UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION II AIR PROGRAMS BRANCH

Technical Support Document

for

EPA(s Notice of Proposed Rulemaking

for the

New Jersey State Implementation Plan Revision:

New Jersey’s Ozone Attainment Demonstration

From the State of New Jersey’s State Implementation Plan (SIP)
Revision for the Attainment and Maintenance of the Ozone National
Ambient Air Quality Standard

8-Hour Ozone Attainment Demonstration

Submitted to EPA in Final Form on October 29, 2007

	January 2009

Technical Support Document - List of Contents

Purpose of the Technical Support Document

Introduction to New Jersey’s State Implementation Plan for Ozone

What Are The Components Of A Modeled Attainment Demonstration?

An Overview of the Modeling Process

The Regulatory Framework

How Did New Jersey Address The Components Of A Modeled Attainment
Demonstration?

Conceptual description of the problem

Modeling/analysis protocol

The model used to support the demonstration

Meteorological time periods used in the modeling

Domain of the model, horizontal/vertical resolution and the initial and
boundary conditions

Vertical resolution is the number of layers and the size of each layer
in the model.

Meteorological data used in the air quality model

Emissions used in the air quality model

Model base case run and performance evaluation

Future year (2009 control case) modeling for the attainment year and the
attainment test

Are the results of the photochemical modeling system correctly
predicting future air quality?

Summary of Photochemical Grid Modeling Results

How Did New Jersey Describe Its Attainment Demonstration And What Were
Its Conclusions?

What Are the Elements of New Jersey’s Attainment Demonstration?

Overview

Design Value Adjustment:  New Jersey’s SIP uses average of five
years’ 4th highest annual ozone centered on 2002

Adjustment of Modeled Reduction Factors:  New Jersey’s SIP uses ozone
reduction from the monitoring site with the greatest reduction in ozone
for all monitoring sites

New Jersey’s SIP’s Technical Justification for Adjusting Modeling
Results:  2006 Air Quality Data are Near the Predicted Concentration for
2009

New Jersey’s SIP’s Technical Justification for Adjusting Modeling
Results:  Comparison of the Modeling Simulation with Special Study Data

New Jersey’s SIP’s Technical Justification for Adjusting Modeling
Results:  Comparison of the Modeling Simulation with Recent Ambient Air
Quality Data

New Jersey’s SIP’s Technical Justification for Adjusting Modeling
Results:

Blackout Studies

EPA’s Additional Analyses of Ambient Data

Recent monitored design values compared to the photochemical grid
model’s estimate of 2009’s design value when computed following
EPA’s guidance

Additional reductions - What measures can New Jersey use to predict
reductions in ozone?

Assessing the possibility that New Jersey’s additional reductions
could bring its nonattainment areas into attainment by 2009

Assessing the possibility that reductions between 2007 and 2009 could
bring the nonattainment areas into attainment by 2009

EPA’s Evaluation of the Technical Information in New Jersey’s Weight
of Evidence

Summary of EPA’s Technical Findings

Recommendation of Disapproval of Attainment Demonstration

Appendices

Appendix 1.  Summary of Emission Inventory Work from New Jersey’s SIP
Submittal

List of Attachments

Technical Support Document

Modeling for New Jersey’s State Implementation Plan for Ozone

for New Jersey’s Eight-hour Ozone Nonattainment Areas

Purpose of the Technical Support Document

This Technical Support Document (TSD) describes the Environmental
Protection Agency’s (EPA’s) evaluation of New Jersey(s plan to
attain the 1997 eight-hour ozone standard by the ozone season of 2009 in
the Philadelphia-Wilmington-Atlantic City, PA-NJ-DE-MD and the New
York-Northern New Jersey-Long Island, NY-NJ-CT nonattainment areas.

EPA prepares a TSD to provide more detailed information than can be
contained in the official notice published in the Federal Register.
Readers who need more information than we provide in this TSD or want to
review the modeling in more detail should read New Jersey(s State
Implementation Plan for ozone.

Introduction to New Jersey’s State Implementation Plan for Ozone

New Jersey(s State Implementation Plan (SIP) for ozone includes many
elements required by the Clean Air Act (CAA) and EPA’s regulations.
New Jersey’s plan includes attainment demonstrations, reasonable
further progress (RFP) plans for 2008 and 2009, reasonably available
control measures analyses for both areas, contingency measures, on-road
motor vehicle emission budgets, and general conformity emission budgets
for McGuire Air Force Base and Lakehurst Naval Air Station. This SIP
revision was subject to notice and comment by the public and the State
addressed the comments received on the proposed SIPs before adopting the
plans and submitting them for EPA review and approval into the SIP.

This document, and the Federal Register notice it supports, addresses
the portion of New Jersey’s plan that deals with the attainment
demonstration for its ozone nonattainment areas.  Particularly, it
answers the question: are the control measures included in the SIP
sufficient to show attainment of the 0.08 ppm ozone standard before the
attainment deadline of June 2010?

New Jersey’s SIP addresses this question by including strategies the
State plans to apply to reduce ozone-causing emissions for their
portions of the New York City and Philadelphia ozone nonattainment
areas.  The SIP also includes air quality modeling designed to predict
whether the areas will meet the ozone standard by the due date.  This
TSD reviews New Jersey’s ozone reduction plans, which includes
emission controls for its portions of two areas, the Philadelphia
(Philadelphia-Wilmington-Atlantic City, PA-NJ-DE-MD) and New York City
(New York-Northern New Jersey-Long Island, NY-NJ-CT) ozone nonattainment
areas, which EPA classified as moderate ozone nonattainment areas for
the 1997 eight-hour ozone standard.  The TSD reviews New Jersey’s
documentation of modeling that attempts to show attainment of the
eight-hour ozone standard by the 2009 ozone season, the last full ozone
season before the attainment deadline of June 2010.  Other states in the
Philadelphia nonattainment area are Pennsylvania, Maryland and Delaware.
 The other states in the New York City nonattainment area are New York
and Connecticut.  All of the states in the northeastern United States
cooperated via the Ozone Transport Commission’s (OTC’s) Modeling
Committee to prepare the modeling that was performed by the New York
State Department of Environmental Conservation and supporting
organizations.

New Jersey, in its SIP, makes a case that the air quality modeling and
additional information, when taken all together, “indicates that it is
plausible” for both the Philadelphia and New York City ozone
nonattainment areas to reach attainment by the 2010 deadline.  EPA draws
attention to this statement since New Jersey’s technical analysis does
not assert that attainment is likely or that attainment is certain
within some set of parameters.

What Are The Components Of A Modeled Attainment Demonstration?

An Overview of the Modeling Process

EPA guidance recommends that states use the model is a relative sense,
not relying directly on the values the model predicts for 2009, but
using the difference between the base run and the future run of the
model.  The method was labeled “design value rollback” because it
starts with measured ozone data and uses the ozone reduction predicted
by a photochemical grid model to predict future concentrations.  This
methodology, described in the following paragraph, is recommended by
EPA’s modeling guidance and was followed the states as their modeling
system they used to show attainment of the ozone standard.

The OTC Modeling Committee used the Community Multi-scale Air Quality
(CMAQ) model as its photochemical grid model.  The model used
simulations of chemical reactions, emission of ozone precursors and a
sophisticated meteorological model to produce ozone concentrations over
the eastern United States using emissions and weather data for most of
the ozone season of 2002.  The Committee used the CMAQ photochemical
grid model to predict ozone for the attainment year by running the model
again, but this time with emissions estimated for 2009, while continuing
to use the 2002 weather conditions.  The Committee followed EPA’s
guideance by using the 2002 weather conditions so that the results of
changing the emissions would not be obscured by changes in meteorology.
States then calculated the amount that ozone changed between the 2002
and 2009 model runs.  This output is called a relative response factor.
Then the predicted ozone for the attainment year is calculated by
multiplying the base case value (derived from measured ozone data) by
the relative response factor.  If the result 0.08 ppm or less at all
locations, the modeling system will have predicted attainment of the
ozone air quality standard.

The Regulatory Framework

Section 110 (a) (2) (k) of the Clean Air Act requires states to prepare
air quality modeling to show how they will meet ambient air quality
standards.   EPA determined that areas classified as ‘moderate’ or
above must use photochemical grid modeling, or any other analytical
method determined by the Administrator to be at least as effective, as
part of their demonstration of attainment of the ozone health-based
standard by the required attainment date (40 CFR 51.908, published at 70
FR 71612 on November 29, 2005).  In 40 CFR 51.903, published at 69 FR
23951 on April 30, 2004, EPA specified how areas would be classified
with regard to the eight-hour ozone standard set by EPA in 1997.  At 69
FR 23858, on April 30, 2004, EPA followed these procedures and
classified the Philadelphia-Wilmington-Trenton, PA-NJ-DE-MD and New
York-Northern New Jersey-Long Island, NY-NJ-CT ozone nonattainment areas
as moderate, so they must attain the 1997 eight-hour ozone standard by
June 2010.  Since the attainment date is June 2010 for moderate areas,
states must achieve emission reductions by the ozone season of 2009 in
order for ozone concentrations to be reduced to show attainment during
the last complete ozone season before the 2010 deadline.

EPA(s guidance [Guidance on the Use of Models and Other Analyses for
Demonstrating

Attainment of Air Quality Goals for Ozone, PM2.5, and Regional Haze, EPA
-454/B-07-002, April 2007, included in EPA’s rules at 40 CFR Part 51
Appendix W] describes how to use a photochemical grid model and
additional analytical methods to complete a weight of evidence analysis
to estimate if emissions control strategies will lead to attainment of
the eight-hour NAAQS for ozone.

The guidance lists nine steps for preparing modeling to demonstrate
attainment of the ozone standard.

1. Develop a conceptual description of the problem to be addressed.

2. Develop a modeling/analysis protocol.

3. Select an appropriate model to support the demonstration.

4. Select appropriate meteorological time periods to model.

5. Choose an appropriate area to model with appropriate
horizontal/vertical resolution

and establish the initial and boundary conditions that are suitable for
the application.

6. Generate meteorological inputs to the air quality model.

7. Generate emissions inputs to the air quality model.

8. Run the air quality model with basecase emissions and evaluate the
performance.

Perform diagnostic tests to improve the model, as necessary.

