Emissions Inventory Input 

Format Version 3.0. As discussed in greater detail in Section 5.2.2.3, the modeling inventory 

files were processed in Sparse Matrix Operator Kernel Emissions (SMOKE) /Inventory Data 

Analyzer. 

The inventories include annual emissions for oxides of nitrogen (NOx), volatile organic 

compounds (VOC), carbon monoxide, sulfur dioxide (SO2), ammonia, particles with an 

aerodynamic diameter less than or equal to a nominal 10 micrometers (PM10) and, particles with 

an aerodynamic diameter less than or equal to a nominal 2.5 micrometers (PM2.5). The 

inventories also included summer day, winter day, and average day emissions. However, not all 

states included daily emissions in their inventories. In these instances, temporal profiles 

prepared for this project were used to calculate daily emissions. 

Work on Version 1 of the 2002 MANE-VU inventory began in April 2004. The consolidated 

inventory for point, area, onroad, and nonroad sources was prepared by starting with the 

inventories that the MANE-VU state/local agencies submitted to the USEPA from May through 

July of 2004 as a requirement of the Consolidated Emissions Reporting Rule (CERR). This 

version of the final inventory and SMOKE input files were finalized during January 2005. 

Work on Version 2 (covering the period from April through September 2005) involved 

incorporating revisions requested by some MANE-VU state/local agencies on the point, area, 

and onroad inventories. Work on Version 3 (covering the period from December 2005 through 

April 2006) included additional revisions to the point, area, and onroad inventories as requested 

by some states. Thus, the Version 3 inventory for point, area, and onroad sources were built 

upon Versions 1 and 2. This work also included development of the biogenics inventory. In 

version 3, the nonroad inventory was completely redone because of changes that the USEPA 

made to the NONROAD2005 model.

Addressing Woodsmoke Emissions

There are differences between the 2002 base case inventory that was developed by New Jersey 

and the 2002 alternative wood burning emissions inventory that was developed regionally for 

modeling (fractional reduction from the base case). Both NOx and VOC emissions are different 

in the base case and the modeling case, too.

The reason for this difference is that the regional modeling was conducted by starting with a ton 

per year value, not ton per day emissions as was used by the State’s emission inventory. The 

Sparse Matrix Operator Kernel Emissions (SMOKE) model takes those tons per year emissions 
99

and breaks them into hourly emissions using the temporal profiles built into the SMOKE model. 

Using this SMOKE temporal profile fewer residential wood burning emissions are placed into 

the model in the summer months, as most residential wood burning is not done in the summer. 

This would also be consistent with how the New Jersey Department of Environmental Protection 

(NJDEP) developed emissions in its inventory. However, SMOKE further speciates the tons of 

VOC from woodsmoke into specific species, so that it is not possible from the SMOKE output to 

see where that ton of emissions went. The ton of VOC disappears into the sum of all component 

species. 

5.2.2.2.2 Emission Control Inventories

The following is a summary of the future year inventories that were developed:

• Three projection years: 2009, 2012, and 2018; 

• Three source sectors: non-Electric Generating Units (non-EGUs) point sources, area 

sources, and nonroad mobile sources. Under separate efforts, MANE-VU prepared EGU 

projections using the Integrated Planning Model and onroad mobile source projections 

using the SMOKE emission modeling system. The documentation for those efforts is 

included in Appendix B5-1.

The two emission control scenarios are: 

1) A combined “on-the-books/on-the-way” (OTB/OTW) control strategy accounting for 

emission control regulations already in place, as well as some emission control 

regulations that are not yet finalized but are likely to achieve additional reductions by 

2009 (i.e., adoption of the six shortfall measures by states outside the core Ozone 

Transport Region states); and

2) A beyond on the way (BOTW) scenario to account for controls from potential new 

regulations that may be necessary to meet attainment and other regional air quality goals.

The inventories were developed for seven pollutants, which are SO2, NOx, VOCs, carbon 

monoxide, PM10-Primary (sum of the filterable and condensable components), PM2.5-Primary (sum of 

the filterable and condensable components), and ammonia.

The states included in the emission inventory are those that comprise the MANE-VU region. In 

addition to the District of Columbia, the 11 MANE-VU states are Connecticut, Delaware, Maine, 

Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, 

and Vermont.

An inventory technical support document for these future inventories is included in Appendices

B5-1 and B5-2 and explains the data sources, methods, and results for future year emission 

forecasts for three years; three emission sectors; two emission control scenarios; seven 

pollutants; and eleven states plus the District of Columbia.
100

5.2.2.3 Emissions Processor Selection and Configuration

The SMOKE Processing System was selected for the modeling analysis. SMOKE is principally 

an emissions processing system; this means that, with the exception of mobile and biogenic 

sources, its purpose is to provide an efficient, modern tool for converting emissions inventory 

data into the formatted emissions files required for a photochemical air quality model.

Inside the Ozone Transport Region, the modeling inventories were processed by the NYSDEC 

and NESCAUM using the SMOKE (Version 2.1) processor to provide inputs for the CMAQ 

model. A detailed description of all SMOKE input files such as area, mobile, fire, point, and 

biogenic emissions files and the SMOKE model configuration are provided in Appendices B6, 

B7, and B8.

5.2.2.4 Regional Modeling Coordination

The CMAQ model was installed at all participating modeling centers and diagnostic tests were 

run to insure that the model was operating as designed. In addition, the CMAQ model was 

benchmarked against other modeling platforms to ensure similar results. The OTC modeling 

committee oversaw the modeling effort and reported to the OTC Oversight Committee. The 

NJDEP participated as a member of the various OTC committees. While the focus of this 

modeling effort was to develop estimates of ozone formation, care was taken during the process 

to ensure that the data developed could be useful for future particulate SIP efforts.

5.2.2.5 Domain and Data Base Issues

5.2.2.5.1 Episode Selection

The entire 2002 base case and 2009 future case years were simulated with 2002 meteorological 

conditions for PM2.5 modeling. This complete year of modeling provides a more robust analysis 

of the seasonal variations in PM2.5 levels due to secondary aerosol formation, an important 

pathway to understanding the transport of particulate matter from out-of-state sources.

5.2.2.5.2 Size of the Modeling Domain

In defining the modeling domain, the location of the local urban area, the downwind extent of the 

elevated PM2.5 levels, the location of large emission sources, and the availability of 

meteorological and air quality data need to be considered. The domain or spatial extent to be 

modeled includes as its core the nonattainment area. Beyond this, the domain includes enough 

of the surrounding area such that major upwind sources fall within the domain and the emissions 

produced in the nonattainment area remain within the domain throughout the day.

Figure 5.1 shows the OTC modeling boundaries. This domain covers the Northeast region, 

including the Northeastern, Central and Southeastern United States as well as Southeastern 

Canada. The final SIP modeling analysis utilized this modeling domain. Further discussion of 

the modeling domain selection is provided in Appendices B1 and B3.
101

Figure 5.1: Mid-Atlantic/Northeast Visibility Union 12-Kilometer CMAQ Modeling 

Domain

5.2.2.5.3 Horizontal Grid Size

The basic CMAQ modeling platform utilized a two-way nested domain consisting of a course 36 

km horizontal grid resolution for the continental United States domain and a fine 12-km grid 

over the eastern United States. A larger domain was selected for the MM5 simulations to 

provide a buffer of several grid cells around each boundary of the CMAQ 36 km domain. This 

was designed to minimize any errors in the meteorology from boundary effects. A 12 km inner 

domain was selected to better characterize air quality in the Ozone Transport Region and 

surrounding Regional Planning Organization regions. The horizontal grid definitions for the 

CMAQ and MM5 modeling domains are contained in Appendices B1 and B3.

5.2.2.5.4 Vertical Resolution

The vertical grid used in the CMAQ modeling was primarily defined by the MM5 vertical 

structure. The MM5 model employed a terrain following coordinate system defined by 

atmospheric pressure. The layer averaging scheme adopted for CMAQ was designed to reduce 

the computational demands of the CMAQ simulations, therefore only the uppermost layers of the 

CMAQ domain were coalesced. All layers in the planetary boundary layer were unchanged 

between the MM5 and the CMAQ simulation. This ensures that the near-surface processes that 
102

affect air pollution the most are represented realistically in CMAQ, while the meteorological 

systems that are driven by upper level winds are allowed to develop properly in MM5. The 

effects of layer averaging have a relatively minor effect on the model performance metrics when 

compared to ambient monitoring data. The vertical layer definitions and other details related to 

the MM5 and CMAQ modeling domains are contained in Appendices B1 and B3.

5.2.2.5.5 Initial and Boundary Conditions

The objective of a photochemical grid model is to estimate the air quality given a set of 

meteorological and emissions conditions. When initializing a modeling simulation, the exact 

concentration fields are not known in every grid cell for the start time. Therefore, typically 

photochemical grid models begin with clean conditions within the domain and are allowed to 

stabilize before the period of interest is simulated. In practice this is accomplished by starting 

the model several days prior to the period of interest; this is called spin-up time.

The winds move pollutants into, out of, and within the domain. The model handles the 

movement of pollutants within the domain and out of the domain. An estimate of the 

concentration of pollutants at the edge of the domain, and therefore the quantity of pollutants 

moving into the domain, is needed as an input to the model. These are called boundary 

conditions. The 12 km grid boundary conditions were extracted from the 36 km CMAQ 

simulation. To estimate the boundary conditions for the modeling study, boundary conditions 

for the inner OTR 12-km grid used hour by hour boundary conditions extracted from the 

continental 36 km CMAQ run results by researchers at Harvard University using the GEOSCHEM global chemical transport model.202,203

The influence of initial conditions was minimized by using a 15-day spin-up period, which is 

sufficient to establish pollutant levels that are encountered in the eastern United States. 

Additionally, the predominant winds flow from west to east, thus New Jersey is not influenced 

by nearby boundary conditions as the boundary begins in the states west of the Mississippi River. 

Additional information on the extraction of boundary conditions is provided in Appendix B1.

5.2.2.6 Quality Assurance

All the air quality, emissions, and meteorological data within the MANE-VU Regional Planning 

Organization used in the regional modeling effort were reviewed to ensure completeness, 

accuracy, and consistency before proceeding with modeling. Any errors, missing data or 

inconsistencies, were addressed using appropriate methods that are consistent with standard 

practices. All modeling was benchmarked through the duplication of a set of standard modeling 

results across different modeling centers using different computer platforms to calculate results. 

Emissions inventories obtained from the other Regional Planning Organizations were examined 

 202 Moo, N. and Byun, D. A Simple User’s Guide For “geos2cmaq” Code: Linking CMAQ with GEOS-CHEM. 

Version 1.0. Institute for Multidimensional Air Quality Studies (IMAQS). University of Houston, Houston, Texas, 

2004.

203 Baker, K. Model Performance for Ozone in the Upper Midwest over 3 Summers. Presentation given at the Lake 

Michigan Air Directors Consortium, 2005 AWMA Annual Conference, Minneapolis, MN, June 24, 2005. 
103

to check for errors in the emissions estimates. When such errors were discovered, the problems 

in the input data files were corrected, and the models were run again. 

The CMAQ air quality model inputs and outputs were plotted and examined to ensure 

sufficiently accurate representation of the observed data in the model ready fields, and temporal 

and spatial consistency and reasonableness. The output of the CMAQ model results for the 2002 

period underwent operational and scientific evaluations of the meteorological and air quality 

modeling data used and is discussed in greater detail in Section 5.2.2.7.

5.2.2.7 Model Performance Evaluation

The first step in the modeling process is to verify the model’s performance in terms of its ability 

to predict particulate concentration fields in the right locations and at the right levels. To do this, 

model predictions for the base year simulation are compared to the actual ambient data observed 

in the historical episode. This verification is a combination of statistical and graphical 

evaluations. If the model appears to be predicting particulate matter in the right locations for the 

right reasons, then the model can be used as a predictive tool to evaluate various control 

strategies and their effects on particulate formation. The purpose of the model performance 

evaluation is to assess how accurately the model predicts particulate levels observed in the 

historical episode and to use the knowledge of CMAQ’s performance to put CMAQ’s 

predictions of future year air quality in the appropriate context so that future policy decisions are 

informed by CMAQ’s predictions and its performance. 

The results of a model performance evaluation were examined prior to using CMAQ’s results to 

support the attainment demonstration. The performance of CMAQ was evaluated using both 

operational and diagnostic methods. Operational evaluation refers to the model’s ability to 

replicate observed concentrations of particulate matter and/or its precursors (surface and aloft), 

whereas diagnostic evaluation assesses the model’s accuracy with respect to characterizing the 

sensitivity of particulate formation to changes in emissions (i.e., relative response factors). 

The NYSDEC conducted a performance evaluation of the 2002 base case CMAQ simulation for 

PM2.5 on behalf of the Ozone Transport Region member states. Appendix B9 provides 

comprehensive operational and diagnostic evaluation results, including spreadsheets containing 

the assumptions made to compute statistics. Highlights of this evaluation are summarized in 

Section 5.2.2.7.1.

5.2.2.7.1 Summary of Model Performance

The CMAQ model was employed to simulate PM2.5 for the entire year of 2002. A comparison of 

the temporal and spatial distributions of PM2.5 and its precursors was conducted for the study 

domain, with additional focus placed on performance in both the Northern New Jersey/New 

York/Connecticut and Southern New Jersey/Philadelphia nonattainment areas.

The model performance for both Northern New Jersey/New York/Connecticut and the Southern 

New Jersey/Philadelphia nonattainment areas averaged over all stations and all days met the 

guidelines in the USEPA Modeling Guidance. Applying those criteria to individual days is a 
104

much more stringent test that is not required by the USEPA. In general, the CMAQ model 

results were best for daily maximum ozone and daily average PM2.5 and sulfate (SO4) mass.

No significant differences in model performance for particulate matter and its precursors were 

encountered across different areas of the Ozone Transport Region. While there are some 

differences in the spatial data among sub-regions, there is nothing to suggest a tendency for the 

model to respond in a systematically different manner between regions. Examination of the 

statistical metrics by sub-region confirms the absence of significant performance problems 

arising in one area but not in another, building confidence that the CMAQ modeling system is 

operating consistently across the full Ozone Transport Region domain.

Also, the USEPA Modeling Guidance suggests the use of the concentrations estimated from the 

mean of the nearby grid cells where the ambient monitor is located unless large concentration 

gradients are encountered within the adjoining grid cells. If the modeling shows that large 

concentration gradients exist then the USEPA guidance suggests using only the concentration 

from the grid cell containing the monitor. An analysis of the Relative Reduction Factors (RRFs) 

in the grid cell containing the monitor and the average of the nine grid cells surrounding the 

monitor shows that large concentration gradients do not exist in the modeling conducted. This 

analysis is presented in Appendix B10 of this SIP and shows relatively consistent results whether 

the concentrations of the one cell or concentrations of the average of nine cells are used. The 

attainment demonstration will, therefore, present the RRFs for the nine cell mean or average of 

the grid cells as this is consistent with USEPA guidance.204

As stated previously, the model performance for the 2002 annual run meets all USEPA 

guidelines and thus demonstrates that the modeling platform is appropriate for modeling

emissions control scenarios for the Northern New Jersey/New York/Connecticut and the 

Southern New Jersey/Philadelphia nonattainment areas. The CMAQ model has been evaluated 

by using measures that reflect its ability to represent average conditions instead of its ability to 

respond to changes in emissions. Therefore, although CMAQ has met the traditional 

performance measures as stated in the USEPA Modeling Guidance, it may in fact under or over 

predict the magnitude of secondary aerosol formation changes due to the various control 

measures being modeled. This means future year (i.e., 2009) modeling results should not be 

viewed as exact, but should be utilized in a relative manner (see Section 5.2.4). Additional 

discussion on the uncertainty associated with the CMAQ model results is provided in Section 

5.3. 

5.2.3 Control Measures Modeled

As previously stated, the objective of the photochemical modeling analysis is to enable state air 

agencies to analyze the efficacy of various control strategies, and to demonstrate that the 

measures included as part of the SIP will result in attainment of the PM2.5 standard by 2009. 

 204 USEPA. Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality 

Goals for Ozone, PM2.5, and Regional Haze. United States Environmental Protection Agency, Office of Air Quality 

Planning and Standards, Air Quality Analysis Division, Air Quality Modeling Group, Research Triangle Park, NC, 

EPA-454/B-07-002, April 2007, page 28.
105

New Jersey’s attainment demonstration relies on the Beyond-on-the-Way (BOTW) 2009 

modeling run, which predicts future 2009 air quality conditions, after accounting for all air 

pollution controls that have been implemented since the base year of 2002 (OTB/OTW 

measures), and applying new control measures (BOTW measures) that will be implemented in 

time to reduce emissions in 2009. Table 5.1 lists all of the control measures included for New 

Jersey in the projected 2009 BOTW CMAQ modeling run. Each of these control measures is 

discussed in detail in Chapter 4.

While Table 5.1 shows all the OTB/OTW and BOTW measures that New Jersey took into 

account within the 2009 attainment demonstration model run, the overall attainment 

demonstration is reliant upon all the states' in the Ozone Transport Region implementing 

measures to reduce the amount of their emissions in order for New Jersey to achieve its goals. 

Table 5.2 shows which BOTW measures each state in the Ozone Transport Region believed 

would be implemented in time to achieve benefits in 2009. These were the measures included in 

the BOTW model run for each state.
106

Table 5.1: Modeled Control Measures Included in the 2009 BOTW Model Run

Pre-2002 with benefits achieved Post-2002 - On the Books

Federal

Residential Woodstove NSPS

Onboard Refueling Vapor Recovery (ORVR) beyond Stage II

Tier 1 Vehicle Program

National Low Emission Vehicle Program (NLEV)

Tier 2 Vehicle Program/Low Sulfur Fuels

HDDV Defeat Device Settlement

HDDV Engine Standards

Nonroad Diesel Engines

Large Industrial Spark-Ignition Engines over 19 kilowatts

Recreational Vehicles (includes snowmobiles, off-highway motorcycles, and all-terrain vehicles)

Diesel Marine Engines over 37 kilowatts 

Phase 2 Standards for Small Spark-Ignition Handheld Engines at or below 19 kilowatts

Phase 2 Standards for New Nonroad Spark-Ignition Non-Handheld Engines at or below 19 

kilowatts

Post-2002 - On the Books

New Jersey Measures Done Through a Regional Effort

Consumer Products 2005 

Architectural Coatings 2005 

Portable Fuel Containers 2005 (Area Source Only)

Mobile Equipment Repair and Refinishing

Solvent Cleaning

NOx RACT Rule (2006)

New Jersey Heavy Duty Diesel Rules Including "Not-To-Exceed" (NTE) Requirements

New Jersey Only

Stage I and Stage II (Gasoline Transfer Operations)

On-Board Diagnostics (OBD) – (I/M) Program for Gasoline Vehicles

Federal

USEPA MACT Standards

Acid Rain

CAIR (NOx Controls in 2009 Only)

Refinery Consent Decrees (Sunoco, Valero, and ConocoPhillips)

Post-2002 - Beyond on the Way

New Jersey Measures Done Through a Regional Effort

Consumer Products 2009 Amendments

Portable Fuel Containers 2009 Amendments (Area Source Only)

Asphalt Paving
107

Adhesives and Sealants

Industrial/Commercial/Institutional (ICI) Boiler Rule 2009

Controls from EGU Consent Decrees (PSE&G Mercer)

Controls from EGU Consent Decrees (PSE&G Hudson NOx)

New Jersey Only

New Jersey Low Emission Vehicle (LEV) Program
108

Table 5.2: Ozone Transport Region-Wide Modeling Assumptions for the 2009 BOTW Model Run

< 25 

mmBtu/

hr

25-50 

mmBtu/

hr

50-100 

mmBtu/

hr

< 25 

mmBtu/

hr

25-50 

mmBtu/

hr

50-100 

mmBtu/

hr

100-250 

mmBtu/

hr

>250 

mmBtu/

hr

NY NAA

Connecticut x x x x x x x x x x x x

New Jersey x x x x x x x x

New York x x x x x x x x x x x x x x

Phila. NAA

Delaware x x x x

Maryland x x x x x x x

New Jersey x x x x x x x x

Pennsylvania x x x x

Other States

Maine x x x x

New Hampshire x x x x x x

Vermont

Massachusetts x x x x

Rhode Island x x x x

DC x x x x x

ICI Boilers - Area Sources 

*Source: MACTEC. Development of Emission Projections for 2009, 2012, and 2018 for NonEGU Point, Area, and Nonroad Sources in the MANE-VU Region, Final 

TSD. Prepared for the Mid-Atlantic Regional Air Management Association by MACTEC Federal Programs, Inc., February 28, 2007.

Adhesives & 

Sealants

Consumer 

Products 

2005/2009

PFC 

2005/

2009

Asphalt 

Paving

Asphalt 

Plants

ICI Boilers - Non-EGU Point Sources

Cement 

Kilns

Glass 

Furnances
109

It is also important to note that the 2009 BOTW modeling did not contain the first round of 

Clean Air Interstate Rule (CAIR) controls for SO2 expected to occur in 2010. If these lowered 

emissions were modeled, the modeling results would show lower predicted levels of PM2.5 than 

are presented in this attainment demonstration. Implementation of the CAIR SO2 controls is 

expected to provide a more assurance that the annual PM2.5 standard of 15.0 μg/m3 will be 

attained by 2010. 

