1

EPA Region 2 Technical Support Document for the

Approval of Air Quality Implementation Plans; New Jersey,

Carbon Monoxide Maintenance Plan

[Docket No. EPA-R02-OAR-2016-0059; FRL- ]

(Including the Shutdown of the CO Maintenance Area 

Monitors in Burlington, Freehold, Morristown, Perth 

Amboy, and East Orange, New Jersey)

February 2016

US Environmental Protection Agency (EPA)
2

Region 2

Division of Environmental Planning and Protection

Air Programs Branch
3

Table of Contents

Page

I. Carbon Monoxide Attainment Inventory and Limited

Maintenance Plan (LMP) Requirements for the NJ Portion 

of the New York-Northern New Jersey-Long Island 5-County

CO Nonattainment Areas ...................................................... 4

II. New Jersey 2007 CO Base Year Emissions Inventory SIP 

for the NJ Portion of the New York-Northern New JerseyLong Island 5-County CO Nonattainment Areas ........................ 9

III. CO Maintenance Area Monitor shutdowns .............................. 17

Attachments ................................................................... 22

CO Maintenance Area Monitors to be shut down and

their surrogate sites ......................................................... 23

All NJ CO Monitor Sites ................................................. 24

Camden CO site surrogate for Burlington CO site ................. 25 

Elizabeth Lab CO site surrogate for Freehold CO site ............ 26

Elizabeth Lab CO site surrogate for Morristown CO site ........ 27

Elizabeth Lab CO site surrogate for Perth Amboy CO site ...... 28

Elizabeth Lab CO site surrogate for East Orange CO site ....... 29

Carbon Monoxide Emissions from Mobile Sources ................ 30
4

I. Carbon Monoxide Attainment Inventory and Limited 

Maintenance Plan (LMP) Requirements for the NJ Portion of 

the New York-Northern New Jersey-Long Island 5-County CO 

Nonattainment Areas
5

PREFACE

This document is to support EPA's approval of a revision to the New Jersey State 

Implementation Plan (SIP) which pertains to the following: The Carbon Monoxide Attainment 

Inventory and Limited Maintenance Plan (LMP) requirements for the NJ Portion of the New 

York-Northern New Jersey-Long Island 5-County CO Nonattainment Areas.

This TSD contains a detailed review of New Jersey CO Attainment Inventory and inventory

portion of the LMP submittals. Among the topics discussed below are the recent history and 

criteria for approval and EPA’s final recommendations.

A. Attainment Year Inventory Requirements

2007 CO Attainment Year Inventory

Page 3, of the October 6, 1995, memorandum from Joseph W. Paisie, Group Leader, Integrated 

Policy and Strategies Group to Regional Air Branch Chiefs entitled Limited Maintenance Plan 

Options for non-classifiable CO Nonattainment Areas, states that for inventory purposes, the 

State is only required to submit an attainment inventory to EPA that is based on monitoring data 

which shows attainment. There is no requirement to project emissions over the maintenance 

period. This means if 2007 is a calendar year which has monitoring data which demonstrates

attainment, the 2007 base year inventory can be used as the attainment year inventory and no 

projection inventories are required over the years of the maintenance period. Only calendar year 

2007 summary emissions data (based on winter season day) are required. In addition, this 

inventory should be consistent with EPA’s most recent guidance on emission inventories for 

nonattainment areas available at the time and should include emissions during the time period 

associated with the monitoring data showing attainment.

New Jersey submitted a limited maintenance plan (LMP) which included calendar year 2007 

emissions inventory. The 2007 emissions inventory is also classified as the attainment year 

inventory for the LMP. New Jersey has elected 2007 because it is the attainment year base year 

that will be used for LMP and 2007 represents the one of the years of violation-free monitored 

data in the area. The inventory included peak wintertime daily emissions from stationary point, 

stationary area, off-highway mobile, and highway mobile sources of CO. These emission 

estimates were prepared in accordance with EPA guidance.

B. CO Limited Maintenance Plan Requirements 

1. Select a calendar year which shows violation-free data and develop an emissions 

inventory based on that year for the CO nonattainment area. This is considered as the 

attainment year inventory.

Yes, NJ selected calendar year 2007. See Section IV of Final SIP Revisions for the 

Attainment and Maintenance of the 8-Hour CO NAAQS CO Maintenance and Monitoring 

Plan, June 2015 hereafter referred to as “NJ SIP 2015.”
6

2. Emissions are based on winter season daily emissions for CO. 

Yes, See Section IV of NJ SIP 2015.

3. Inventory must be reported in the prescribed format as indicated in the most recent 

inventory guidance. (For details, see Section C.)

4. Provide an explanation on how the point, area, nonroad mobile and onroad mobile source 

inventory are developed. 

See Yes, see Appendix III, Attachment 3, of NJ SIP 2015.