9. Perform future year modeling (including additional control
strategies, if necessary) and

apply the attainment test.

Also, the guidance describes how to use these results, including a
weight of evidence analysis, which is a supporting analysis that
determines if the results of the photochemical modeling system are
correctly (or not correctly) predicting future air quality.

How Did New Jersey Address The Components Of A Modeled Attainment
Demonstration?

New Jersey’s plan addresses each of the elements of a modeling
attainment demonstration as follows:

Conceptual description of the problem

A conceptual model describes how weather patterns affect the formation
and transport of ozone, accounting for emissions and photochemistry.
New Jersey’s plan explains how high ozone concentrations occur in New
Jersey.  On warm sunny days, winds from the southwest and west blow
emissions from sources of ozone-forming chemicals both at the surface
and aloft toward New Jersey.  In addition, emissions from large
combustion sources in the Ohio Valley and other areas are brought
eastward by upper level winds to the east coast, augmenting the ozone
formed locally.  New Jersey explains this in Chapter 2 of their SIP.

Modeling/analysis protocol

The Ozone Transport Commission’s (OTC’s) Modeling Committee
developed a protocol for modeling the ozone problem in the northeastern
United States.  New Jersey’s plan includes the modeling protocol as
Appendix D-1.  It was developed with the cooperation of EPA’s air
modeling experts.  It adequately describes the states’ plan to perform
the photochemical grid modeling for use in the ozone attainment plans.

The model used to support the demonstration

New York State Department of Environmental Conservation ran the
Community Multi-scale Air Quality Model (CMAQ) for the states in the
northeast ozone transport region, including New Jersey.  CMAQ is an
acceptable model, listed in the photochemical modeling guidance as a
currently used photochemical grid model.  EPA agrees CMAQ is appropriate
for this modeling demonstration.  The inputs to the model are described
in Section 5.2.2.

Meteorological time periods used in the modeling

Section <IP_ADDRESS>.1 of New Jersey’s SIP notes that the OTC Modeling
Committee agreed to model the entire ozone season of 2002.  Using the
entire ozone season of 2002 covers many different kinds of ozone
episodes and exceeds EPA’s recommendations for episode selection.
2002 was a good year to model because it was the base year for the
attainment plans and is representative of typical ozone seasons.

Domain of the model, horizontal/vertical resolution and the initial and
boundary conditions

The model domain extends from Maine to Florida to the Mississippi River,
including the emission sources that affect ozone formation in the
northeastern United States.  Over the northeastern United States, the
model used grid cells 12 kilometers on each side in the northeastern
United States, including the nonattainment areas affected by New Jersey.
 The OTC Modeling Committee used a 12-kilometer grid size for the areas
in and near its states to provide fine resolution in the northeast to
make detailed predictions of ozone concentrations.  The OTC Modeling
Committee believed that based on its states’ experiences with the
one-hour ozone attainment modeling, modeling at finer resolutions would
be slow and not any more accurate that the 12 kilometer resolution in
the model.  Outside the local area, the resolution was 36 kilometers.
This was acceptable to EPA.

Vertical resolution is the number of layers and the size of each layer
in the model.  The layers in the photochemical grid model were set up to
be compatible with the model that produced weather conditions for the
photochemical grid model.  EPA believes that the vertical resolution
adequately represented the atmosphere where ozone forms and is
transported.  The model’s boundaries are out the in the Atlantic Ocean
on the east and the Mississippi River region to the west.  Even this
boundary is defined by a larger photochemical model the covered much of
North America.  EPA believes that the boundaries are unlikely to have a
negative effect on the modeling results.  The resolution of the model is
described in New Jersey SIP Sections <IP_ADDRESS>.3 and 4.  The domain is
described in <IP_ADDRESS>.2.  How the Modeling Committee provided boundary
conditions for the model is explained at <IP_ADDRESS>.5.

Meteorological data used in the air quality model

The OTC Modeling Committee decided to use a computer model that provided
a life-like simulation of weather conditions for the photochemical grid
model to use.  The model was the Pennsylvania State University/National
Center for Atmospheric Research Mesoscale Meteorological Model (MM5)
version 3.6.  Testing demonstrated that this model provided a reasonable
representation of weather conditions at the surface and aloft.  New
Jersey’s SIP summarizes this process at section <IP_ADDRESS>.

Emissions used in the air quality model

States across the eastern United States provided emissions information
from their sources to be used in the model.  MARAMA collected, quality
assured the emissions data and used a computer program to process these
data for the photochemical grid model to use.  Data from outside the
northeast was obtained from other regional planning organizations.  New
Jersey’s SIP summarizes this process at section <IP_ADDRESS>.

Model base case run and performance evaluation

The performance of the CMAQ photochemical grid model in predicting
ozone, and the chemicals that form ozone, met EPA’s guidelines for
model performance.  The model outputs are generally consistent from day
to day, with low bias and error.  The OTC Modeling Committee noted that
the CMAQ photochemical grid model tended to overpredict low
concentrations and slightly underpredict peak concentrations.  The
Modeling Committee accepted the performance of CMAQ and EPA believes the
model performed well.  New Jersey’s SIP summarizies this process at
section <IP_ADDRESS>.

Future year (2009 control case) modeling for the attainment year and the
attainment test

The photochemical grid model used with projected emissions for 2009,
including emission changes due to regulations the states are planning to
implement and expected growth by the 2009 ozone season.

See Table 5.2 in New Jersey’s SIP listing the emission controls
included in the modeling by New Jersey and other states in the ozone
transport region.

The photochemical grid model used weather conditions from 2002, the same
as the base case modeling.  Day to day weather in 2009 is unknown years
in advance.  Using the base case weather information allows us to see
the effects of changes in states’ emissions, without being complicated
by changes in weather from year to year.

For the attainment test, the states used the results from the
photochemical grid model in a relative sense, that is, by calculating
the difference from ozone predicted in 2002 to ozone predicted with
emission controls New Jersey and other states planned to have in place
in 2009.  When the difference in ozone from 2002 to 2009 is subtracted
from the baseline air quality data centered in the base year of 2002,
the resulting 2009 ozone prediction should be less than 85 ppb at all
monitoring stations to meet the attainment test.  The state calculated
that in 2009, ozone will not meet the attainment test, since design
values are projected to be over the 84 ppb standard in the nonattainment
areas that New Jersey is part of.

Are the results of the photochemical modeling system correctly
predicting future air quality?

Based on the air quality modeling alone, the
Philadelphia-Wilmington-Trenton, PA-NJ-DE-MD and New York-Northern New
Jersey-Long Island, NY-NJ-CT nonattainment areas will not attain the
ozone standard by the 2009 ozone season.  EPA’s photochemical modeling
guidance requires a weight of evidence determination if the supporting
analyses determine that the results of the modeling are not correctly
predicting future air quality.  New Jersey’s supporting analyses
conclude that there is evidence that New Jersey’s nonattainment areas
may attain the standard by the attainment deadline.

EPA has reviewed the information provided by New Jersey – the
photochemical grid modeling, supplemental analyses, and its weight of
evidence analysis – as well as additional scientific data and recent
air quality data to determine if the model has correctly predicted that
New Jersey’s ozone nonattainment areas will not attain the eight-hour
ozone standard.  EPA’s evaluates this information later in this TSD.

Summary of Photochemical Grid Modeling Results

In summary, the basic photochemical grid modeling used by New Jersey in
its SIP meets EPA’s guidelines, and when the modeling system applies
the methods recommended in EPA’s modeling guidance, it is acceptable
to EPA.  When New Jersey uses the EPA’s methods, the modeling system
predicts that, for the attainment year, ozone would be 92 ppb in the
Philadelphia-Wilmington-Atlantic City, PA-NJ-DE-MD and 90 ppb in the New
York-Northern New Jersey-Long Island, NY-NJ-CT ozone nonattainment
areas.  Thus, New Jersey is not expected to reach attainment of the
ozone standard in the 2009 attainment year with the emission reduction
strategies committed to by the OTC states and included in the
photochemical grid modeling.

How Did New Jersey Describe Its Attainment Demonstration And What Were
Its Conclusions?

In New Jersey’s SIP, Table ES.1 (summarized in Table 1 below),
provides the results of New Jersey’s analyses of attainment of the
ozone standard.  New Jersey characterizes its attainment demonstration
plan in these words:  “Table ES.1 presents the results for the two
controlling monitors in the multi-state nonattainment areas associated
with New Jersey. The results indicated that it is plausible for both
areas to reach attainment by June 15, 2010.”  New Jersey has submitted
an attainment plan that they claim is “plausible”, but the State
does not have enough faith in the analysis to claim a stronger degree of
certainty.

Table 1:  Ozone Design Values in the New Jersey (NJ) SIP for the
Attainment Year

Site Name, County and State	Photochemical Grid Modeling Result
Alternative Baseline and Maximum Reduction

(Approach 1)	Adjusted for Transport (Approach 2)	NJ’s Estimate of
Additional Ozone Reduction due to Emissions Quantified but not Included
in the Modeling	NJ’s Estimate of Additional Ozone Reduction due to
Emissions not Quantified and not Included in the Modeling

Stratford, Fairfield Co., CT

90 ppb

83 ppb

85 ppb

-0.2 to -2 ppb

-1 to -3 ppb

Colliers Mills, Ocean Co., NJ

92 ppb

86 ppb

85 ppb

-0.3 to -4 ppb

-1 to -3 ppb

NOTES for Table 1:

The information in Table 1 is condensed from New Jersey’s SIP - Table
ES.1 and Sections <IP_ADDRESS> and 5.4.5.

Attainment of the ozone standard is 84 ppb or less.

Stratford, in Fairfield Co., CT, is the site with the highest ozone
design value predicted by the modeling system for the New York-Northern
New Jersey-Long Island, NY-NJ-CT ozone nonattainment area.

Colliers Mills, in Ocean Co., NJ, is the site with the highest ozone
design value predicted by the modeling system for the
Philadelphia-Wilmington-Atlantic City, PA-NJ-DE-MD ozone nonattainment
area.

