1 

## Technical Basis for Designating New Jersey Attainment for the Annual PM 2.5 

## National Ambient Air Quality Standard of 12 μ g/m 3



## Prepared by the New Jersey Department of Environmental Protection

February 24, 20142 

### Table of Contents
Introduction

.............................................................................................................................. ..................... 3 The Northern New Jersey Combin ed Statistical Area (CSA) .................................................................... 6 Five-Factor Analysis of the Southern New Je rsey Combined Statistical Area (CSA) ................................... 7 Factor 1: Air Quality Data .................................................................................................... .......................... 7 a. Background on PM 2.5 Components at New Jersey Speciation Monitoring Sites................................ 7 b. Validity of Air Quality Data at Nonattainment Monitors ................................................................... 9 c. Trends Analysis for the Pennsyl vania Nonattainment Monitors ........................................................ 9 d. Urban Excess Analysis Using Speciation Data at New Garden and Arendtsville, PA .................... 10 Factor 2: Emissions and Emissions-Related Data in the Southern New Jersey Combined Statistical Area (CSA)

.............................................................................................................................. ................ 11 Point, Mobile and Area Emissions .............................................................................................. ............. 11
Point Source Emissions ........................................................................................................ .................... 11
Mobile Emissions .............................................................................................................. ....................... 17
a. Motor Vehicle Traffic Level s ..................................................................................................... 17
b. Commuting Patterns ..................................................................................................................... 19
Area Source Emissions ......................................................................................................... .................... 20 Factor 3: Meteorology (including Wind Trajectories and Wind Roses) ..................................................... 21 Factor 4: Geography/Topography ................................................................................................ ............ 23
Factor 5: Jurisdictional Boundaries ........................................................................................... ............... 24 Summary of why New Jersey should not be associated with the Pennsylvania nonattainment area. ...... 24 Five Factor Analysis of the Northampton/Warren County Core Based Statistical Area for the Annual PM 2.5 NAAQS ......................................................................................................................... ............................... 25 Factor 1: Air Quality Data ..................................................................................................................... 25 Trends Analysis for the Freemansburg, PA Monitor ........................................................................... 26 Factor 2: Emissions in the Northampton/Warren County Core Based Statistical Area ......................... 27
Point Sources ................................................................................................................. ........................... 27
Level of control of emission sources ..................................................................................................... 27
Area Sources .................................................................................................................. ........................... 28 Population/Population Density ................................................................................................. ........... 28 Factor 3: Meteorology (including Wind Trajectories and Wind Roses) ..................................................... 28
Factor 4 : Geography/Topography ........................................................................................................... 30
Factor 5: Jurisdictional boundaries ......................................................................................................... 30 Summary of why New Jersey should not be associated with the Northampton nonattainment area. ...... 303 

### Five Factor Analysis for the Designation of Areas in New Jersey for the Annual

Fine Particulate (PM 2.5 

### ) National Ambient Air Quality Standard (NAAQS) of 12μg/m 3

Introduction

The United States Environmental Protection Agency (USEPA) promulgated a new annual PM 2.5 1 National Ambient Air Quality Standard (NAAQS) on December 14, 2012. This new annual standard for fine particulate matter was lowered from 15 micrograms per cubic meter (μg/m 3 ) to 12μg/m 3

. According to Section 107(d)(l)(A) of the federal Clean Air Act, stat es have one year from the new standard’s promulgation to submit a recommen dation to the USEPA for designating areas as attainment or nonattainment. The USEPA then has one year to decide what the final nonattainment area size and designation should be.
Under the old 15μg/m 3 PM 2.5 standard, New Jersey had 13 coun ties in northern and southern New Jersey designated as nonattainment. Due to im provements in air quality, the USEPA redesignated these counties as at taining the annual PM 2.5 standard of 15μg/m 3 in August 2013, thus making the entire State of New Jersey attainment of the old 15μg/m 3 PM 2.5 NAAQS and the 35μg/m 3 24-hour PM 2.5 NAAQS. New Jersey’s recomme ndation that the entire State of New Jersey be designated attainment of the new annual NAAQS for PM 2.5 was submitted to the USEPA on December 18, 2013.
For the new, annual 12μg/m 3 standard, the USEPA issued guida nce for determining nonattainment areas on April 17, 2013. 2 This guidance includes five factors to be used by states for determining the size of nonattainment areas. A five factor analysis is init iated if a monitor measures air quality above the standard. Under initial consideration for nonatta inment, the size of a nona ttainment area is the boundary of the Core Based Statistical Area (CBSA) 3 or the Combined Statistical Area (CSA) 4 , unless a state can demonstrate that a smaller size or at tainment for its portion of the CBSA or CSA is warranted.
New Jersey is part of two Combined Statistical Ar eas (CSAs): the Northern New Jersey CSA which it shares with New York, Connectic ut and Pennsylvania, and include s the New Jersey counties of Bergen, Essex, Hudson, Mercer, Middlesex, Monmouth, Morris, Ocean, Passaic, Somerset and Union; and the Southern New Jersey CSA shared with Phila delphia, Delaware and Ma ryland, and includes the New Jersey counties of Burlingt on, Camden, Cumberland, Gloucester, and Salem. New Jersey also has three Core Based Statistical Areas (CBSAs): the Warren County CBSA, which it shares with the Pennsylvania counties of Carbon, Lehigh, and Northamp ton; the Atlantic County CBSA and the Cape May County CBSA. The Atlantic County and Cape May County CBSAs are not associated with any other areas. These two counties are existing attainment areas. A map of the current CBSAs and CSAs for New Jersey is shown in Figure 1.