C. Essential Summary Tables for Attainment Year Inventory 

For clarity, please provide the following emission summary tables for the Attainment and End 

Year Inventories. 

 

 

Emission Inventory

Electronic Reporting Documentation 

CO Attainment/Nonattainment Areas 

 

At a minimum, states should ensure that the following is reported to the EPA Regional office. 

Unless otherwise noted, in each of the following cases we refer the State to pages in the 

document entitled, Example Documentation Report for 1990 Base Year Ozone and Carbon 

Monoxide State Implementation Plan Emission Inventories, March 1992 located at the 

following website address: http://www.epa.gov/ttn/chief/publications.html#general 

 

 

1. STATIONARY POINT SOURCES 

 

- Total winter season daily CO emissions from point sources, by county, by 

nonattainment area (see Table 4-3 on page 4-11) 

 

Yes, see Appendix III, Attachment 4 of NJ SIP 2015..

- Summary listing of winter season daily CO point sources emissions by county, by 

nonattainment area. This listing should include plant name, address, county, control 

efficiency, SIC code and annual emissions e (see Table 4-3 on page 4-11) 

 
7

See Excel file 2007 Point by Faclity.xlsx 

2. STATIONARY AREA SOURCES 

 

- Summary of winter season daily CO emissions by area source category, by 

county, by nonattainment area (see pages 5-4 thru 5-9)

Yes, see Appendix III, Attachment 6 of NJ SIP 2015..

 

3. ON-ROAD MOBILE SOURCES 

 

- Summary of winter season daily CO on-road mobile source emissions by MOVES 

Source Type (for Source Types, see Table 2 of the document Using MOVES to Prepare 

Emission Inventories in State Implementation Plans and Transportation Conformity: 

Technical Guidance for MOVES2010, 2010a and 2010b, April 2012) by county, by 

nonattainment area (see pages 7-2 and 7-19) 

- MOVES model inputs (as either Excel file(s) or MySQL database(s)) outlining 

current program parameters

- MOVES model outputs: 

- If MOVES is run in “Inventory” mode, supply a copy of the MySQL output 

database(s)

- If MOVES is run in “Emission Rate” mode, supply a copy of the MySQL 

output database(s) along with post-processing files

 

Yes, see Appendix III, Attachment 3, page 15, Table 2, Attachment 7, and Attachment 8, 

NJ SIP 2015.

 

4. NON-ROAD MOBILE SOURCES 

 

- Summary of winter season daily CO non-road mobile source emissions by nonroad category (for a list of the 14 nonroad categories see Section 5.5.2 of Emission 

Inventory Guidance for Implementation of ozone and Particulate Matter NAAQS and 

Regional Haze Regulation , dated August 2005), by county, by nonattainment area (see 

page 5-6)

 

- The summary reports mentioned should be submitted in Microsoft Spreadsheet 

formats. 

 

Yes, see Appendix III, Attachment 3, pages 16-25 and Attachment 9A NJ SIP 2015.
8

5. Provide an explanation on how the point, area, nonroad mobile and onroad mobile source 

inventory are developed. 

Yes, see Appendix III, Attachment 3 of NJ SIP 2015.

IV. EPA RECOMMENDATIONS

EPA is approving the inventory portion of the CO Limited Maintenance Plan inventory for the 

counties of Bergen, Essex, Hudson, Union and Passaic counties. A more detailed discussion of 

how the emission inventory was reviewed and the results are presented in Section II of the 

technical support document (TSD).

The following table presents a summary of the 2007 CO winter season daily emissions estimates 

in tons per winter day for the counties of Bergen, Essex, Hudson, Union and Passaic counties. 

See table below.

2007 Attainment Inventory for the

NJ Portion of the New York-Northern New Jersey-Long Island 5-County 

CO Nonattainment Area 

(Tons/Peak Winter Season Day)

County Point

Sources

Area Sources

Onroad 

Mobile 

Sources

Nonroad

Mobile

Sources

TOTAL

Bergen 1.82 14 .75 346.29 139.60 502.47

Essex 5.52 12 .93 198.99 75.20 292.64

Hudson 2.46 10 .05 111.77 35.70 159.97

Passaic 0.32 6.52 144.70 42.30 193.84

Un ion 4.18 8.31 169.18 53.60 235.27

Total 14.30 52 .56 970.93 346.50 1,384.19
9

II. New Jersey 2007 CO Base Year Emissions Inventory 

SIP for the NJ Portion of the New York-Northern New 

Jersey-Long Island 5-County CO Nonattainment Areas
10

I. PREFACE

This document is to support EPA's approval of a revision to the New Jersey State 

Implementation Plan (SIP) which pertains to the following: 

Where applicable, 2007 base year inventory winter season daily emissions for CO for the NJ 

Portion of the New York-Northern New Jersey-Long Island area which includes the following 

counties: Bergen, Essex, Hudson, Union and Passaic counties.