5.2.4 Photochemical Modeling Results

The USEPA recommends using the regional photochemical model estimates in a “relative” 

rather than “absolute” sense, due to the uncertainties and biases in the modeling system. Thus, 

the assumption is that the change between the modeled base year (2002) and the modeled future 

year (2009) reflects the impact of growth and control over time and is an appropriate use of the 

results. The “absolute” modeled results are used in a “relative” sense by applying the ratios of 

the model’s future to current (baseline) predictions at each PM2.5 monitor to the actual 2002 

design values, thereby grounding the future design value to the monitored results. These ratios 

are termed the “relative reduction factor” (RRF). An RRF is defined by the USEPA as the ratio 

of a future maximum concentration predicted “near a monitor” to a baseline maximum 

concentration predicted “near the monitor” averaged over selected days.205,206 More simply put, 

the RRF is the ratio of average future concentrations over average baseline concentrations for 

each monitoring site. 

The baseline design values used in the modeling application were calculated differently from the 

monitored design values although both are based on monitored ambient air quality data. The 

monitoring design values are calculated as the three-year average of the one-year annual average 

values where the one-year annual average value for a given year is first calculated using the 

quarterly average of the daily values at each monitoring site. In other words, the quarterly 

average mass is calculated first, and then the average annual mass is calculated from the 

quarterly values for a given year. For modeling purposes, the baseline design value is calculated 

by averaging three three-year design value periods, centered on the base inventory year of 2002. 

Specifically, the modeling baseline design value was calculated using the 2000-2002, 2001-2003, 

and 2002-2004 periods. For more information about the modeling design values and how they 

were calculated, see Appendices B11-1 and B11-2. The average annual base line design value 

(DVB-I) as shown in Table 5.3 and Table 5.4 was calculated using the three, three-year average 

design values centered around the 2002 base year. These values, calculated using the five years 

of monitoring data from 2000 to 2004, were then applied to the modeling output using the 

relative reductions as determined by the future year modeling.

Four monitoring sites located in New Jersey contain monitors that measure the component 

species of PM2.5 and are designated as Speciation Trends Network (STN) monitors. These 

monitors are located in Camden, Chester, Elizabeth, and New Brunswick. The STN monitoring 

program provides for the concentration of major ions, carbon compounds, and trace elements 

 205 ibid. 206 “Near a monitor” was determined by using an average of the concentration predicted within a 3x3 array of grid 

cells surrounding each monitor, as recommended by the USEPA for 12-km grid resolution modeling.
110

which constitute the bulk of the PM2.5 mass. The STN samplers operate on a one-in-three day 

sampling schedule. It is important to note that only one of the STN samplers, the Camden 

monitor, is located in the New Jersey portion of the Southern New Jersey/Philadelphia 

nonattainment area; the other three (Chester, Elizabeth, and New Brunswick) are located in the 

Northern New Jersey/New York/Connecticut nonattainment area.

Most of the samples from the PM2.5 monitoring sites in New Jersey are collected and analyzed 

according to the Federal Reference Method (FRM). The FRM for fine particulate matter 

requires a 24-hour collection period using a filter-based collection method to measure fine 

particulate mass. The FRM samplers, like the STN samplers, operate on a one-in-three day 

schedule. Also, as per the network design requirements, several FRM sites have collocated 

duplicate samplers or measure fine particulate matter by other means than the Federal Reference 

Method (e.g., Tapered Element Oscillating Microbalance (TEOM) sampling).

It is important to understand the unique aspects of measuring and modeling particulate matter as 

it relates to determining attainment. The PM2.5 attainment test uses both the total PM2.5 mass 

results from the FRM monitors as well as the individual components of PM2.5 as measured at the 

STN sites. Therefore, the modeled attainment test for PM2.5 is called the Speciated Modeled 

Attainment Test (SMAT). In order to perform the recommended modeled attainment, the 

observed total mass concentrations of PM2.5 as measured at the FRM monitoring sites need to be 

first partitioned into seven components (plus passive mass).207 These components are:

• Mass associated with sulfates

• Mass associated with nitrates

• Mass associated with ammonium

• Mass associated with organic carbon

• Mass associated with elemental carbon

• Mass associated with particle bound water

• Mass associated with “other” primary inorganic particulate matter, and

• Passively collected mass.

A separate site specific calculation of the quantity of the component species was performed for 

each of these PM2.5 components (except passive mass) for each FRM monitoring site. This 

calculation applied the same ratio of each species collected from the “nearest” STN site, to the 

total PM2.5 mass measured at the FRM site. Each of these site-specific ratios is called a 

component-specific design value. 

Future PM2.5 design values were estimated at each existing FRM monitoring site by multiplying 

the modeled RRF “near” each monitor times the observed “component specific design value.” 

Future total PM2.5 design values at a site were then estimated by summing the future year design 

values of the seven PM2.5 components. If the total of all future species-specific PM2.5 annual 

 207 The monitors are located either within the boundaries of the nonattainment area, or in close proximity to the 

nonattainment area.
111

design values for each site was less than or equal to 15.0 μg/m3

, the annual PM2.5 NAAQS, the 

test for attainment of the standard, is passed.

Since the USEPA Speciated Modeled Attainment Test software is not available for the states to 

use for their attainment demonstrations, the following procedure was performed by the NYSDEC 

and the UMDNJ/ORC (see Appendices B2, B11-1, B11-2, and B12), following the USEPA 

guidance for modeling attainment of the PM2.5 health standard, to analyze the 2009 BOTW 

modeling results.

1. Using the data provided by the USEPA Region 2208 on the monitored levels of particulate 

matter through the USEPA’s Air Quality System (AQS) database, the quarterly averages 

of Federal Reference Method (FRM) mass for each monitor were determined.

2. The average quarterly STN speciation ratio for the years 2002 to 2004 (using the 

Camden, Chester, Elizabeth, and New Brunswick, New Jersey and the four New Yorksited STN monitors to determine the fraction of each species that would be present in the 

total PM2.5 mass measured at the FRM monitoring sites) was determined. (Note: In order 

to ensure that comparable mass measurements between STN and FRM measurement 

techniques were used, an adjustment for a blank correction was made to remove the blank 

mass). 

3. The quarterly RRF values from the modeling results for all the species using the 2002 

Base B1 and 2009 BOTW B4 were calculated (Note: nine cell averages of the grid cells 

surrounding each monitoring site were used to calculate the RRF.)

4. The measured FRM mass at each monitoring site was divided by the total mass into the 

individual species using the ratio from Step 2.

5. Computed future values of species other than water and ammonia through RRF scaling 

using the Degree of Neutralization (DON) and future sulfate, retained nitrate to estimate 

the ammonia concentration, and a polynomial approximation from the NYSDEC to 

estimate water within the total PM2.5 mass.209 

6. The blank mass was then added back to the total mass to determine the total measured 

PM2.5 mass so that the predicted modeled results could be directly compared to measured 

concentrations.

The following equation illustrates how New Jersey calculated the future design values for each 

monitoring site (i):

(RRF)ij for each species = ([Cj,projected of species x ]/[Cj,current of species x])i

 208 Personal communication by e-mail, entitled “Fw: Re: Files from MATS,” between Kenneth Fradkin, USEPA, 

Region 2 and Ray Papalski, NJDEP, August 17, 2007.

209 See Appendix B12.
112

Where:

Cj,current is the quarterly mean concentration of species x predicted at or near the monitoring site 

(i) with emissions characteristic of the period used to calculate the baseline design value for 

annual PM2.5

Cj,projected is the future year quarterly mean concentration of species x predicted at or near the 

monitoring site (i) from a representative STN monitoring location.

The design value for each species or component was then calculated as follows:

DVF-I for each species = (RRFI * DVB-I ) 

Where:

DVB-I = the average base concentration (design value) of each component monitored at site I, in 

micrograms per cubic meter (μg/m3

)

RRFI = the relative response factor calculated for each component at site (i) 

DVF-I = the estimated future design value for the time attainment is required, in μg/m3

The quarterly mean of each component was then summed to get quarterly mean PM2.5 values. 

Then the quarterly mean PM2.5 concentrations were averaged to get a future year annual average 

PM2.5 estimate for each FRM monitoring site. 

Table 5.3 shows the PM2.5 modeling results using the 2009 BOTW run for all monitors located 

within the Northern New Jersey /New York/Connecticut nonattainment area.
113

Table 5.3: 2009 Modeled PM2.5 Design Values for the

Northern New Jersey/New York/Connecticut Nonattainment Areas

(Bold Type indicates Values over the Annual Standard of 15.0 μg/m3)

Site ID Monitoring Site Name State Name

Average Annual 

Baseline Design 

Value (DVB-I)

(μg/m3)

Projected 2009 

Annual Design 

Value (DVF-I) 

(μg/m3)

90010010 Bridgeport - Roosevelt School Connecticut 13.1 11.5

90010113 Bridgeport - Congress Street Connecticut 12.6 11.2

90011123 Danbury Connecticut 12.8 11.2

90012124 Stamford Connecticut 12.9 11.4

90013005 Norwalk Connecticut 12.9 11.3

90019003 Westport Connecticut 11.8 10.4

90090018 New Haven - Stiles Street210 Connecticut 16.3 14.4

90091123 New Haven- 715 State St Connecticut 13.7 11.7

90092123 Waterbury Connecticut 13.1 11.2

90099005 Hamden Connecticut 11.6 9.9

340030003 Fort Lee Library New Jersey 13.7 12.1

340130015 Newark Cultural Center New Jersey 13.9 11.8

340130016 Newark Lab New Jersey 14.7 12.5

340171003 Jersey City Primary New Jersey 14.9 13.3

340172002 Union City New Jersey 16.0 14.3

340210008 Trenton New Jersey 13.9 11.8

340218001 Washington Crossing New Jersey 11.9 10.1

340230006 New Brunswick New Jersey 12.5 10.4

340270004 Morristown New Jersey 12.4 10.4

340273001 Chester New Jersey 11.1 9.3

340310005 Paterson New Jersey 13.2 11.4

340390004 Elizabeth New Jersey 15.7 13.5

340390006 Elizabeth Downtown New Jersey 13.5 11.8

340392003 Rahway New Jersey 13.1 11.4

360050080 Morrisania Center -Gerard Ave. New York 15.8 14.2

360050083 Botanical Gardens New York 13.8 12.4

360050110 East 156 Street New York 14.7 13.3

360470052 PS 314-60th St and GawanusExp. New York 15.2 13.4

360470076 PS 321- 180 7th Ave. New York 14.4 12.7

360470122 JHS 126 424 Leonard St New York 14.7 13.0

 210 The New Haven/Stiles St. monitor was designated as a “special purpose” monitor, and as such cannot be used to 

make an attainment or nonattainment designation. The site was found to be overly influenced by micro-scale 

phenomena, including heavy duty truck exhaust from trucks leaving the New Haven Terminal area and accelerating 

uphill on the Interstate-95 on-ramp. The monitor was less than twenty feet from the traffic lane. Following a 

special, multi-site monitoring study conducted by CTDEP, the Stiles Street monitor was deemed unrepresentative of 

population exposure in the City of New Haven. In 2006, it was shut down as part of the I-95 bridge reconstruction 

project. The information on this site, therefore, is for informational purposes only and should not be used to assess 

attainment of the standard.
114

Site ID Monitoring Site Name State Name

Average Annual 

Baseline Design 

Value (DVB-I)

(μg/m3)

Projected 2009 

Annual Design 

Value (DVF-I) 

(μg/m3)

360590012 East Hills Elementary School New York 11.9 10.5

360590013 1055 Stewart Place New York 12.0 10.6

360610056 PS 59, 288 E. 57th St., Manhattan New York 17.4 15.3

360610062 Post Office, 350 Canal St. New York 16.3 14.1

360610079 School IS 45, 2351 1st Ave. New York 14.7 12.9

360610128 PS 19, 185 1st Avenue New York 15.9 14.0

360710002 NYC- 55 Broadway New York 11.5 10.2

360810094 NYC- PS 29 125-10 23rd Avenue New York 13.7 12.1

360810096 NYC- 3115 140th Street New York 13.7 12.1

360810124 NYC- 14439 Gravett Road New York 13.3 11.8

360850055 Post Office, 364 Port Richmond New York 14.0 12.0

360850067 Susan Wagner New York 12.1 10.4

361030001 East Farmingdale Water Plant New York 12.1 10.6

361191002

5th Avenue & Madison, Thruway 

Exit 9 New York 12.3 10.8

As can be seen from this table, the only site with a projected 2009 design value greater than the 

annual fine particulate standard of 15.0 μg/m3 is the P.S. 59 site located in Manhattan, New York 

City. This is also illustrated in Figure 5.2. All other sites are below the annual fine particulate 

standard. The projected 2009 value for the P.S. 59 site is within the weight-of-evidence range of 

values defined in the PM2.5 modeling guidance as 14.5 μg/m3 through 15.5 μg/m3

.

211 Further 

justification to explain why New Jersey, New York, and Connecticut believe that fine particulate 

levels at this site as well as all other sites, will be lower than predicted in 2009 and why this site 

will achieve the annual standard by 2009 is presented in Section 5.3

Table 5.4 shows the PM2.5 modeling results using the 2009 BOTW run for all monitors located 

within the Southern New Jersey/Philadelphia nonattainment area.

 211 USEPA. Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality 

Goals for Ozone, PM2.5, and Regional Haze. United States Environmental Protection Agency, Office of Air Quality 

Planning and Standards, Air Quality Analysis Division, Air Quality Modeling Group, Research Triangle Park, NC, 

EPA-454/B-07-002, April 2007, page 105.
115

Figure 5.2: Map of the 1997 PM2.5 Northern New Jersey/New York/Connecticut 

Nonattainment Area

Table 5.4: 2009 Modeled PM2.5 Design Values for the Southern New 

Jersey/Philadelphia/Delaware Nonattainment Area

(Bold Type indicates Values over the Annual Standard of 15.0 μg/m3)

Site ID Monitoring Site Name State Name

Average Annual 

Baseline Design 

Value (DVB-I)

(μg/m3)

Projected 2009 

Annual Design 

Value(DVF-I) 

(μg/m3)

100031003 Bellefonte Delaware 14.7 12.6

100031007 Lums2 Delaware 13.6 11.4

100031012 Newark-Univ. Del. No. Campus Delaware 15.0 12.8

100032004 Wilmington Delaware 16.0 13.7

340070003 Camden New Jersey 14.3 12.3

340071007 Pennsauken New Jersey 14.3 12.4

340155001 Clarksboro New Jersey 13.7 11.8

420170012 Bristol Pennsylvania 14.1 12.0

420290100 New Garden (Airport) Pennsylvania 14.9 12.5

420450002 Chester Pennsylvania 15.3 13.3

420910013 Norristown Pennsylvania 13.7 11.9

421010004 Frankford (Lab Pennsylvania 14.9 12.9

421010014

Philadelphia- Roxy Water Pump 

Station Pennsylvania 13.6 11.8

421010020

Philadelphia- Belmont Avenue 

Water Plant Pennsylvania 14.2 12.4
116

Site ID Monitoring Site Name State Name

Average Annual 

Baseline Design 

Value (DVB-I)

(μg/m3)

Projected 2009 

Annual Design 

Value(DVF-I) 

(μg/m3)

421010024 Philadelphia - Northeast Airport Pennsylvania 13.8 11.8

421010047

Philadelphia- 500 South Broad 

Street212 Pennsylvania 16.1 13.9

421010052

Philadelphia- 1439 East Passyunk 

Avenue Pennsylvania 13.1 11.4

421010136 Philadelphia- Southwest (Elm) Pennsylvania 14.5 12.6

As can be seen from this table, all sites in the Southern New Jersey/Philadelphia nonattainment 

area are projected to be below the annual fine particulate standard of 15.0 μg/m3 and below the 

weight of evidence range of values. 

5.3 Demonstrations

5.3.1 Introduction

A modeled attainment demonstration consists of: 

• Analyses which estimate whether selected emission reductions will result in ambient 

concentrations that meet the NAAQS, and 

• An identified set of control measures which will result in the required emission 

reductions. 

An analysis of the selected emission reductions which will result in ambient concentrations that 

meet the annual PM2.5 NAAQS is discussed in Section 5.2.4. The measures included in the 

photochemical modeling, the 2009 BOTW modeling run, are listed in Table 5.1. Table 5.3 and 

Table 5.4 provide 2002 modeling baseline design value concentrations and projected 2009 

annual PM2.5 concentrations, by nonattainment area. These tables show that all but one monitor 

in the Northern New Jersey/New York/Connecticut nonattainment area and all the monitors in 

the New Jersey/Philadelphia nonattainment area are predicted to be in attainment of the annual 

PM2.5 NAAQS by the attainment date of April 5, 2010. 

In the Northern New Jersey/ New York/Connecticut nonattainment area, one monitor is 

predicted to be above the annual PM2.5 standard of 15.0 μg/m3 in 2009. This monitor is located 

at P.S. 59 in Manhattan, New York City. This monitor is predicted to be at a value of 15.3 

 212 The site at 500 South Broad St. was the design value monitoring site for the City of Philadelphia for PM2.5

NAAQS, and had been an area of focus for the USEPA-Region 3 due to the need to find a suitable location for this 

monitoring site as a result of the pending closure of the 500 South Broad Street office. Additionally, data from the 

fourth quarter of 2005 have not been quality assured but had been reported to AIRS-AQS. The NJDEP expects that 

the City of Philadelphia and the State of Pennsylvania will resolve the data quality issues with this site in the near 

future and address them in their own State’s SIP. It is not expected that this site will be over the annual standard of 

15 μg/m3 using the latest, quality-assured monitoring data.
117

μg/m3

. This value is within the weight-of-evidence range that is defined in USEPA guidance: 

14.5 μg/m3 to 15.5 μg/m3.

213 Additional emission reductions of PM2.5 and precursors will occur 

between now and 2009 and are discussed in Section 5.3.2.6.

In the Southern New Jersey/Philadelphia nonattainment area, the monitors located in New 

Jersey, Pennsylvania (Philadelphia area), and Delaware are predicted to come into attainment by 

2009 (see Table 5.4). The highest value predicted in this nonattainment area is located on Broad 

Street in Philadelphia, PA, and the value is predicted to be 13.9 μg/m3

. This value is below the 

weight-of-evidence range that is defined in the USEPA guidance: 14.5 μg/m3 to 15.5 μg/m3. 

Additional emission reductions of PM2.5 and precursors will occur between now and 2010 and 

are discussed in Section 5.3.2.5. 

5.3.2 Supplemental Analysis/Weight-of-Evidence

While the USEPA attainment demonstration guidance emphasizes a single design value from a 

single modeling simulation as the core of any attainment demonstration, 214 it also supports, in 

conjunction with the Clean Air Act Advisory Committee (CAAAC), states utilizing a multianalysis approach to their PM2.5 attainment demonstrations.215 This is because the principles of 

atmospheric science acknowledge that, in using models, all of the uncertainties and biases need 

to be considered. Uncertainties associated with emission inventories, meteorological data, and 

the representation of photochemistry in the model can result in over or under predictions in 

design values. The CAAAC also recommends that states decrease reliance on modeling results 

to demonstrate attainment and rather focus more on ambient air monitoring data.

5.3.2.1 Monitoring Data Shows Trend toward Attainment of the Annual PM2.5 

NAAQS and a Downward Trend in Ambient Air Concentrations

Tables 5.5 and 5.6 present the annual average monitoring results and design values, respectively, 

from the Northern New Jersey/New York/Connecticut nonattainment area PM2.5 monitors from 

2000 through 2006. These monitoring results show that the measured values at the monitors in 

the nonattainment area have generally been decreasing since 2000, and that the monitored values 

in 2006 were all below the lower range of values for the weight-of-evidence range for annual 

PM2.5 (14.5 μg/m3 to 15.5 μg/m3

). During the period of 2000 to 2006, two New Jersey monitors 

in the Northern New Jersey/New York/Connecticut nonattainment area were not operating for 

part of the time: Union City and Newark Lab. The site located in Union City, New Jersey had 

the highest annual PM2.5 results in 2000 within the State, although not the highest values within 

the nonattainment area. The annual PM2.5 result at the Union City monitor in 2006 was 13.9 

 213 USEPA. Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals 

for Ozone, PM2.5, and Regional Haze. United States Environmental Protection Agency, Office of Air Quality 

Planning and Standards, Air Quality Analysis Division, Air Quality Modeling Group, Research Triangle Park, NC, 

EPA-454/B-07-002, April 2007, page 17. 214 USEPA. Guidance on the Use of Models and Other Related Analyses in Attainment Demonstrations for the 8-

Hour Ozone NAAQS. United States Environmental Protection Agency, Office of Air Quality Planning and 

Standards, Emissions, Monitoring, and Analysis Division, Air Quality Modeling Group, Research Triangle Park, 

North Carolina, EPA-454/R-05-002, October 2005. 215 ibid.
118

μg/m3

; preliminary results for 2007 show that this value is the same at this monitor and below 

the weight of evidence range of values. The downward trends in these values are consistent with 

the annual PM2.5 results seen in Chapter 2. 

Table 5.6 contains the design values for the monitors in the Northern New Jersey/New 

York/Connecticut nonattainment area. Despite slightly elevated PM2.5 values in 2005, the 2006 

design values are also showing a decreasing trend. These results further reinforce that the New 

Jersey portion of the Northern New Jersey/New York/Connecticut nonattainment area will attain 

the annual PM2.5 standard in 2009.

Tables 5.7 and 5.8 present the annual average monitoring results and design values, respectively, 

from the Southern New Jersey/Philadelphia PM2.5 monitors from 2000 through 2006. These 

monitoring results show that the measured values at the monitors in the nonattainment area have 

been decreasing, and that the monitored values in 2006 were all below the lower range of values 

for the weight-of-evidence range for annual PM2.5 (14.5 μg/m3 to 15.5 μg/m3). The design 

values in Table 5.8 show that the air quality in the New Jersey portion of the Southern New 

Jersey/Philadelphia nonattainment area is in attainment of the annual PM2.5 NAAQS.