1 PM 2.5 is also referred to as fine or respirable particulate matter. 2 USEPA Guidance on Area Designations, Ap ril 17, 2013 (“Area Designation Guidance”) 3 The United States Office of Management and Budget (OMB) defines a core based statistical area (CBSA) as one or more adjacent counties or county-equivalents having at le ast one urban cluster of at least 10,000 population, plus adjacent territory that ha s a high degree of social and economic integration with the core as measured by commuting ties.
4 The United States Office of Management and Budget (OMB) defines a combined statistical area (CSA) as an aggregate of adjacent c ore based statistical areas that are linked by commuting ties.4 Figure 1: New Jersey Combined Statistical Areas and Core Based Statistical Area

All New Jersey monitors show attainme nt and a downward trend in measured PM 2.5 levels over the last 10 years. The downward tre nd is expected to cont inue due to new control measures and the continued effectiveness of existing control measures (See Figure 2). For example, New Jersey has adopted a low sulfur content standard for dis tillate and residual fuel oils of 500 parts per million (ppm) that will take effect in Ju ly, 2014, with the next lower sulfur-content pha se (15 ppm) beginning in July 2016. The low sulfur fuel standard is expected to lower particulate levels even further in New Jersey and in all downwind areas. The historical tren d of New Jersey's statew ide annual design values is shown in Figure 2.
Based on its analysis pursuant to th e USEPA’s “Area Designation Guidance”, all New Jersey counties should be designated attainment . No counties in New Jersey should be included within the nonattainment area outside of New Jerse y, but within the same CSAs and CBSAs.5 Figure 2: PM 2.5 Design Value Concentrations, A nnual Design Values 1999 – 2012 New Jersey Statewide

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n d use a i ng the h at may8 The New Jersey Speciation Network currently cons ists of five sites (E lizabeth, Newark, New Brunswick, Chester, and Camden) at which air fi lters are analyzed to determine the chemical characteristics of the particulate matter collecte d on the filter. Data from 2002 through 2012 was used in this speciation analysis. Since the Camden sp eciation monitoring site re started operation in 2013, after being shut down sin ce 2008, it was not included in the analys is due to incomplete data. The Newark monitor was also not included in the analysis, because the s ite began operation in 2010.
The annual statewide speciation data from the mo nitors at Elizabeth, New Brunswick, and Chester were averaged for each year from 2002-2012. The five most prevalent compounds in New Jersey’s fine particles are sulf ate, organic carbon, nitrat e, ammonium, and elemental carbon. The “other” category includes all other trace elements for "crust al" calculations (aluminum, silicon, calcium, iron, titanium, etc.) that were measured.
Organic carbon and sulfate comprise a pproximately 63 percent of the total PM 2.5 mass. Studies 5 have shown that the primary sources of organic and el emental carbon are gasoline a nd diesel vehicles and local sources such as wood burning (depending on the area and season). The major contributors of sulfate are primarily from burning coal and secondari ly from burning other fuel s that contain sulfur, such as heating oil.
The speciation data at all New Jersey sites show a downward trend in sulfat es, nitrates, ammonium, and organic carbon. A graph showing the downward trend in the components that make up fine particulate matter is shown in Figure 5. This downw ard trend is consistent with reductions in the emissions of fine particulate matte r that New Jersey has made over the years (see in this document, Factor 2 – Emissions and Emissions-related Data).
Figure 5: New Jersey PM 2.5 Speciation Summary Statewide Annual Average Concentrations, 2002 – 2012

