1

Technical Basis for Designating New Jersey Attainment for the 

Annual PM2.5 National Ambient Air Quality Standard of 

12μg/m3

Prepared by the 

New Jersey Department of 

Environmental Protection 

February 24, 2014    
2

Table of Contents 

Introduction ................................................................................................................................................... 3 

The Northern New Jersey Combined Statistical Area (CSA) .................................................................... 6 

Five-Factor Analysis of the Southern New Jersey Combined Statistical Area (CSA) ................................... 7 

Factor 1: Air Quality Data .............................................................................................................................. 7 

a. Background on PM2.5 Components at New Jersey Speciation Monitoring Sites................................ 7 

b. Validity of Air Quality Data at Nonattainment Monitors ................................................................... 9

c. Trends Analysis for the Pennsylvania 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 Levels ..................................................................................................... 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 PM2.5 

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. ...... 30
3

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

Fine Particulate (PM2.5) National Ambient Air Quality Standard (NAAQS) of 

12μg/m3

Introduction

The United States Environmental Protection Agency (USEPA) promulgated a new annual PM2.5

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/m3) to 12μg/m3. 

According to Section 107(d)(l)(A) of the federal Clean Air Act, states have one year from the new 

standard’s promulgation to submit a recommendation 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/m3

 PM2.5 standard, New Jersey had 13 counties in northern and southern New 

Jersey designated as nonattainment. Due to improvements in air quality, the USEPA redesignated 

these counties as attaining the annual PM2.5 standard of 15μg/m3

 in August 2013, thus making the 

entire State of New Jersey attainment of the old 15μg/m3 PM2.5 NAAQS and the 35μg/m3 24-hour 

PM2.5 NAAQS. New Jersey’s recommendation that the entire State of New Jersey be designated 

attainment of the new annual NAAQS for PM2.5 was submitted to the USEPA on December 18, 2013. 

For the new, annual 12μg/m3 standard, the USEPA issued guidance 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 initiated if a monitor measures air quality above 

the standard. Under initial consideration for nonattainment, the size of a nonattainment 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 attainment for its portion of the CBSA or CSA is 

warranted. 

New Jersey is part of two Combined Statistical Areas (CSAs): the Northern New Jersey CSA which it 

shares with New York, Connecticut and Pennsylvania, and includes 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 Philadelphia, Delaware and Maryland, and includes the 

New Jersey counties of Burlington, 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 Northampton; 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

 PM2.5 is also referred to as fine or respirable particulate matter. 2

 USEPA Guidance on Area Designations, April 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 least one urban cluster of at least 10,000 population, plus adjacent territory that has 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 core 

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 attainment and a downward trend in measured PM2.5 levels over the 

last 10 years. The downward trend is expected to continue 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 distillate and residual fuel oils of 500 parts per million 

(ppm) that will take effect in July, 2014, with the next lower sulfur-content phase (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 trend of New Jersey's statewide annual design values 

is shown in Figure 2. 

Based on its analysis pursuant to the 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 Jersey, but within the same CSAs and CBSAs.
5

Figure 2: PM2.5 Design Value Concentrations, Annual Design Values 1999 – 2012 

New Jersey Statewide 

 

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8

The New Jersey Speciation Network currently consists of five sites (Elizabeth, Newark, New 

Brunswick, Chester, and Camden) at which air filters are analyzed to determine the chemical 

characteristics of the particulate matter collected on the filter. Data from 2002 through 2012 was used 

in this speciation analysis. Since the Camden speciation monitoring site restarted operation in 2013, 

after being shut down since 2008, it was not included in the analysis due to incomplete data. The 

Newark monitor was also not included in the analysis, because the site began operation in 2010. 

The annual statewide speciation data from the monitors 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 sulfate, organic carbon, nitrate, ammonium, and elemental carbon. The “other” 

category includes all other trace elements for "crustal" calculations (aluminum, silicon, calcium, iron, 

titanium, etc.) that were measured. 

Organic carbon and sulfate comprise approximately 63 percent of the total PM2.5 mass. Studies5

 have 

shown that the primary sources of organic and elemental carbon are gasoline and 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 secondarily from burning other fuels that contain sulfur, 

such as heating oil. 

The speciation data at all New Jersey sites show a downward trend in sulfates, 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 downward trend is consistent with reductions in the 

emissions of fine particulate matter that New Jersey has made over the years (see in this document, 

Factor 2 – Emissions and Emissions-related Data). 