These results further reinforce that the New Jersey portion of the Southern New 

Jersey/Philadelphia will attain the annual PM2.5 standard in 2009. 

5.3.2.2 Monitoring Data Shows Progress towards Attainment of the New Daily PM2.5

NAAQS of 35 μg/m3

While the monitoring data shows a consistent downward trend in fine particulate concentrations, 

the monitored values are still above the new 2006 Federal 24-hour NAAQS of 35 μg/m3

. Tables 

5.9 and 5.10 show the monitored fine particulate levels associated with New Jersey’s Northern 

New Jersey/New York/Connecticut nonattainment area and the Southern New 

Jersey/Philadelphia nonattainment, respectively. For 2006, several sites (shown in bold and 

shaded) are above the 35 μg/m3 daily standard but it should be noted that all sites are well below 

the former daily standard of 65 μg/m3. 
119

Table 5.5: Annual Ambient PM2.5 Levels in the Northern New Jersey/New York/Connecticut Nonattainment Area

State County Monitor Site Address 2000 2001 2002 2003 2004 2005 2006

NJ Bergen Fort Lee 14.6 14.5 13.0 13.3 12.0 14.5 11.8

Essex Newark Cultural Center 15.6 13.5 13.2 14.1 13.2 14.3 12.1

Essex Newark Lab 15.3 14.1 13.1

Hudson Jersey City Primary 16.8 14.1 14.3 14.8 13.8 15.2 13.3

Hudson Union City 17.1 15.8 16.8 17.4 13.9

Mercer Trenton 14.7 14.9 13.0 13.5 12.5 13.0 12.5

Mercer Washington Crossing 12.1 12.2 11.5 12.0 11.0 12.1 10.0

Middlesex New Brunswick 13.1 13.2 11.1 13.0 11.2 13.4 10.8

Morris Chester 11.1 11.8 10.5 10.7 10.1 10.9 9.0

Morris Morristown 12.9 13.4 11.5 12.2 11.1 12.5 10.1

Passaic Paterson 13.7 13.1 12.9 13.3 12.6 13.4 12.0

Union Elizabeth Turnpike Primary 16.9 15.8 14.9 16.2 15.2 15.2 14.2

Union Elizabeth Downtown 15.2 13.4 13.1 14.0 12.6 14.3 12.4

Union Rahway 14.2 12.8 12.4 13.3 12.6 14.0 11.9

NY Bronx Morrisania Center, 1225-57 Gerard Ave. 16.6 15.9 15.4 15.7 14.6 16.9 13.9

Bronx 200th St. And Southern Blvd. 14.4 13.5 13.4 12.7 13.9 12.0

Bronx E 156th St. Bet Dawson and Kelly 15.3 14.6 15.0 14.8 13.5 14.8 12.8

Kings Jhs 126 424 Leonard St. 15.3 14.0 14.8 13.8 15.3 12.8

Nassau Lawrence High School, Arlington Place 12.2 12.9 11.4 12.4 11.4 12.4 10.8

New York Ps 59, 288 E. 57th Street 18.5 17.8 16.4 15.4 17.0 14.4

New York Post Office, 350 Canal St. 17.6 17.3 16.0 15.8 14.5 15.7 12.8

New York School Is 45, 2351 1st Ave. 15.5 15.2 14.7 14.5 13.2 14.3 12.7

Orange 55 Broadway 11.6 11.0 11.8 10.4 12.1 9.7

Orange 14439 Gravett Rd. 14.2 12.7 13.5 12.2 12.4 11.6

Richmond Post Office, 364 Port Richmond Ave. 14.3 14.5 13.8 13.3 14.5 12.2

Richmond Susan Wagner HS, Brielle Ave. & Manor Rd. 12.4 13.1 11.5 11.6 12.5 10.4

Suffolk East Farmingdale Water Plant 13.0 11.4 11.9 10.7 12.0

Westchester 5th Ave. & Madison, Thruway Exit 9 12.9 11.8 12.1 11.3 12.4 11.0

CT Fairfield Roosevelt School Park Ave. 14.0 13.7 12.8 12.8 12.7 14.4 12.5
120

State County Monitor Site Address 2000 2001 2002 2003 2004 2005 2006

Fairfield Trailer, W. Connecticut State University 12.7 13.2 12.6 13.3 11.2 13.4 12.3

Fairfield Hillandale Ave. 12.9 13.0 12.7 13.5 11.8

Fairfield Norwalk Health Dept., 137 East Ave. 13.4 12.6 13.1 12.4 13.2 11.7

Fairfield Sherwood Island State Park 13.0 12.1 11.5 11.7 11.1 12.2 10.7

New Haven Stiles St. 16.2 17.0 15.9 16.8 15.4 18.9

New Haven Woodward Ave. 11.9 11.5 13.1 11.7

New Haven 1 James St. 12.2 13.3 12.2

New Haven 715 State St. 14.1 14.3 13.3 14.0 12.8 13.8 12.7

New Haven Agri. Expr. Sta. Huntington St. 11.9 11.1 11.8 10.8

New Haven Shed Meadow and Bank St. 13.7 13.9 13.1 12.6 12.1 14.1 11.9
121

Table 5.6: Ambient PM2.5 Design Values in the Northern New Jersey/New York Connecticut Nonattainment Area216

State County Monitor Site Address

2000-

2002

2001-

2003

2002-

2004

2003-

2005

2004-

2006

NJ Bergen Fort Lee 14.0 13.6 12.8 13.3 12.8

Essex Newark Cultural Center 14.1 13.6 13.5 13.9 13.2

Essex Newark Lab 14.7 14.2 13.6 13.1

Hudson Jersey City Primary 15.1 14.4 14.3 14.6 14.1

Hudson Union City 16.6 16.3 16.8 17.4 15.7

Mercer Trenton 14.2 13.8 13.0 13.0 12.7

Mercer Washington Crossing 11.9 11.9 11.5 11.7 11.0

Middlesex New Brunswick 12.5 12.4 11.8 12.5 11.8

Morris Chester 11.1 11.0 10.5 10.6 10.0

Morris Morristown 12.6 12.4 11.6 11.9 11.2

Passaic Paterson 13.2 13.1 12.9 13.1 12.7

Union Elizabeth Turnpike Primary 15.9 15.6 15.4 15.5 14.9

Union Elizabeth Downtown 13.9 13.5 13.2 13.6 13.1

Union Rahway 13.1 12.8 12.8 13.3 12.8

NY Bronx Morrisania Center, 1225-57 Gerard Ave. 16.0 15.7 15.2 15.7 15.1

Bronx 200th St. And Southern Blvd. 14.2 13.9 13.4 13.3 12.9

Bronx E 156th St. Bet Dawson and Kelly 15.0 14.8 14.4 14.4 13.7

Kings Jhs 126 424 Leonard St. 14.9 14.4 14.6 14.0

Nassau Lawrence High School, Arlington Place 12.3 12.4

New York Ps 59, 288 E. 57th Street 17.6 17.6 16.8 17.0 15.6

New York Post Office, 350 Canal St. 17.0 16.4 15.4 15.3 14.3

New York School Is 45, 2351 1st Ave. 15.1 14.8 14.1 14.0 13.4

New York 55 Broadway 15.7 15.8 15.8 15.2

Orange 14439 Gravett Rd. 11.7 11.6 11.2 11.4 10.7

Queens Post Office, 364 Port Richmond Ave. 13.6 12.9 12.7 12.1

Richmond Susan Wagner HS, Brielle Ave. & Manor Rd. 14.4 14.0 13.7 13.7 13.4

 216 Monitoring sites with only two or less three-year average values are not shown as no discernable trends can be seen due to a lack of sufficient data points. Also, only one 

monitoring value is shown at some sites that have duplicate monitoring performed to avoid confusion. In these limited cases, the higher value of the two monitors is shown.
122

State County Monitor Site Address

2000-

2002

2001-

2003

2002-

2004

2003-

2005

2004-

2006

Richmond East Farmingdale Water Plant 12.5 12.2 11.7 11.9 11.5

Suffolk 5th Ave. & Madison, Thruway Exit 9 12.5 12.3 11.5 11.5

Westchester Morrisania Center, 1225-57 Gerard Ave. 12.5 11.9 12.0 11.6

CT Fairfield Roosevelt School Park Ave. 13.4 13.1 12.7 13.3 13.2

Fairfield Trailer, W. Connecticut State University 12.8 13.1 12.4 12.7 12.3

Fairfield Hillandale Avenue 12.9 13.1 12.7

Fairfield Norwalk Health Dept., 137 East Avenue 12.9 13.0 12.7 12.9 12.4

Fairfield Sherwood Island State Park 12.2 11.8 11.4 11.7 11.3

New Haven Stiles Street 217 16.4 16.6 16.1 17.1

New Haven 715 State Street 13.8 13.7 13.1 13.4 13.1

New Haven Shed Meadow And Bank Street 13.8 13.7 12.9 13.4 12.9

New Haven Mill Rock Basin 11.5 11.8

 217 See Footnote 211 for explanation of the Stiles Street monitor.
123

Table 5.7: Annual Ambient PM2.5 Levels in the Southern New Jersey/Philadelphia Nonattainment Area

State County Monitor Site Address 2000 2001 2002 2003 2004 2005 2006

NJ Camden Pennsauken 15.5 14.2 13.9 13.9 13.2 14.3 12.4

Camden Camden Lab Primary 15.0 14.5 13.3 16.3 13.3 14.4 12.2

Gloucester Gibbstown 15.1 14.5 12.3 13.8 12.4 14.1 9.0

PA Bucks Rockview Lane 13.6 14.5 14.2 14.4 13.0 14.3 12.2

Chester New Garden Airport - Toughkenamon 14.6 15.6 14.3 15.9 12.6

Delaware Front St. & Norris St. 16.0 15.9 14.7 15.3 15.0 16.5 14.0

Montgomery State Armory - 1046 Belvoir Rd. 13.5 14.9 13.6 13.9 12.0 12.5 12.1

Philadelphia 1501 E. Lycoming Ave. Ams Lab 14.9 16.5 14.8 14.8 13.9 14.3 13.5

Philadelphia Ford Rd.-Belmont Ave. Water Treat Plant 14.7 15.4 13.8 13.7 13.9

Philadelphia Grant-Ashton Roads, Phila. NE Airport 14.4 14.6 13.9 13.0 12.8 13.0 12.4

Philadelphia 500 South Broad St. - Parking Lot (Chs) 17.0 16.6 16.2 15.5 14.4

Philadelphia Amtrak, 5917 Elmwood Ave. 14.8 16.7 14.4 14.1 12.8 14.3 13.2

DE New Castle River Road Park, Bellefonte 15.4 15.6 14.0 14.8 13.9 14.3 12.3

New Castle Lums Pond State Park 14.2 14.5 13.0 13.3 13.2 13.8 11.4

New Castle Univ. Del. North Campus 15.4 15.8 14.3 14.8 14.5 14.4 12.7

New Castle MLK Blvd. and Justison St. 16.4 17.6 14.8 15.5 14.9 15.0 14.7
124

Table 5.8: Ambient PM2.5 Design Values in the Southern New Jersey/Philadelphia Nonattainment Area218

 218 Monitoring sites with only two or less three-year average values are not shown as no discernable trends can be seen due to a lack of sufficient data points. Also, only one 

monitoring value is shown at some sites that have duplicate monitoring performed to avoid confusion. In these limited cases, the higher value of the two monitors is shown.

State County Monitor Site Address

2000-

2002

2001-

2003

2002-

2004

2003-

2005

2004-

2006

NJ Camden Pennsauken 14.5 14.0 13.7 13.8 13.3

Camden Camden Lab Primary 14.3 14.7 14.3 14.7 13.3

Gloucester Gibbstown 14.0 13.5 12.8 13.4 11.8

PA Bucks Rockview Lane 14.1 14.3 13.9 13.9 13.2

Chester New Garden Airport - Toughkenamon 14.8 15.2 14.2

Delaware Front St. & Norris St. 15.5 15.3 15.0 15.6 15.2

Montgomery State Armory - 1046 Belvoir Rd. 14.0 14.1 13.2 12.8 12.2

Philadelphia 1501 E. Lycoming Ave. Ams Lab 15.4 15.4 14.5 14.3 13.9

Philadelphia Ford Rd.-Belmont Ave. Water Treat Plant 14.6 14.3 13.8

Philadelphia Grant-Ashton Roads, Phila. NE Airport 14.3 13.8 13.2 12.9 12.7

Philadelphia 500 South Broad St. - Parking Lot 16.6 16.1 15.4

Philadelphia Amtrak, 5917 Elmwood Ave. 15.3 15.0 13.7 13.7 13.4

DE New Castle River Road Park, Bellefonte 15.0 14.8 14.2 14.3 13.5

New Castle Lums Pond State Park 13.9 13.6 13.2 13.4 12.8

New Castle Univ. Del. North Campus 15.2 15.0 14.6 14.6 13.9

New Castle MLK Blvd. and Justison St. 16.6 16.7 15.7 15.8 15.5
125

Table 5.9: Averaged Daily PM2.5 Ambient Levels in the Northern New Jersey/New York/Connecticut Nonattainment Area (μg/m3)

98th Percentile 24-Hour Average (μg/m3) 3-Year Average 98th Percentile 24-Hour Average (μg/m3)

State County Monitor Site Address 1999 2000 2001 2002 2003 2004 2005 2006 1999-

2001

2000-

2002

2001-

2003

2002-

2004

2003-

2005

2004-

2006

NJ Bergen Fort Lee 39 36 30 33 39 31 41 38 35 33 34 34 37 37

Essex Newark Cultural Center 44 42 29 32 40 35 40 40 38 34 34 36 38 38

Hudson Jersey City Primary 46 40 34 34 46 37 38 41 40 36 38 39 41 39

Hudson Union City 50 39 35 38 44 41 42 37 36 38 44 43

Mercer Trenton 33 43 31 35 41 33 34 36 35 36 35 36 36 34

Mercer Washington Crossing 28 32 26 32 35 28 33 30 29 30 31 32 32 30

Middlesex New Brunswick 31 35 27 26 45 36 34 33 31 29 33 36 38 34

Morris Chester 30 29 31 30 36 30 33 28 30 30 32 32 33 31

Morris Morristown 35 30 27 30 37 31 33 30 31 29 31 33 34 31

Passaic Paterson 41 35 30 35 40 31 41 33 35 33 35 35 37 35

Union Elizabeth Turnpike Primary 41 39 38 42 37 41 43 40 39 40 39 40 40 41

Union Elizabeth Downtown 43 36 26 30 41 33 39 39 35 31 32 35 38 37

Union Rahway 17 38 29 31 35 37 38 38 28 33 32 34 37 37

NY Bronx Morrisania Center, 1225-57 Gerard 

Ave.

45 40 37 35 45 38 38 40 41 37 39 39 40 39

Bronx 200th St. And Southern Blvd. 35 39 35 33 38 31 37 35 36 36 36 34 35 34

Bronx E 156th St. Bet Dawson and Kelly 34 41 39 41 38 29 37 38 38 40 39 36 34 35

Kings PS 321 180 7th Av 38 42 35 32 33 38 36 33

Kings Jhs 126 424 Leonard St. 35 36 41 37 36 38 37 38 38 37

Nassau Lawrence High School, Arlington 

Place

32 31 32 39 31 35 33 32 32 34 34 35 33

New York PS 59, 288 E. 57th St. (monitor 2) 47 42 40 38 37 41 39 43 40 38 39 39

New York PS 59, 288 E. 57th St. (monitor 1) 36 42 40 38 37 41 40 41 39 40 38 39 39 41

New York Post Office, 350 Canal St. (monitor 1) 45 41 42 39 46 39 40 36 43 41 42 41 42 38

New York School Is 45, 2351 1st Ave. (monitor 

1)

41 36 36 46 38 37 38 38 39 40 40 37

New York PS 19 185 1st Ave. 38 38 48 39 38 38 42 42 42 38

New York 55 Broadway 30 28 32 31 27 30 28 30 30 30 29 28

Queens 14439 Gravett Rd. 36 39 39 33 34 34 38 37 36 34

Richmond Post Office, 364 Port Richmond Ave. 40 32 40 46 31 33 36 37 39 39 37 34

Richmond Susan Wagner HS, Brielle Ave.& 

Manor Rd.

33 31 28 32 34 33 32 32 31 30 31 33 33
126

98th Percentile 24-Hour Average (μg/m3) 3-Year Average 98th Percentile 24-Hour Average (μg/m3)

State County Monitor Site Address 1999 2000 2001 2002 2003 2004 2005 2006 1999-

2001

2000-

2002

2001-

2003

2002-

2004

2003-

2005

2004-

2006

Suffolk East Farmingdale Water Plant 32 34 36 39 31 34 33 34 36 35 35

Suffolk East Farmingdale Water Dist.,Gazza 

Blvd.

36 39 31 34 32 35 35 32

Westchester 5th Ave. & Madison, Thruway Exit 9 34 33 37 34 33 34 35 34 34 34

CT Fairfield Roosevelt School Park Ave. 31 42 40 35 40 34 38 37 38 39 38 36 37 36

Fairfield Trailer, W. Connecticut State 

University

33 35 31 37 28 33 34 33 34 32 33 32

Fairfield Hillandale Ave. 36 37 35 42 32 36 38 36

Fairfield Norwalk Health Dept., 137 East Ave. 36 34 43 35 35 36 38 37 38 35

Fairfield Sherwood Island State Park 33 35 31 44 31 35 31 33 36 35 37 32

New Haven Stiles St. 40 40 41 40 44 35 44 40 40 42 40 41

New Haven Woodward Ave. 46 32 36 37 38 35

New Haven 1 James St. 37 38 37 37

New Haven 715 State St. 32 37 40 32 44 36 41 38 36 36 39 38 40 38

New Haven Agri. Expr. Sta. Huntington St. 44 32 33 34 36 33

New Haven Shed Meadow and Bank St. (USEPA, 

monitor 1)

38 34 35 33 13 30 34 36 36 34 27 25 26 33

New Haven Shed Meadow and Bank St. (CTDEP) 38 34 35 33 38 30 36 36 36 34 35 34 35 34

New Haven Mill Rock Basin 28 35 32 29 44 32 32 35
127

Table 5.10: Averaged Daily PM2.5 Ambient Levels in the Southern New Jersey/Philadelphia Nonattainment Area (μg/m3)

98th Percentile 24-Hour Average (μg/m3) 3-Year Average 98th Percentile 24-Hour Average (μg/m3)

State County Monitor Site Address 1999 2000 2001 2002 2003 2004 2005 2006

1999-

2001

2000-

2002

2001-

2003

2002-

2004

2003-

2005

2004-

2006

NJ Camden Pennsauken 35 36 33 35 38 35 37 38 35 35 35 36 37 37

Camden Camden Lab Primary 32 32 30 35 43 35 38 34 31 32 36 38 39 36

Gloucester Gibbstown 25 34 29 29 35 29 32 24 29 31 31 31 32 29

PA Bucks Rockview Lane 38 39 37 40 30 35 34 38 39 36 35 33

Chester New Garden Airport - Toughkenamon 34 39 33 34 38 35 35 35

Delaware Front St. & Norris St. 36 36 40 32 38 31 37 37 37 36 37 34 35 35

Delaware State Armory - 1046 Belvoir Rd. 32 48 37 38 29 36 39 41 35

Philadelphia 1501 E. Lycoming Ave. Ams Lab 39 41 40 40 40 34 36 38 40 40 40 38 37 36

Philadelphia

Ford Rd-Belmont Ave. Water Treat 

Plant 32 36 34 39 29 34 37 34

Philadelphia Grant-Ashton Roads Phila. NE Airport 38 37 34 39 33 36 35 36 37 35 36 35

Philadelphia 500 South Broad St. 39 40 36 42 32 38 39 37

Philadelphia Amtrak, 5917 Elmwood Ave. 39 46 37 36 30 38 41 40 34

DE New Castle River Road Park, Bellefonte 33 38 41 34 36 33 35 37 38 37 34 34 33

New Castle Lums Pond State Park 36 36 37 31 36 29 35 34 34 33 35 32

New Castle Univ. Del. - North Campus 35 40 40 42 36 29 35 31 38 41 39 36 33 32

New Castle MLK Blvd. and Justison St. 38 39 43 41 37 34 37 38 40 41 40 37 36 36
128

5.3.2.3 Discussion of Monitoring Results Collected at P.S. 59, Manhattan, New York 

One monitor associated with New Jersey’s Northern New Jersey/New York/Connecticut 

nonattainment area is projected to have fine particulate levels slightly above the annual fine 

particulate standard of 15.0 μg/m3 in 2009. The annual PM2.5 design value at this monitor 

located at P.S. 59 in New York City is predicted to be 15.3 μg/m3 in 2009. This predicted value 

is within the USEPA weight-of-evidence range of values. 