5 For details on other PM 2.5 speciation data studies, including se asonal trends, for New Jersey and the region, refer to: NJDEP State Implementation Plan (SIP) Revision fo r the Attainment and Maintenance of the Fine Particulate Matter (PM 2.5 ) National Ambient Air Quality Standard: PM 2.5 Attainment Demonstrati on, Final, Chapter 2, A ppendices B11 and B12. New Jersey Department of Environmental Protection, Marc h 26, 2009 (http://www.state.nj.us/ dep/baqp/sip/siprevs.htm).9 The total PM 2.5 mass measured at the specia tion monitors decreased by 30 percent between 2002 and 2012, while the sum of the known species (as shown in Figure 5) decreased by about 50 percent. The reduction is due to significant decreases over the 10-year period in all five of the primary PM 2.5 components. Average reductions of each of thes e components from 2002-2012 in the statewide annual averages are as follows:

• Sulfate: - 58 percent

• Organic carbon: - 56 percent

• Elemental carbon: - 50 percent

• Ammonium: - 59 percent

• Nitrate: - 28 percent
In summary, organic carbon, sulfates and sulfur make up the majority of the PM 2.5 mass measured at New Jersey monitors. Significant de creases are noted in the annual av erage data in all of the five major species listed above from 2002-2012. Organic carbon and sulfate consis tently remain the top two largest components on an individual basis.
b. Validity of Air Quality Data at Nonattainment Monitors
There are three Pennsylvania monitors that record PM 2.5 levels above the 12μg/m 3 health standard: Chester, PA (Delaware County), New Garden, PA (Chester County), and th e East Lycoming Avenue (Philadelphia, PA) in the Southern New Jersey CSA (See Figures 4 and 6) . The Philadelphia Department of Health determined that the East Lycoming Avenue monitor data was not appropriate for determining an area ’s attainment status 6 . Thus, the monitor was not included in New Jersey’s analysis. c. Trends Analysis for the Pennsylvania Nonattainment Monitors

The particulate matter levels meas ured at the Chester and New Ga rden monitors have dropped in recent years. The following table shows the number of days during the last three years when the measured levels of particulate matter were greater than 12μg/m 3 . Daily monitoring data from the two monitors was used for this analysis.

6 http://www.phila.gov/health/ pdfs/2013_14AMNPFinalwAppendices__20130628.pdf10 Figure 6: Pennsylvania Monitors wi th valid data measuring above 12 μ g/m3 in the Southern New Jersey CSA.

Table 1: Percent of Days (2010 - 2012) with monitored PM 2.5 levels greater than 12 μ g/m 3 at the Chester and New Garden, PA Sites.
Monitor Year # Days with Data % of Days with Data Days with PM 2.5 > 12μg/m 3 % of days with PM 2.5 > 12μg/m 3 Chester, PA 2010 349 96% 175 48% 2011 341 93% 163 45% 2012 299 82% 135 37% New Garden, PA 2010 341 93% 178 49% 2011 297 81% 142 39% 2012 329 90% 94 26%
d. Urban Excess Analysis Using Speciation Data at New Garden and Arendtsville, PA

An urban excess analysis is conducted to determine the amount of particulat e matter that is emitted locally in urban areas. Typical urban sources consid ered to be local in natu re and that may impact PM 2.5 levels at an air monitor include nearby vehicu lar traffic, local indus try, construction activity, pesticide use and wood burning.
New Jersey could not conduct a suffici ent urban excess analysis due to la ck of adequate speciation data in the area near the Chester and New Garden monitoring sites. The closest New Jersey speciation monitor with data to compare to the Pennsylvania spec iated data collected at New Garden is located in Morris County, NJ. These two sites are located over 72 miles from each other. Because of this lack of sufficient data, New Jersey will rely upon the ur ban excess analysis performed by the State of11 Pennsylvania.
New Jersey does not disagree with Pe nnsylvania’s determination of the urban excess as contained in its report released in December 2013 7 . In that report, Pennsylvania conc luded that the urban contribution at the New Garden, PA monitoring site is local in nature, and that there is excess nitrate, ammonium, and organic carbon at the New Garden monitor. The levels of these PM 2.5 components have decreased in New Jersey between 28 and 59 percent since 2002 (see in this doc ument, Factor 1 – Air Quality Data).