Figure 5: New Jersey PM2.5 Speciation Summary Statewide Annual Average Concentrations, 

2002 – 2012 

                                                            

5

 For details on other PM2.5 speciation data studies, including seasonal trends, for New Jersey and the region, refer to: NJDEP 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, Chapter 2, Appendices B11 and B12. New Jersey Department of 

Environmental Protection, March 26, 2009 (http://www.state.nj.us/dep/baqp/sip/siprevs.htm). 
9

The total PM2.5 mass measured at the speciation 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 PM2.5 

components. Average reductions of each of these 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 PM2.5 mass measured at 

New Jersey monitors. Significant decreases are noted in the annual average data in all of the five 

major species listed above from 2002-2012. Organic carbon and sulfate consistently 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 PM2.5 levels above the 12μg/m3 health standard: 

Chester, PA (Delaware County), New Garden, PA (Chester County), and the 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 status6. Thus, the monitor was not included in New Jersey’s 

analysis. 

c. Trends Analysis for the Pennsylvania Nonattainment Monitors 

The particulate matter levels measured at the Chester and New Garden 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/m3

. Daily monitoring data from the two 

monitors was used for this analysis. 

                                                            

6

 http://www.phila.gov/health/pdfs/2013_14AMNPFinalwAppendices__20130628.pdf 
10

Figure 6: Pennsylvania Monitors with valid data measuring above 12μg/m3 in the Southern 

New Jersey CSA. 

Table 1: Percent of Days (2010 - 2012) with monitored PM2.5 levels greater than 12μg/m3 at the 

Chester and New Garden, PA Sites. 

Monitor Year # Days 

with Data 

% of Days 

with Data 

Days with 

PM2.5 > 

12μg/m3

% of days 

with PM2.5

> 12μg/m3

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 particulate matter that is emitted 

locally in urban areas. Typical urban sources considered to be local in nature and that may impact 

PM2.5 levels at an air monitor include nearby vehicular traffic, local industry, construction activity, 

pesticide use and wood burning. 

New Jersey could not conduct a sufficient urban excess analysis due to lack 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 speciated 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 urban excess analysis performed by the State of 
11

Pennsylvania. 

New Jersey does not disagree with Pennsylvania’s determination of the urban excess as contained in its 

report released in December 20137. In that report, Pennsylvania concluded 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 PM2.5 components have decreased 

in New Jersey between 28 and 59 percent since 2002 (see in this document, Factor 1 – Air Quality 

Data). 

Factor 2: Emissions and Emissions-Related 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 major 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 amounts of sulfur dioxide and particulate emissions are occurring 

in most counties. Sources in Pennsylvania counties continue to contribute the largest portion of 

emissions within and upwind of the Pennsylvania monitors that measure high PM2.5 levels. 

Figure 7: Emissions and Locations of Major Point Sources near the Chester and New Garden, 

PA monitors (Indicated with Orange Circles). 

                                                            

7

 http://www.dep.state.pa.us/dep/deputate/airwaste/aq/attain/pm25des/AppendixC-1-Greater_Philadelphia_Area.pdf 
12

Figure 8A: 

2008 PM2.5 County Total Emissions from Point 2011 PM2.5 County Total Emissions from 

Sources in Southern New Jersey CSA Sources in Southern New Jersey C
13

Figure 8B:

2008 SO2 County Total Emissions from Point 2011 SO2 County Total Emissions from 

Sources in Southern New Jersey CSA Sources in Southern New Jersey C
14

Figure 8C: 

2008 NOx County Total Emissions from Point 2011 NOx County Total Emissions from 

Sources in Southern New Jersey CSA Sources in Southern New Jersey C
15

Figure 9 shows the location of the major point sources in New Jersey and Pennsylvania. 

Figure 9: Emissions and Locations of Major PM2.5 Point Sources for New Jersey 

and Pennsylvania 
16

Table 2 shows 2011 total emissions (in tons per year) for point sources located in the counties 

included in the CSA. (Data Source: 2011 National Emissions Inventory at 

http://www.epa.gov/pmdesignations/2012standards/docs/nei2011v1pointnei2008v3county.xlsx). The 

pollutants analyzed include PM2.5 and its precursors: oxides of nitrogen (NOx) and sulfur dioxide 

(SO2). 

In 2011, New Jersey’s total point source emissions only contribute approximately 18 percent of the 

overall emissions in the area: 22 percent of PM2.5, 16 percent of SO2 and 19 percent of NOx. The 

Pennsylvania counties in the CSA contribute the majority of the emissions: 69 percent of the total 

PM2.5 emissions, 78 percent of the total SO2 emissions and 70 percent of the total NOx 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 SO2 for 

the point sources. These point sources are also large emitters of nitrogen oxides and particulate 

matter. 