New York has prepared a weight-of-evidence demonstration for the P.S. 59 monitor to point out 

the factors unique to this site that need to be considered when determining that the site will attain 

the annual PM2.5 NAAQS by April 5, 2010. First, the monitoring data is lacking complete 

information for the third quarter of 2003. During this period, construction work was occurring at 

the site location that potentially invalidated a number of samples during the quarter and unfairly 

biased the collected fine particulate levels to the high side (see Appendix B2-1, Attachment 1); 

the construction work was the sole reason for the incomplete dataset. Also, analysis of the 

monitoring data suggests that lack of collocated speciation monitors and use of speciation 

information from the nearest neighborhood monitor may have contributed to the estimate of 

PM2.5 being above the level of NAAQS at the P.S.59 monitor. Examining the trends in 

precursors as well as measured PM2.5 at P.S.59 suggests a downward path and that coupled with 

the observation that the contribution to the secondary species is from upwind regions rather than 

local, favors strongly that this monitor will also be in attainment similar to the rest of them in the 

region. A more detailed discussion of these measures is included in Appendix B12.

In addition, New York lists the following programs in the process of being adopted or 

implemented in their state, that are not represented in the projection inventories for 2009, and 

that will contribute to attainment at the P.S. 59 monitor (refer to Appendix B12 for a 

comprehensive discussion of each of these measures): 

• Part 222, Distributed Generation

• Part 227-2, NOx RACT (High Electric Demand Day Units)

• Parts 243, 244, and 245, Clean Air Interstate Rule

• Diesel Emissions Reduction Act of 2006

• Existing and New/Revised State VOC Reduction Measures

• Federal Rules for VOC Reductions

• Proposed Federal Rules for VOC, NOx, and PM Reductions

• Canadian Air Quality Efforts

• Governor Spitzer’s “15 by 15” Initiative

• New York State Energy Research and Development Authority (NYSERDA) Programs 

New Jersey agrees with this demonstration and further believes that additional control measures 

not included in the 2009 modeling, like those that will occur in New Jersey (see Section 5.3.2.5) 

and the early implementation of CAIR SO2 controls prior to 2010, will lower ambient 

concentrations even further than the levels needed to demonstrate attainment of the annual fine 

particulate standard. New York’s weight-of-evidence discussion for the P.S. 59 monitor is 

included in Appendix B12.
129

5.3.2.4 The Contribution of Transport to Nonattainment 

Representing the amount of transported particulates, and the components that contribute to 

secondary aerosol formation, accurately in the regional modeling not only affects the accuracy of 

the modeling results but also the contribution of regional sources to nonattainment at a particular 

location. This information ultimately helps to inform the process on what sources to control to 

reduce precursor pollutants and thus fine particulate matter. 

Fine particulate pollution apportionment modeling analyses show that transport from states 

outside the State are significant contributors to nonattainment in New Jersey. Recent modeling 

conducted in 2005 by the USEPA to support the implementation of the CAIR indicates that outof-state contributions of sulfate and nitrate to Union County, New Jersey from just the Electric 

Generating Units in other states will contribute at least 3.4 μg/m3 to the projected 2010 levels 

and at least 4.8 μg/m3 (or about 30 percent) to the P.S. 59 monitor in New York City.219

Chapter 2 describes several studies that analyzed the sources of fine particulate matter in New 

Jersey’s air. Secondary sulfate appears as the largest portion of the fine particulate mass in both 

urban and rural areas of New Jersey. Transported sulfate concentrations from upwind electric 

power plants appears to be the largest contributor to these sulfate levels. Implementation of SO2

controls under the first phase of CAIR in 2010 is anticipated to provide additional benefits as 

explained in Section 5.3.2.5. The implementation of the second phase of CAIR in 2015 will also 

have an air quality benefit on New Jersey.

5.3.2.5 SO2 CAIR Reductions May Provide Early Reductions in PM2.5

The effects of the SO2 reductions from implementation of the Clean Air Interstate Rule in 2010 

on air quality in the Northern New Jersey/New York/Connecticut nonattainment area were not 

evaluated as part of the 2009 modeling. As the focus of that modeling was to gauge attainment 

of the ozone and fine particulate matter standards in 2009, adding SO2 emission reductions 

which had not yet occurred, but would appear a year later in 2010, would not be appropriate for 

the 2009 modeling year. It is anticipated that these additional SO2 reductions through CAIR will 

further lower fine particulate levels in 2010, and these reductions may occur sooner. 

A substantial amount of technical information was provided by the USEPA when it promulgated 

the CAIR. Part of this information included an analysis of the contributions from upwind states 

to downwind states fine particulate levels in the outside air. The USEPA defined the states listed 

in Table 5.12 as significantly contributing to fine particulate or ozone levels in New Jersey and 

quantified the contribution that these states were having on the county containing the monitor of 

concern for the Northern New Jersey/New York/Connecticut nonattainment area in this SIP 

revision (i.e., New York, New York). Table 5.12 shows the 2003 emissions of SO2 and 

additional SO2 reductions through CAIR implementation in the states identified by the USEPA 

 219 USEPA. Technical Support Document for the Final Clean Air Interstate Rule: Air Quality Modeling Analyses, 

Appendix H: PM2.5 Contributions to Each Nonattainment County in 2010. United States Environmental Protection 

Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC, March 2005.
130

as significantly contributing and the modeled contribution that these states were having prior to 

implementation of CAIR.

Table 5.11: Reductions from CAIR in 2010 in States that Significantly Contribute to Ozone 

or Fine Particulate Levels in New Jersey and the Modeled Contribution to NYC from those 

States

State

2003 SO2

Emissions

(thousand tons 

per year)

2010 SO2

 

Emissions

(thousand 

tons per 

year)

SO2 Emission

Reductions by 

2010 (thousand 

tons per year)

Modeled PM2.5

Contribution to NY, NY 

(μg/m3)

New Jersey 51 27 24 0.45

New York 254 66 188 2.00

Pennsylvania 967 235 732 0.95

Delaware 37 28 9 0.09

Maryland 269 62 207 0.22

West Virginia 540 250 290 0.17

Virginia 216 136 80 0.21

Massachusetts 0 0 0 0.12

Ohio 1,176 298 878 0.41

Michigan 351 381 -30* 0.21

District of Columbia 51 27 24 NA (w/ Maryland)

Total 3,912 1,510 2,403 4.83

Source: USEPA at http://www.epa.gov/oar/interstateairquality/where.html

* A negative number indicates an increase

Regional modeling results for 2009, presented in Table 5.3 predicts that the annual PM2.5 design 

value in 2009 at the P.S. 59 monitor (i.e., the design value monitor) will be 15.3 μg/m3 after 

implementation of the first phase of the CAIR for additional NOx (but not SO2) controls. The 

USEPA analysis used a starting concentration without CAIR implementation (i.e., a 2010 Base 

Case) of 16.29 μg/m3 and determined that 4.83 μg/m3 of this fine particulate level came from the 

states that significantly contribute. As the effects of the first phase of the NOx reductions were 

already accounted for in the OTC modeling to obtain the predicted concentration of 15.3 μg/m3

, 

it would not be appropriate to again account for this effect on air quality. Holding the emissions 

of NOx constant, and adjusting for the emission reductions from SO2 in 2010, a 48 percent 

additional reduction in the total amount of SO2 will occur (USEPA estimate) as a result of the 

first phase of CAIR SO2 reductions in 2010 in the states significantly contributing to New 

Jersey’s air quality.220 A 48 percent reduction of the 4.83 μg/m3 that these states contributed in 

2003 would then also be expected due to the additional SO2 controls. Using the data presented 

from the USEPA modeling, an additional 2.31 μg/m3 reduction will occur at the P.S. 59 monitor 

 220 The 48 percent is determined by (1 minus (1,118 thousand tons of NOx in 2003 + 1,510 thousand tons of SO2

predicted to be emitted in 2010) divided by (1,118 thousand tons of NOx held constant + 3,912 thousand tons of SO2

emitted in 2003)) times 100 to get percent.
131

as a result of CAIR SO2 controls.221 The predicted concentration in 2010, or earlier, at the P.S. 

59 monitor due to the CAIR SO2 reductions would be 13.0 μg/m3,

222 well below the weight-ofevidence range of values for the annual PM2.5 NAAQS. This estimate of SO2 reductions 

provides further assurance that the P.S. 59 monitor will be in attainment by 2010. 

5.3.2.6 Additional Measures Not Included in the 2009 BOTW Attainment Modeling

5.3.2.6.1 Introduction 

New Jersey is working to propose and implement a number of additional control measures by 

2010 that were not included in the attainment demonstration modeling. In addition, some 

Federal measures are expected to become effective by 2010 that will provide air quality benefits. 

All these additional measures were the result of the efforts by the USEPA, the OTC, New 

Jersey’s Reasonably Available Control Technology (RACT) analysis, or other New Jersey 

initiatives to identify measures that would improve air quality. 

While there are numerous reasons why certain emission control measures were not included in a 

modeling scenario, the two most significant are: 

• The preparatory work needed to run these models is resource-intensive, making it neither 

practical nor reasonable to model every possible control measure, and 

• The uncertainty in calculating emission reduction benefits from certain types of control 

measures is acknowledged by the USEPA in its guidance for emerging measures, or 

measures that are difficult to accurately quantify.223 Examples of these types of measures 

include tree planting or replacing roofs with reflective material, both of which help to 

decrease the high temperatures in an urban area that result from the ‘heat island effect’ that 

indirectly impacts ozone and PM2.5 concentrations.

Although these additional measures and refinements were finalized too late to be included in the 

2009 BOTW modeling, they will provide additional emission reductions by 2009 or by 2010, the 

attainment year for the annual fine particulate standard. As such, they provide additional 

evidence to support New Jersey’s conclusion that both of its associated nonattainment areas will 

attain the annual PM2.5 standard by their required attainment dates in addition to the continued 

monitored attainment of the areas. These measures will also bring us closer to attaining New 

Jersey’s goal of a 12 μg/m3 annual standard and closer to attaining the 2006 24-hour PM2.5

standard of 35 μg/m3.

 221 4.83 μg/m3 times 48 percent = 2.3 μg/m3 

222 15.3 μg/m3 predicted – 2.3 μg/m3 reduction from first round SO2 reductions = 13.0 μg/m3

223 USEPA. Incorporating Emerging and Voluntary Measures in a State Implementation Plan (SIP). United States 

Environmental Protection Agency (USEPA), Office of Air and Radiation, Air Quality Strategies and Standards 

Division, Office of Air Quality Planning and Standards, Research Triangle Park, NC, September 2004.
132

5.3.2.6.2 Additional Measures to Improve Air Quality 

Even though it is not yet possible to determine the associated emission reductions from certain 

types of programs with the precision necessary for full Federal approval and for SIP credit 

toward attainment of the PM2.5 NAAQS, the programs discussed in this section provide a 

cumulative effect of reducing air emissions, which will help bring New Jersey and its associated 

nonattainment areas into attainment. For example, some of the measures listed in this section 

will result in reductions of VOC emissions, and although New Jersey has not identified VOCs as 

a PM2.5 precursor, New Jersey expects that these measures will also result in improved air 

quality. However, emission reductions of these air pollution control strategies were not included 

in the scenarios utilized in the modeling analysis, as a quantified benefit is needed for each 

control measure that is used in photochemical modeling. 

New Jersey is aware that the control measures in this section do and will continue to improve the 

State’s overall air quality by indirectly decreasing fine particulate matter concentrations. As 

such, these strategies will result in actual air quality benefits that will be reflected in the 

monitoring data in both the Northern New Jersey/New York/Connecticut and Southern New 

Jersey/Philadelphia nonattainment areas in the years leading up to 2010. New Jersey promotes 

and supports these measures, but is not relying upon them to demonstrate attainment.

The control measures and strategies that will further improve air quality can be grouped into 11 

categories:

1) Contingency Measures

Contingency measures are additional controls needed to further reduce emissions in the event a 

nonattainment area fails to attain by its attainment date. These contingency measures must be 

fully adopted rules or measures that are ready for implementation quickly without further action 

by the State or the USEPA upon failure to reach attainment. New Jersey contingency measures 

have been identified and quantified and are discussed in Chapter 6, Chapter 9, and in Appendix 

C. A more detailed explanation of these control measures is included in Chapter 4.

 

a) Diesel idling,

b) Municipal Waste Combustors (Incinerators) NOx rule,

c) Onroad Motor Vehicle Control Programs (Fleet turnover 2010),

d) Nonroad Motor Vehicle Control Programs (Fleet turnover 2010),

e) ICI Boiler Rule 2009 (portion not modeled),

f) NOx RACT Rule 2006 (portion not modeled)

g) Asphalt Production Plants Rule

h) Controls from EGU Consent Decree (PSE&G Hudson SO2).

i) Refinery Consent Decrees (Sunoco and Valero)

2) Point Source Related Measures

The NJDEP Air Quality Permitting Program (AQPP) is responsible for permitting and testing 

stationary sources of air pollution to ensure they do not adversely affect air quality in the State. 
133

Most old sources (those already constructed) and newer facilities are permitted. To accomplish 

this, the AQPP reviews air pollution control permit applications, evaluates air quality impact and 

health risks, and ensures stack emissions are measured properly. Some examples of point source 

related measures that improve air quality that were not included in the 2009 BOTW attainment 

modeling, but are expected to result in PM2.5 benefits, include enhanced controls for glass 

furnaces and Nonattainment New Source Review (NNSR). 

New Jersey proposed amendments to its current glass manufacturing rules at N.J.A.C. 7:27-

19.10. The proposed amendments, based on OTC guidance, would revise the NOx emission rates 

to reduce emissions consistent with the installation of oxy-fuel firing at the time of the next 

furnace re-build. Of New Jersey’s 25 glass manufacturing furnaces, five are already equipped 

with oxy-fuel firing and nine are electric. In addition to demonstrated nitrogen reduction at a 

reasonable cost, oxy-firing may result in reduced PM2.5 emissions, lowered energy consumption,

and increased glass production.

The Clean Air Act (CAA), 42 U.S.C. § 7503, requires new or modified major sources to install 

the Lowest Achievable Emission Rate (LAER) control equipment and obtain a one for one 

emission offsets in order to locate in a nonattainment area. Thus, the NNSR program provides 

for continual emission reductions to help improve the air quality in the nonattainment area and 

further downwind. 

For more information on the enhanced controls for glass furnaces and NNSR, see Chapter 4.

3) VOC Measures

The State is implementing several VOC control measures that were adopted as discussed in the 

2007 8-hour Ozone Attainment Demonstration SIP.224 Although the USEPA does not consider

VOC as a PM2.5 precursor for SIP and conformity purposes, New Jersey anticipates some PM2.5 

benefit from the implementation of these measures. The VOC measures that were not included 

in the 2009 BOTW attainment modeling, but are still expected to result in a PM2.5 benefit, are 

shown in Table 4.5.

4) Federal Measures 

The Federal government plans to implement several measures that will provide emission 

reductions prior to the summer of 2009. These Federal measures included the Small Offroad 

Engine Standards rule and a rule for Locomotive Engines and Marine Compression-Ignition 

Engines Less Than 30 Liters per Cylinder. 

The Small Offroad Engine Standards rule225 was adopted by the USEPA on May 18, 2007 and 

will set stricter standards for most lawn and garden equipment and small recreational watercraft. 

 224 NJDEP. State Implementation Plan (SIP) Revision for the Attainment and Maintenance of the Ozone National 

Ambient Air Quality Standard: 8-Hour Ozone Attainment Demonstration Proposal. New Jersey Department of 

Environmental Protection, June 15, 2007. 

225 72 Fed. Reg. 28098-146 (May 18, 2007).
134

The USEPA has indicated that states can claim the benefits from its proposed Small Offroad 

Engine Standards rule for contingency.226 However, the USEPA has not released official 

guidance on the credit that states can claim for this proposed rulemaking.

The Locomotive Engines and Marine Compression-Ignition Engines Less than 30 Liters per 

Cylinder rule,227 adopted by the USEPA on March 14, 2008, requires more stringent exhaust 

emission standards for locomotives and marine diesel engines. This rule will result in reduced 

direct PM2.5 and NOx emissions. As stated in Chapter 4, the standards for remanufactured 

locomotives will take effect as soon as certified remanufacture systems are available (as early as 

2008). Tier 3 standards for newly-built locomotive and marine engines would phase in starting 

in 2009. Tier 4 standards for newly-built locomotives and marine diesel engines would phase in 

beginning in 2014 for marine diesel engines and 2015 for locomotives.

All of these actions, while not quantified, will provide continued reductions toward attaining the 

annual and daily revisions to the PM2.5 NAAQS, and added public health and environmental 

protection to address adverse impacts of PM2.5 below the current NAAQS. Detailed discussions 

of these measures are included in Chapter 4.

5) PM2.5 RACT measures

New Jersey conducted a Reasonably Available Control Technology (RACT) analysis which 

demonstrates that additional reductions of direct PM2.5 emissions and its precursors, SO2 and 

NOx are reasonable. New Jersey’s PM2.5 RACT analysis is discussed in detail in Appendix A7.

6) Voluntary Strategies

The strategies in this category are/will be implemented on a voluntary basis. Companies and 

organizations commit to various initiatives that reduce fine particulate and the secondary aerosol 

precursors. Examples of these strategies include: state-level programs for days with high levels 

of particulate; a Federal campaign that targets reducing raw material usage; reusing waste 

products, and decreasing waste production; and a tool to help permit writers, enforcement 

officers, and the regulated community identify and employ pollution prevention methods to 

reduce or eliminate releases of hazardous materials to the environment.

7) Energy Savings and Alternative Energy Strategies

The strategies in this category are specific to reducing energy consumption and utilizing 

alternative energy sources. Examples of strategies in this category include New Jersey’s Clean 

Energy Program and USEPA’s Green Power Partnership. Energy efficiency measures have a 

lasting “cumulative” effect on electric demand. The savings in the installation year of an energy 

efficiency measure continue for the duration of its life. Therefore, the efficiency savings 

installed one year can be added to the measures included in all of the preceding years within its 

 226 Personal email communication from Paul Truchan, USEPA Region 2 to Christine Schell, NJDEP, May 16, 2007. 227 73 Fed. Reg. 25097 (May 6, 2008).
135

life. These energy efficiency and renewable energy programs are designed to lower the growth 

of electricity demand and avoid emissions associated with such growth. 

The United States Department of Energy (USDOE), USEPA, NJDEP, and New Jersey Board of 

Public Utilities (NJBPU) collaborated on efforts to estimate emission reductions from energy 

efficiency.228 The scenarios analyzed by this effort may be utilized in the future to determine 

SIP credit when the environmental benefits from the Clean Energy Program might be realized 

with the retirement of NOx allowances issued for the Clean Energy Program by the NJBPU. The 

NJDEP may take SIP credit for the environmental benefits of the Clean Energy Program after 

2009.

8) High Electrical Demand Day Program (HEDD)

As discussed in Chapter 4, the regional High Electrical Demand Day (HEDD) program will 

address peak load emissions from the electrical generation sector on a seasonal basis on days 

when the demand for electricity is high. Therefore, the High Electrical Demand Day program 

provides reductions only on the days that are categorized with a high electrical demand, not on a 

daily basis. The High Electrical Demand Day measure is expected to provide significant NOx

emission reductions on the days they are most needed. 

In March 2007, following a year long process, six of the OTC states committed to pursue 

reductions in NOx emissions from electrical generating units that primarily operate on high 

electrical demand days (HEDD) starting with the 2009 ozone season.229 On these high electric 

demand days, increased power generation is needed, usually on short notice. 

As part of the HEDD initiative, New Jersey plans to reduce NOx emissions by 19.8 tpd on these 

high electrical demand days starting in 2009. Specifically, power generators in New Jersey will 

be responsible for securing these reductions and will be required to submit a plan on how they 

will reduce NOx. The generators will have flexibility in securing the 2009 to 2015 reductions. 

New Jersey also plans to require that all HEDD units meet performance standards that reflect 

modern low NOx technology by May 1, 2015. This will result in greater reductions on HEDD 

and throughout the year for NOx, with co-benefits for PM2.5 and SO2. 

9) Mobile Strategies

The strategies in this category focus on reducing vehicle miles traveled and fuel consumption, 

and increasing the use of alternative fuel sources. Mobile strategies target onroad and nonroad 

vehicles and equipment. Examples of strategies in this category include Carpool Makes $ense 

Program (Governor Corzine’s Initiative), the USEPA’s SmartWay Transport Partnership, and the 

Northeast Diesel Collaborative.

 228 USDOE. Final Report on the Clean Energy/Air Quality Integration Initiative Pilot Project of the U.S. 

Department of Energy’s Mid-Atlantic Regional Office. United States Department of Energy, Office of Energy 

Efficiency and Renewable Energy, Philadelphia, PA, May 2006.

229 OTC. Memorandum of Understanding among the States of the Ozone Transport Commission Concerning the 

Incorporation of High Electrical Demand Day Emission Reduction Strategies into Ozone Attainment State 

Implementation Planning. Ozone Transport Commission, March 2, 2007.
136

10) New Jersey Diesel Strategies

The NJDEP has an active Diesel Risk Reduction Program. This effort includes both Federal and 

State retrofit programs, including the USEPA’s Voluntary Diesel Retrofit Program and projects 

under New Jersey’s Diesel Risk Reduction Program. In New Jersey, the Diesel Retrofit Law in 

2005 was passed by the Legislature to clean up emissions from certain onroad, diesel-powered 

motor vehicles and nonroad vehicles/equipment through the use of retrofit emission control 

technology. The benefits of this law and the subsequent regulations adopted by the NJDEP are a 

reduction of the harmful diesel exhaust that New Jersey citizens are exposed to every day. The 

regulations require a variety of vehicles and equipment to install “retrofits” by established 

deadlines at State expense. The mandatory installation of this technology will decrease 

emissions of particulate matter by 150 tons per year.230 Additional information on this effort 

may be found at http://www.state.nj.us/dep/stopthesoot/retrofit.htm. 