This TSD contains a detailed review of New Jersey’s 2007 CO base year emission inventory

submittal. Among the topics discussed below are the recent history and criteria for approval and 

EPA’s final recommendations.

II. BACKGROUND 

Sections 182(a) (1) and (2) of the Clean Air Act require the periodic submission of base 

inventory for SIP planning purposes to address the pollutants for the eight hour-ozone, PM2.5 

and CO National Ambient Air Quality Standards (NAAQS.). Identifying the base year gives 

certainty to states that are required to submit of the ozone, PM2.5 and CO emission inventories 

periodically. These requirements allow the EPA, based on the states’ progress in reducing 

emissions, to periodically reassess its policies and air quality standards and revise them as 

necessary. Most important, the ozone, PM2.5 and CO inventories will be used to develop and 

assess new control strategies that the states will need to submit in their attainment demonstration 

SIPs for the new NAAQS for ozone, PM2.5 and for CO. The base year inventory may also serve 

as part of statewide inventories for purposes of regional modeling in transport areas. The base 

year inventory plays an important role in modeling demonstrations for areas classified as 

nonattainment and outside transport regions. For the reasons stated above, ideally EPA would 

therefore emphasize the importance and benefits of developing a comprehensive, current, and 

accurate ozone, PM2.5 and CO emission inventory (similar to the 1990 base year inventory

effort). In this case, the 2007 base year has been selected as the inventory that will be used for 

planning purposes for the NJ Portion of the New York-Northern New Jersey-Long Island CO 

nonattainment area. 

III. CRITERIA FOR APPROVAL

There are general and specific components of an acceptable emission inventory. In general, the 

State must submit a revision to its SIP and the emission inventory must meet the minimum 

requirements for reporting by source category. Specifically, the source requirements are detailed 

below.

The Level I and II review process is used to determine that all components of the base year 

inventory are present. The review also evaluates the level of supporting documentation provided 
11

by the State and assesses whether the emissions were developed according to current EPA or 

acceptable alternative guidance. The data quality is also evaluated. 

The Level III review process is outlined here and consists of points that the inventory must 

adequately address. For a base year emission inventory to be acceptable it must pass all of the 

following acceptance criteria: 

1. Adequate documentation must be provided that enabled the reviewer to determine the

emission estimation procedures and the data sources used to develop the inventory.

2. Evidence that the inventory was quality assured by the state and its implementation 

documented.

3. The point source inventory must be complete.

4. Point source emissions must have been prepared or calculated according to the current 

EPA guidance.

5. The area source inventory must be complete.

6. The area source emissions must have been prepared or calculated according to the current 

EPA guidance.

7. Non-road mobile emissions were prepared according to current EPA guidance for all of 

the source categories.

8. The method (e.g., HPMS or a network transportation planning model) used to develop 

VMT estimates must follow EPA guidance. The VMT development methods must be 

adequately described and documented in the inventory report.
12

9. The MOVES model must be correctly used to produce the on-road emission inventory.

IV. DETAILED ACTION AND EVALUATION

This TSD contains a detail discussion and summary of the review conducted by EPA for, where 

applicable, the 2007 base year inventory winter season daily emissions for CO for the NJ Portion 

of the New York-Northern New Jersey-Long Island CO nonattainment area.

A. Details on How New Jersey Meets Criteria 1 for the Quality Assurance Plan

Quality Assurance Plan Implementation

The Quality Assurance (QA) plan was implemented for all portions of the inventory. The QA 

plan included a QA/Quality control (QC) program for assessing data completeness and standard 

range checking. Critical data elements relative to the inventory sources were assessed for 

completeness. QA checks were performed relative to data collection and analysis, and double 

counting of emissions from point, area and mobile sources. QA/QC checks were conducted to 

ensure accuracy of units, unit conversions, transposition of figures, and calculations. The QA 

plan for the inventory was performed in accordance with section 6.0 of Emission Inventory

Guidance for Implementation of ozone and Particulate Matter NAAQS and Regional Haze 

Regulation, dated August 2005 and Example Documentation Report for 1990 Base Year for 

ozone and CO SIP Emissions Inventories, March 1992. 

See Appendix III, Attachment 3 of Section VI of Final SIP Revisions for the Attainment 

and Maintenance of the 8-Hour CO NAAQS CO Maintenance and Monitoring Plan, June 

2015 hereafter referred to as “NJ SIP 2015.”