New Jersey’s SIP shows the projected ozone air quality design values
for all the sites in these nonattainment areas.  All sites in a
nonattainment area must attain in the attainment year for the SIP to
demonstrate attainment.  If the highest site in an area listed in Table
1 does not attain, attainment is not demonstrated for that area.  Thus,
this TSD only lists the highest sites for each of New Jersey’s
nonattainment areas.

EPA’s Objective in Reviewing New Jersey’s Attainment Demonstration

New Jersey’s SIP includes data and scientific research primarily
focusing on how the photochemical model may have flaws that would lead
to the erroneous conclusion that the nonattainment areas, including New
Jersey, would not attain in 2009.  In particular, EPA’s modelers have
reviewed New Jersey’s attainment demonstration including the
supplementary data and research studies.  EPA needed to determine if the
additional information provided by New Jersey is an acceptable
supplement to the photochemical grid modeling and can be approved by EPA
to meet the Clean Air Act requirement as “...any other analytical
method determined ...to be at least as effective” to supplement the
photochemical grid modeling.  EPA has evaluated the information provided
by the State and other information relevant to whether or not New
Jersey’s ozone nonattainment areas will attain the ozone standard by
the attainment year and concludes that New Jersey has not made a
conclusive case that it will attain the ozone standard by the attainment
year for the nonattainment areas it shares with its neighboring states.
We discuss the details of New Jersey’s analyses and EPA’s
conclusions in the sections that follow.

What Are the Elements of New Jersey’s Attainment Demonstration?

Overview

New Jersey’s SIP attempts to demonstrate attainment by adjusting the
results of the modeling system and adding the estimated effects of
emission controls not included in the photochemical grid modeling.  As
seen in Table 1, New Jersey cannot show attainment of the ozone standard
unless it combines the effects of adjusting the model plus the
anticipated impact of additional measures.

New Jersey adjusts the results of the modeling guideline methods because
of the model’s purported lack of response to emission reductions.  New
Jersey’s weight of evidence assessment considers two approaches to
“adjust” the photochemical model predictions for the attainment
year.  One approach results in neither of the two nonattainment areas in
which New Jersey is located attaining the standard in the attainment
year based on modeling alone.  The second approach results in only the
New York-Northern New Jersey-Long Island, NY-NJ-CT nonattainment area
attaining the standard in 2009 based on adjusted photochemical modeling
predictions.

Table 2.  Schematic of New Jersey’s (NJ’s) Attainment Demonstration

NJ’s Steps to Calculate Attainment Year Ozone 	EPA’s Guideline
Method	NJ’s SIP Approach #1-Design Value and Reduction Factor
Adjustments 	NJ’s SIP Approach #2-

Adjustment for Lack of Transported Reduction in Ozone

Base Case Concentration	Average of three years’ design values:
2002,03, 04	Average of five years’ 4th highest annual ozone:
2000,01,02,03,04	No adjustment to EPA guidance method for base year
concentrations

Reduction Factor Calculated from Photochemical Grid Modeling Results	For
each monitoring sites, average ozone reduction around each monitoring
site	For all monitoring sites, use ozone reduction from the monitoring
site with the largest reduction in ozone	Increase reduction in ozone to
account for the photochemical grid model’s lack of ability to give
full ozone reduction from reduced transport of ozone and precursors

Additional Measures – Not Modeled but Quantifiable

Estimate additional ozone reductions by extrapolating from modeled
results

Additional Measures – Not Modeled and Unquantifiable

Estimate additional ozone reductions by using modeled results from
reduction in mobile source emissions

Design Value Adjustment:

New Jersey’s SIP uses average of five years’ 4th highest annual
ozone centered on 2002

EPA defines the 8-hour ozone design value as the 3-year average of the
fourth highest

monitored daily 8-hour maximum value at each monitoring site.  The
standard is met if the design value is <0.08 ppm (in practice, this
translates to 84 ppb as the tenths of a ppb are truncated).  The
detailed description of the methodology can be found in 40 CFR Part
50.10, and Appendix I to Part 50.

EPA’s modeling guidance recommends that states use the model in a
relative sense.  Rather than taking the ozone concentrations that the
photochemical grid model predicted when run with 2009 emissions, EPA
recommends that states calculate difference between the base case and
future case values predicted by the model to get a ration of future to
base ozone concentrations.  In order to predict a future design value to
compare with EPA’s air quality standard, EPA recommends using the
average of the three design value periods, which includes the baseline
inventory year, as the baseline value.

For example, for the 2002 base year, the recommended approach would
average the design values from 2002, 2003 and 2004.  This means the
following list of 4th highest ozone days would be averaged from each of
the following years:

2002 design value:  2000, 2001, 2002

2003 design value:            2001, 2002, 2003

2004 design value:                      2002, 2003, 2004

So the base year’s ozone is used three times, the year before and
after the base year is used twice each and the year two years before and
after the base year used once each.

The modeling guideline notes other methods that were considered as the
recommended method:

1) The designation design value period (one example is the 2002 design
value);

2) The design value period that straddles the baseline inventory year
(in this case, 2003 design value which uses the years 2001, 2002 and
2003 surrounding the 2002 baseline inventory year).

3) The highest (of the three) design value periods which include the
baseline inventory year (in this case, the highest of the 2000-2002,
2001-2003, and 2002-2004 design value periods for a 2002 baseline
inventory year).

EPA chose the average of the three design value periods as more stable
and more representative of the meteorology and emissions of the 2002
emissions baseline year.

New Jersey chose to use another method, a five year, unweighted average
centered on 2002.  This number is the average of the fourth highest
ozone from the years 2000, 2001, 2002, 2003 and 2004.  EPA did not
recommend this method.  New Jersey’s method gives equal weight to the
2004 ozone season, two years after the ozone measures in the SIP start
to take effect and a relatively cool summer.  In 2004, the New Jersey
– New York area had the fewest number of days with eight-hour ozone 85
ppb or more over the period 1980 to 2007.  According to the National
Climatic Data Center, the summer of 2004 was ranked as the 20th coolest
of the last 110 years in the Northeast.  The Midwest, upwind from the
northeast and a significant source of ozone precursors, was ranked 5th
coolest.  2004 was significantly cooler than normal, which means 2004
was not typical according to the conceptual model described in the SIP.
With a much cooler-than-usual summer limiting ozone formation, plus
sharply lower concentrations due to implementation of the NOx SIP Call,
including 2004 in a precontrol strategy baseline biases any averaging
method that includes it equally with other years.  The TSD will describe
later how the extraordinary decrease in ozone in 2004 is not confirmed
in following years, when ozone design values increased while emissions
did not increase.

The SIP notes that New Jersey’s method could produce higher or lower
values than the method in EPA’s modeling guideline.  However, for this
SIP, it produces a lower value.  There are other ways of calculating a
baseline value that the State did not evaluate.  For example, here are
various results from other methods that could be used to calculate a
2002 baseline ozone concentration for the peak ozone site of the
Philadelphia-Wilmington -Atlantic City, PA-NJ-DE-MD nonattainment area
at Colliers Mills, New Jersey:

the EPA guideline method baseline is 105.7 ppb;

	the New Jersey alternative baseline is 104 ppb;

	the 2002 design value is 112 ppb; and

the 2003 designation design value, centered on 2002, is 106 ppb.

Methods equally as reasonable as New Jersey’s method give baseline
values the same as EPA’s recommended method or even higher.  The
baseline value calculated using EPA’s recommended method is well
within the range of values calculated by other methods, so using EPA’s
recommended method is reasonable and does not produce an anomalous
value.  Using New Jersey’s lower value will naturally lead to a lower
predicted future design value, which would be closer to attainment than
if the EPA method was used.  Since a weight of evidence analysis must
properly balance all of the evidence, using only a method that gives the
most favorable answer for attaining the ozone standard, without
evaluating other alternatives, is not acceptable to EPA.

Adjustment of Modeled Reduction Factors:

New Jersey’s SIP uses ozone reduction from the monitoring site with
the greatest reduction in ozone for all monitoring sites

New Jersey calculated 2009 modeled ozone design values by multiplying
the modeling baseline design values with a relative response factor
(RRF) as recommended by EPA’s photochemical modeling guidance.  In the
standard EPA method, at each monitoring site, the state calculates the
RRF associated with days with high eight-hour ozone concentration in the
nine grid cells nearest with the monitoring site on high ozone days.
The lower the RRF number, the larger the decrease in ozone between the
base and future years.  Thus, ozone will be lower in future years when
lower RRFs are used.  The attainment demonstration skews the modeled
results by applying the lowest RRF calculated by the model at any of the
monitoring sites to every monitoring site in an attempt to compensate
for what New Jersey believes to be the model’s underestimation of the
improvement in air quality.

So, New Jersey’s SIP uses the largest amount of ozone decrease for the
change in emissions.  EPA is more likely to approve an alternative
method if it is justified using supporting technical information that
explains why an alternative method better describes how the model
responds to emission changes.  New Jersey has not described why the
largest reduction in ozone in nonattainment area, which gives the lowest
future ozone prediction, is appropriate for every monitor, except to say
that it might compensate for the model’s lack of responsiveness.  The
SIP does not provide a good description of how the amount of its
adjustment is linked to the magnitude of any lack of responsiveness by
the photochemical grid model.

Using the reduction factor from the area around each monitor, as per
EPA’s recommendation, is more likely to be representative of ozone
response in that area.  In addition, there are several alternative
answers that may be just as appropriate and, objectively, are equally
likely.  If the SIP used the highest RRF for every monitor, the
predicted 2009 ozone concentration would be higher and further from
attainment than New Jersey’s method, and further from attainment than
the EPA modeling guidance method.  Lacking a good reason why this
best-case reduction in ozone is appropriate everywhere, EPA will not
approve using New Jersey’s one-sided adjustment to the EPA recommended
method for predicting air quality in 2009.