Factor 2: Emissions and Emissions-Re lated Data in the Southern New Jersey Combined Statistical Area (CSA)
Point, Mobile and Area Emissions

Point Source Emissions

Figure 7 shows the emission and locations of majo r point sources near the Chester, PA and New Garden monitors. The maps in Figure 8A, 8B, and 8C show the total emissions of fine particulates, sulfur dioxide, and oxides of nitrogen, respectively, in each county of the Southern New Jersey CSA between 2008 and 2011. Decreasing am ounts of sulfur dioxide and par ticulate emissions are occurring in most counties. Sources in Pennsylvania countie s continue to contribut e the largest portion of emissions within and upwind of the Penns ylvania monitors that measure high PM 2.5 levels.
Figure 7: Emissions and Locations of Major Po int Sources near the Chester and New Garden, PA monitors (Indicated with Orange Circles).

7 http://www.dep.state.pa.us/dep/deput ate/airwaste/aq/attain/p m25des/AppendixC-1-Greater _Philadelphia_Area.pdf12Figure 8A:2008 PM2.5County Total Emissionsfrom Point 2011 PM2.5County Total Emissions from PointSources in Southern New Jersey CSA Sources in Southern New Jersey CSA13Figure 8B:2008 SO2County Total Emissions from Point 2011 SO2County Total Emissions from PointSources in Southern New Jersey CSA Sources in Southern New Jersey CSA14Figure 8C:2008 NOxCounty Total Emissions from Point 2011 NOxCounty Total Emissions from PointSources in Southern New Jersey CSA Sources in Southern New Jersey CSA15 Figure 9 shows the loca tion of the majo r point sources in New Je rsey and Pe nnsylvania.

Figure 9: Emissions and Locations of Major PM 2.5 Point Sources for New Jersey and Pennsylvania16 Table 2 shows 2011 total emissions (in tons per y ear) for point sources lo cated in the counties included in the CSA. (Data Source: 2011 National Emissions Inventory at http://www.epa.gov/pmdesignations/2012standar ds/docs/nei2011v1pointnei2008v3county.xlsx). The pollutants analyzed include PM 2.5 and its precursors: ox ides of nitrogen (NO x ) and sulfur dioxide (SO 2 ).
In 2011, New Jersey’s total point source emissions only contribute approximately 18 percent of the overall emissions in the area: 22 percent of PM 2.5 , 16 percent of SO 2 and 19 percent of NO x . The Pennsylvania counties in the CSA c ontribute the majority of the emissions: 69 percent of the total PM 2.5 emissions, 78 percent of the total SO 2 emissions and 70 percent of the total NO x emissions.
The highest point source emissions in the CSA for all three pollutants occur in Delaware County, PA, where the Chester monitor is located. Figure 9 shows the location and relative emissions of SO 2 for the point sources. These point sources are also large emitters of nitrogen oxides and particulate matter.
The high number of large point sour ces located in Pennsylvania is cont ributing to this urban excess at the New Garden and Chester monitors, given the predominant wind directions and wind trajectories on days of high monitored PM 2.5 levels at New Garden and Ch ester sites (see Factor 2 and 3 discussion).

Table 2: Total point source emissions (in tons per year) for Delaware, Pennsylvania, New Jersey, and Maryland counties included in the Southern New Jersey CSA

County 2011 PM 2.5 ( tons per year ) 2011 SO 2 (tons per year) 2011 NO x ( tons per year )

New Castle, DE 597 896 2,756 Total DE Portion 597 (9.0%) 896 (6%) 2,756 (11%) Philadelphia, P A 1,034 730 2,568 Delaware, P A 1,497 4,976 7,642 Montgomery, P A 306 292 1,456 Chester, PA 513 1,007 1,530 Berks, PA 722 4,651 3,139 Bucks, PA 330 260 1,271 Total PA Portion 4,402 (69.0%) 11,916 (78%) 17,606 (70%) Gloucester, NJ 332 742 1,758 Camden, NJ 562 48 433 Burlington, NJ 51 89 286 Cumberland, NJ 203 348 723 Salem, NJ 222 1,256 1,540 Total NJ Portion 1,370 (22.0%) 2,483 (16%) 4,740 (19%) Cecil, MD 16 6 77 Total MD Portion 16 (0.0%) 6 (0%) 77 (0%) Total Emissions in CSA 6,385 15,301 25,179
The lower emissions in the New Jersey counties are attributed to state regul atory efforts to reduce emissions that contribute to PM 2.5 . All large coal burning sources in the New Jersey portion of the CSA are controlled using sc rubbing technology to reduce sulf ur dioxide emissions, baghouse filtration to reduce particulate emissions, and sel ective catalytic reduction (SCR) to reduce nitrogen oxides emissions.17 The Pennsylvania counties within the Southern Ne w Jersey CSA have multiple large point sources that are concentrated along the borders of Phila delphia and Delaware C ounties and upwind of the Chester monitor as shown in Figure 9. This indicat es that local influence from these point sources may be responsible for the elevated PM 2.5 levels measured at Chester, rather than emissions from New Jersey emission sources that are smaller and further away than the Pennsylvania sources.
The emissions of elemental and organic carbon
, NO x , and SO 2 are expected to continue to decrease in New Jersey because of the State of New Jersey and federal efforts to control air emissions, including lower sulfur Home Heating Oil and Reasonably Available Control Technology rules to address emissions of oxides of nitrogen and PM 2.5. The location of the major point sources as shown in Figure 9 is also considered in the Factor 3 analysis of the predominant wind directions.