B. Details on How New Jersey Meets Criteria 2 and 3 for the Point Source Inventory

Point Source Inventory

New Jersey’s inventory includes major point sources based on the following thresholds for each 

pollutant in tons per year (tpy): 100 tpy or more of CO. The inventory report describes how 

point source activity levels and their associated parameters were developed, and how the data 

were used to calculate emission estimates. The report provides referenced documents for activity

level and emission factors used. Information on how rule effectiveness and control efficiencies 

were derived (with the associated sample calculations) is also provided. Plant summary

information on detailed, plant, county and nonattainment area levels, are included in the 

inventory. Where applicable, winter season daily emissions are provided for the CO 

nonattainment area. The inventory was developed in accordance with section 5.3 of Emission 

Inventory Guidance for Implementation of ozone and Particulate Matter NAAQS and Regional 
13

Haze Regulation, dated August 2005 and Example Documentation Report for 1990 Base Year 

for ozone and CO SIP Emissions Inventories, March 1992, 

See Appendix III, Attachment 3 of NJ SIP 2015.

C. Details on How New Jersey Meets Criteria 4 and 5 for the Area Source Inventory

Area Source Inventory

The inventory lists the source categories that are included in (and excluded from) from the area 

source inventory. The inventory documentation includes emissions factors, activity levels, 

seasonal adjustment factors, and sample calculations. Referenced information for the input 

values to equations is included. Point source contributions have been correctly factored out of 

the area source category totals where appropriate. Rule effectiveness, control efficiency and rule 

penetration were correctly applied for several source categories and a discussion as to the basis 

for application is provided. Area source emissions are presented on a source category, county 

basis. Where applicable, winter season daily emissions are provided for CO nonattainment 

areas. The inventory was developed in accordance with section 5.4 of Emission Inventory

Guidance for Implementation of ozone and Particulate Matter NAAQS and Regional Haze 

Regulation, dated August 2005 and Example Documentation Report for 1990 Base Year for 

ozone and CO SIP Emissions Inventories, March 1992, 

See Appendix III, Attachment 3 of NJ SIP 2015.

D. Details on How New Jersey Meets Criteria 7 for Non Road Mobile Source Inventory

Nonroad Mobile Source Inventory

For the New Jersey, the predominant non-road mobile source categories (i.e., agricultural 

equipment, construction equipment, industrial equipment, airport service equipment, light 

commercial equipment, lawn and garden equipment...etc.) were developed by the Nonroad 

Emissions Equipment Model 2008 (Nonroad2008, July 2009 version) released by EPA's Office 

of Transportation and Air Quality (OTAQ). Nonroad mobile source emissions are presented on 

a source category, county basis. Where applicable, winter season daily emissions are provided 

for CO nonattainment areas. The inventory was developed in accordance with section 5.5.2 of 

Emission Inventory Guidance for Implementation of ozone and Particulate Matter NAAQS and 

Regional Haze Regulation, dated August 2005 and Example Documentation Report for 1990 

Base Year for ozone and CO SIP Emissions Inventories, March 1992, 

See Appendix III, Attachment 3 and Attachments 9a/9b of NJ SIP 2015.

Aircraft Emissions

Aircraft emissions for are provided for CO were calculated based on the number of landing and 

takeoffs (LTO) cycles generated at each airport. These values were used as inputs to the 

Emissions and Dispersion Modeling System, the Federal Aviation Agency modeling tool. 

Aircraft source emissions are presented on a source category, county basis. Where applicable, 

winter season daily emissions are provided for CO nonattainment areas. The inventory was 
14

developed in accordance with section 5.5.2 of Emission Inventory Guidance for Implementation 

of ozone and Particulate Matter NAAQS and Regional Haze Regulation, dated August 2005 and 

Example Documentation Report for 1990 Base Year for ozone and CO SIP Emissions 

Inventories, March 1992, 

See Appendix III, Attachment 3 and Attachments 9a/9b of NJ SIP 2015.

Locomotive Emissions

Locomotives emissions for CO were calculated based on the estimated fuel consumption for 

individual railroad systems operating in New Jersey. NJDEP received specific fuel use data 

from Class II and III, yard/switch, freight and commuter locomotive railroads. An estimation of 

fuel consumption based on gross ton miles and fuel consumption indexes were prepared for those 

railroads that did not submit statewide fuel data. For Class I line haul locomotives, NJ used 

Class I line haul county level emissions used from the ERTAC 2008 inventory that was 

developed for the MARAMA States. Annual emissions were estimated and then divided by 365 

days. Locomotive source emissions are presented on a source category, county basis. Where 

applicable, CO winter season emissions are provided for CO nonattainment areas. The inventory

was developed in accordance with section 5.5.2 Emission Inventory Guidance for 

Implementation of ozone and Particulate Matter NAAQS and Regional Haze Regulation, dated 

August 2005 and Example Documentation Report for 1990 Base Year for ozone and CO SIP 

Emissions Inventories, March 1992, 

See Appendix III, Attachment 3 and Attachments 9a/9b of NJ SIP 2015.