In addition to the mandatory diesel retrofit law, the Diesel Risk Reduction Program is involved 

in voluntary projects that also result in improved air quality. One of these projects includes the 

reduction of diesel emissions from ports. 

With respect to emissions from train engines, New Jersey Transit (NJ Transit) has voluntarily 

implemented an “Idling Reduction Policy” to shut down their diesel passenger locomotives 

within one hour of idling when the temperature is above zero degrees. The NJ Transit has also 

agreed to move forward with a New Jersey Transportation Planning Authority (NJTPA) proposal 

to install idling reduction technologies and is seeking funding. Benefits from this voluntary 

action at one train station are estimated to be 1.5 tons per year, based on an 82 percent emissions 

reduction from implementing this policy.231 However, New Jersey is not claiming these benefits 

in this SIP revision.

Additional diesel reductions from trucks may be realized from truck stop electrification projects 

where trucks are encouraged to turn off their engines and instead use electricity provided. New 

Jersey is also working on establishing an inspection program for medium duty vehicles with a 

gross weight between 8,501 – 17,999 pounds. The inspection program will be a combination of 

on-board diagnostic (OBD) and smoke opacity inspections, and would help control particulate 

emissions. 

Diesel Smoke (I/M Cutpoint) Rule Changes: Like the diesel idling efforts, the NJDEP 

requirements for the inspection and maintenance (I/M) of diesel vehicles are designed to reduce 

the emissions from diesel engines, which are significant contributors to ozone, PM2.5, and its 

precursors. The NJDEP proposed amendments on June 16, 2008 to its existing diesel I/M rules 

to reduce the allowable smoke from heavy-duty diesel vehicles. Smoke opacity, which is used as 

a surrogate for particulate matter, is the degree to which a plume of smoke will obstruct 

transmission of visible light. Smoke opacity is used as an indicator for mal-maintenance. The 

NJDEP expects the benefit of these rule changes to be 13 tpy PM2.5 and 29.9 tpy NOx in the New 

 230 38 N.J.R. 5244(a) (December 18, 2006). 231 Data are not available to calculate emission benefits from all NJ Transit locomotives but an assumption could be 

made that an 82 percent reduction in idling is occurring from its 100 locomotives.
137

Jersey portion of the Northern New Jersey/New York/Connecticut nonattainment area and 3 tpy 

PM2.5 and 6.9 tpy NOx in the New Jersey portion of the Southern New Jersey/Philadelphia

nonattainment area.

New Jersey’s diesel initiatives are described further in Chapter 4.

11) Wood Burning Strategies

Several wood burning strategies to lower emissions from the burning of wood have been 

investigated. In order to provide information on wood burning, New Jersey has developed an 

informational webpage regarding techniques for proper wood burning, health effects of wood 

burning, and links to other useful web pages.232

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). One particulate control 

measure has already been implemented, namely to limit air pollution control permits to prevent 

open burning on days forecast to be of unhealthful air quality. This permit condition requires the 

permit holder to delay open burning until forecast meteorological conditions and air quality have 

improved so that forecasted unhealthful conditions for that day will not be made worse by this 

activity. Similarly, New Jersey is considering a seasonal home wood heating advisory program 

to further curtail wood smoke emissions, similar to the program adopted in Lane County, 

Oregon.233 This program would advise homeowners when they could heat their homes with 

wood, according to the current air quality. Additionally, New Jersey will propose changes to 

New Jersey’s open burning regulation (N.J.A.C. 7:27-2 et seq.) to limit the types of eligible open 

burning activities, and to increase fees for the activity; these changes are included in Chapter 4. 

Other control measures might include wood stove and fireplace change-out 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. New Jersey expects 

to include additional wood burning strategies in the proposed SIP for the 2006 24-hour PM2.5

NAAQS. 

5.4 Emission Reduction Credits from Shutdowns and Curtailments

Section IV.C.3 (Emission Reduction Credits from Shutdowns and Curtailments) of Appendix S

to 40 C.F.R. pt. 51, states that emissions reductions achieved by shutting down an existing source 

or curtailing production or operating hours may be credited for offsets if such reductions are 

surplus, permanent, quantifiable, and federally enforceable and the shutdown or curtailment 

occurred after the last day of the base year (12/31/2002) for the SIP planning process. Appendix 

S allows the use of pre-2002 shutdown and curtailment credits of PM2.5, and its precursors (SO2

and NOx), emissions for offsets, provided the projected emissions inventory used to develop the 

 232 NJDEP. Wood Burning in New Jersey. New Jersey Department of Environmental Protection, Bureau of Air 

Quality Planning. http://www.state.nj.us/dep/baqp/woodburning.html, April 15, 2008. 233 LRAPA. Public Education: Home Wood Heating Programs. Lane Regional Air Protection Agency (LRAPA). 

http://www.lrapa.org/public_education/home_wood_heating_programs/, accessed May 14, 2008.
138

attainment demonstration explicitly includes emissions for offsets from such previously 

shutdown or curtailed emission units. 

The banked emissions from pre-2002 facility or equipment shutdowns were not included in the 

2002 modeling inventory. However, as discussed in detail in Appendix C, there is a modeled 

differential between the modeled design values for 2009 and the PM2.5 annual NAAQS of 15.0 

μg/m3, which has been used to allow banked credits in the future. In this SIP revision, New 

Jersey has assigned 268 tpy of PM2.5, 1,227 tpy of SO2, and 573 tpy of NOx from the estimated 

modeled differential for potential use as emission offset credits from the bank. For more details 

regarding this assignment, see Appendix B13. 

5.5 Results

When added together, all the control measures and refinements discussed in Section 5.3.2.6.2 

will result in emission reductions of direct PM2.5, NOx, and SO2 in the Northern New Jersey/New 

York/Connecticut nonattainment area and in the Southern New Jersey/Philadelphia 

nonattainment area.

234 These reductions will occur in addition to those included in the regional 

modeling and will further reduce the uncertainty associated with the 2009 modeled design values 

and supports New Jersey's demonstration of attainment of the PM2.5 NAAQS in its two multistate nonattainment areas.

The regional modeling assessment discussed in Section 5.2 demonstrates that the New Jerseyassociated nonattainment areas have attained the PM2.5 NAAQS by their designated attainment 

date. New Jersey is not directly relying on these additional measures to demonstrate attainment 

of the annual PM2.5 NAAQS. These measures will help attain the new 24-hour PM2.5 NAAQS 

and the New Jersey annual goal of 12 μg/m3

. These control measures and refinements are not 

being considered as “bundled measures” for this SIP revision.235 Rather, this evaluation of 

emission reductions expected from these additional control measures and refinements provides 

further confidence that New Jersey will attain the PM2.5 standard by 2010, and gives the State an 

abundance of additional emission reductions to rely upon in the event of exceedance. The 

benefits of these measures and refinements will be reflected in the ambient air monitors. These 

measures are discussed further as part of the State’s contingency measure strategy for attainment 

in Chapter 6. 

 234 These are approximate emission reduction totals as the additional control measures and refinements to be 

proposed and adopted by May 2008, in accordance with New Jersey Administrative Procedures Act (N.J.S.A. 

52:14B-1 et. seq.) and the Air Pollution Control Act (N.J.S.A. 26:2C-1 et. seq.).

235 USEPA. Incorporating Bundled Measures in a State Implementation Plan (SIP). United States Environmental 

Protection Agency (USEPA), Office of Air and Radiation, Air Quality Strategies and Standards Division, Office of 

Air Quality Planning and Standards, and Office of Transportation and Air Quality, Transportation and Regional 

Programs Division, Research Triangle Park, NC, August 2005.
139

5.6 Unmonitored Area Analysis 

The USEPA’s modeling guidance236 requires an unmonitored area analysis:

“The unmonitored area analysis for a particular nonattainment area is intended to 

address potential problems within or near that nonattainment area. The analysis 

should include, at a minimum, all nonattainment counties and counties surrounding 

the nonattainment area (located within the State).”237

The USEPA has developed a software package called “Modeled Attainment Test Software” 

(MATS)238 which will spatially interpolate data, adjust the spatial fields based on model output 

gradients and multiply the fields by model calculated RRFs. The MATS software for PM2.5 was 

not available at the time of SIP development. Therefore, New Jersey performed its own 

unmonitored area analysis and was unable to verify the results of this analysis using the MATS 

software.

Thirteen New Jersey counties are designated as nonattainment of the annual PM2.5 standard. Ten 

of those counties are associated with the Northern New Jersey/New York/Connecticut 

nonattainment area and three with the Southern New Jersey/Philadelphia nonattainment area. 

New Jersey's monitoring program and the use of the modeling results from a 9-cell average 

provide adequate coverage of the State to determine attainment of the fine particulate standard. 

All modeling grid cells containing a monitor and the eight (8) adjoining grid cells were analyzed 

in New Jersey's attainment demonstrations to get a nine cell average of grid cells. By using this 

technique, a large area of the State is included in the analysis and is represented by the 

monitoring program. Therefore, New Jersey does not have any areas that would be considered 

unmonitored. Figure 5.3 shows the coverage that is afforded by the current NJDEP monitoring 

network and the surrounding grid cells included in the modeling analysis. Note, on this map, 

areas covered solely by New Jersey’s monitoring stations are colored in orange (in black & white 

- lightly shaded) and areas covered by either New Jersey’s monitoring stations or by those in 

another bordering state are shaded in red (in black & white - darker shaded). 

 236 USEPA. Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality 

Goals for Ozone, PM2.5, and Regional Haze. United States Environmental Protection Agency, Office of Air Quality 

Planning and Standards, Air Quality Analysis Division, Air Quality Modeling Group, Research Triangle Park, NC, 

EPA-454/B-07-002, April 2007.

237 USEPA. Guidance on the Use of Models and Other Related Analyses in Attainment Demonstrations for the 8-

Hour Ozone NAAQS. United States Environmental Protection Agency, Office of Air Quality Planning and 

Standards, Emissions, Monitoring, and Analysis Division, Air Quality Modeling Group, Research Triangle Park, 

NC, EPA-454/R-05-002, October 2005. 238 USEPA. Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality 

Goals for Ozone, PM2.5, and Regional Haze. United States Environmental Protection Agency, Office of Air Quality 

Planning and Standards, Air Quality Analysis Division, Air Quality Modeling Group, Research Triangle Park, NC, 

EPA-454/B-07-002, April 2007.
140

Figure 5.3: Map of Grid Cells Used in Photochemical Modeling Associated With New 

Jersey Fine Particulate Matter Monitors

5.7 Conclusions

The current air quality data (2006) demonstrates that the New Jersey monitors are currently in 

attainment of the annual PM2.5 NAAQS. With the exception of the Union City monitor, the 

design values at all New Jersey monitors are in attainment of the annual PM2.5 NAAQS, and are 

below the weight-of-evidence range of values (14.5 μg/m3 through 15.5 μg/m3. The regional air 

quality modeling demonstrates the two multi-state nonattainment areas which include New 

Jersey will be in attainment of the annual PM2.5 NAAQS by 2009. The only site with a projected 

2009 design value greater than the annual fine particulate standard of 15.0 μg/m3 is the P.S. 59 

site located in Manhattan, New York City. All other sites are below the annual fine particulate 

standard and lower bound of the weight-of-evidence range. The projected 2009 value for the 

P.S. 59 site is within the weight-of-evidence range of values defined in the PM2.5 modeling 

guidance as 14.5 μg/m3 through 15.5 μg/m3.

239

 239 USEPA. Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality 

Goals for Ozone, PM2.5, and Regional Haze. United States Environmental Protection Agency, Office of Air Quality 

Legend

*Orange (in black & white - lightly shaded): Areas covered solely by New Jersey’s 

monitoring stations.

*Red (in black & white - darker shaded): Areas covered by either New Jersey’s 

monitoring stations or by those in another bordering State.
141

Additional air quality benefits associated with the control measures not included in the modeling 

reduces the uncertainty of the demonstration and thus supports New Jersey’s demonstration of 

attainment of the PM2.5 standard by 2010 in the Northern New Jersey/New York/Connecticut and 

Southern New Jersey/Philadelphia nonattainment areas. Additional support for this conclusion 

includes those additional measures being implemented in New York City to provide emission 

reductions. All areas of the two nonattainment areas are expected to be in attainment by April 5, 

2010.

The 2006 design value data show that more emission reductions are necessary to attain the 

State’s internal goal for annual PM2.5 of 12 μg/m3 and to meet the 2006 24-hour PM2.5 NAAQS. 

Only four of the 13 New Jersey monitors in the Northern New Jersey/New York/ Connecticut 

nonattainment area are currently below the annual PM2.5 goal of 12 μg/m3 and only eight of the 

13 New Jersey monitors in the Northern New Jersey/New York/ Connecticut nonattainment area 

are above the 2006 24-hour PM2.5 NAAQS.

 Planning and Standards, Air Quality Analysis Division, Air Quality Modeling Group, Research Triangle Park, NC, 

EPA-454/B-07-002, April 2007, page 105.
142

6.0 CONTINGENCY MEASURES 

6.1 Background

42 U.S.C. § 7502(c)(9) of the Clean Air Act (Section 172(c)(9)) and the United States 

Environmental Protection Agency’s (USEPA’s) final fine particulate matter (PM2.5) 

implementation rule240 require that the State Implementation Plans (SIPs) for all PM2.5

nonattainment areas include contingency measures. Contingency measures are additional 

controls needed to further reduce emissions in the event an area fails to meet a Reasonable 

Further Progress (RFP)241 milestone or fails to attain by its attainment date. These contingency 

measures must be fully adopted rules or measures that are ready for implementation quickly 

without further action by the State or the USEPA upon failure to meet an RFP milestone or reach 

attainment. The USEPA does not require a separate RFP submittal for areas with 2010 

attainment dates and a demonstration that shows attainment (72 Fed. Reg. 20633 (April 25, 

2007)). Thus, New Jersey does not need to submit a separate contingency plan related to RFP 

due to its submittal of an attainment demonstration that satisfies the 2010 deadline. There are 

separate RFP requirements for those nonattainment areas with attainment dates beyond 2010. 

The PM2.5 attainment milestone for New Jersey’s associated annual PM2.5 nonattainment areas is 

defined as 2009 (to achieve reductions by the April 2010 attainment goal). Therefore, no RFP 

and no RFP contingency is required for this standard. Contingency measures must provide for 

one year of reductions needed for RFP, based on the overall level of reductions needed to 

demonstrate attainment divided by the number of years from the 2002 base year to the attainment 

year.

242 There is no percent reduction associated with the RFP requirement for PM2.5 as there is 

with the Rate of Progress (ROP) requirement under Subpart 2 for ozone.243 Federal or local 

measures that are adopted and/or implemented prior to the milestone year and provide emission 

reductions in excess of those needed to meet an RFP or attainment milestone may be used as 

contingency measures.244 The USEPA’s guidance encourages this early implementation of 

contingency measures and relying on measures already implemented or under development.245

The remainder of this chapter:

- discusses the contingency targets (needed total emission reductions) associated with 

attainment of the 1997 annual PM2.5 NAAQS; 

- lists contingency measures associated with attainment of the 1997 annual PM2.5 NAAQS; 

and

- demonstrates that the reductions expected from the contingency measures listed meet the 

attainment contingency requirement.

 240 72 Fed. Reg. 20586-667 (April 25, 2007). 241 In general, the USEPA uses the term Reasonable Further Progress (RFP) as the more generic progress 

requirement under Subpart 1, whereas it uses the term rate of progress (ROP) to denote the specific Subpart 2 (ozone 

specific) progress requirements that are defined as specific percent reductions from a baseline emissions inventory. 

242 72 Fed. Reg. 20643 (April 25, 2007). 243 USEPA Memorandum from Lydia N. Wegman and Peter Tsirigotis to Regional Air Division Directors, “2002 

Base Year Emission Inventory SIP Planning: 8-hr Ozone, PM2.5, and Regional Haze Programs,” November 18, 

2002.

244 72 Fed. Reg. 20642 (April 25, 2007). 245 72 Fed. Reg. 20642-43 (April 25, 2007).
143

The measures included here as contingency measures are described in detail in Chapter 4. The 

calculation methodologies used to quantify these measures are included in Appendix C.

6.2 Contingency Measures for the Attainment Demonstration

As discussed above, the Clean Air Act requires New Jersey to identify contingency measures to 

be implemented in the event that the State does not attain the 1997 annual PM2.5 standard by 

2010. Attainment of this standard is determined based upon the 2009 annual PM2.5 design values 

from the air quality monitors. Table 6.1 shows the contingency measure calculations for 

attainment on April 5, 2010, as well as the contingency measures and their associated emission 

reductions, for both the New Jersey portions of its PM2.5 multi-state nonattainment areas. 

Contingency measures need to achieve the one year of RFP emission reductions for direct PM2.5

and its precursors (oxides of nitrogen (NOx), and sulfur dioxide (SO2)). This amount was 

calculated using the 2002 adjusted baseline inventory from Version 3 of the modeling inventory 

and the projected 2009 modeling inventory (refer to Chapter 5 for additional information on the 

emission inventories used for this SIP revision). Following the USEPA guidance outlined in 

Section 6.1, the State has estimated the contingency requirement to be 15,993 tons per year (tpy) 

of direct PM2.5, NOx, and SO2 in the New Jersey portion of the Northern New Jersey/New 

York/Connecticut nonattainment area and 3,489 tpy of direct PM2.5, NOx, and SO2 in the New 

Jersey portion of the Southern New Jersey/Philadelphia nonattainment area. 

New Jersey has identified eight control measures not included in the regional attainment 

demonstration modeling for the 1997 annual PM2.5 NAAQS to fulfill the contingency 

requirement should either of the nonattainment areas associated with New Jersey fail to 

demonstrate attainment by 2010. In addition, New Jersey has identified one control measure 

included in the regional attainment demonstration modeling for the 1997 annual PM2.5 NAAQS 

to fulfill the contingency requirement for the New Jersey portion of the Southern New 

Jersey/Philadelphia nonattainment area. The contingency requirements for the New Jersey 

portion of the Northern New Jersey/New York/Connecticut nonattainment area are satisfied 

through the eight measures not included in the regional attainment demonstration modeling. The 

refinery consent decrees for Sunoco, Valero, and ConocoPhillips were included in the attainment 

demonstration photochemical modeling for PM2.5. As discussed in detail in Appendix C, there is 

a “modeled differential” between the modeled design values for 2009 and the PM2.5 annual

NAAQS of 15.0 μg/m3

. For the purposes of satisfying the contingency requirements, New 

Jersey is allocating 738 tpy of the emission reductions provided by the refinery consent decrees 

in the New Jersey portion of the Southern New Jersey/Philadelphia nonattainment area from the 

modeling differential.

The attainment demonstration discussed in Chapter 5 projects both nonattainment areas 

associated with New Jersey to attain by 2010. If both areas reach attainment based upon the 

ambient air quality data from 2007-2009, the measures identified for New Jersey’s contingency 

plan will still be implemented and will provide additional air quality benefits beyond the benefits 

projected by the annual PM2.5 attainment demonstration modeling. The State and Federal 

contingency measures are:

1) Diesel idling,
144

2) Municipal Waste Combustors (Incinerators) NOx Rule,

3) Onroad Motor Vehicle Control Programs (Fleet turnover 2010),

4) Nonroad Motor Vehicle Control Programs (Fleet turnover 2010),

5) Industrial/Commercial/Institutional (ICI) Boiler Rule 2009 (portion not modeled),

6) NOx RACT Rule 2006 (portion not modeled),

7) Asphalt production plants rule, and

8) Controls from EGU Consent Decrees (Hudson SO2), and 

9) Refinery Consent Decrees (Sunoco and Valero).
145

Table 6.1

PM2.5 Attainment Contingency Measures for 2009

New Jersey Portion of the Northern New Jersey/New York/Connecticut Nonattainment 

Area (tons per year)

Direct PM2.5 NOx SO2 TOTAL

1. Calculations for the Contingency Requirement

2002 Baseline Modeling 

Emissions Inventory (tpy)

15,797 198,518 52,889 267,205

2009 Predicted Modeling 

Emissions Inventory (tpy)

14,752 113,690 26,811 155,254

Difference Between 2009-2002 

Emission Inventories (tpy)

1,045 84,828 26,078 111,951

Contingency Requirement (1/7) 

(tpy)

149 12,118 3,725 15,993

2. New Jersey Contingency Measures (tpy)

Diesel Idling Rule Changes 4 218 222

Municipal Waste Combustors 

(Incinerators) NOx Rule

0 0

Onroad Fleet Turnover (2010) 51 5,613 5,664

Nonroad Fleet Turnover (2010) 34 1,065 185 1,284

ICI Boiler Rule 2009 (portion 

not modeled)

681 681

NOx RACT Rule 2006 (portion 

not modeled)

548 548

Asphalt Production Plants Rule 50 50

Controls from EGU Consent 

Decrees (PSEG Hudson SO2)

51,124 51,124

Total Reductions Available for 

Contingency by Pollutant (tpy)

89 8,175 51,309 59,573

A. Total Reductions from New 

Jersey's Contingency Measures 

(tpy)

59,573

B. Total Emissions Target for 

the Contingency Requirement 

(tpy)

15,993

C. Difference (A-B) 43,580

Requirement Met? YES
146

Table 6.2

PM2.5 Attainment Contingency Measures for 2009

New Jersey Portion of the Southern New Jersey/Philadelphia Nonattainment Area

(tons per year)

Direct PM2.5 NOx SO2 TOTAL

1. Calculations for the Contingency Requirement

2002 Baseline Modeling Emissions 

Inventory (tpy)

4,485 48,409 12,506 65,400

2009 Predicted Modeling Emissions 

Inventory (tpy)

4,336 30,928 5,712 40,976

Difference Between 2009-2002 

Emission Inventories (tpy)

149 17,481 6,794 24,424

Contingency Requirement (1/7) 

(tpy)

21 2,497 971 3,489

2. New Jersey Contingency Measures (tpy)

Diesel Idling Rule Changes 2 112 114

Municipal Waste Combustor 

(Incinerators) NOx Rule

309 309

Onroad Fleet Turnover (2010) 25 1,808 1,833

Nonroad Fleet Turnover (2010) 7 166 32 205

ICI Boiler Rule 2009 (portion not 

modeled)

193 193

NOx RACT Rule 2006 (portion not 

modeled)

82 82

Asphalt Production Plants Rule 15 15

Refinery Consent Decrees (Sunoco 

and Valero)

738 738

Total Reductions Available for 

Contingency by Pollutant (tpy)

34 2,685 770 3,489

A. Total Reductions from New 

Jersey's Contingency Measures (tpy)

3,489

B. Total Emissions Target for the 

Contingency Requirement (tpy)

3,489

C. Difference (A-B) (tpy) 0

Requirement Met? YES

New Jersey is meeting its contingency requirement in the Northern New Jersey/New 

York/Connecticut and Southern New Jersey/Philadelphia nonattainment areas with the control 

measures and emission benefits shown in Tables 6.1 and 6.2, respectively. 
147

6.3 Contingency Measure Implementation Schedule

The required implementation schedule of contingency measures, should the USEPA make a 

finding of failure to attain the PM2.5 NAAQS, is one year. The earliest that contingency 

reductions would need to be in place would be September 2010. The measures in Tables 6.1 and 

6.2 will achieve even greater emission reductions than demonstrated, due to additional 

requirements within the rules that phase-in after 2009 that will achieve additional benefits.