New Jersey’s SIP’s Technical Justification for Adjusting Modeling
Results:  2006 Air Quality Data are Near the Predicted Concentration for
2009

New Jersey compares photochemical grid modeling results with monitored
air quality data to make its case that actual ozone in 2009 will be
lower then predicted by photochemical grid modeling results using
EPA’s guideline methods.  More specifically, New Jersey claims the
photochemical grid modeling does not give enough credit for reductions
in ozone and its precursors from areas upwind of the northeastern United
States.  New Jersey uses information comparing the modeling simulations
with observed data from special studies conducted during the 2002 base
year and compared 2006 observed air quality to show that the modeling
system predictions of ozone for 2009 are not far from existing air
quality data.   The argument continues that if the ozone data in 2006
are nearly at the concentrations the model predicts for 2009, the
additional emissions controls between 2006 and 2009 will reduce ozone to
even less than predicted by the model in 2009, thus increasing the
chances for attainment by 2009.  However, these arguments fail for
several reasons.  First, more recent air quality data since 2006 does
not support New Jersey’s argument, as New Jersey’s nonattainment
areas are not close to attaining the standard as the attainment year
approaches.  Second, close examination of the model’s output reveals
that the photochemical grid model may overpredict the impact of local
controls, which New Jersey does not account for in its analysis.  Third,
the argument assumes that emissions will continue to decrease and
decrease so much that the 6 to 8 ppb gap between the model-predicted
ozone in the attainment year and the ozone standard will be eliminated.

New Jersey’s SIP’s Technical Justification for Adjusting Modeling
Results:  Comparison of the Modeling Simulation with Special Study Data

To make the case that the individual modeling days do not compare well
with actual ambient data on the same days, New Jersey cites University
of Maryland studies that compare the performance of the CMAQ
photochemical grid modeling with measurements from aircraft flights and
surface monitors.

The University of Maryland reported a wide range of differences between
the model predictions and aircraft data among the various flights.
Overall, the analysis suggests that CMAQ overestimates ozone in the
lowest layers by about 15 percent and underestimates ozone aloft by
about 10 percent.  This finding leads New Jersey to the conclusion that
CMAQ underestimates ozone transport aloft, which implies that reductions
in long-range transport of ozone will not be fully predicted by the
model.

Another University of Maryland analysis in New Jersey’s SIP compared
surface ozone measurements with ozone modeled by CMAQ.  Surface ozone
was well correlated the model’s predictions, but the modeled results
were 7 to 8 ppb lower than the observed data.  This bias was most
pronounced in rural areas where transport may have a greater effect on
surface ozone concentrations, but little bias was observed in urban
areas.  If the photochemical grid model is underpredicting transported
ozone, but has little bias in urban areas, then the model must be
compensating for the lack of tranported ozone by overpredicting ozone
from local sources.  The University of Maryland study cited by New
Jersey agrees, suggesting that these data also show that the influence
of local control measures are overpredicted.

If the photochemical grid model results are overly sensitive to local
controls, this creates several problems for New Jersey’s analysis.
First, the SIP adjusts the photochemical grid modeling results for a
lack of effect of transported pollutants aloft, but does not adjust for
the compensating oversensitivity to local emission reductions.  This
means that New Jersey’s adjustment is one-sided, only adjusting when
the model is not sensitive enough to emission controls but not adjusting
when the model is oversensitive to emission reductions.  Therefore, the
SIP’s adjusted ozone prediction for 2009 is biased low, biased toward
proving the area will attain the ozone standard.

Also, most of the measures that led to reductions in transported ozone
from distant sources are already in place by 2007 and the remaining
measures in New Jersey’s SIP are local reductions.   While the
upcoming local measures will reduce ozone, the modeling has already
taken them into account and, perhaps, overpredicted the amount of impact
they will have on reducing ozone.  In addition, while this document
discusses recent air quality data in another section, any
underestimation of effect of changes in transport reduction will not
help close the gap between 2007’s air quality and the ozone attainment
year of 2009, since there are few reductions in transported ozone
expected from distant sources between now and the attainment year.
Almost all of the emission reductions in the next few years will be in
the local area and any additional measures the State may implement will
also not be part of the reduction in transported pollutants.

In summary, New Jersey’s main argument is that an underestimation of
transport in the photochemical grid model leads to the model being less
responsive than it should be to change in emissions, and therefore
overestimates future year ozone.  But the studies they cite note that
the model probably overemphasizes the local controls.  Combined with the
observation that the model has little bias in urban areas, it is likely
there are compensating errors in the modeling system.  So, the benefits
of upwind controls are underestimated and the benefits of local controls
are overestimated, and New Jersey only adjusts for the underestimating
of upwind controls.

In any case, New Jersey’s conclusion is only a possible explanation.
Despite these results, New Jersey did not rerun the photochemical grid
model to determine the response of the model to local vs. upwind
controls (and controls from low-level sources vs. controls on sources
that put pollutants into upper layers of the model).  They have not
shown that the model response to local controls was reasonable, but make
not adjustments for a likely overreaction to local controls.  No new
modeling was done with modifications designed to improve the
photochemical grid model’s simulation of transported ozone and
precursors.  They did not use an alternative chemical system to
determine if the model could more simulate more completely the reactions
of ozone precursors emitted from distant sources.  Thus, the SIP can
only speculate on what effects these differences between observed and
predicted ozone have on the ability of states to judge how effective
their emission control plans will be.

New Jersey’s SIP’s Technical Justification for Adjusting Modeling
Results:  Comparison of the Modeling Simulation with Recent Ambient Air
Quality Data

In a supporting line of argument, New Jersey compares 2009 design values
predicted by the photochemical grid model using EPA’s modeling
guidelines methods and actual measured 2004-2006 design values at
certain sites.  New Jersey uses the results of these comparisons to
support its contention that the air quality in 2009 will be better than
predicted by the photochemical grid model using EPA’s guidance
recommendations.  Additional data from 2007 should support New
Jersey’s conclusion, but it does not.

New Jersey did not have access to data from 2007 when it wrote its SIP.
However, even at that time, information was available that showed a
comparison between a 2006 design value with modeled 2009 results was
biased toward an optimistic result because 2004 was a much cooler than
normal summer.  Data from 2005 and 2006 showed that the number of 4th
high values over the ozone standard were much higher in 2005 and 2006
than 2004’s in both the Philadelphia and New York City nonattainment
areas.  (See figure below.)  We also know, based on the new 2005-2007
design values, that the 2004-2006 design values were biased low due to
the extremely low values measured in 2004, due to weather conditions in
2004 explained earlier in this document.

Based on all of the evidence, there is very little justification for a
downward adjustment.  Based on the 2005-2007 ambient data, the modeled
2009 values now appear to be either reasonable or maybe even too low.
The model predicted value of 91 ppb at Colliers Mills is right in line
with the 05-07 observed value of 92 ppb.  New Jersey SIP included an
example of how to apply an adjustment for transport at the Fair Hill,
Maryland site, also in the Philadelphia ozone nonattainment area.  The
model predicted 81 ppb in 2009 at Fair Hill, which is well below the
2005-2007 design value of 93 ppb.  The adjusted value for Fair Hill in
the attainment year is 72 ppb, almost twenty parts per billion lower
than the present design value, and thus it is an unreasonably low
prediction, making it unlikely that this method of adjustment corrects
the modeling system’s results in an appropriate fashion.

New Jersey’s SIP’s Technical Justification for Adjusting Modeling
Results:

Blackout Studies

New Jersey’s SIP cites studies by the University of Maryland to
support its argument that the CMAQ photochemical grid model has
underpredicted the decrease in ozone due to a lack of sensitivity to
reductions in ozone transported from the Midwest.  Measured changes in
ozone at Selinsgrove PA during the August 14, 2003 blackout are used to
argue that CMAQ does not respond adequately to upwind emissions
reductions.  In order to determine what ozone should have been if the
blackout had not occurred,  the University of Maryland paper compared
ozone with meteorologically similar days in the past and predicts that
ozone should have been reduced by twice as much as the amount predicted
by photochemical grid modeling done by Georgia Tech (Hu, 2006) for the
blackout day.

EPA understands that comparing different days with similar weather
conditions is only an approximation as no two weather patterns are
exactly alike.  However, the weather on the days used to compare with
the blackout day was significantly different because the air on the
blackout day was mostly from Western New York and Northern Ontario, as
opposed to from the Northern Ohio and Western Pennsylvania on the
comparison days.  The reduction in ozone on the blackout day would be
less than if the blackout occurred on the comparison days since the
blackout day’s emissions came from an area with less emissions than
the comparison days.  For these reasons, and others discussed in the
Georgia Tech paper, the modeling may not be wrong when it predicts only
a 2.2 ppb decrease in ozone on the blackout day in the area upwind of
the northeast corridor’s ozone nonattainment areas.  Also, the studies
compared the model with observations in central Pennsylvania, not the
northeast corridor.  Central Pennsylvania is not representative of ozone
impacting the urban areas of the northeast corridor, where mobile source
NOx emissions are more important, emissions that were not affected as
much during the blackout.

A recent study by Hogrefe (2008), concludes that changes in modeled
ozone due to changes in emissions are on the same order as changes due
to imprecision in the emission inventories.  The reduction in ozone over
time is not larger than changes due to alternative ways of calculating
the base case design value used as a starting point.  The implication
for ozone attainment demonstrations is that changes in base year design
values may have a larger impact on reaching ozone attainment than
changes in the photochemical grid model.  An attainment demonstration
should not adjust its base case design value without very compelling
reasons.

A very recent paper by Gilliland (2008) compared modeled change in ozone
from 2002 to 2005 with changes in monitored values.  Reductions in
modeled ozone for the highest five percent of all ozone values were
about 40 percent less than the reduction in monitored ozone
concentrations.  This study provides support for the states’
contention that the model does not reduce ozone as much as occurs in
reality.  Further study is needed to determine if these conclusions are
confirmed for peak ozone monitors in New Jersey’s nonattainment areas.
 Present air quality is reviewed later in this document, but ozone air
quality in recent years should be much lower if the model was incorrect
by 40 percent.  If the results of Gilliland were applied directly to the
states’ analysis, ozone in 2009 would be predicted to be around 85
ppb, which is much lower than present air quality levels in New
Jersey’s nonattainment areas.  The difference between the implications
of Gilliland (2008) and the actual air quality to date, does not support
the states’ contention that model’s results should be adjusted to
produce lower ozone in the attainment year.