Commercial Marine Vessel Emissions

Commercial marine vessel (CMV) emissions for CO for the Northern New Jersey area were 

taken from the CMV emissions inventory report prepared by Starcrest Consulting Group, LLC. 

The inventory report relied on actual operational data and then used local activity parameters to 

extend emission estimates to those portions of the CMV not directly inventoried. From this 

information, emission estimates were prepared based on estimated horsepower demand. The 

inventory is based on calendar year 2000. NJ projected these emissions from 2000 to 2007 using 

NJ/NJ Port Authority trade statistics. CMV source emissions are presented on a source category, 

county basis. Annual emissions were estimated and then divided by 365 days. Where applicable, 

winter season daily emissions are provided for CO 5 nonattainment areas. The inventory was 

developed in accordance with section 5.5.2 Emission Inventory Guidance for Implementation of 

ozone and Particulate Matter NAAQS and Regional Haze Regulation, dated August 2005 and 

Example Documentation Report for 1990 Base Year for ozone and CO SIP Emissions 

Inventories, March 1992, 

See Appendix III, Attachment 3 and Attachments 9a/9b of NJ SIP 2015.

E. Details on How New Jersey Meets Criteria 8 and 9 for the Onroad Source Inventory

Onroad Mobile Source Inventory

New Jersey’s mobile source inventory was developed by first using the North Jersey
15

Transportation Planning Authority’s North Jersey Regional Transportation Model-Enhanced 

travel demand model (TDM) as the basis for estimating county level vehicle miles traveled 

(VMT) and speeds. New Jersey then used the PPSUITE custom pre-processing software to 

prepare the VMT and other required inputs, and to run the MOVES2010a model to generate the 

on-road emission inventory.

This method used to determine on-road emission estimates has been explained in the report. The 

report describes how the following key MOVES inputs were developed:

 Source type age distribution

 Distribution of VMT by road type

 Fraction of vehicle hours travelled (VHT) on highway ramps

 Source type population

 Inspection and maintenance program

 NJ Low-emission vehicle program

 Distribution of average speeds by source type and road type

 Meteorology

 Fuel parameters

On-road CO emissions are presented by county and source type. The inventory was developed in 

accordance with Using MOVES to Prepare Emission Inventories in State Implementation Plans 

and Transportation Conformity: Technical Guidance for MOVES2010, 2010a and 2010b, dated 

April 2012 and Example Documentation Report for 1990 Base Year for ozone and CO SIP 

Emissions Inventories, March 1992. The use of MOVES2010a is appropriate as this SIP was 

developed prior to the release of MOVES2014.

See Appendix III, Attachment 3, Attachment 7, and Attachment 8 of NJ SIP 2015.

EPA RECOMMENDATION

New Jersey has a SIP that will ensure that the requirements of emission inventory measures and 

reporting are adequately met. To comply with the emission inventory requirements, the State 

submitted a complete inventory containing point, area, on-road, and non-road mobile source 

data, and accompanying documentation. The SIP submittal does not present any particular issues 

associated with enforceability. 

EPA is approving this SIP submittal as meeting the essential reporting requirements for an 

Emission Inventory. The following table presents a summary of the 2007 CO winter season 

daily emissions estimates in tons per winter day for the counties of Bergen, Essex, Hudson, 

Union and Passaic counties. See table below.
16

2007 Attainment Inventory for the

NJ Portion of the New York-Northern New Jersey-Long Island 5-County 

CO Nonattainment Area 

(Tons/Peak Winter Season Day)

County Point

Sources

Area Sources

Onroad 

Mobile 

Sources

Nonroad

Mobile

Sources

TOTAL

Bergen 1.82 14.75 346.29 139.60 502.47

Essex 5.52 12.93 198.99 75.20 292.64

Hudson 2.46 10.05 111.77 35.70 159.97

Passaic 0.32 6.52 144.70 42.30 193.84

Union 4.18 8.31 169.18 53.60 235.27

Total 14.30 52.56 970.93 346.50 1,384.19
17

III. CO Maintenance Area Monitor shut downs
18

INTRODUCTION

This Technical Support Document evaluates the State of New Jersey’s formal revision to its 

carbon monoxide (CO) maintenance plan, in which New Jersey proposes to revise its State 

Implementation Plan (SIP) to permit the shutdown of the Burlington, Freehold, Morristown, 

Perth Amboy, and East Orange CO monitoring sites. 