The status of the control measures identified for contingency is included in Table 9.1. The dates 

provided in Table 9.1 indicate that all of the measures will be implemented in time for 

contingency if failure to meet the attainment date occurs. By following the USEPA’s guidance 

that encourages early implementation of contingency measures and relying on measures already 

implemented or under development,246 New Jersey is ensuring that no additional contingency 

measures will need to be developed and implemented beyond those identified, and is 

safeguarding itself against failure to attain. Since the contingency measures relied upon in this 

SIP revision will be implemented by the specified dates, which are before the time when the 

contingency measures would be required, there is no need for a trigger mechanism if the 

attainment goal is not reached. 

Since New Jersey relied upon its attainment demonstration to satisfy RFP, New Jersey would 

need to modify its attainment demonstration so that it meets the standard if New Jersey does not 

achieve attainment, thereby also satisfying the RFP requirements.247

6.4 Conclusions

New Jersey has demonstrated that it met its contingency requirements for attainment. It is 

possible that the emission benefits estimated for New Jersey’s rule proposals may be amended in 

response to comments. If this does occur, there are sufficient modeling differential and 

associated control measures as shown in this SIP revision to satisfy contingency requirements 

and requirements for attainment of the 1997 annual PM2.5 NAAQS. In addition, recent 

preliminary monitoring results indicate that the monitors are currently in compliance with the 

NAAQS of 15.0 μg/m3 in the regional Southern New Jersey/Philadelphia nonattainment area and 

in the New Jersey portion of the Northern New Jersey/New York/Connecticut nonattainment 

area. Therefore, the data indicates that the contingency measures will not be necessary to show 

attainment of the NAAQS of 15.0 μg/m3

. 

 246 72 Fed. Reg. 20642-43 (April 25, 2007). 247 72 Fed. Reg. 20633 (April 25, 2007).
148

7.0 TRANSPORTATION CONFORMITY

7.1 Introduction

The Clean Air Act248 requires that Federal actions conform to a State’s State Implementation 

Plan (SIP). Specifically the Clean Air Act requires the action/activity will not:

• Cause or contribute to any new violation of any National Ambient Air Quality Standard 

(NAAQS) in any area;

• Increase the frequency or severity of any existing violation of any NAAQS in any area; or,

• Delay timely attainment of any NAAQS or any required interim emission reductions or any 

other milestones in any area.

To implement this requirement, the Clean Air Act directed249 the United States Environmental 

Protection Agency (USEPA) to issue rules that governed how conformity determinations would 

be conducted for two categories of actions/activities: 1) those dealing with transportation plans, 

programs and projects (Transportation Conformity), and 2) all other actions, e.g., projects 

requiring Federal permits. This latter category is referred to as General Conformity.

The Federal Transportation Conformity Rule (40 C.F.R. § 93.100-129) provides the process by 

which the air quality impact of transportation plans, transportation improvement programs, and 

projects are analyzed. The agency preparing transportation plans (projections of twenty or more 

years), transportation improvement programs (projections of at least four years), or approving a 

transportation project must analyze the emissions expected from such a proposal in accordance 

with the Transportation Conformity Rule.250

For the purposes of transportation conformity, the emission budget is essentially a cap on the 

total emissions allocated to onroad vehicles. The projected regional emissions calculated based 

on a transportation plan, transportation improvement program, or project, may not exceed the 

motor vehicle emissions budget or cap contained in the appropriate SIP. Emissions in years for 

which no motor vehicle emissions budgets are specifically established must be less than or equal 

to the motor vehicle emissions budget established for the most recent prior year.

Emission budgets in New Jersey are established by nonattainment area and Metropolitan 

Planning Organization boundary. New Jersey is part of two nonattainment areas as shown in 

Figure 7.1: ten counties in Northern New Jersey associated with New York City and three 

counties in Southern New Jersey associated with Philadelphia. 

 248 42 U.S.C. § 7506.

249 42 U.S.C. § 7506. 250 For New Jersey, such plans are prepared by three Metropolitan Planning Organizations (North Jersey 

Transportation Planning Authority, South Jersey Transportation Planning Organization, and Delaware Valley 

Regional Planning Commission).
149

Figure 7.1: USEPA Designations of Nonattainment Areas for the PM2.5

National Ambient Air Quality Standard

There are three Metropolitan Planning Organizations (MPOs) in New Jersey that cover the 

geographic areas shown in Figure 7.2. These are the North Jersey Transportation Planning 

Authority (NJTPA), the Delaware Valley Regional Planning Commission (DVRPC), and the 

South Jersey Transportation Planning Organization. Each MPO is responsible for the 

transportation plans and transportation improvement programs for its designated area. The 

MPOs each work in consultation with the Federal Highway Administration, the New Jersey 

Department of Transportation (NJDOT), the USEPA, and the New Jersey Department of 

Environmental Protection (NJDEP) to remain at or under established transportation emission 

budgets for their area. Transportation conformity budgets for PM2.5 are developed for each MPO 

by adding the onroad emissions from individual counties within each MPO planning area located 

within the New Jersey portions of the PM2.5 nonattainment areas. This results in the formation of 

the following three areas for budget development:

• Nine counties located in the NJTPA MPO planning area and the New Jersey portion of the 

Northern New Jersey/New York/Connecticut (NNJ/NY/CT) PM2.5 nonattainment area 

(Bergen, Essex, Hudson, Middlesex, Monmouth, Morris, Passaic, Somerset, and Union 

Counties), 

• Mercer County located in the DVRPC MPO geographic area and the Northern New 

Jersey/New York/Connecticut nonattainment area, and 

• Three counties included in the DVRPC MPO geographic area and the New Jersey portion of 

the Southern New Jersey/Philadelphia (SNJ/Phila.) PM2.5 nonattainment area (Burlington, 

Camden, and Gloucester Counties).

BERKS

PIKE

ORANGE

SUFFOLK

LUZERNE

KENT

BUCKS

OCEAN

CHESTER

LANCASTER

MONROE

SUSSEX

FAIRFIELD

BURLINGTON

MORRIS

SCHUYLKILL

CECIL

WAYNE

ATLANTIC

NEW HAVEN

SALEM

KENT

COLUMBIA

CARBON

HARFORD

LEHIGH

WARREN

SULLIVAN

WYOMING

MONMOUTH

LEBANON

CUMBERLAND

HUNTERDON

WESTCHESTER

NASSAU

MIDDLESEX

BERGEN

PUTNAM

MERCER

PASSAIC

ESSEX

LITCHFIELD

UNION

NEW CASTLE

MONTGOMERY

LACKAWANNA

SOMERSET

MIDDLESEX

CAMDEN

GLOUCESTER

NORTHAM PTON

QUEEN ANNES

CAPE MAY

ROCKLAND

DELAWARE

ULSTER

QUEENS

CAROLINE

PHILADELPHIA

HARTFORD

KINGS

HUDSON

BRONX

RICHMOND

NEW YORK

In Attainment 

NY_NJ_LI_CT_nonattainment_area

PA_NJ_DE_nonattainment_area

Geographic Areas

DE

NJ

CT

NY

PA

MD

In Attainment

NNJ/NY/CT Nonattainment Area

SNJ/Phila. Nonattainment Area
150

Figure 7.2: Metropolitan Planning Organizations in New Jersey

Delaware Valley Regional

Planning Commission

North Jersey Transportation

Planning Authority

South Jersey Transportation

Planning Organization
151

The South Jersey Transportation Planning Organization does not have to perform transportation 

conformity for PM2.5 because the counties within their planning area are in attainment of the 

PM2.5 annual NAAQS.

7.2 Transportation Conformity for PM2.5

7.2.1 Interim Tests to be used Prior to the Establishment of Budgets

The Transportation Conformity Rules that established the criteria and procedures relating to 

Transportation Conformity for PM2.5 were promulgated by the USEPA on July 1, 2004.251 

Transportation Conformity for PM2.5 became effective on April 5, 2006; the effective date is 

based on a one-year grace period from the effective date of designations, April 5, 2005.

Before a SIP budget is available, either through an adequacy finding or approval by the USEPA, 

conformity of the transportation plan, transportation improvement program, or project not from a 

conforming plan is demonstrated with the interim emissions tests.252 The interim emissions tests 

for PM2.5 are either the baseline year test or the build/no-greater-than-no-build test. The baseline 

year test is passed when the emissions from the proposed transportation system are either less 

than or no greater than the baseline year (2002) motor vehicle emissions in a given 

nonattainment area. With the build/no-greater-than-no-build test conformity is demonstrated if 

emissions from the proposed transportation system (“build” or “action” scenario) are less than or 

equal to the emissions in the same future analysis year from the existing transportation system 

(“no-build” or “baseline” scenario). The MPOs performing planning in PM2.5 nonattainment 

areas were required to utilize either the baseline year test or the build/no-greater-than-no-build 

test until emission budgets are approved or found adequate by the USEPA. Currently, the 

NJTPA and the DVRPC are using early budgets that have been approved by the USEPA for the 

counties in the Northern New Jersey/New York/Connecticut nonattainment area. The DVRPC is 

currently using interim tests for the counties in the Southern New Jersey/Philadelphia 

nonattainment area.

7.2.2 PM2.5 Precursors

For transportation conformity, four PM2.5 precursors – oxides of nitrogen (NOx), volatile organic 

compounds (VOCs), sulfur dioxide (SO2), and ammonia (NH3) – are considered in the 

conformity process in PM2.5 nonattainment areas,253 pursuant to the following USEPA 

requirements:

 

• Regional emissions analysis must include NOx as a PM2.5 precursor in all PM2.5

nonattainment areas, unless the head of the state air agency and the USEPA Regional 

Administrator make a finding that NOx is not a significant contributor to the PM2.5 air 

quality problem in a given area. 

 251 69 Fed. Reg. 40004-81 (July 1, 2004). 252 40 C.F.R. § 93.119. 253 70 Fed. Reg. 24280-92 (May 6, 2005).
152

• Regional emissions analyses are not required for VOC, SO2, or NH3 before an approved 

SIP budget for such precursors is established, unless the head of the state air agency or 

the USEPA Regional Administrator makes a finding that onroad emissions of any of 

these precursors is a significant contributor.

The following criteria are considered in making significance or insignificance findings for PM2.5

precursors:

• The contribution of onroad emissions of the precursor to the total 2002 baseline SIP 

inventory; 

• The current state of air quality for the area; 

• The results of speciation monitoring for the area; 

• The likelihood that future motor vehicle control measures will be implemented for a 

given precursor; and,

• Projections of future onroad emissions of the precursor. 

After reviewing the USEPA requirements and the criteria regarding significance, the New Jersey 

transportation conformity budgets for PM2.5 precursors will only include the establishment of an 

annual NOx budget for the two PM2.5 nonattainment areas addressed by this attainment 

demonstration SIP revision. 

7.2.3 Road Dust and Construction Related Fugitive Dust

The Federal Transportation Conformity Rule specifies that re-entrained road dust is to be 

included as a component of direct PM2.5 for transportation conformity regional emissions 

analysis only if the USEPA Regional Administrator or the director of the State air agency has 

made a finding that emissions from re-entrained road dust within the area are a significant 

contributor to the PM2.5 nonattainment problem and has so notified the MPO and NJDOT.254 

Also, for PM2.5 areas in which the implementation plan does not identify construction-related 

fugitive PM2.5 as a significant contributor to the nonattainment problem, the fugitive PM2.5

emissions associated with highway and transit project construction are not required to be 

considered in the regional emissions analysis.255

The USEPA has indicated that a finding of significance for re-entrained road dust would be 

based on a case-by-case review of the following factors: the contribution of road dust to current 

and future PM2.5 nonattainment; an area’s current design value for the PM2.5 standard; whether 

control of road dust appears necessary to reach attainment; and whether increases in re-entrained 

dust emissions may interfere with attainment. Such a review would include consideration of 

local air quality data and/or air quality or emissions modeling results.256

 254 40 C.F.R. § 93.119(f)(8). 255 40 C.F.R. § 93.122(f)(1). 256 69 Fed. Reg. 40033 (July 1, 2004).
153

Findings of significance have not been made for either re-entrained road dust or constructionrelated fugitive dust for the New Jersey portions of the Northern New Jersey/New 

York/Connecticut and the Southern New Jersey/Philadelphia nonattainment areas. As described 

in Chapter 2, a number of source apportionment studies have concluded that the primary 

components of the PM2.5 mass measured in New Jersey monitors are: secondary sulfate from 

large-coal fired power plants located primarily in other states, automotive emissions and biomass 

burning. Re-entrained road dust and fugitive dust from road construction projects would be 

monitored as a component of soil material. Soil material makes up a relatively small percentage 

of the PM2.5 mass measured in New Jersey monitors.257 Therefore, neither re-entrained road dust 

emissions or fugitive dust emissions from highway and transit project construction have been 

included in the PM2.5 transportation conformity budgets. 

7.2.4 Early Budgets for PM2.5

In a 2006 SIP revision258 (referred to hereafter as the “2006 SIP Revision”), New Jersey 

established early PM2.5 transportation conformity emission budgets including documentation of 

the justification for the early budgets. Early budgets were established for directly emitted fine 

particulate matter (direct PM2.5) and annual NOx (a PM2.5 precursor) for the New Jersey portion 

of the Northern New Jersey/New York/Connecticut nonattainment area. This nonattainment area 

includes one county in the DVRPC MPO planning area (Mercer County), with the other nine 

counties in the NJTPA MPO planning area. These early budgets for New Jersey were approved 

by the USEPA on July 10, 2006.259 Once approved by the USEPA, these early budgets became 

the existing attainment budgets that must be used for transportation conformity determinations 

made by the NJTPA and the DVRPC.

In the recent 8-hour ozone attainment demonstration SIP, the Division of Air Quality (DAQ) 

updated the planning assumptions that were used in the transportation conformity analyses. The 

distribution of vehicle miles traveled (VMT) between vehicle types was updated to reflect a 

greater fraction of the total VMT attributed to the heaviest class of diesel trucks (trucks greater 

than 60,000 lbs. Gross Vehicle Weight Rating). When the updated VMT/vehicle type mix is 

used, the predicted emissions of direct PM2.5 and annual NOx increase. The higher predictions 

result in values that are significantly higher than the existing budgets.

 

The amount of the budget exceedance for Mercer County was much greater than the emission 

reductions that could be achieved by changes to transportation projects by 2009. Therefore, an 

update to the existing budget for Mercer County was proposed on December 17, 2007 as a SIP 

 257 Hopke, P. K. and Kim, E. Application of Advanced Factor Analysis Modeling to Apportion PM2.5 in New 

Jersey. Center for Air Resources Engineering and Science, Clarkson University, March 2005. 258 NJDEP. State Implementation Plan (SIP) Revisions for the Attainment and Maintenance of the 8-Hour Carbon 

Monoxide National Ambient Air Quality Standard, 1-Hour Ozone National Ambient Air Quality Standard, and Fine 

Particulate Matter National Ambient Air Quality Standard; and the 2002 Periodic Emission Inventory. New Jersey 

Department of Environmental Protection, May 2006.

259 71 Fed. Reg. 38770-72 (July 10, 2006).
154

revision.260 This SIP revision was approved by the USEPA, effective June 5, 2008.261 This will 

enable the DVRPC MPO to meet its transportation conformity requirements when it conducts its 

regional analysis this spring. Updates to the existing budget established for the NJTPA MPO are 

provided in Section 7.3.

7.3 Budgets for Attainment of the Annual PM2.5 NAAQS

The existing and updated attainment transportation conformity emission budgets for directly 

emitted fine particulate matter (direct PM2.5) and annual NOx (a PM2.5 precursor), by MPO 

planning area for the New Jersey portions of the Northern New Jersey/New York/Connecticut 

and the Southern New Jersey/Philadelphia nonattainment areas, are provided in Table 7.1. The 

attainment budgets are based on the latest planning assumptions, including those for vehicle age 

distribution, VMT by vehicle type fraction, diesel sulfur level (43 ppm),

262 and the 2009 

projected vehicle activity data. 

Each MPO used their Travel Demand Models (TDM) to estimate the 2009 projected vehicle 

activity data. Both MPOs used the monthly approach outlined in the USEPA guidance263 to 

calculate annual average emissions. This approach involves twelve sets of MOBILE6.2 

modeling runs using monthly average input conditions. The 12 months of results were then 

averaged together to compute the annual emissions used to estimate the attainment budgets. 

Once approved by the USEPA, the attainment budgets must be used for future transportation 

conformity determinations by the NJTPA and the DVRPC. Computer files that document the 

calculation of the attainment budgets are provided in Appendix D.

 260 NJDEP. Proposed State Implementation Plan Revision For Attainment of the Fine Particulate Matter National 

Ambient Air Quality Standard, Update of Early Transportation Conformity Budgets for Mercer County. New Jersey 

Department of Environmental Protection, December 17, 2007. 

261 73 Fed. Reg. 24868 (May 6, 2008). 262 USEPA. Technical Guidance on the Use of MOBILE6.2 for Emission Inventory Preparation. United States 

Environmental Protection Agency, EPA420-R-04-013, Section 5.5.3, page 64, August 2004. 263 USEPA. Guidance for Creating Annual On-Road Mobile Source Emission Inventories for PM2.5 Nonattainment 

Areas for Use in SIPs and Conformity. United States Environmental Protection Agency, EPA420-B-05-008, page 7, 

August 2005.
155

Table 7.1: Existing and Updated Transportation Conformity Emission Budgets for PM2.5 

Attainment

Direct PM2.5 Emissions(a) 

 (tons per year) 

NOx Emissions 

(tons per year)

Type of Budget Existing Updated Existing Updated

NJTPA and NNJ/NY/CT 

Nonattainment Area(b) 1,207 842 61,676 44,321

DVRPC and NNJ/NY/CT 

Nonattainment Area(c) 105 105 5,323 5,323

DVRPC and SNJ/Phila. 

Nonattainment Area(d) No Existing 

Budget 341 No Existing Budget 17,319

Notes: (a) Direct PM2.5 consists of the sum of: SO4, organic carbon, elemental carbon, particulate matter from 

gasoline vehicles, lead, brake particles, and tire particles.

(b) This area consists of Bergen, Essex, Hudson, Middlesex, Monmouth, Morris, Passaic, Somerset and 

Union Counties (New Jersey portion of the NNJ/NY/CT nonattainment area also located in the NJTPA 

planning area).

(c) This area consists of Mercer County.

(d) This area consists of Burlington, Camden and Gloucester Counties (New Jersey portion of the SNJ/Phila. 

nonattainment area).

Table 7.1 indicates that the updated attainment budgets for direct PM2.5 and NOx for NJTPA are 

365 and 17,355 tons per year less, respectively, than the early budgets set forth in the 2006 SIP 

Revision. These new attainment budgets incorporate the latest planning assumptions, including 

recent updates to the NJTPA TDM. The update of the TDM results in reductions in emission 

predictions that more than compensated for the increases from the update to the VMT by vehicle 

type fractions. 

The Mercer County budget was proposed on December 17, 2007 in a separate Transportation 

Conformity SIP and proposed for approval by the USEPA on May 6, 2008, as discussed in 

Section 7.2.4. Thus, the updated budget in Table 7.1 is the same as the budget that was proposed 

in December 2007 in the Transportation Conformity SIP. Regarding the updated budget 

established for the DVRPC MPO for its three counties included in the New Jersey portion of the 

Southern New Jersey/Philadelphia nonattainment area, this represents the first time that a PM2.5 

budget has been established for these counties. 
156

8.0 SECTION 110 INFRASTRUCTURE REQUIREMENTS

8.1 Introduction and Background

42 U.S.C. § 7410(a)(1) and (2) (Sections 110(a)(1) and (2)) of the Federal Clean Air Act), 

hereafter referred to as the “Infrastructure” State Implementation Plan (SIP) requirements, 

requires states to submit an implementation plan to the United States Environmental Protection 

Agency (USEPA) Administrator that demonstrates their ability and authority to implement, 

maintain, and enforce each National Ambient Air Quality Standard (NAAQS). Section 110(a)(1) 

of the Clean Air Act addresses the timing requirement for the submissions of any Infrastructure 

SIP revisions, while Section 110(a)(2) of the Clean Air Act lists the required elements that a state 

needs to demonstrate its authority for implementing. These elements including, but are not 

limited to, air quality monitoring, data analysis, and reporting; enforcement; resources; 

consultation; emergency procedures; and reductions in transported air pollution. 