Mobile Emissions

a. Motor Vehicle Traffic Level s
In 2011, motor vehicle emissions accounted for approxi mately 79 percent of the nitrogen oxides and 32 percent of the direct fine particulate emissions in New Jersey. The amount of emissions from passenger vehicles can be estimated by looking at the number of miles driven within all counties in the metropolitan area (i.e.; the total Vehicle Miles Traveled (VMT) for each county). The total VMT for 2011 is shown in Figure 10 for each county in the Southern New Jersey CSA 8 in millions of miles. The 2011 data is shown in Table 3, which i ndicates that a greater degree of commuting occurs within the upwind Penns ylvania counties surrounding the Chester and New Garden, PA monitors than in the downwind neighboring New Jersey counties of Burlington, Camden, Cumberland, Gloucester, and Salem. 95 percent more people are co mmuting within Pennsylvania to Delaware County than are commuting from New Jersey.

Table 3: Total Number and Percent of Commut ers and Vehicle Miles Travelled (VMT) within Pennsylvania and from other States that travel to Delaware County, PA

Home County VMT (Millions) #Commute rs to Delaware, PA PA's Total Commuters within PA 27,573 192,677 NJ Total Commuters to PA 12,942 8,773 DE Total Commuters to PA 5,201 8,150 MD Total Commuters to PA 1,356 373 Grand Totals 47,072 209,973 PA % of Total 58.6 91.8 NJ % of Total 27.5 4.1 DE % of Total 11.0 3.9 MD % of Total 2.9 0.2

8 http://www.epa.gov/pmdesignations /2012standards/docs/vmt2011.xlsx18 Figure 10: Driving miles for Passenger Vehicles within each county in 201119 b. Commuting Patterns
Table 4 presents the total number of commuters from a specific home county in Pennsylvania and New Jersey to Delawa re County, Pennsylvania 9 . Similarly, Table 3 summarizes the total number of commuters by State and presents th e percentage of commuters to De laware County from each state. New Jersey commuters comprise only about 4% of the commuters to Delaware County, PA. The majority of the commuters within Delaware County come from within Pennsylvania itself. This pattern of commuting indicates that Pennsylvania residents drive and commute to work by motor vehicle more than do New Jersey residents.

Table 4: 2011 Number of Commuters and Vehi cle Miles Travelled (VMT) from specific residence counties in Pennsylvania and New J ersey to Delaware County, Pennsylvania

Home County VMT (Millions) #Commuters to Delaware County, PA Philadelphia, PA 5,345 21,802 Delaware, PA 3,336 137,988 Montgomery, PA 6,505 11,758 Chester, PA 4,277 17,870 Bucks, PA 4,728 2,754 Berks, PA 3,382 505 PA residents. living within the CSA, commuting to Delaware County, PA 27,573 192,677 Gloucester, NJ 2,713 3,179 Camden, NJ 3,849 3,232 Burlington, NJ 4,478 1,771 Cumberland, NJ 1,122 105 Salem, NJ 780 486 NJ residents, living within the CSA, commuting to Delaware County, PA 12,942 8,773

9 Ibid20 Area Source Emissions
a. Existing Population and Expected Growth
The New Jersey counties have some of the lo west populations and population densities when compared to the Pennsylvania portion of the CSA (see Table 5). A little less than 1.5 million people in the CSA live in the five New Jersey counties. By comparison, over 4 m illion people live in the Pennsylvania counties of this CSA. Camde n, Gloucester, Cumberland, Salem and Burlington Counties i n Ne w J e r s e y experienced low to ne gative growth in New Jersey (between -0.5% and 0.6%) between 2010 and 2012, which was less than the growth in the Pe nnsylvania counties of the CSA. Therefore, the contribution from Ne w Jersey’s emissions due to population-related emission sources (e.g.; home heating and cons umer products) would be much less than the contribution from Pennsylvania’s population related sources.