The high number of large point sources located in Pennsylvania is contributing to this urban excess at 

the New Garden and Chester monitors, given the predominant wind directions and wind trajectories 

on days of high monitored PM2.5 levels at New Garden and Chester 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 

PM2.5 (tons per 

year)

2011 

SO2 (tons per year)

2011

NOx (tons per year)

New Castle, DE 597 896 2,756 

Total DE Portion 597 (9.0%) 896 (6%) 2,756 (11%) 

Philadelphia, PA 1,034 730 2,568 

Delaware, PA 1,497 4,976 7,642 

Montgomery, PA 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 regulatory efforts to reduce 

emissions that contribute to PM2.5. All large coal burning sources in the New Jersey portion of the 

CSA are controlled using scrubbing technology to reduce sulfur dioxide emissions, baghouse 

filtration to reduce particulate emissions, and selective catalytic reduction (SCR) to reduce nitrogen 

oxides emissions. 
17

The Pennsylvania counties within the Southern New Jersey CSA have multiple large point sources 

that are concentrated along the borders of Philadelphia and Delaware Counties and upwind of the 

Chester monitor as shown in Figure 9. This indicates that local influence from these point sources 

may be responsible for the elevated PM2.5 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, NOx, and SO2 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 PM2.5.

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 Levels

In 2011, motor vehicle emissions accounted for approximately 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 CSA8 in millions 

of miles. The 2011 data is shown in Table 3, which indicates that a greater degree of commuting 

occurs within the upwind Pennsylvania 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 commuting within Pennsylvania to 

Delaware County than are commuting from New Jersey. 

Table 3: Total Number and Percent of Commuters 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.xlsx 
18

Figure 10: Driving miles for Passenger Vehicles within each county in 2011 
19

b. Commuting Patterns 

Table 4 presents the total number of commuters from a specific home county in Pennsylvania and 

New Jersey to Delaware County, Pennsylvania9

. Similarly, Table 3 summarizes the total number of 

commuters by State and presents the percentage of commuters to Delaware 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 Vehicle Miles Travelled (VMT) from specific 

residence counties in Pennsylvania and New Jersey 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

 Ibid 
20

Area Source Emissions 

a. Existing Population and Expected Growth 

The New Jersey counties have some of the lowest 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 million people live in the 

Pennsylvania counties of this CSA. Camden, Gloucester, Cumberland, Salem and Burlington 

Counties i n Ne w J e r s e y experienced low to negative growth in New Jersey (between -0.5% 

and 0.6%) between 2010 and 2012, which was less than the growth in the Pennsylvania counties of 

the CSA. Therefore, the contribution from New Jersey’s emissions due to population-related 

emission sources (e.g.; home heating and consumer 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 201210

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/2012standards/docs/population2010.xls and 2012 population data 

from http://www.census.gov/popest/data/historical/2010s/vintage_2012/index.html 
21

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

Wind trajectory analysis demonstrates that New Jersey’s point sources of PM2.5 are not located in 

the predominant directions that the wind blows when elevated PM2.5 levels are detected at the 

Chester and New Garden monitors. 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 PM2.5 levels were 

detected at the Chester and New Garden monitoring sites. These wind trajectories are represented 

as lines on these maps, showing the location of where the wind traveled over the preceding 24-

hour period before reaching the monitoring location. The wind collects air pollutant emissions 

from upwind regions as it travels along the path of these wind trajectories. The wind blows on the 

largest majority of the days from Pennsylvania and other States (shown as red lines on the map) 

to the monitoring sites, rather than from New Jersey (shown in colors other than red) during days 

of elevated PM2.5 levels in Pennsylvania. 

Wind roses from the Philadelphia airport, located in close proximity to the Chester, PA, monitor is 

shown in each of the following maps. These wind roses also show that the predominant directions 

from which the wind is blowing are from the northwest and west. This means that the air over the 

New Garden and Chester monitoring sites travels over Pennsylvania during most times of the year. 

It is less likely, therefore, that emissions from New Jersey affect particulate level concentrations at 

the New Garden and Chester monitoring sites. 

Figure 11: 
22

Figure 12: 

Discussion of Pennsylvania Analysis of Wind Trajectories 

On December 10, 2013, the Pennsylvania Department of Natural Resources recently released a 

report outlining recommendations for the non-attainment areas within Pennsylvania. This report 

(http://www.dep.state.pa.us/dep/deputate/airwaste/aq/attain/pm25des/AppendixC-1-

Greater_Philadelphia_Area.pdf ), included an analysis of the wind trajectories on the days of 

regionally low particulate level concentrations, but locally high particulate levels at the Chester, PA 

monitoring site. The analysis shows that the wind trajectories on these days are predominantly from 

three directions; southwesterly, easterly, and northeasterly. The analysis also concluded that there 

are multiple local, major sources of PM2.5, SO2, and NOx 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 local 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 large 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 fine 
particulate m

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23

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24

Factor 5: Jurisdictional Boundaries 

The current jurisdictional boundaries for New Jersey should be considered since all New Jersey 

monitors are currently measuring PM2.5 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 decreasing 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 monitor in Delaware County, PA is influenced by 

local sources11. 