On August 15, 2006, the USEPA issued guidance264 on what states should submit in order to 

comply with Section 110(a)(2)(D)(i) of the Clean Air Act concerning transported air pollution. 

Subsequently, on October 2, 2007, the USEPA issued guidance265 on what states should submit 

in order to comply with the remaining non-transport-related requirements of Section 110(a)(2) 

for both the 1997 8-hour ozone and fine particulate matter (PM2.5) NAAQS. 

New Jersey has complied with both of the USEPA’s guidance documents to address its 

Infrastructure SIP requirements for the 1997 8-hour ozone and PM2.5 NAAQS in two parts:

 On February 25, 2008, the NJDEP submitted an Infrastructure SIP266,267 which addressed 

all the non-transport-related elements of Section 110(a)(2) with respect to the 1997 8-

hour ozone and PM2.5 NAAQS.268 (See Appendix E)

 On December 22, 2006, the New Jersey Department of Environmental Protection 

(NJDEP) sent the USEPA a letter269 describing New Jersey's plan for addressing the 

transported emission requirements prescribed in Section 110(a)(2)(D)(i) of the Clean Air 

Act with respect to the 1997 8-hour ozone and PM2.5 NAAQS. As described in this letter, 

the transported emissions related actions would be part of various SIP proposals, which 

would all go through a public comment process prior to being finalized for submission to 

the USEPA. To date, the NJDEP has held public hearings on New Jersey’s 8-hour ozone 

 264 USEPA. Guidance for State Plan Submission to Meet Current Outstanding Obligations Under Section 

110(a)(2)(D)(i) for the 8-Hour Ozone and PM2.5 National Ambient Air Quality Standards. United States 

Environmental Protection Agency, August 15, 2006.

265 USEPA. Guidance on SIP Elements Required Under Sections 110(a)(1) and (2) for the 1997 8-Hour Ozone and

PM2.5 National Ambient Air Quality Standards. United States Environmental Protection Agency, October 2, 2007. 266 Letter from NJDEP Commissioner Lisa P. Jackson to USEPA Regional Administrator Steinberg dated February 

25, 2008. (See Appendix E)

267 NJDEP. State Implementation Plan Revision For Meeting the Infrastructure Requirements of the Clean Air Act. 

New Jersey Department of Environmental Protection, February 2008. 

268 The infrastructure SIP proposal was submitted in December 2007: NJDEP. Proposed State Implementation Plan 

Revision For Meeting the Infrastructure Requirements of the Clean Air Act. New Jersey Department of 

Environmental Protection, December 2007. Available at http://www.state.nj.us/dep/baqp/infrastructure.pdf.

269 Letter from NJDEP Commissioner Lisa P. Jackson to USEPA Regional Administrator Steinberg dated December 

22, 2006. The letter is posted on the NJDEP’s website at http://www.state.nj.us/dep/baqp/sip/siprevs.htm.
157

reasonably available control technology (RACT) SIP and its Clean Air Interstate Rule 

(CAIR), both of which included a discussion of interstate transport as outlined in the 

December 22, 2006 NJDEP letter to the USEPA.

Through these two efforts, New Jersey demonstrated that it has the authority to implement its 

Infrastructure SIP requirements outlined in the USEPA’s guidance documents with respect to 

both the 1997 8-hour ozone and PM2.5 NAAQS. Furthermore, these actions by the State satisfied 

the timing requirement under the Consent Decree for the Section 110(a)(2) elements for the 1997 

8-hour ozone and PM2.5 NAAQS. 

On October 22, 2008, the USEPA determined that the State’s Infrastructure SIP did not include 

two elements:

 A plan pertaining to the Part C Prevention of Significant Deterioration (PSD) permit 

program, and 

 A PM2.5 significant harm level (SHL) in a plan that addresses the infrastructure element 

concerning emergency powers and adequate contingency plans.270 

New Jersey addresses the plan for the PSD program in Section 8.2.2 of this SIP.271 Pertaining to 

the SHL for PM2.5 emergency episodes, New Jersey is waiting for further guidance from the 

USEPA.272 

As with 8-hour ozone, addressing transported emissions of PM2.5 and its precursors, both to and 

from the State, is critical for New Jersey’s multi-state nonattainment areas to attain and maintain 

the health-based ambient air quality standards. To emphasize this importance, the remainder of 

this Chapter reiterates the State’s plan as outlined in its transport letter, submitted to the USEPA 

on December 22, 2006,273 as it pertains to the PM2.5 NAAQS, and provides updates on the 

State’s progress in addressing interstate transport of PM2.5-related emissions. The public hearing 

on New Jersey’s proposed CAIR,274 held on March 28, 2007, included a discussion of interstate 

transport as outlined in the December 22, 2006 NJDEP letter to the USEPA. New Jersey’s CAIR 

allocation rule was adopted on June 19, 2007, became effective on July 16, 2007, became 

operative on August 17, 2007,275 and the USEPA approved these rules on October 1, 2007.276 

 270 73 Fed. Reg. 62904 (October 22, 2008). 271 The USEPA stated that the requirement was already addressed by a Federal Implementation Plan (FIP) and no 

further FIP actions were required. (73 Fed. Reg. 62904 (October 22, 2008)). 272 The USEPA proposed the Significant Harm Level (SHL) for PM2.5 at 500 μg/m3 on January 19, 2009. At the 

time of this SIP revision, this proposal was not published in the Federal Register and is currently under review by 

the new Federal Administration. 

273 Letter from NJDEP Commissioner Lisa P. Jackson to USEPA Regional Administrator Steinberg dated December 

22, 2006. The letter is posted on the NJDEP’s website at http://www.state.nj.us/dep/baqp/sip/siprevs.htm.

274 39 N.J.R. 300(a) (February 5, 2007). 275 39 N.J.R. 2637(a) (July 16, 2007). Also, see N.J.A.C. 7:27-30. 276 72 Fed. Reg. 55666-72 (October 1, 2007).
158

8.2 Interstate Transport (§ 110(a)(2)(D))

Section 110(a)(2)(D)(i) of the Clean Air Act

Each state’s SIP must contain adequate provisions prohibiting any source, or other type of 

emissions activity, within the State from emitting any air pollutants in amounts that will:

1) Contribute significantly to nonattainment of the NAAQS for areas in another state or 

interfere with the maintenance of the NAAQS by another state; 

2) Interfere with measures required to meet the implementation plan for any other state related 

to Regional Haze and Visibility; or,

3) Interfere with measures required to meet the implementation plan for any other state related 

to prevention of signification deterioration (PSD).

8.2.1 Significant Contribution to Nonattainment, or Interference with Maintenance, of a 

NAAQS in Another State

The USEPA’s analysis in support of the CAIR277 shows that New Jersey is not a significant 

contributor to PM2.5 nonattainment in any other state (because its transported contribution is less 

than 0.2 μg/m3). However, that same USEPA analysis indicates that the following upwind states 

significantly contribute to PM2.5 nonattainment in Union County, New Jersey:278

- Maryland/Washington, D.C.,

- Michigan,

- New York,

- Ohio,

- Pennsylvania, and 

- West Virginia.

Further, the USEPA’s analysis in support of the CAIR indicates that the following states 

significantly contribute to PM2.5 nonattainment in New Jersey’s associated PM2.5 multi-state 

nonattainment areas: 

- Maryland/Washington, D.C.,

- Michigan,

- New York,

- Ohio,

- Pennsylvania, 

- West Virginia, and 

- Virginia.

 277 USEPA. Technical Support Document for the Final Clean Air Interstate Rule Air Quality Modeling, Air Quality 

Modeling Analyses – VII: Modeling to Assess Interstate PM2.5 Contributions. United States Environmental 

Protection Agency Office of Air Quality Planning and Standards, Research Triangle Park, NC, March 2005. 278 Union County was the only New Jersey county identified in nonattainment by the USEPA’s CAIR analysis. 
159

The USEPA’s transport guidance allows states that are subject to requirements of the CAIR to 

satisfy the requirements of Section 110 (a)(2)(D)(i) through submittal of a CAIR SIP or reliance 

of the CAIR Federal Implementation Plan (FIP). New Jersey finalized an abbreviated CAIR SIP 

on June 19, 2007 that complies with CAIR requirements.279 As part of this submittal, New 

Jersey stated that the CAIR SIP also served to partially address the transport requirement, and 

took that action through the public process. Based on the USEPA’s transport guidance, this 

action by New Jersey satisfies the first of the requirements of Section 110 (a)(2)(D)(i). 

However, the implementation of CAIR alone will not be sufficient to address interstate transport 

issues, especially for the Northeastern and Mid-Atlantic United States. The U.S. Court of 

Appeals for the D.C. Circuit identified six major problems in the CAIR in its July 11, 2008 

opinion (State of North Carolina v. Environmental Protection Agency, 531 F.3d 896 (D.C. Cir. 

2008)), which included:

 CAIR trading programs are flawed because the region wide focus on emission reductions 

did not factor in each state’s contribution to air pollution issues;

 The USEPA did not give independent significance to the “interfere with maintenance” 

language in Section 110(a)(2)(D) and thus did not provide enough protection to 

downwind areas; 

 The 2015 compliance date for Phase 2 of CAIR is inconsistent with downwind states’ 

2010 attainment deadlines for PM2.5 and ozone NAAQS;

 Both SO2 and NOx budgets (i.e., the allowances states were given in their trading 

programs) were not based on the objectives of section 110(a)(2)(D).

In addition, CAIR focuses solely on Electric Generating Units (EGUs), and does not address 

interstate transport of emissions from other sectors (non-EGU, mobile, area). In light of these 

concerns, New Jersey commits to implement additional strategies to address the transport of 

PM2.5 and PM2.5 precursor emissions, as discussed in Section 8.2.2.

8.2.2 The Regional Haze and Visibility Interference Requirement

PM2.5 is the main component of regional haze. Therefore, the PM2.5 SIP is relevant to the 

visibility requirements of Section 110(a)(2)(D)(i). 

Regional Haze is visibility impairment caused by air pollutant emissions from numerous sources 

over a wide geographic area. In 1977, Section 169A of the Clean Air Act set forth a national 

goal for visibility which is the “prevention of any future, and the remedying of any existing, 

impairment of visibility in Class I areas which impairment results from manmade air pollution.” 

Class I areas are defined as any national park larger than 6,000 acres in size, national wilderness 

areas or memorial parks greater than 5,000 acres in size, and all international parks which were 

in existence on August 7, 1977. There are 156 Class I areas across the United States, including 

the Brigantine Wilderness Area of the Edwin B. Forsythe National Wildlife Refuge in New 

Jersey. 

In the 1990 Clean Air Act Amendments, Congress added Section 169B requiring the states to 

achieve ‘reasonable progress’ toward the national goal of removing any visibility impairment 

 279 39 N.J.R. 2637(a) (July 16, 2007). Also, see N.J.A.C. 7:27-30.
160

from manmade air pollution to the designated Class I area. The Brigantine Wilderness Area of 

the Edwin B. Forsythe National Wildlife Refuge in New Jersey is afforded the same visibility 

protection as the Grand Canyon. The goal of the USEPA Regional Haze Rule is to improve 

visibility to natural background levels by the year 2064 in all federally designated Class I areas. 

States with Class I areas are required to establish Reasonable Progress Goals for Class I areas 

within their borders, and compare their projected rate of improvement with the Uniform Rate of 

Progress, with 10-year incremental mid-term goals to be attained along the way. All states are 

required to periodically conduct an analysis of available reasonable measures and implement 

those measures. The analysis and measures must be included in a SIP.

New Jersey proposed its Regional Haze SIP on September 15, 2008. This plan proposes to 

establish the baseline and natural visibility conditions, identifies the states which contribute to 

visibility impairment at the Brigantine Wilderness Area, and establishes the 2018 Reasonable 

Progress Goal. Based on a variety of technical methods, including the USEPA’s CAIR analysis 

discussed is Section 8.2.1, New Jersey identified 22 states which contributed to visibility 

impairment at the Brigantine Wilderness Area with respect to the 2018 Reasonable Progress 

Goal, as pictured in Figure 8.1.

Figure 8.1: States Identified as Contributing to

Visibility Impairment in New Jersey’s Class I Area

New Jersey

Illi no is

Georgi a

M ichi gan

K entuck y

Ten nessee

South Carolina

M ic higan

Di st rict of ColumbiaDelaware

Ohi o

Virginia

I ndiana

New York

Pennsy lvania

North C arolina

W est Virginia

M aryland

Maine

Vermon t

Mass achu set ts

Con nect icut

N ew H amp shi re

Rho de Is land

Iow a

Mis so uri

Ark ans as

Alabama

W is co n si n

Louisiana

Mis si ss ip pi

M inneso ta

Kansas

Tex as

N ebraska

Sou th D ako ta

Flo rid a

Ok lah o ma

No rth Dak ot a

Reason for Inclusion

Not Id entified

MANE-VU Member

Contributory to Briga ntine

New Jersey

Additionally, New Jersey contributes to visibility impairment at the Brigantine Wilderness Area. 

Maine, New Hampshire, and Vermont determined that New Jersey contributed to their Class I 

areas, Acadia National Park and Moosehorn Wilderness Area, Great Gulf Wilderness Area and 

Presidential Range/Dry River Wilderness Area, and Lyebrook Wilderness Area, respectively. 

To achieve the 2018 Reasonable Progress Goal, the proposed plan relies upon the identified 

contributing states implementing the reasonable measures identified by New Jersey and the MidAtlantic/Northeast Visibility Union (MANE-VU) states. Based on the modeling results and 

other analysis performed by MANE-VU, the MANE-VU states developed “Asks”, which are 

“emission management” strategies. These strategies served as the basis for the consultation with 
161

the other states.280 The State consulted with the other Regional Planning Organizations and the 

contributing states within MANE-VU regarding the reasonableness of the identified measures. 

The contributing states within MANE-VU agreed to adopt and implement reasonable measures. 

The measures used to set the 2018 Reasonable Progress Goal are:

 Timely implementation of the Clean Air Act requirement to install Best Available 

Retrofit Technology (BART) on eligible sources;

 At least 90% SO2 emission reductions from 2002 levels at the top 100 electric generating 

unit (EGU) sources that impact the Brigantine Wilderness Area (for the six MANE-VU 

visibility protected areas; there are 167 different EGU stacks that impact one or more of 

these areas); 

 For the MANE-VU states, reducing the level of sulfur in fuel oil. 

 For the contributing states outside of MANE-VU, a 28% emission reduction from nonelectric generating unit sources is sought;281

 Continued evaluation of other measures, including Energy Efficiency, Alternative Clean 

Fuels and other measures to reduce SO2, PM, and NOx from all coal-burning facilities by 

2018, and new source performance standards for wood combustion.

These regional reductions in air pollutant emissions will improve air quality in New Jersey. 

New Jersey commits to implement additional strategies to address the transport of direct PM2.5 

and PM2.5 precursor emissions both to and from New Jersey. As part of a regional effort, New 

Jersey commits to:

- Continue to meet its obligations under the oxides of nitrogen (NOx) SIP Call, 

including an allocation mechanism that encourages energy efficiency for New Jersey 

sources in the Federal CAIR program;

- Adopt multi-pollutant (NOx, sulfur dioxide (SO2), and particulate matter (PM)) 

performance standards providing additional emission reductions for coal-fired 

Electric Generating Units (EGUs);

- Update its RACT rules to address the PM2.5 precursors (see Table 9.1);

- Continue to implement the Low Emission Vehicle (LEV) program; 

- Adopt rules and/or other measures to address emissions from oil and gas EGUs on 

High Electrical Demand Days (HEDD); and

- Propose rules to implement long-term, regional strategies, consistent with the MANEVU statement (see Appendix A6), affecting the sulfur content and corresponding 

emission limits of No. 2, 4, and 6 fuel oil.

The emission reductions from large stationary sources through the NOx SIP Call have achieved 

significant progress in reducing the transport of PM2.5 and its precursors in the eastern United 

 280 The regulations at 40 C.F.R. 51.308 (d)(1)(iv) requires states with Class I areas to develop reasonable progress 

goals in consultation with any state that may reasonably cause or contribute to visibility impairment in the Class I 

area. 

281 New Jersey and the other MANE-VU Class I states are recommending that contributing states determine the best 

way to achieve this level of emission reduction. The 28% represents an estimate of the benefits from the MANEVU fuel oil strategy.
162

States. The demonstration of attainment in Chapter 5 relies on the implementation of additional 

control measures by upwind states. These PM2.5 measures include new or additional regulations 

on asphalt production, cement kilns, glass furnaces, and Industrial/Commercial/Institutional (ICI) 

boilers. Because New Jersey has demonstrated that it needs the emissions reductions from these 

other states in order to meet its attainment obligations, the State requests (see Chapter 9) that the 

USEPA, in reviewing the SIP revisions from other states, take into consideration the other states’ 

impact on New Jersey’s attainment obligations, and ensure that other states are doing what is 

needed for New Jersey’s associated multi-state nonattainment areas to reach attainment as soon 

as practicable. 

All actions which New Jersey determines are necessary to attain and maintain the PM2.5 NAAQS 

in New Jersey, and to maintain the PM2.5 NAAQS in neighboring states, will be proposed and 

included as a revision to New Jersey’s SIP. In accordance with the New Jersey Administrative 

Procedures Act (APA) (N.J.S.A. 52:14B-1 et seq.) and the Air Pollution Control Act (APCA) 

(N.J.S.A. 26:2C-1 et seq.), these proposals will be taken through public process at that time.

8.2.3 Prevention of Significant Deterioration/Nonattainment New Source Review 

(PSD/NNSR) Requirement

With respect to the PM2.5 standard, New Jersey has both attainment and nonattainment areas 

throughout the State, necessitating both a PSD and NNSR program with respect to this pollutant. 

This section explains how the separate regulatory actions the USEPA has taken to implement 

these programs and how New Jersey plans to implement its programs for the PM2.5 health-based 

standard.

On April 25, 2007, the USEPA finalized its implementation rule for the 1997 PM2.5 NAAQS.

282

No final PM2.5 requirements for the NSR program were included. Prior to the implementation of 

that rule, the USEPA issued interim guidance283,284 calling for use of coarse particulate matter 

(PM10) as a surrogate for PM2.5 in the PSD and NNSR programs until NSR rules were finalized. 

Due to the lack of PM2.5 NSR rules, PM10 was used as a surrogate in both attainment and 

nonattainment areas. Under the surrogate approach, compliance with applicable requirements 

for PM10 was assumed to satisfy PM2.5 requirements.

On September 21, 2007, the USEPA proposed a rule on increments, significant impact levels 

(SIL), and significant monitoring concentrations (SMC).285 The proposal has not been finalized 

as of this SIP revision. The final rule is anticipated in the summer of 2009.

 282 72 Fed. Reg. 20586-667 (April 25, 2007). 283 USEPA Memorandum from Stephen D. Page, Director, Office of Air Quality Planning and Standards, to 

Regional Air Directors, “Implementation of New Source Review Requirements in PM-2.5 Nonattainment Areas,” 

April 5, 2005. 

284 USEPA Memorandum from John S. Seitz, Director, Office of Air Quality Planning and Standards, to Regional 

Air Directors, “Interim Implementation of New Source Review for PM2.5,” October 23, 1997.

285 72 Fed. Reg. 54112-156 (September 21, 2007).
163

On May 16, 2008, the USEPA issued a portion of the NSR rule for PM2.5.

286 That rule changed 

the Federal rule for PSD, Appendix S of 40 C.F.R. pt. 51 for nonattainment areas, and the 

Federal guidance for state PSD and nonattainment NSR SIPs.

PSD Requirements in New Jersey’s Attainment Counties:

For attainment areas implementing the Federal PM2.5 PSD program through delegation, where 

the Federal government or a delegated state issues PSD permits, the PM2.5 PSD rule changes 

published on May 16, 2008 are effective as of July 15, 2008.287 New Jersey is a PSD delegated 

state. According to that rule, the changes for New Jersey’s attainment counties implementing the 

Federal PSD program through delegation were effective as of July 15, 2008. The PM10 surrogate 

policy no longer applied after July 15, 2008. 

Nonattainment NSR (NNSR) Requirements in New Jersey’s Nonattainment Counties:

Between July 15, 2008 and the effective date of New Jersey’s NSR rules for PM2.5 (expected in 

2011), the USEPA’s Appendix S (40 C.F.R. pt. 51) applies.

The PM2.5 NSR rule allows up to three years for states to revise their regulations and SIP. New 

Jersey expects the three year clock to be triggered once the USEPA adopts the remaining 

components of its PM2.5 NSR implementation rules, which are expected by the summer of 2009. 

The NJDEP expects to develop NNSR rule strategies in 2009, propose a NNSR rule revision in 

2010, and adopt a revised NSR rule in 2011. 

The NJDEP also expects to adopt New Jersey specific PSD rules in the same timeframe. 

Currently, NJDEP implements most of the Federal PSD rules under a delegation agreement and 

will continue to do so until New Jersey PSD rules are effective.