Table 5: 2010 Population and Population Change for the counties in the Southern New Jersey CBSA between 2010 and 2012 10

County Name Population Estimates Change from 2010 to 2012 2010 Population Estimated 2012 Population Number Percent Change

Pennsylvania Counties Total 4,420,433 4,464,284 43,851 1.0
Chester County, PA 498,878 506,575 7,697 1.5 Philadelphia County, PA 1,526,006 1,547,607 21,601 1.4 Montgomery County, PA 799,881 808,460 8,579 1.1 Berks County, PA 411,447 413,491 2,044 0.5 Delaware County, PA 558,972 561,098 2,126 0.4

Bucks County, PA 625,249 627,053 1,804 0.3 New Jersey Counties Total 1,473,666 1,478,020 4,354 0.3 Burlington County, NJ 448,731 451,336 2,605 0.6 Cumberland County, NJ 156,898 157,785 887 0.6 Gloucester County, NJ 288,288 289,586 1,298 0.5 Camden County, NJ 513,666 513,539 -127 0.0 Salem County, NJ 66,083 65,774 -309 -0.5

10 2010 population data from http://www.epa.gov/pmdesignations/2 012standards/docs/population2010.xls and 2012 population data from http://www.census.gov/popest/data/hi storical/2010s/vinta ge_2012/index.html21 Factor 3: Meteorology (including Wind Trajectories and Wind Roses)

Wind trajectory analysis demonstrates th at New Jersey’s poi nt sources of PM 2.5 are not located in the predominant directions that the wind blows when elevated PM 2.5 levels are detected at the Chester and New Garden m onitors. Figure 11 and Figure 12 show the wind trajectories on the top 10 percent of the days over the last three year period when elevated PM 2.5 levels were detected at the Chester and New Garden monitori ng sites. These wind traj ectories are represented as lines on these maps, showing the location of wher e the wind traveled over the preceding 24- hour period before reac hing the monitoring loca tion. The wind collects air pollutant emissions from upwind regions as it travels along the path of these wind trajectori es. The wind blows on the largest majority of the days fro m Pennsylvania and other States (shown as red li nes on the map) to the monitoring sites, rather than from New Jers ey (shown in colors other than red) during days of elevated PM 2.5 levels in Pennsylvania.
Wind roses from the Philadelphia air port, located in close proximity to the Chester, PA, monitor is shown in each of the following maps. These wind ro ses also show that the predominant directions from which the wind is blowing are from the northwe st and west. This means that the air over the New Garden and Chester monitoring sites travels ove r Pennsylvania during most times of the year. It is less likely, therefore, that em issions from New Jersey affect pa rticulate level concentrations at the New Garden and Chester monitoring sites.
Figure 11:22 Figure 12:

Discussion of Pennsylvania An alysis of Wind Trajectories
On December 10, 2013, the Pennsylvania Department of Natural Resources recently released a report outlining recommendations for the non-attainme nt areas within Pennsylvania. This report ( http://www.dep.state.pa.us/dep /deputate/airwaste/aq/a ttain/pm25des/AppendixC-1- Greater_Philadelphia_Area.pdf ), included an analysis of the wind trajectories on the days of regionally low particulate level concentrations, but lo cally high particulate levels at the Chester, PA monitoring site. The analysis show s that the wind trajectories on th ese days are predominantly from three directions; southwesterly, easterly, and north easterly. The analysis also concluded that there are multiple local, major sources of PM 2.5 , SO 2 , and NO x located in close proximity of the Chester monitor. The wind direction analysis conducted by Pennsylvania shows that the predominant winds on the top 25% of high particulate days travel directly over these Pennsylvania sources. The Pennsylvania analysis indicates the lo cal nature of the high particulate levels at the Chester monitor. There are no major point sources of emissions located in New Jersey that are located directly east of the Chester, PA monitoring site . Also, there are several la rge emission sources located in Pennsylvania to the southwest and northeast of this monitoring site. (See Figure 7D).
Figure 13 shows the Chester monitoring site to be located within the fence-line of a major point source of particulate emissions and next to an unpaved lot. These nearby emissions of fineparticulate m influence m Pennsylva n monitor co m

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### Factor 5: Jurisdictional Boundaries

The current jurisdictional boundaries for New Jersey should be considered since all New Jersey monitors are currently measuring PM 2.5 levels below the NAAQS. Also, New Jersey’s air pollution control rules will continue to reduce sulfur and particulate emissions within New Jersey. For example, New Jersey will have more stringent sulfur in fuel oil standards than Pennsylvania beginning in July 2016. This will continue the decrea sing trend in monitored levels of particulates in New Jersey and all downwind areas when fully implemented. 