3. When daily PM2.5 concentrations are high at Pennsylvania’s nonattainment monitors, the 

winds are not from New Jersey. 

4. New Jersey’s contributions of PM2.5 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 the 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/deputate/airwaste/aq/attain/pm25des/AppendixC-1-Greater_Philadelphia_Area.pdf 
Five Fact

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26

Figure 15: PM2.5 Monitors in the Northampton/Warren County CBSA 

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 measured over the last three years when the measured levels of 

particulate matter were greater than 12μg/m3

. Having more days greater than 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/m3

. 

Table 6: Percentage of days with monitored PM2.5 levels greater than 12μg/m3 at the 

Freemansburg, PA monitoring site during 2010 to 2012. 

Monitor Year # Days with 

Data 

Days with Value > 

12μg/m3

% of days 

with Values 

> 12μg/m3

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 Generating Station and other large Pennsylvania 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 other counties in the area. These local emissions 

will be the greatest contributor to sulfur dioxide and fine particulate levels in the area. 

Table 7 shows 2011 point source emissions (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 amounts to the overall emissions in the CBSA with 

only 2.6 percent of the total PM2.5 emissions, 0.2 percent of the total SO2 emissions and 3.2 percent 

of the total NOx emissions. Pennsylvania counties contribute most of the emissions in the CBSA 

with 97.4 percent of the total PM2.5 emissions, 99.8 percent of the total SO2 emissions and 96.8 

percent of the total NOx emissions. 

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

counties included in the CBSA 

County 2011 

PM2.5 (tons per 

year)

2011 

SO2 (tons per year)

2011

NOx (tons per 

year)

Lehigh, PA 245 374 628 

Northampton, PA 1,306 19,222 8,117 

Carbon, PA 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 9,790 
28

Area Sources 

Population/Population Density 

Warren County, NJ is a rural county and does not have a high population density. 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, Northampton, 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 predominant directions that the wind blows 

when elevated levels of PM2.5 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 

PM2.5 levels are monitored at the Freemansburg monitoring site. The Hysplit model was used to 

determine the wind trajectories for these highest PM2.5 days by tracking back the direction of the 

wind for the preceding 24 hours. These wind trajectories are represented 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 304
29

showing the location of the wind over the preceding 24-hour period before reaching the 

monitoring location. The wind collects air pollutant emissions from upwind regions as it travels 

along the path of these wind trajectories. The wind blows on most of the days from Pennsylvania 

and other States (shown as red lines on the map) to the Freemansburg monitoring site, rather than 

from New Jersey (shown in colors other than red) during days of elevated PM2.5 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 run. Each dot also represents the location of the 

parcel of air at that particular hour of the day. 

The wind rose from the Allentown, PA area, located in close proximity to the Freemansburg, PA 

monitor, is shown on the following map. This wind rose shows that the predominant 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 PM2.5 Recommendations for Northampton County. 

The Pennsylvania Department of Natural Resources 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 PM2.5 days at the Freemansburg monitor. 

The analysis shows that the predominant winds on the top 25 percent days, as well as the highest 

PM2.5 concentrations, are coming from the south. Pennsylvania’s analysis of PM2.5 speciated data 

during the 25% days with the highest PM2.5 indicate high levels of crustal materials which could be 

associated with local construction activities at the former Bethlehem Steel corporation industrial site 

(which lies just south of Freemansburg). Pennsylvania is recommending that only Northampton 

County be listed as nonattainment due to this local construction activity and influence13. 

Factor 4: Geography/Topography

Higher concentrations of PM2.5 at the Freemansburg, PA monitoring site do not appear to be 

occurring because of the geographical or topographical features in the area. 

Factor 5: Jurisdictional boundaries

The entire State of New Jersey should be designated attainment based on all monitors within New 

Jersey’s jurisdictional boundaries showing PM2.5 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 Core Based Statistical 

Area. 

2. Pennsylvania determined that the Freemansburg monitor in Northampton County, PA is 

influenced by local sources in Pennsylvania. 

3. New Jersey’s direct PM2.5 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 PM2.5 concentrations are high at the Freemansburg monitor, the winds are not 

from New Jersey. 

                                                            

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