8.3 Conclusion

New Jersey complied with the USEPA’s guidance in determining that it has the authority to 

implement its Infrastructure SIP requirements with respect to both the 1997 8-hour ozone and 

PM2.5 NAAQS. Furthermore, the State has satisfied the timing requirement under the Consent 

Decree for the Section 110(a)(2) elements for the 1997 8-hour ozone and PM2.5 NAAQS. 

Addressing transported emissions, both to and from the State, is critical for New Jersey’s PM2.5

multi-state nonattainment areas to attain and maintain the health-based ambient air quality 

standards. New Jersey is complying with the USEPA’s guidance regarding interstate transport as 

it relates to the PM2.5 NAAQS and is doing more to ensure that it is not inferring with the ability 

of its neighboring states to attain and maintain that standard. While many of New Jersey’s 

existing requirements are already more stringent than the existing pollution control requirements 

in the neighboring upwind states, New Jersey will consider any additional measures, beyond 

those already in place, implemented by the neighboring upwind states, if they are more stringent 

 286 73 Fed. Reg. 28321-350 (May 16, 2008). 287 73 Fed. Reg. 28321-350 (May 16, 2008).
164

than New Jersey’s current actions. New Jersey also encourages the USEPA to take action where 

states are preempted from action. New Jersey relies on the USEPA to ensure sufficient progress 

in securing upwind emission reductions to provide for expeditious attainment of the PM2.5

NAAQS. 
165

9.0 COMMITMENTS AND REQUESTS FOR FUTURE ACTION

As discussed in Chapter 5, the two multi-state annual fine particulate matter (PM2.5)

nonattainment areas associated with New Jersey are projected to reach attainment of the 1997 

annual PM2.5 National Ambient Air Quality Standard (NAAQS) by their attainment date (i.e., 

April 5, 2010). This demonstration is contingent upon the continued implementation and 

enforcement of existing control measures, as well as the implementation of a number of new 

State and Federal control measures. The measures that were included in the attainment 

demonstration modeling are referred to as either on the books/on the way (OTB/OTW), or 

measures that are beyond on the way (BOTW). These control measures are outlined in Chapter 

4.

In addition, although not outlined specifically in Chapter 4, other State and Federal measures 

were implemented, and achieved benefits, prior to the 2002 base year. For example, control 

measures such as the on-board diagnostics (OBD) enhanced Inspection and Maintenance (I/M) 

program, the federal Reformulated Gasoline (RFG) program, and all New Jersey’s existing 

stationary source control measures achieved pre-2002 benefits, and these programs, as well as 

numerous others, are incorporated into the 2002 inventory, from which the future inventories are 

projected.

Chapter 5 also discusses other measures, in addition to those OTB/OTW and BOTW measures 

included in the attainment modeling, that both New Jersey and the United States Environmental 

Protection Agency (USEPA) are implementing that are expected to provide benefits in time to 

help the 1997 PM2.5 multi-state nonattainment areas reach their attainment goals. These 

measures provide additional assurance that New Jersey’s associated multi-state nonattainment 

areas will attain the 1997 annual PM2.5 standard by April 5, 2010. In addition, a portion of these 

measures are relied upon as contingency measures. Additional non-modeled measures provide 

for additional emission reductions that not only will help the State attain both the 1997 8-hour 

ozone and annual PM2.5 NAAQS, but will help the State attain the 2006 daily PM2.5 standard of 

35 μg/m3, address regional haze at New Jersey’s Class I area and other downwind Class I areas, 

reduce air toxic emissions, advance the State’s Greenhouse Gas Initiative, and ultimately help 

the State meet its own PM2.5 goal of goal of 12 μg/m3. See Chapter 1 for more information on 

these other air quality goals. 

The remainder of this chapter summarizes New Jersey’s control measures and other 

commitments, as well as New Jersey’s requests of the USEPA with respect to PM2.5

implementation.

9.1 Control Measure Commitments

Because the Ozone Transport Region conducted one-atmospheric modeling to satisfy both the 8-

hour and PM2.5 attainment demonstration obligations, all of measures included in the State’s 

PM2.5 attainment demonstration modeling are also in the State’s 8-hour ozone attainment 

demonstration. The 8-hour ozone attainment demonstration was submitted to the USEPA for 
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approval on October 29, 2007,288 and since its submittal, the State of New Jersey has been 

working to implement those measures needed for attainment. Table 9.1 provides a status on 

those control measures committed to in the State’s 8-hour ozone state implementation plan (SIP) 

that will also provide the emission reductions needed to bring about PM2.5 attainment. 

The State commits to propose and adopt those measures in Table 9.1 in accordance with the New 

Jersey Administrative Procedures Act (APA) (N.J.S.A. 52:14B-1 et seq.) and the Air Pollution 

Control Act (APCA) (N.J.S.A. 26:2C-1 et seq.). For a detailed explanation of each of these 

control measures, see Chapter 4. 

Table 9.1: PM 2.5 State Control Measure Commitments Not Yet Adopted and

Contingency Measures

Control Measures Status Notes

BOTW Measures Included in Regional PM2.5 Attainment Modeling *

Industrial/Commercial/Institutional 

(ICI) Boiler Rule 2009289

Proposed 8/4/08 NOx reduction measure; for 8-hour 

ozone attainment

Contingency Measures 

Refinery Consent Decrees (Sunoco 

and Valero)

Filed (Final), See Appendix C, 

Attachments 3, 4 and 5

See Modeling Differential Analysis in 

Appendix C

Diesel Idling Promulgated 8/6/07; operative 

9/8/2007

PM2.5 and NOx reductions

Municipal Waste Combustor

(Incinerator) NOx Rule

Proposed 8/4/08 NOx reductions

Asphalt Production Plants Proposed 8/4/08 NOx reductions

ICI Boiler Rule 2009 (portion not 

modeled)

Proposed 8/4/08 NOx reduction measure

NOx RACT Rule (2006) Adopted September 8, 2005 NOx reduction measure

Onroad Motor Vehicle Control 

Programs (Federal) (Fleet turnover 

2010)

New Federal vehicle standards are 

already adopted to provide for these 

benefits 

Direct PM2.5

and NOx reductions

Onroad New Jersey Low Emission 

Vehicle (LEV) Program (Fleet 

turnover)

Adopted November 28, 2005 VOC, NOx, SO2, and direct PM2.5

reductions

Nonroad Motor Vehicle Control 

Programs (Federal) (Fleet turnover 

2010)

New Federal equipment and vehicle 

standards are already adopted to 

provide for these benefits 

Direct PM2.5, SO2, and NOx reductions

Controls from EGU Consent 

Decrees (PSE&G Hudson SO2)

Filed July 26, 2002; amended 

November 30, 2006

SO2 reductions

Additional Measures that Support Attainment

Diesel Smoke (I/M Cutpoint) Rule 

Changes

Proposed 6/16/08 PM2.5 and NOx reductions

* “Beyond On the Way (BOTW)” control measures (state, regional, or federal) that have been or will be proposed 

by New Jersey and will include those measures that were identified as part of the effort to reach attainment by April 

5, 2010.

 288 Letter dated October 29, 2007 from then NJDEP Commissioner Lisa P. Jackson to USEPA Region II 

Administrator Alan J. Steinberg. Available at http://www.nj.gov/dep/baqp/8hrsip/commissioner's%20letter.pdf. 289 Some categories have 2010 compliance dates; remainder have 2011 and 2012 compliance dates.
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The Department has proposed additional control measures as part of the effort to reduce ozone 

which will also have PM2.5 emission reduction benefits. These additional control measures are 

included in Table 9.2.

Table 9.2: Additional Control Measures

Control Measures Status Notes

Additional Measures that Support Attainment**

Ozone and PM2.5 RACT Commitments

Oil and Gas Fired Electric 

generating units (EGUs)

Proposed 8/4/08 NOx reduction measure

Coal-fired boilers serving EGUs Proposed 8/4/08 NOx, SO2, and direct PM2.5 reductions

Sewage sludge incinerators Proposed 8/4/08 NOx reduction measure

Case by Case NOx Emission Limit 

Determinations (FSELs/AELs)

Proposed 8/4/08 NOx reduction measure

High Electric Demand Day 

(HEDD) Program

Proposed 8/4/08 NOx reduction measure

Glass Manufacturing Proposed 8/4/08 NOx reductions but most benefits will 

occur post-2010

Additional Measures that Support Attainment

BOTW VOC Measures

Consumer Products 2009 

Amendments

Adopted 10/30/08 VOC reduction measure; primarily for 8-

hour ozone attainment

Portable Fuel Containers 2009 

Amendments

Adopted 10/30/08 VOC reduction measure; primarily for 8-

hour ozone attainment

Adhesives and Sealants Adopted 10/30/08 VOC reduction measure; primarily for 8-

hour ozone attainment

Additional Measures that Support Attainment

Ozone RACT VOC Measures

VOC stationary storage tanks Proposed 8/4/08 VOC reduction measure

2006 Control Techniques 

Guidelines

Proposed 8/4/08 VOC reduction measure

Asphalt Paving (emulsified and 

cutback)

Proposed 8/4/08 VOC reduction measure

Case by Case VOC Emission Limit 

Determinations (FSELs/AELs)

Proposed 8/4/08 VOC reduction measure

** These measures were not included in the regional attainment modeling for 2009.

Additionally, New Jersey is implementing the Nonattainment New Source Review (NNSR) rule 

revisions (see Chapter 8). The Clean Air Act (CAA), 42 U.S.C. § 7503, requires new or 

modified major sources to install the Lowest Achievable Emission Rate (LAER) control 

equipment and obtain greater than one for one emission offsets in order to locate in a 

nonattainment area. Thus, the NNSR program provides for continual emission reductions to help 

improve the air quality in the nonattainment area and further downwind. See Chapter 4 for 

further discussion on NNSR.

The USEPA has also committed to implement additional emission control measures not listed in 

Tables 9.1 and 9.2. Specifically, the USEPA has proposed new, small offroad engine standards, 

and adopted more stringent exhaust emission standards for locomotives and marine diesel 

engines, as well as adopted a second phase of its Federal Clean Air Interstate Rule (CAIR) 

Program that will result in SO2 reductions (refer to Chapter 4 for details). All of these efforts 
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should provide additional emission reductions for 2009 and beyond. While New Jersey’s PM2.5

attainment demonstration does not rely on further emission reductions from these measures, the 

implementation of these measures will help support New Jersey’s demonstration of attainment 

and will benefit air quality. New Jersey expects the USEPA to promulgate these measures in a 

timely fashion so that emission reductions can be achieved by 2009 and beyond. 

New Jersey commits, as part of this State Implementation Plan (SIP) revision, to implement a 

number of future control measures that will result in emission reductions post-2010. These 

longer-term measures will provide:

1. additional public health protection in view of health effects below the NAAQS, 

consistent with the NJDEP’s internal goal of meeting an annual PM2.5 level of 12 

μg/m3

;

2. progress toward the new 2006 24-hour PM2.5 NAAQS; 

3. additional reductions, which would be relied upon should the State not attain by 2010; 

4. additional benefits toward meeting the State’s other PM-related air quality goals 

outlined in Chapter 1 (e.g., Greenhouse Gas Initiative, Air Toxics, etc.); and,

5. the regulated community with certainty and time to identify the necessary funding to 

install control equipment, modify their products or usage patterns, and/or take other 

actions to implement pollution prevention strategies. 

9.2 Transport-Related Requirements

Chapter 8 of this SIP revision: 1) reiterates the State’s compliance with the USEPA’s guidance 

in determining that it has the authority to implement its Infrastructure SIP requirements, and has 

met all timing requirements associated with those requirements, with respect to the PM2.5

NAAQS, and 2) provides updates on the State’s progress in meeting its requirements under 

Section 110(a)(2)(D)(i) of the Clean Air Act with respect to the 1997 PM2.5 NAAQS. The 

remainder of this Section reiterates the State’s PM2.5-related transport commitments. 

New Jersey commits to implement strategies to address the transport of direct PM2.5 and PM2.5

precursor emissions from New Jersey, particularly in light of the State’s concerns that the 

implementation of CAIR alone does not resolve interstate transport issues.290 New Jersey will 

also address interstate transport by relying upon its Regional Haze SIP to address visibility 

requirements in New Jersey’s Class I area. New Jersey proposed its Regional Haze SIP on 

September 15, 2008. New Jersey commits to consider any additional measures, beyond those 

already in place, implemented by the neighboring upwind states, if they are more stringent than 

our current actions. 

 290 See letter from NJDEP Commissioner Lisa P. Jackson to USEPA Regional Administrator Steinberg dated 

December 22, 2006. The letter is posted on the NJDEP’s website at 

http://www.state.nj.us/dep/baqp/sip/siprevs.htm.
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9.3 State Requests of the USEPA

New Jersey’s Reliance on the USEPA and Other State Actions for Attainment

As discussed in Chapter 4, New Jersey based its demonstration of attainment for its two multistate nonattainment areas on the 2009 BOTW modeling exercise. This modeling demonstration 

relies not only on New Jersey working to meet its commitments to implement certain measures 

by 2009, but also on its neighboring states doing the same. Further, the implementation of 

measures by states upwind than New Jersey’s immediate neighbors is relied upon to reduce the 

transport of PM2.5 and its precursors into the Mid-Atlantic/Northeast Visibility Union (MANEVU) region, including New Jersey. Additional cost effective controls on the largest upwind 

sources are still needed to reduce the PM2.5 and PM2.5 precursors being transported into the 

MANE-VU region. New Jersey requests that the USEPA, in reviewing the SIP revisions from 

other states, take into consideration the impact on New Jersey’s attainment obligations, and 

ensure that upwind states are doing all that is needed to bring New Jersey’s associated multi-state 

nonattainment areas into attainment as soon as practicable. In addition, New Jersey expects that 

the USEPA will adopt all federal measures in a timely fashion so that the state can benefit from 

the emission reductions from these measures.
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10.0 CONCLUSION

The health effects associated with fine particulate matter (PM2.5) are significant, due in part to its 

small size, which allows it to reach deep in the recesses of the lungs, as well as its ability to be a 

“carrier” for other toxic air contaminants. New Jersey and the other states that share New 

Jersey’s 1997 PM2.5 multi-state nonattainment areas are faced with the challenge of meeting the 

1997 annual PM2.5 standard. Although New Jersey and the other states that share the 1997 PM2.5

multi-state nonattainment areas have always met the 1997 daily PM2.5 health-based standard of 

65 μg/m3, and these levels have continued to improve since 2001, New Jersey and the other 

states also face the challenge of meeting the new 2006 daily PM2.5 standard of 35 μg/m3. Given 

the significance of the health concerns associated with fine particulate matter, New Jersey 

approached the requirements to meet the 1997 PM2.5 national ambient air quality standards 

(NAAQS) not as a finite goal, but instead as the first step in a comprehensive plan to address 

PM2.5 emissions, as well as the precursor emissions that can form PM2.5, which can include 

sulfur dioxide (SO2), oxides of nitrogen (NOx), volatile organic compounds (VOCs),291 and 

ammonia. The actions taken in this state implementation plan (SIP) revision, therefore, will 

ensure that New Jersey and its shared nonattainment areas will come into compliance with the 

1997 annual health-based PM2.5 NAAQS by their attainment date of 2010, and will also help the 

State meet a number of other particulate matter (PM)-related goals with deadlines beyond the 

attainment of the 1997 annual PM2.5 NAAQS by 2010. The following other PM-related actions, 

that are anticipated in the near future or are already in place, comprise the rest of the State’s 

overall plan for reducing PM-related emissions:

o Reducing Greenhouse Gas emissions in an effort to help New Jersey meet its obligations 

under the State’s Global Warming Response Act; 

o Continuing to reduce PM2.5 emissions in an effort to meet the new 2006 daily PM2.5

standard of 35 μg/m3 and State’s annual goal of 12 μg/m3

; 

o Supporting the State’s efforts to meet the commitments in its 8-hour ozone attainment 

demonstration SIP, submitted to the United States Environmental Protection Agency 

(USEPA) in October 2007; 

o Continuing the State’s on-going efforts to reduce air toxic emissions throughout New 

Jersey;

o Establishing reasonable progress goals to address visibility in the State’s Class I area; 

and, 

o Supporting the State’s overarching Environmental Justice initiatives.

To meet the requirements of 42 U.S.C. § 7502(c)(1) (Section 172(c)(1) of the Clean Air Act) for 

the 1997 annual PM2.5 NAAQS, New Jersey conducted two separate analyses designed to 

determine what additional actions the State could take to reduce PM2.5 and PM2.5 precursor 

emissions; a Reasonably Available Control Technology (RACT) analysis of emission control 

technologies for major stationary sources and a Reasonably Available Control Measures 

 291 According to the USEPA, high molecular weight organic compounds (typically 25 carbon atoms or more) are 

emitted directly as primary organic particles and exist primarily in the condensed phase at ambient temperatures. 

Accordingly, high molecular weight organic compounds are considered a primary PM2.5 emission for the purposes 

of the PM2.5 implementation program (72 Fed. Reg. 20592 (April 25, 2007)).
171

(RACM) analysis of emission control technologies from all other sources (mobile and area 

sources). New Jersey’s RACM analysis identified several “reasonable” measures. However, the 

implementation of those measures would not advance the nonattainment areas’ attainment date 

by one year, to April 5, 2009 (which would require demonstration of attainment by the end of 

2008). The State and the Federal government are acting to implement several of the measures 

identified as part of this analysis already to ensure the protection of public health and, for New 

Jersey, to move the State further toward meeting its other PM-related goals. New Jersey’s 

RACT analysis demonstrates that reductions of direct PM2.5 emissions and its precursors, SO2

and NOx, from several major stationary source categories, are reasonable. In addition to these 

NJDEP analyses, the State hosted its own, and participated in several regional, stakeholder 

processes designed to select viable control measures. These efforts identified the remainder of 

the control measures relied upon in either the attainment demonstration or the contingency plans. 

New Jersey’s “Reducing Air Pollution Together” Outreach Initiative and the State’s participation 

in regional efforts are discussed in detail in Chapter 4.

As part of this SIP revision, New Jersey is proposing, in accordance with the New Jersey 

Administrative Procedures Act (N.J.S.A. 52:14B-1 et seq.) and the New Jersey Air Pollution 

Control Act, (N.J.S.A. 26:2C-1 et seq.), all the beyond all the way (BOTW) measures included in 

the 2009 attainment photochemical modeling. In addition, New Jersey is proposing, pursuant to 

the New Jersey Administrative Procedures Act (N.J.S.A. 52:14B-1 et seq.) and the New Jersey 

Air Pollution Control Act (N.J.S.A. 26:2C-1 et seq.), a number of other control measures that 

were not included in the 2009 BOTW modeling, but will result in emission reductions by 2009, 

as well as future measures that will result in emission reductions post-2010. These additional 

measures, in addition to providing additional evidence for this proposed attainment 

demonstration, will also provide:

o additional public health protection in view of health effects below the NAAQS, 

consistent with the NJDEP’s internal goal of meeting an annual PM2.5 level of 12 μg/m3

;

o progress toward the new 2006 24-hour PM2.5 NAAQS; 

o additional reductions, which would be relied upon should the State not attain by 2010;

o additional benefits toward meeting the State’s other PM-related air quality goals outlined 

in Chapter 1 (e.g., Greenhouse Gas Initiative, Air Toxics, etc.); and,

o the regulated community with certainty and time to identify the necessary funding to 

install control equipment, modify their products or usage patterns, and/or take other 

actions to implement pollution prevention strategies. 

The State’s status on its regulatory commitments for this SIP revision is discussed in Chapter 9.

The implementation of all of these measures will serve to help ensure that New Jersey’s 

associated nonattainment areas meet their mandatory attainment date, and will ensure that New 

Jersey is not negatively impacting any other area’s ability to meet the NAAQS through 

transported emissions of PM2.5 and its precursors (see Chapter 8). The State’s attainment 

demonstration is not only based on New Jersey’s actions, but on the actions of all the other states 

in the region. Other states’ failure to address their contribution to the New Jersey associated 

multi-state nonattainment areas’ air quality problems could result in New Jersey’s associated 

multi-state nonattainment areas’ inability to meet their attainment goal. Therefore, New Jersey 
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requests that the USEPA evaluate the impact of transported emissions as it reviews the SIPs, 

particularly those from the upwind states. In addition to meeting the interstate transport 

requirements in Section 110 of the Clean Air Act, the SIP revision updates the State’s progress in 

meeting the 1997 PM2.5 Infrastructure SIP requirements (see Chapter 8).

New Jersey has included, as part of this SIP revision (see Chapter 7), onroad vehicle emission 

budgets to ensure that the plans and programs implemented by the Metropolitan Planning 

Organizations conform with the requirements of the SIP. 

In conclusion, this SIP revision provides a comprehensive plan that:

- highlights the successes of the past, demonstrates attainment of the 1997 annual PM2.5

standard, and directs the State beyond that standard toward its other PM-related goals;

- identifies all the control measures necessary in order for New Jersey, and its 

associated multi-state nonattainment areas, to attain the 1997 annual PM2.5 NAAQS 

by the April 5, 2010 attainment date and address transport in and out of the State;

- identifies reasonably available control technology measures for PM2.5; 

- outlines the State’s authority to meet Section 110 (of the Clean Air Act) requirements 

for the 1997 PM2.5 NAAQS;

- provides a safety net of contingency measures in the event that the State fails to attain 

the 1997 annual PM2.5 NAAQS on time; and

- sets transportation conformity budgets that allow for growth without negatively 

impacting the attainment of the 1997 annual PM2.5 NAAQS in the multi-state 

nonattainment areas.