EPA’s Additional Analyses of Ambient Data

New Jersey compares its 2009 modeled design values, calculated using
EPA’s recommended methods, to 2006 monitored ozone concentrations from
the highest reading monitors in 2002.  The 2006 monitored 8-hour ozone
design values for the controlling monitors in both of the nonattainment
areas associated with New Jersey decreased between 2002, the baseline
year for the SIP, and 2006.  The SIP notes the 2006 monitored design
values were only 1 to 2 ppb higher than that modeled for 2009.

Recent monitored design values compared to the photochemical grid
model’s estimate of 2009’s design value when computed following
EPA’s guidance

Nonattainment Area	Design Value

2002	Design Value

2003	Design Value

2004	Design Value

2005	Design Value

2006	Design Value

2007	Design Value 2008 *	Predicted by model for 2009

New York City	101	102	95	91	92	93	89 or 90	90

Philadelphia	112	105	99	94	93	93	92	92

Design value uses ozone from these years:

2000

2001

2002

2001

2002

2003

2002

2003

2004

2003

2004

2005

2004

2005

2006

2005

2006

2007

2006

2007

2008

	Design value units are in ppb.

Attainment occurs when all of the monitoring sites in a nonattainment
area have design values less than 85 ppb.

The design value for a nonattainment area is the highest of the design
values from all of the monitoring sites in the nonattainment area.  Each
sites’ design value is the average of the fourth highest eight-hour
daily ozone for the last three years.

*  Date from preliminary state reports collected October 2008.  Subject
to change.  Possible changes in data at a peak site in Connecticut may
produce a design value in 2008 of 89ppb.

These data show that ozone design values have decreased sharply from the
baseyear of 2002.  EPA’s study of the effect of the NOx SIP Call has
documented the ramifications of the NOx SIP Call reductions across the
eastern United States and that these reductions were mostly in place by
the 2004 ozone season.  The NOx SIP Call and local SIP reductions are
responsible for the step-like decrease in ozone design values from 2002
though 2004.

Since 2004, design values have not continued to decrease as sharply for
several reasons.  First, the 2004 ozone season was cooler than normal,
so the decreases in ozone due to additional controls have been offset
somewhat by higher concentrations in recent years as the areas have
returned to more typical summertime conditions.  Overall, design values
since 2005 have continued to remain much lower than before 2004, even
2007’s design value, which does include data from 2004.  Second,
currently, the rate of reduction in ozone and precursors transported
from the Midwest is not as large as the decreases that occurred while
the NOx SIP Call was implemented.  Even if EPA’s Clean Air
Implementation Rule is implemented, most of the ozone season reductions
due to CAIR are not likely to be implemented until after 2009.  Any
additional reductions in ozone in the 2008 and 2009 ozone seasons will
be limited to local controls in each nonattainment area and a few
reductions in major sources due to States’ initiatives in the Ozone
Transport Region.  While these reductions are worthwhile, they are not a
large as the reductions that occurred from sources across the entire
eastern United States during the implementation of the NOx SIP Call.

While the observed design values for 2007 (the last year of certified
data) are only 1 to 3 ppb higher than the model-predicted value for
2009, an ozone reduction of 9 ppb would be needed to reduce design
values to attainment by 2009.  Unless emission reductions were to match,
or be more effective than, the reductions from 2002 to 2007 when ozone
decreased by up to 10 ppb, New Jersey’s nonattainment areas will not
reach attainment by the 2009 ozone season.  Even if local controls in
2008 and 2009 could reduce emissions by the amount of local reductions
observed during the NOx SIP Call implementation years, comparable
reductions in ozone needed to attain the standard in 2009 will not
happen since the present ozone trends will be not be assisted by the
large reductions in transported ozone and precursors that occurred
before 2005.

Additional reductions - What measures can New Jersey use to predict
reductions in ozone?

Appendix 2 to this Technical Support Document and the technical support
document for other EPA proposed actions on this SIP list the various
measures New Jersey has proposed and discuss if they can be accepted by
EPA as part of New Jersey’s SIP.  EPA is concerned about whether
emissions reductions that New Jersey uses as part of its attainment
demonstration will be in place before the 2009 ozone season.  First, New
Jersey has not adopted and implemented all the control measures that
were included in the 2009 modeling run.  (Listed in Appendix 2, from
Table 5.1 in New Jersey’s SIP.)  If these measures are not implemented
by the beginning of the 2009 ozone season, New Jersey’s SIP will have
an additional shortfall.  Other states that contribute to ozone in New
Jersey’s nonattainment areas must also adopt and implement all the
control measures they included in the 2009 modeling run.

New Jersey’s “Additional Quantifiable Measures” are used for
attainment, RFP, or Contingency purposes, but these have not all been
adopted yet and were not formally committed to in New Jersey’s plan.
(See Appendix 2, from Table 5.11 in New Jersey’s SIP.)    The
“Non-quantifiable strategies” are being implemented throughout New
Jersey primarily for other objectives, but will have air quality
benefits. (These measures are listed in Appendix 2 from New Jersey’s
SIP at section 5.4.5 .)    EPA’s modeling guidance allows the state to
include the likely effects of these measures (as well as the other
measures New Jersey did not formally commit to) in the Weight of
Evidence analysis.  EPA’s Federal Register notice describes EPA’s
determination of whether these “additional” control strategies can
be counted by EPA as creditable toward attaining the ozone standard in
an attainment demonstration, especially since New Jersey explicitly
excludes them from their attainment demonstration,

The lack of a firm commitment and realistic schedule by New Jersey for
these measures makes it less likely they will be adopted and fully
effective by the 2009 ozone season.  Not being able to quantify these
measures also reduces EPA’s confidence in how much effect they will
have on reducing ozone.  EPA can accept non-quantified measures as part
of a state’s weight of evidence analysis, but since the basic
attainment demonstration modeling does not come close to attaining the
standard, EPA cannot agree that these measures will bring New Jersey’s
SIP the rest of the way to attainment by 2009.

Assessing the possibility that New Jersey’s additional reductions
could bring its nonattainment areas into attainment by 2009

New Jersey’s weight of evidence analysis attempts to quantify some
emission reductions not included in the modeling.  There are two kinds
of additional reductions:  reductions that New Jersey can quantify that
were not included in the photochemical grid modeling (Table 5.11 in the
SIP) and other reductions that are harder to quantify (Listed in Section
5.4.5 of the SIP) that were also not included in the photochemical grid
modeling.  The most effective way to predict changes in ozone is through
air quality modeling; however, New Jersey did not perform additional
modeling for these additional measures.

New Jersey’s SIP projects the effect of these measures by two methods:
 extrapolation in the case of quantified emission reductions and by
using data from earlier, modeled sensitivity studies of mobile source
controls in the case of the unquantified emission reductions.

For the quantifiable measures, the State uses extrapolation of the
photochemical modeling results to predict that additional measures will
reduce ozone by 0.3 to 4 ppb in the Philadelphia-Wilmington-Atlantic
City, PA-NJ-DE-MD area and 0.2 to 2 ppb in the New York-Northern New
Jersey-Long Island, NY-NJ-CT area.   To extrapolate the photochemical
modeling results, New Jersey uses a method published by EPA for analysis
of additional measures needed to attain the one-hour ozone standard
(Guidance for Improving Weight of Evidence Through Identification of
Additional Emission Reductions, Not Modeled.  EPA, November 1999).
Depending on the relative effectiveness of reducing ozone by volatile
organic compounds and nitrogen oxides, the estimates produced by this
method have a significant range, as noted by New Jersey.

For harder to quantify measures, New Jersey notes that when the State of
Maryland modeled reduced auto emissions from decreased auto use from
telecommute programs, reductions similar to those measures proposed by
New Jersey as unquantifiable, modeled ozone decreased by 1 to 3 ppb.
Maryland modeled the emission reductions that would occur if forty
percent of all drivers decided not to drive to work on high ozone days;
the model predicted ozone would be reduced by 1 to 3 ppb.  If we need a
forty percent reduction in light duty vehicle emissions across three
nonattainment areas to get a 2 ppb reduction in ozone, then these harder
to quantify measures, which do not appear to exceed the emission
reductions Maryland modeled, are unlikely to produce the 6 to 8 ppb
reduction New Jersey needs to attain the ozone standard.

The additional strategies proposed by New Jersey, both the quantifiable
and the unquantifiable, are not large enough to reduce emissions by the
equivalent of a forty percent reduction in motor vehicle use.
Consequently, it is unlikely that New Jersey’s additional measures
will reduce ozone by more than a few ppb, and certainly not by the 5 to
7 ppb suggested by adding together the upper end of the estimates in New
Jersey’s SIP.

We can also get an idea as to the effectiveness of additional emission
reductions from modeling New York did additional modeling using 2012
emissions.  New York modeled the improvement in ozone if emissions were
reduced to amounts predicted to be obtained by 2012.  For the New York
City nonattainment area, from 2009 to 2012, emissions decreased by
152.95 tons per day of NOx, 97.30 tons per day of VOCs.  The
photochemical grid model used for the attainment demonstrations predicts
a 4.1 ppb decrease in ozone from these emission changes.

An EPA spreadsheet “NJ Areas Summary Information-v16” with emissions
information in “Summary Information R2”, (attached to this
document), using information from SIPs developed for New Jersey’s two
nonattainment areas calculates an additional 35 tons per day  reduction
in NOx for the New York area and 27 to 33 tons per day of NOx for the
Philadelphia area with these additional measures.  These amounts are
well below the amount of emission reductions that only get 4.1 ppb in
the New York State modeling.  4.1 ppb is not enough to cover the 6 to 8
ppb difference between the results of the photochemical grid modeling
using EPA’s guideline results and the ozone standard.

These results are in line with the discussion in EPA’s guidance on
photochemical grid modeling.  The guidance notes that, in most cases,
considerable amounts of precursor control (e.g., 20-25 percent or more)
would be needed to lower projected ozone design values even by 3 ppb, it
is unlikely that an additional reduction of these unmodeled measures
would produce the 6 to 8 ppb reduction needed to reach attainment using
the 2009 modeling.

While the impact of these measures may be difficult to quantify, EPA
encourages New Jersey to implement all of its planned measures as soon
as possible.  Any measures that reduce emissions that cause ozone
pollution, even if New Jersey did not commit to them, will help New
Jersey’s nonattainment areas meet the Clean Air Act’s requirement in
section 172 (c) that all nonattainment areas reach attainment as soon as
practicable.  Even if New Jersey’s attainment plan does not
conclusively show attainment by 2009 and this portion of this SIP is not
approved, attainment must still occur as soon as possible.