BACKGROUND

On September 28, 1995, the State of New Jersey submitted a formal CO redesignation request 

for Camden County and the nine Not-Classified Areas in the State (the City of Atlantic City, the 

City of Burlington, the Borough of Freehold, the Town of Morristown, the Borough of Penns 

Grove, the City of Perth Amboy, the Borough of Somerville, the Toms River Area, and the City

of Trenton). On February 5, 1996 the U.S. EPA redesignated these areas to attainment for the 

CO NAAQS and approved New Jersey’s 10 year maintenance plan for these areas (61 FR 

33678). In 2006, New Jersey submitted a second 10 year maintenance plan to show how these 

areas would continue to attain the CO standard for an additional 10 years. This maintenance 

plan was a Limited Maintenance Plan. This is a less restrictive plan since the areas met the 

requirement of having a CO design value equal to or less than 85% of the CO standard. For 

additional information, the reader is referred to 71 FR 26895 and 71 FR 38770. Since that time, 

there have been no violations of the CO NAAQS of 9 ppm (8 hour average) or 35 ppm (1 hour 

average) in these areas, and CO is trending downward to a level less than 1/3 the NAAQS (see 

Graph 1.)

In addition, on January 15, 2002, the State of New Jersey submitted a formal CO redesignation 

request for the New Jersey portion of the New York-Northern New Jersey-Long Island 

(NYNNJLI) CO area. On October 22, 2002 the U.S. EPA redesignated this area to attainment 

for the CO NAAQS and approved New Jersey’s 10 year maintenance plan for the area. For 

additional information, the reader is referred to 67 FR 54601 and 67 FR 54574. The 

accompanying Federal Register notice proposes to approve New Jersey’s second 10 year 

maintenance plan showing how this area would continue to attain the CO standard for an 

additional 10 years. This maintenance plan is a Limited Maintenance Plan. This is a less 

restrictive plan since the areas met the requirement of having a CO design value equal to or less 

than 85% of the CO standard. Since that first maintenance plan, there have been no violations of 

the CO NAAQS of 9 ppm (8 hour average) or 35 ppm (1 hour average) in that area, and CO is 

trending downward to a level less than 1/3 the NAAQS (see Graph 1).

On August 2, 2010, New Jersey submitted their “New Jersey Ambient Air Monitoring Network 

Assessment 2010” to EPA. This document described New Jersey’s ambient air monitoring 

network and also detailed proposed changes and the rationale for them. In this document, New 

Jersey provided a site-by-site analysis used in order to perform their network assessment. A 

scoring scheme and final network rankings were used to help New Jersey make modifications to 

their ambient air monitoring network. The reasoning behind these requested CO monitor 

shutdowns are included in that submittal. On February 8, 2016, New Jersey submitted an 

addendum to their 2nd CO maintenance plan SIP requesting to also shut down their East Orange 

CO monitoring site.
19

EVALUATION OF NEW JERSEY’S SUBMITTAL

On June 11, 2015, the State of New Jersey submitted a formal revision to its SIP to shut down 

the Burlington, Freehold, Morristown, and Perth Amboy CO monitoring sites (see Figure 1). 

These are “sole pollutant” sites, monitoring only CO. The SIP revision consists of a 

modification to New Jersey’s CO maintenance plan for these CO monitoring sites. On February

8, 2016, the State of New Jersey submitted an addendum to their 2nd CO maintenance plan SIP 

requesting the shutdown of their East Orange CO monitoring site.

The New Jersey Department of Environmental Protection submittal explains that considerable 

resources are utilized each year to cover the lease agreements with the property owners, 

maintenance of the monitoring site and equipment, phone, electricity, travel to and from the sites 

from the main office in Trenton, and staff time to conduct routine and emergency maintenance. 

The New Jersey Department of Environmental Protection asserts and EPA agrees that all of these 

resources could better be used elsewhere in the state’s monitoring program. 

CO levels have been falling in Burlington, Freehold, Morristown, Perth Amboy, and East Orange 

since the early 1980s (see Figures 2 – 7.) The NAAQS of 9 ppm (8 hour average) has not been 

violated1since 1986, and current readings of the design value are in the 2 to 3 ppm range, and 

have been for the past three (3) years. Most of the CO reduction has been due to “fleet turnover,” 

with newer, cleaner motor vehicles making up an increasing share of the fleet, and this trend is 

likely to continue in the future.

In addition to the downward trend shown by the monitoring data, the state performed mobile 

source modeling and conformity analyses which predict that winter time CO concentrations in 

Burlington, Freehold, Morristown, Perth Amboy, and East Orange will remain below the CO 

Conformity Budget levels out into the future (See Table 1). The Burlington analysis extends to 

2020 while the Freehold, Morristown, and Perth Amboy analysis extends to 2014. In their 

addendum on February 8, 2016, New Jersey provided mobile source emission modeling and 

conformity analyses performed by the North Jersey Transportation Planning Authority which 

predicted that CO emissions in Bergen, Essex, Hudson, Passaic and Union counties will remain 

below the approved CO Conformity Budgets through 2040. (See Table 2).