### Summary of why New Jersey should not be associated with the Pennsylvania nonattainment area.

1. There are no violating monitors in the New Jersey in the Southern New Jersey Combined Statistical Area. 2. Pennsylvania determined that the Chester moni tor in Delaware County, PA is influenced by local sources 11

. 3. When daily PM 2.5 concentrations are high at Pennsylv ania’s nonattainment monitors, the winds are not from New Jersey. 4. New Jersey’s contributions of PM 2.5 emissions and its precursors are small compared to Pennsylvania’s contributions in the CSA. 5. The number of commuters from New Jersey to Delaware County, PA, where the Chester, PA monitor is located is small compared to th e number of commuters from Pennsylvania to Delaware County. 6. The emission contributions from New Jersey’s population-related emission sources are much less than the contributions from such sources in Pennsylvania.

11 http://www.dep.state.pa.us/dep/deput ate/airwaste/aq/attain/p m25des/AppendixC-1-Greater _Philadelphia_Area.pdf

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Trends Analysis for the Freemansburg, PA Monitor

The levels of particulate matter measured at the Freemansburg, PA monitor dropped in 2012. Table 6 shows the percent of days meas ured over the last three years when the measured levels of particulate matter were greater than 12μg/m 3 . Having more days greater th an this level increases the likelihood that the annual average concentration (i.e., the measured value each day divided by the number of sampling days) will also be greater than 12μg/m 3

. Table 6: Percentage of days with monitored PM 2.5 levels greater than 12μg/m 3 at the Freemansburg, PA monitoring site during 2010 to 2012.
Monitor Year # Days with Data Days with Value > 12 μ g/m 3 % of days with Values

> 12 μ g/m 3 Freemansburg 2010 336 170 47% 2011 340 177 48% 2012 351 132 36%27 Factor 2: Emissions in the Northampton/ Warren County Core Based Statistical Area

Point Sources

Level of control of emission sources
There are no large point sources of emissions in Warren County, NJ, and the emissions of all air pollutants from Warren County are small. Located between the Freemansburg monitoring site and New Jersey is the Portland Gene rating Station and other large Pe nnsylvania sources of emissions. The Portland Generating Station coal units will be shut down in 2014, pursuant to an enforcement settlement agreement approved by the court. Emissions from within Northampton County, PA, where the monitor is located, are higher than all ot her counties in the area. These local emissions will be the greatest contributor to sulfur dioxi de and fine particulate levels in the area.
Table 7 shows 2011 point source em issions (in ton per year) for Pennsylvania and New Jersey counties in the CBSA. (Data Source: 2011 National Emissions Inventory).
Warren County, NJ emissions contribute small amount s to the overall emissi ons in the CBSA with only 2.6 percent of the total PM 2.5 emissions, 0.2 percent of the total SO 2 emissions and 3.2 percent of the total NO x emissions. Pennsylvania counties contri bute most of the emissions in the CBSA with 97.4 percent of the total PM 2.5 emissions, 99.8 percent of the total SO 2 emissions and 96.8 percent of the total NO x emissions.

Table 7: Total point source emissions (in tons per year) for Pennsylvania and New Jersey counties included in the CBSA

County 2011 PM 2.5 ( tons per year ) 2011 SO 2 (tons per year) 2011 NO x ( tons per year )

Lehigh, P A 245 374 628

Northampton, P A 1,306 19,222 8,117

Carbon, P A 50 799 730

Total PA Portion 1,601 (97.4%) 20,395 (99.8%) 9,475 (96.8%)

Warren, NJ 43 52 315

Total NJ Portion 43 (2.6%) 52 (0.2%) 315 (3.2%)

Total Emissions in CBSA 1,644 20,447 9,79028 Area Sources
Population/Population Density

Warren County, NJ is a rural county and does not have a high population de nsity. See Table 8.
Table 8: 2010 Population Density for the CBSA

Source: U.S. Census Bureau, 2010 Population
The total amount of population in Lehigh, Northa mpton, and Carbon County, PA are also much greater than the population of Warren County, NJ. Northampton and Lehigh counties have also experienced positive growth in the last several years, while Warren County has experienced negative growth, as shown in the Table 9. 12