Assessing the possibility that reductions between 2007 and 2009 could
bring the nonattainment areas into attainment by 2009

New Jersey’s SIP points out that the photochemical grid modeling
results are close enough to 2006 air quality to claim that air quality
will show attainment of the ozone standard by 2009.  The corollary to
that argument is between 2006 and the attainment year of 2009, air
quality will improve sufficiently that the fourth highest ozone at all
monitors in the nonattainment areas will be less than 85 ppb.  Emission
reductions since 2002 have produced a significant decrease in ozone in
New Jersey’s nonattainment areas.  The question is, how much will air
quality improve between now and 2009 and what will happen to cause an
improvement?

Improvements in air quality between now and the 2009 attainment deadline
will come from several possible types of sources.  Based on the
conceptual model for ozone formation in the northeastern United States
ozone can be formed from urban plumes, transport along the corridor, and
transport from outside the corridor.  Ozone can vary from year to year
as weather may be more or less conducive for ozone transport and
formation.  Specifically, the following factors can change ozone between
now and 2009:

Emission reductions from the Philadelphia and New York City
nonattainment areas

Emission reduction from outside the local urban area that will reduce
transported ozone and precursors from other areas in the Ozone Transport
Region

Emission reductions from outside the Ozone Transport Region, especially
from areas with major point sources in the Midwest.

If meteorological conditions occur that are unfavorable for ozone
formation.

Emissions from major point sources in the Midwest were controlled
significantly when the NOx SIP Call was implemented in the early part of
this decade.  Few reductions from the planned (now legally on hold) CAIR
program were to be in place by the 2009 attainment date.  Thus any
expected local ozone reductions will not get support from changes in
ozone and precursor transport from the Midwest.

Ozone reductions in the early part of this decade from inside the Ozone
Transport Region were propelled by the OTR’s NOx SIP Call, other
measures promoted by the Ozone Transport Commission, local and state
reductions, as well as federal programs such as the Federal Motor
Vehicle Control Programs for new cars.  Cleaner cars are expected to
continue to improve air quality for a number of years.  Some states are
continuing to implement programs that reduce ozone precursors and some
reductions in major point source precursors are still occuring (e.g.,
the Maryland Healthy Air Act), but only in some parts of the
northeastern United States.  Overall, taking all of these programs and
their effectiveness, into account, emission reductions will not continue
at the rate observed in the earlier part of this decade.

In summary, for ozone reductions to continue as they have since 2002,
then emission reductions would have to continue as they have in the
past.  Reductions in local emissions may continue to be about the same
as past years, but reductions in transported emissions will not be at
the same level seen during the implementation of the NOx SIP call
earlier in this decade.  Therefore, we should not assume that a
continuation of local emission reductions per the rate achieved during
the earlier part of this decade will mean the same reduction in ozone
now, as transported ozone will not be reduced at the same rate as in
previous years.

States have not provided quantitative information about how much
emissions in the Ozone Transport Region outside New Jersey’s
nonattainment areas will be reduced compared to earlier years.  To make
an estimate of reductions, EPA used information in New Jersey’s plan
and those of surrounding states to calculate the amount of emission
reductions in states’ plans for both of the New Jersey’s
nonattainment areas.  We calculate that emissions from 2007 to 2009 will
decrease by close to 15 percent from 2007 emission levels.  The states
have not modeled the impact of this projected decrease on ozone levels,
so we have no proof that New Jersey’s nonattainment areas will have
sufficient decreases in ozone to meet the air quality standard by 2009.

However, there are several ways to estimate if the reductions still to
come could produce attainment by 2009.  As noted earlier, New York State
modeled a reduction of an additional 15.9 percent of NOx and 7.4 percent
of VOCs from 2009 to 2012 for the New York City metro nonattainment
area.  This percentage of emission reductions is larger than the
reductions expected by states in New Jersey’s nonattainment areas
between 2007 and 2009.  (An attached Excel spreadsheet has calculations
by EPA of emission reductions between 2007 and 2009 from data in the
states’ plans.)  Modeling New York’s emission reductions from 2009
to 2012 produced a reduction in ozone of 4.1 ppb, less than the 9 ppb
needed to reach attainment by 2009 from 2007’s air quality data.

Another way of evaluating whether reductions in emissions from 2007 to
2009 are likely to bring New Jersey’s nonattainment areas into
attainment is to compare reductions in ozone and precursors over the
past few years with precursor reductions anticipated from 2007 to 2009.
Emissions from 2002 to 2008 were reduced by 91 tpd for VOC and 175 tpd
for NOx.  If  both VOC and NOx contribute proportionally to ozone
reductions (not necessarily true, but used here as a simplifying
assumption), then the 22 ppb improvement in ozone from 2002 to 2008 in
the Philadelphia nonattainment area works out to 12.09 tpd for every
1ppb improvement in ozone.  Quantifiable measures in New Jersey’s plan
produce an estimate of 15 tpd of VOC and 5 tpd of NOx reduced from 2008
to 2009, which would, by linear extrapolation, produce 1.65 ppb ozone
reduction by 2009.

Other methods may give an estimate of more reductions between now and
2009, but with a 9 ppb reduction still needed to needed to attain, if
the emission reduction from 2007 to 2009 was comparable to the reduction
in emissions from 2002 to 2007, there would be some hope that the areas
could achieve attainment.  However, the anticipated reductions from 2007
to 2009 projected for the New York City and Philadelphia nonattainment
areas are well under the amount of past reductions that have decreased
ozone by the amount needed to attain.  Additional analysis (attached to
the end of this document) prepared by EPA’s New England office, using
preliminary data from 2008, support the conclusions in this TSD.

As noted above, ozone design values in the past five years have
decreased enough to get New Jersey’s nonattainment areas more than
halfway to attaining the standard by 2009.  However, that large drop in
ozone concentration was aided by the NOx SIP Call.  Emission reductions
for the next two years are less than the past five year period.  There
will be no comparable reduction in long-range transported pollutants
scheduled to occur in the next two years, even if the CAIR program was
implemented on schedule.

EPA’s guidance on photochemical grid modeling notes that, typically, a
20 to 25 percent reduction in ozone precursors are needed to reduce
ozone by 3 ppb, a 15 percent reduction is not likely to produce a 9 ppb
reduction in ozone by 2009.

New Jersey’s SIP indicates if the projected impact of the two
(quantified and unquantified) sets of measures are combined and their
peak effects occurred at the peak monitoring location, these additional
measures could reduce 2009 ozone by 1 to 7 ppb for the
Philadelphia-Wilmington-Atlantic City, PA-NJ-DE-MD area and 1 to 5 ppb
for the New York-Northern New Jersey-Long Island, NY-NJ-CT area.  The
photochemical grid modeling predicted air quality above the standard by
more than these amounts, by 8 ppb above the standard in
Philadelphia-Wilmington-Atlantic City, PA-NJ-DE-MD and 6 ppb in New
York-Northern New Jersey-Long Island, NY-NJ-CT.

In order to determine if New Jersey’s estimates of ozone benefits are
credible, EPA used information from New Jersey’s SIP to estimate, as
much as is possible, the additional emissions reductions that will occur
from emission reductions planned, but not included in the modeling.  EPA
estimates these additional, unmodeled measures will amount to a
reduction of no more than 5 percent of 2007 NOx emissions and 2.6
percent of VOC.  Since EPA’s guidance on photochemical grid modeling
notes that, in most cases, considerable amounts of precursor control
(e.g., 20-25 percent or more) would be needed to lower projected ozone
design values even by 3 ppb, it is unlikely that an additional reduction
of these unmodeled measures would produce the 6 to 8 ppb reduction
needed to reach attainment using the 2009 modeling.

Even at the upper range of impact, these emission reductions not
included in the modeling, while improving public health, will not
produce attainment of the ozone standard unless EPA accepts New
Jersey’s alternative modeling methods.  In addition, New Jersey notes
that these additional control strategies are not officially part of New
Jersey’s attainment SIP (See section 5.4.5 of New Jersey’s SIP.).

If weather conditions in 2009 are unusually cool or otherwise not
favorable for ozone formation, ozone could decrease from previous years
due to changes in year-to-year weather.  However, EPA policy on
attainment planning, as expressed in the Photochemical Modeling
Guidance, assumes for planning purposes no change in weather from the
base year (a year EPA agreed was representative) to the attainment year,
since future year weather could be different from the base year weather
in a variety of ways that can’t be predicted in advance.  Thus, while
ozone in 2009 may be better or worse than predicted due to weather, EPA
does not consider this in predictions of attainment for 2009.  Also,
attainment due to favorable weather conditions is not a permanent,
enforceable way to keep an area in attainment of the ozone health
standard.

EPA’s Evaluation of the Technical Information in New Jersey’s Weight
of Evidence

New Jersey’s modeling photochemical grid modeling results predicts a
2009 projected design value well above the air quality health standard
for New Jersey’s nonattainment areas.  Even with additional measures
not included in the modeling, following EPA’s photochemical modeling
guidance does not predict attainment of the ozone standard by 2009 for
New Jersey’s nonattainment areas.  The SIP makes a possible, but
ultimately, not credible, argument to show that ozone will be less than
85 ppb in 2009.  With the modeled result at least 6 ppb away from
attainment, EPA’s guidance reasonably points out that New Jersey needs
to supply a very substantial amount of evidence that the model is
seriously overestimating future ozone concentrations.

Modeling studies give conflicting results as to whether New Jersey will
get more reductions in ozone than predicted by the model.  Taken
together, studies of the northeast blackout do not support an argument
that the model overpredicts concentrations in the attainment year.
Recent air quality data confirm the large gap between present air
quality and attainment by 2009.

New Jersey has suggested that it can adopt additional emission reduction
strategies which will reduce ozone, but these reductions are not yet in
place or are voluntary and mostly unquantifiable emission control plans.
 They are not likely to be enough reduce ozone enough to reach the
standard by 2009, even if they are implemented and if they actually
reduce ozone.  EPA also cannot give much credit for additional measures
that New Jersey says it will implement, but will not commit to or
officially include them in its attainment SIP.