To use its resources more prudently, and because of the low concentrations and downward CO 

trend, the state requests permission to cease monitoring for CO in Burlington, Freehold, 

Morristown, and Perth Amboy. New Jersey DEP will continue monitoring for CO at the nearby 

Camden and Elizabeth Lab sites. New Jersey DEP will use the Camden CO data as a surrogate 

for Burlington and will use the Elizabeth Lab CO data as a surrogate for Freehold, Morristown, 

Perth Amboy, and East Orange (See Figures 2 – 7 comparing CO levels in those groups of cities. 

EPA notes that the five (5) other CO not classified maintenance areas (Somerville, Trenton, 

Penns Grove, Toms River, and Atlantic City) currently do not have CO monitoring sites.

In this SIP submittal, NJ is requesting that EPA modify a portion of the federally approved New 

 

1 A CO violation is defined as the 2nd exceedance of the standard at the same site during the same calendar year.
20

Jersey CO maintenance plan. That approved maintenance plan obligates the State to select a 

contingency threshold or ‘trigger,’ such as a monitored CO exceedance or violation, and commit 

to implementing the appropriate contingency measure once the threshold is exceeded. This 

modification is an additional trigger that will cause NJ to re-establish their shutdown sites in the 

event that a surrogate site exceeds 75% of either of the CO standards twice in 1 calendar year, as 

outlined below.

What happens if the modified (75%) contingency trigger is exceeded at a surrogate site?

 In the event the second-highest CO concentration in any calendar year, as monitored at 

the Camden site, reaches 75 percent of either the federal 1-hour or 8-hour NAAQS for 

CO, New Jersey will, within 9 months of recording such concentrations, re-establish a 

CO monitoring site in Burlington consistent with EPA siting criteria, and resume 

analyzing and reporting those data.

 In the event the second-highest CO concentration in any calendar year, as monitored at 

the Elizabeth Lab site, reaches 75 percent of either the federal 1-hour or 8-hour NAAQS 

for CO, New Jersey will, within 9 months of recording such concentrations, re-establish 

CO monitoring sites in Freehold, Morristown, Perth Amboy, and East Orange consistent 

with EPA siting criteria, and resume analyzing and reporting those data.

What happens is there is a violation of the CO standard at any site?

In addition to the re-establishing of the shutdown sites:

 New Jersey is proposing to implement its contingency program for Burlington in the 

event that a CO violation of either the federal 1-hour or 8-hour NAAQS is monitored at 

the Camden site in any year during the 1996 – 2016 maintenance period and to consider 

one or more of the other EPA-approved measures if necessary.

 New Jersey is proposing to implement its contingency program for Freehold, 

Morristown, Perth Amboy, and East Orange in the event that a CO violation of either the 

federal 1-hour or 8-hour NAAQS is monitored at the Elizabeth Lab site in any year 

during the 1996 – 2016 maintenance period and to consider one or more of the other 

EPA-approved measures if necessary.

 New Jersey will also continue to commit to implement its contingency program at the 

surrogate sites in the event that a CO violation is monitored at any of the re-established 

monitoring sites at any time during the 1996 – 2016 maintenance period, and to consider 

one or more of the other EPA-approved measures listed in their contingency plan if 

necessary to reduce CO levels.

When implementing contingency measures, New Jersey will review and implement the measures 

necessary to remedy the violation, including transportation control measures (TCM), and other 

additional vehicle or fuel controls. These measures will remain in effect until the CO monitors 

in question show that the areas are in attainment of the CO standards.
21

CONCLUSION

The State of New Jersey submitted a formal revision to its SIP to shut down the Burlington, 

Freehold, Morristown, and Perth Amboy CO monitoring sites. These sites only monitor CO. 

The State also submitted a formal revision to its 2nd maintenance plan SIP to shut down the East 

Orange CO monitoring site. These SIP revisions consist of a modification to New Jersey’s CO 

maintenance plan for these CO monitoring sites. EPA concurs that NJDEP’s proposal to 

shutdown CO monitors in certain CO maintenance areas is sufficiently supported by the 

following reasons:

 CO concentrations have continuously decreased over the past 25 years,

 Mobile source emissions, the major contributor to ambient concentrations of CO, are 

projected to continue to decrease as cleaner cars replace older vehicles, and

 New Jersey committed to reestablish these monitoring sites if CO concentrations are 

measured at concentrations over 75% of the existing standard.

EPA agrees that New Jersey DEP’s proposal represents a reasonable plan modification and 

approach for shutting down specific CO monitors that are currently measuring concentrations 

well below the existing 1- hour and 8- hour CO NAAQS. The alternative method that New 

Jersey adopted as a contingency triggering mechanism is an appropriate part of its CO 

maintenance plan. Under these revised plans, EPA believes air quality goals will be maintained, 

and State monitoring resources conserved.

SIP Revision Recommendation: Approval
22

ATTACHMENTS
23

Figure 1.
24

Figure 2.