Table 9: Population Changes and Estimates in the Northampton/ Warren County CBSA
County Name Population Estimates Change from 2010 to 2012 2010 Population Estimated 2012 Population Number Percent Change
Pennsylvania Counties 712,481 719,518 7,037 1.0 Lehigh County, PA 349,497 355,245 5,748 1.6 Northampton County, PA 297,735 299,267 1,532 0.5 Carbon County, PA 65,249 65,006 -243 -0.4 New Jersey Counties 108,692 107,653 -1,039 -1.0

Warren County, NJ 108,692 107,653 -1,039 -1.0

Factor 3: Meteorology (including Wind Trajectories and Wind Roses)

New Jersey’s point sources are not located in the predominan t directions that the wind blows when elevated levels of PM 2.5 are detected at the Freemansburg monitors. Figure 16 shows the wind trajectories on the top 10 percent of the days over the last three year period when the highest PM 2.5 levels are monitored at the Freemansburg monitoring site. The Hysplit model was used to determine the wind trajectories for these highest PM 2.5 days by tracking back the direction of the wind for the preceding 24 hours. These wind trajectories are repres ented as lines on these maps,

12 http://factfinder2.census.gov/ faces/tableservices/jsf/pages /productview.xhtml?src=bkmk

County 2010 Population Density (population per sq. mile)

Northampton, PA 805 Lehigh, PA 1,012

Carbon, PA 171

Warren, NJ 30429 showing the location of the wind over the preceding 24-hour period before reaching the monitoring location. The wind collects air pollutant emission s from upwind regi ons as it travels along the path of these wind trajectories. The wi nd blows on most of the days from Pennsylvania and other States (shown as red lines on the ma p) to the Freemansburg moni toring site, rather than from New Jersey (shown in colors other than red) du ring days of elevated PM 2.5 levels in Pennsylvania.
The wind trajectory lines shown in Figure 16 are made up of 24 dots representing each hour of the day for the days when the back trajectories were r un. Each dot also repres ents the location of the parcel of air at that pa rticular hour of the day.

The wind rose from the Allentown, PA area, loca ted in close proximity to the Freemansburg, PA monitor, is shown on the following map. This wind rose shows that the pr edominant direction from which the wind is blowing is from the northwest and west. This means that the air over the Freemansburg, PA monitoring site comes from over Pennsylvania during most of the time. It is more likely, therefore, for emissions coming from Pennsylvania affect particulate level concentrations at the New Garden and Chester monitoring sites than for emissions coming from New Jersey.
Figure 16:30 Discussion of Pennsylvania’s PM 2.5 Recommendations for Northampton County.
The Pennsylvania Department of Natural Re sources released a report on December 10, 2013, outlining recommendations for the nonattainment areas within Pennsylvania. This report included an analysis of the meteorological conditions impacting high PM 2.5 days at the Freemansburg monitor. The analysis shows that the predominant winds on the top 25 percent days, as well as the highest PM 2.5 concentrations, are coming from the s outh. Pennsylvania’ s analysis of PM 2.5 speciated data during the 25% days with the highest PM 2.5 indicate high levels of crus tal materials which could be associated with local construction activities at th e former Bethlehem Steel co rporation industrial site (which lies just south of Freemansburg). Pe nnsylvania is recommending that only Northampton County be listed as nonattainment due to this local construction activity and influence 13

. 

### Factor 4 : Geography/Topography

Higher concentrations of PM 2.5 at the Freemansburg, PA monito ring site do not appear to be occurring because of the ge ographical or topographical features in the area.



### Factor 5: Jurisdictional boundaries

The entire State of New Jersey should be designa ted attainment based on all monitors within New Jersey’s jurisdictiona l boundaries showing PM 2.5 levels less than the NAAQS, including two monitors in Warren County. 

### Summary of why New Jersey should not be associated with the Northampton nonattainment area.

1. There are no violating New Jersey monitors in the Warren County Co re Based Statistical Area. 2. Pennsylvania determined that the Freemans burg monitor in Northampton County, PA is influenced by local s ources in Pennsylvania. 3. New Jersey’s direct PM 2.5 emissions and its precursors are small compared to Pennsylvania’s contributions in the Core Based Statistical Area. 4. The emission contributions from New Jersey due to population-related emission sources are much less than the contributions from Pennsylvania. 5. When daily PM 2.5 concentrations are high at the Freemansburg monitor, the winds are not from New Jersey.

13 http://www.dep.state.pa.us/dep/de putate/airwaste/aq/attain /pm25des/Appendix_C-2-Northampton_County_Area.pdf