Air quality data through 2007 are so far above the level needed for
attainment that it is unlikely states will able to implement enough
emission controls to reach the standard by 2009.  The present air
quality also does not support the hypothesis that the models are
incorrect.  Present air quality concentrations should be closer to the
standard since New Jersey is only two years from when it should be
attaining the standard.  Reductions anticipated to take effect between
now and 2009 are also not enough to close this gap.  Preliminary air
quality data from 2008 (see attached “Air Quality Trends in the
CT-NY-NJ 8-hour Ozone Nonattainment Area”) support the conclusion that
air quality is not improving enough to show attainment by the attainment
date (see attached “Emissions Trends in the CT-NY-NJ 8-hour Ozone
Nonattainment area”).

The information and calculations provided by New Jersey’s SIP
emphasizes methods or data that support their claims that the
nonattainment areas could attain the standard by the deadline.  EPA’s
review of the “weight of evidence” analyses must evaluate a spectrum
of likely alternative calculations, not only those that tend to show the
area will attain the ozone standard.  As noted before, the method
recommended by EPA’s guidance and other reasonable variations on
EPA’s methods predict the area will not attain the ozone standard by
2009.  New Jersey has made a thoughtful case, but has not proven the
proposition that the proposed adjustments to the photochemical grid
model’s attainment year forecast will give a more accurate answer than
the calculations based on EPA’s recommendations in its modeling
guidance.

Summary of EPA’s Technical Findings

The result of the photochemical grid modeling analysis, using EPA’s
recommended methods, predicts that New Jersey’s nonattainment areas
will not attain the standard by the attainment year.  In response to
this, New Jersey has offered a number of alternative modeling approaches
and additional control strategies.  New Jersey’s SIP suggests that
when taken together, adjustments to the modeling results and additional
measures might plausibly demonstrate attainment.  Here is what EPA found
in its review of the attainment demonstration portion of its New
Jersey’s SIP:

New Jersey’s modeling, using an appropriate photochemical grid model
and EPA’s guidance methods, does not predict attainment in 2009.

New Jersey’s attainment demonstration greatly relied on adjustments to
the baseline assumptions which formed the basis of the photochemical
modeling analysis. These adjustments to the base year starting value and
the amount of reduction in ozone from 2002 to 2009 differ from EPA’s
modeling guidance, and, more importantly, are not sufficiently justified
and are weighted toward a conclusion that New Jersey’s nonattainment
areas will attain the standard.

New Jersey’s attainment demonstration greatly relied on research which
evaluated the impact of a widespread power blackout to develop an
alternative approach to estimating anticipated air quality improvements
from upwind power plants.  While EPA believes that this approach
provides some insight into the transport of ozone precursors, a critical
review of all the research available to EPA and New Jersey leads EPA to
disagree with the premise that the air quality modeling results should
be adjusted using New Jersey’s alternative approaches.

New Jersey’s State Implementation Plan relies on emission reductions
resulting from a commitment to adopt and implement a number of
regulations prior to the start of the 2009 ozone season.  Some of these
were included in the photochemical grid modeling.  These regulations
would provide for additional reductions from boilers, refineries, power
generation, consumer products and portable fuel containers.  The plan
proposed to adopt these regulations by May of 2008.  As of mid-Summer
2008, none of the regulations have been adopted.  While New Jersey has
proposed two rule packages, the third has yet to be proposed.  New
Jersey’s own analysis shows that New Jersey must adopt all these
measures, and additional measures as well to show attainment by 2009.
New Jersey must adopt these measures as soon possible to insure that
these emission reductions occur by the start of the 2009 ozone season to
have any chance of attaining the standard in 2009.

New Jersey’s SIP asks that EPA take into account the effects of
additional measures which were not included in the original
photochemical modeling analysis.  The effects of some of these measures
can be quantified, others can only be estimated, and most of these
measures are contained in the SIP but not committed to by New Jersey as
part of its attainment demonstration.  While EPA encourages New Jersey
to continue to promote these worthwhile and important emission reduction
programs, the amount of tangible air quality benefit is difficult to
estimate with any degree of certainty.  Based on the estimates in New
Jersey’s SIP, implementing these measures will move the State’s
nonattainment areas closer to attainment.  Even using the most favorable
assumptions of the effectiveness of these measures, whose implementation
is uncertain, New Jersey’s nonattainment areas cannot reach attainment
of the ozone standard in 2009.

Comparing the measured ozone concentrations in 2007 to the ozone
concentrations predicted for 2009 by using EPA’s recommended
application of the photochemical grid modeling, supports the technical
finding (made independently of the assessment of recent air quality
data), that the photochemical grid model does not exhibit the magnitude
of inaccuracies suggested in New Jersey’s attainment demonstration.
Preliminary data from 2008 continue to support these technical findings.

Regardless of the issues raised by New Jersey regarding the performance
of EPA’s recommended air quality models, the air quality measured
during 2007 and preliminary data collected in 2008 continued to exceed
the ozone standard by a significant margin.  Even a linear comparison of
the percentage of additional emission reductions planned by the state
with the needed improvement in air quality between 2007 and 2009
indicates it is unlikely that air quality will improve enough to meet
the ozone standard by 2009.

EPA encourages New Jersey to implement all of its planned measures as
soon as possible to meet the Clean Air Act’s requirement that all
nonattainment areas reach attainment as soon as practicable.

Recommendation of Disapproval of Attainment Demonstration

EPA has carefully evaluated the information provided by New Jersey and
other information it deems relevant to help understand what the air
quality is likely to be by the 2009 ozone season.  EPA concludes that
attainment in 2009 is not likely and the possibility that attainment is
plausible does not satisfy the Clean Air Act’s requirement that State
Implementation Plans provide for attainment of the National Ambient Air
Quality Standard by the applicable attainment date.

For New Jersey’s attainment demonstration to show attainment of the
air quality standard, several factors would have to coincide.  The
photochemical grid model would have to be underpredicting the change in
ozone by at least 40 percent.  All of the measures New Jersey committed
to implement as part of its SIP would have to be implemented by the
beginning of the 2009 ozone season.  All or most of the additional
measures, quantifiable and unquantifiable measures, would need to be
implemented by the beginning of the 2009 ozone season and be effective.
The unquantifiable measures would have to have a significant impact on
ozone air quality.  To count on all of these factors occurring is not a
plausible plan.  In addition, based on recent air quality data, New
Jersey and its surrounding states would have to implement a large
fraction, perhaps half of its planned reductions in emissions, between
2007 and the beginning of the 2009 ozone season.  Based on EPA’s
evaluation of New Jersey’s rate of progress plans, it is unlikely that
any more than 20 percent of New Jersey’s reductions will occur over
the period from 2007 to the beginning of the 2009 ozone season, making
it implausible that ozone in New Jersey’s nonattainment areas will be
reduced from 2007’s design value of 93 ppb to 84 ppb by 2009.

The technical information provided in New Jersey’s SIP submittal leads
EPA to conclude that New Jersey’s SIP does not demonstrate that its
nonattainment areas will attain the ozone standard by the attainment
year.  EPA’s evaluation of the research cited by New Jersey and more
recent air quality data does not support New Jersey’s hypothesis about
the magnitude of a lack of model responsiveness.  For New Jersey’s
ozone nonattainment areas to reach attainment of the 1997 0.08 ppm ozone
standard by the attainment date, the photochemical grid model would have
to be underpredicting air quality improvements by forty percent, plus,
additional measures pledged by New Jersey (but not formally included in
the SIP) would have to be implemented in time and have an effectiveness
on the high end of the range of potential effectiveness provided by New
Jersey.  Neither of these are likely and both are needed to demonstrate
attainment by the attainment deadline.  These findings compel EPA to
propose disapproving the attainment demonstration portion of New
Jersey’s SIP submittal.

Appendices

Appendix 1.  Summary of Emission Inventory Work from New Jersey’s SIP
Submittal

Attachments

Attachment 1:  Table of additional reductions and post 2007 reductions
for New York City and Philadelphia nonattainment areas.

Attachment 2:  Listing of Agenda from meetings of EPA Regions with
states that share New Jersey’s nonattainment areas, after New Jersey
submitted its plan to EPA.

Attachment 3:  Air Quality Trends in the New York-N. New Jersey-Long
Island NY-NJ-CT 8-hour Ozone Nonattainment Area, prepared by EPA’s New
England Office.

Attachment 4:  Emissions Trend in the CT-NY-NJ 8-hour Ozone
Nonattainment area, prepared by EPA’s New England Office.

Attachment 5:

The 2003 North American electrical blackout: An accidental experiment in
atmospheric chemistry.  Lackson T. Marufu, Brett F. Taubman, Bryan
Bloomer, Charles A. Pi.  GEOPHYSICAL RESEARCH LETTERS, VOL. 31, L13106,
doi:10.1029/2004GL019771, 2004, 15 July 2004.

Attachment 6:

Re-examination of the 2003 North American electrical blackout impacts on
regional air quality.

Hu, Yongtao, and M. Talat Odman, and Armistead G. Russell. GEOPHYSICAL
RESEARCH LETTERS, VOL. 33, L22810, doi:10.1029/2006GL027252, 2006, 25
November 2006.

Attachment 7:

Rethinking the Assessment of Photochemical Modeling Systems in Air
Quality Planning Applications.  Hogrefe, Christan, and Kevin L.
Civerolo, Winston Hao, Jia-Yeong Ku, Eric E. Zalewsky, and Gopal Sistla.
 J. Air & Waste Manage. Assoc. 58:1086–1099

DOI:10.3155/1047-32<IP_ADDRESS>6, August 2008.

Attachment 8:

Dynamic evaluation of regional air quality models:  Assessing changes in
O3 stemming from changes in emissions and meteorology.  Gilliland, Alice
B., and Christian Hogrefe, Robert W. Pindera, James M. Godowitch,
Kristen L. Foley, S.T. Rao.  Atmospheric Environment 42 (2008)
5110–5123, doi:10.1016/j.atmosenv.2008.02.018 .

Appendix 1:

Summary of Emission Inventory Work from New Jersey’s SIP Submittal,
with EPA’s Commentary (Formal evaluation of the SIP inventory work is
considered in a separate document, found in EPA’s docket for this
proposed action.)