All NJ CO Monitor Sites

0.0

5.0

10.0

15.0

20.0

25.0

30.0

35.0

40.0

45.0

Parts Per Million

Year

2nd Highest 1-hr CO Concentrations

Camden

Ancora S.H.

East Orange

Elizabeth

Elizabeth Lab

Fort Lee

Freehold

Hackensack

Jersey City

Morristown

Perth Amboy

Burlington

Newark

1-Hr Standard

0.0

5.0

10.0

15.0

20.0

25.0

30.0

Parts Per Million

Year

2nd Highest 8-hr CO Concentrations

Camden

Ancora S.H.

East Orange

Elizabeth

Elizabeth Lab

Fort Lee

Freehold

Hackensack

Jersey City

Morristown

Perth Amboy

Burlington

Newark

8-Hr Standard
25

Figure 3.

Camden CO site surrogate for Burlington CO site

0.0

5.0

10.0

15.0

20.0

25.0

30.0

35.0

40.0

Parts Per Million

Year

2nd Highest 1-hr CO Concentrations

Camden/Burlington

Camden

Burlington

Newark

0.0

5.0

10.0

15.0

20.0

Parts Per Million

Year

2nd Highest 8-hr CO Concentrations

Camden/Burlington

Camden

Burlington

Newark
26

Figure 4.

Elizabeth Lab CO site surrogate for Freehold CO site

0.0

5.0

10.0

15.0

20.0

25.0

30.0

35.0

40.0

Parts Per Million

Year

2nd Highest 1-hr CO Concentrations

Elizabeth Lab/Freehold

Elizabeth Lab

Freehold

1-Hr Standard

0.0

5.0

10.0

15.0

Parts Per Million

Year

2nd Highest 8-hr CO Concentrations

Elizabeth Lab/Freehold

Elizabeth Lab

Freehold

8-Hr Standard
27

Figure 5.

Elizabeth Lab CO site surrogate for Morristown CO site

0.0

5.0

10.0

15.0

20.0

25.0

30.0

35.0

40.0

45.0

Parts Per Million

Year

2nd Highest 1-hr CO Concentrations

Elizabeth Lab/Morristown

Elizabeth Lab

Morristown

1-Hr Standard

0.0

5.0

10.0

15.0

20.0

25.0

30.0

Parts Per Million

Year

2nd Highest 8-hr CO Concentrations

Elizabeth Lab/Morristown

Elizabeth Lab

Morristown

8-Hr Standard
28

Figure 6.

Elizabeth Lab CO site surrogate for Perth Amboy CO site

0.0

5.0

10.0

15.0

20.0

25.0

30.0

35.0

40.0

Parts Per Million

Year

2nd Highest 1-hr CO Concentrations

Elizabeth Lab/Perth Amboy

Elizabeth Lab

Perth Amboy

1-Hr Standard

0.0

5.0

10.0

15.0

20.0

Parts Per Million

Year

2nd Highest 8-hr CO Concentrations

Elizabeth Lab/Perth Amboy

Elizabeth Lab

Perth Amboy

8-Hr Standard
29

Figure 7.
30

Table 1.

Carbon Monoxide Emissions from Mobile Sources

The following CO budgets were approved on February 5, 1996 when the U.S. EPA redesignated 

these areas to attainment for the CO NAAQS and approved New Jersey’s 10 year maintenance 

plan for these areas (61 FR 33678).

Burlington City

Year VMT CO Emissions 

(tons/day)

CO Budget (tons/day)

2007 12,209,000 154.90 170.43

2010 12,540,100 135.93 170.43

2020 13,788,500 119.12 170.43

Source: Transportation Conformity of the DVRPC FY 2007 Transportation Improvement Programs and the Destination 2030 

Long Range Transportation Plan, May 2006

Perth Amboy

Year VMT CO Emissions 

(tons/day)

CO Budget (tons/day)

2007 17,485,354 244.59 244.99

2014 19,814,012 203.95 244.99

Freehold

Year VMT CO Emissions 

(tons/day)

CO Budget (tons/day)

2007 15,703,237 219.68 231.55

2014 16,418,941 169.52 231.55

Morristown

Year VMT CO Emissions 

(tons/day)

CO Budget (tons/day)

2007 14,735,071 209.88 244.05

2014 15,591,325 162.57 244.05

Source: The Northern New Jersey Air Quality Conformity Determination of the 2005 Regional Transportation Plan and the FY 

2007-2010 Transportation Improvement Program, June 2006
31

Table 2.

Carbon Monoxide (CO) Budget for Bergen, Essex, Hudson, Passaic, and

Union Counties

YEAR PROJECTED DAILY 

VMT

PROJECTED CO 

EMISSIONS (tons/day)

CO BUDGET 

(tons/day)

2015 59,953,733 362 899

2025 64,285,191 204 899

2030 66,566,894 160 899

2040 71,376,130 131 899