I. 2002 Emission Inventories

The 2002 emissions were first generated by the individual Ozone
Transport Region states.  MARAMA then coordinated and quality assured
the 2002 inventory data, and projected it for the relevant control
years.  The 2002 emissions for non-Ozone Transport Region areas within
the modeling domain were obtained from other Regional Planning
Organizations for their corresponding areas.  These Regional Planning
Organizations included the Visibility Improvement State and Tribal
Association of the Southeast (VISTAS), the Midwest Regional Planning
Organization and the Central Regional Air Planning Association.

All references to the “New Jersey SIP submittal” or “appendices”
refer to the:

	The State of New Jersey Department of Environmental Protection

	State Implementation Plan (SIP) Revision for the Attainment and
Maintenance of 	the Ozone National Ambient Air Quality Standard - 8-Hour
Ozone Attainment Demonstration – Final October 29, 2007

The documentation for the OTC base and control modeling inventories are
presented in Appendices D7 and D8, respectively, of the NJ Attainment
Demonstration SIP revision.  The use of emission inventory data from the
non-Mid-Atlantic/Northeast Visibility Union (MANE-VU) states is
documented in Appendix D8.

Version 3 of the 2002 base year emission inventory was used in the
regional modeling exercises.  A technical support document for this
inventory, which is included in Appendix D7, explains the data sources,
methods, and results for preparing this version of the 2002 base year
criteria air pollutant and ammonia emissions inventories for point,
area, onroad, nonroad, and biogenic sources for the MANE-VU Regional
Planning Organization.

The inventories include annual emissions for oxides of nitrogen (NOx),
volatile organic compounds (VOC), carbon monoxide, ammonia, particles
with an aerodynamic diameter less than or equal to a nominal 10
micrometers (PM10) and PM2.5.  The inventories also included summer day,
winter day, and average day emissions.

The inventory and supporting data prepared includes the following:

Comprehensive, county-level, mass emissions and modeling inventories for
2002 emissions for criteria air pollutants and ammonia for the State and
Local agencies included in the MANE-VU region;

The temporal, speciation, and spatial allocation profiles for the
MANE-VU region inventories;

Inventories for wildfires, prescribed burning, and agricultural field
burning for the southeastern provinces of Canada; and

Inventories for other Regional Planning Organizations, Canada, and
Mexico.

II. Control Measures Modeled

The two emission control scenarios are:

a combined “on-the-books/on-the-way” (OTB/W) control strategy
accounting for emission control regulations already in place, as well as
some emission control regulations that are not yet finalized but are
likely to achieve additional reductions by 2009 (i.e., adoption of the
six shortfall measures by states outside the core Ozone Transport Region
states); and

a beyond on the way (BOTW) scenario to account for controls from
potential new regulations that may be necessary to meet attainment and
other regional air quality goals.

New Jersey’s attainment demonstration relies on the Beyond-on-the-Way
(BOTW) 2009 modeling run, which predicts future 2009 air quality
conditions, after accounting for all air pollution controls that have
been implemented since the base year of 2002 (OTB measures), and
applying new control measures (BOTW measures) that will be implemented
in time to reduce emissions in 2009.  Table 5.1, of the NJ SIP, lists
all of the control measures New Jersey has included in the projected
2009 BOTW CMAQ modeling run.  The reader is referred to the New Jersey
SIP submittal, Chapter 4 for a detailed discussion of the control
measures.

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

Pre-2002 with benefits achieved Post-2002 - On the Books

Federal

Residential Woodstove NSPS

Onboard Refueling Vapor Recovery (ORVR) beyond Stage II

Tier 1 Vehicle Program

National Low Emission Vehicle Program (NLEV)

Tier 2 Vehicle Program/low sulfur fuels

HDDV Defeat Device Settlement

HDDV Engine Standards

Nonroad diesel engines

Large industrial spark-ignition engines over 19 kilowatts

Recreational Vehicles  (includes snowmobiles, off-highway motorcycles
and all-terrain vehicles)

Diesel Marine Engines over 37 kilowatts

Phase 2 standards for small spark-ignition handheld engines at or below
19 kilowatts

Phase 2 standards for new nonroad spark-ignition nonhandheld engines at
or below 19 kilowatts

Post-2002 - On the Books

New Jersey Measures Done Through a Regional Effort

Consumer Products 2005

Architectural Coatings 2005

Portable Fuel Containers 2005

Mobile Equipment Repair and Refinishing

Solvent Cleaning

NOx RACT rule 2006 (including distributed generation)

Stage I and Stage II - Gasoline Transfer Operations

On-Board Diagnostics – I/M

New Jersey Heavy Duty Diesel Rules Including "Not-To-Exceed" (NTE)
Requirements

Federal

USEPA MACT Standards including Industrial Boiler/Process Heater MACT

CAIR

Refinery Enforcement Initiative

Post-2002 - Beyond on the Way

New Jersey Measures Done Through a Regional Effort

Consumer Products 2009 Amendments

Portable Fuel Containers 2009 Amendments

Asphalt Paving

Adhesives and Sealants

Certain Categories of ICI Boilers

While Table 5.1 shows all the OTB and BOTW measures that New Jersey took
credit for in the 2009 attainment demonstration model run, the overall
attainment demonstration is reliant upon all the states' in the Ozone
Transport Region implementing measures to reduce ozone in order for New
Jersey to achieve its goals.  As such, Table 5.2, of the NJ SIP, shows
which BOTW measures each state in the Ozone Transport Region believed
would be implemented in time to achieve benefits in 2009.  These were
the measures included in the BOTW model run for each state.

EPA Evaluation

The table below identifies the status of the modeled control measures
which were included in the modeling for 2009 BOTW run.  The delay in
adopting and implementing these control measures will impact the results
of this modeling run and New Jersey’s conclusions.  In addition, Table
5.2 identifies measures that surrounding states must adopt and implement
in order for the 2009 BOTW modeling run to be a valid point at which a
weight of evidence analysis can begin.  Some of these measures have not
yet been adopted.

Modeled Control Measures Included in the 2009 BOTW Model Run

Post-2002 - Beyond on the Way	 Status

New Jersey Measures Done Through a Regional Effort

	Consumer Products 2009 Amendments	Proposed 12/07,

Adopted 10/30/08

Portable Fuel Containers 2009 Amendments	Proposed 12/07,

Adopted 10/30/08

Asphalt Paving	Proposed 7/08

Asphalt Production	Proposed 7/08

Adhesives and Sealants	Proposed 7/08,

Adopted 10/30/08

Certain Categories of ICI Boilers 	Proposed 7/08

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

III. Additional Quantifiable Measures

Table 5.11, of the NJSIP, lists the additional control measures and
refinements that New Jersey is planning to propose by no later than
November 2007, and adopt by May 2008.  While these additional measures
and refinements were finalized too late to be included in the 2009 BOTW
modeling, they will provide additional emission reductions by 2009.  As
such, they provide additional evidence to support New Jersey’s
conclusion that both of its associated nonattainment areas will attain
the 8-hour ozone standard by their required attainment dates.

Table 5.11: Additional Quantifiable Measures Not Included in the 2009
BOTW Modeling

Pre-2002 with benefits achieved Post-2002 - On the Books

New Jersey

New Source Review (NSR)

Post-2002 - On the Books

New Jersey Measures Done Through a Regional Effort

     Additional Benefits from Modeled Measures

NOx RACT rule 2006 (includes distributed generation)

Portable Fuel Containers 2005

Post-2002 - Beyond on the Way

New Jersey Measures Done Through a Regional Effort

Portable Fuel Containers 2009 Amendments

Certain Categories of ICI Boilers

Refinery rulesa

High Electric Demand Day Program

New Jersey Only Measures

Petroleum Storage Tank Measuresb

USEPA CTGs (5 categories)c

Case by case VOC and NOx determinations (FSELs/AELs)

Municipal Waste Combustor Measures

Diesel Idlingd

Diesel Inspection and Maintenance

Federal

New nonroad engine standards

a Includes proposed requirements for process heaters, flares, FCCs/FCUs
and leak detection and repair

b Includes proposed requirements for floating roof top sleeves,
degassing, cleaning and landing losses

c Includes state review and action on four new CTGs covering five
categories, including flexible packaging printing materials,
lithographic printing materials, letterpress printing materials,
industrial cleaning solvents, and flat wood paneling coatings.

d The Diesel Idling Rule changes were adopted in June 2007

EPA Evaluation

NJ identified and committed to the additional  quantifiable measures
some that are used in the SIP for attainment, RFP, or contingency
purposes.  See table below for a list of these measures, how they are
used in the SIP and their status.  Several of the measures are being
held in reserve.  Many have yet to be adopted and, therefore, at this
time the likelyhood that they will be adopted and implemented in time to
achieve the planned emission reductions by May 2009, is problematic.

Status and Use in NJ SIP of Additional Quantifiable Measures

Pre-20Pre -2002 with benefits achieved

 Post-2002 - On the Books	How Used in SIP	Status

New Jersey

New Source Review (NSR)	In reserve	Adopted

Post-2002 - On the Books

NJ Measures Done Through a Regional Effort

     Additional Benefits from Modeled Measures

NOx RACT rule 2006 (includes distributed generation)	Attainment/ 2008
RFP	Adopted

Portable Fuel Containers 2005	Attainment/ 2008 RFP,

2008RFP Contingency	Adopted

Post-2002 - Beyond on the Way

New Jersey Measures Done Through a

Regional Effort

Portable Fuel Containers 2009 Amendments	Attainment/ RFP, 2008 RFP
Contingency	Adopted

Certain Categories of ICI Boilers	Attainment	Proposed

Refinery rulesa	2009 Contingency	Pre-proposal

High Electric Demand Day Program	In reserve	Proposed

New Jersey Only Measures

Petroleum Storage Tank Measuresb	2009 Contingency	Proposed

USEPA CTGs (5 categories)c	In reserve	Proposed

Case by case VOC and NOx determinations (FSELs/AELs)	In reserve	Proposed

Municipal Waste Combustor Measures	2009 Contingency	Proposed

Diesel Idlingd	2009 Contingency	Adopted

Diesel Inspection and Maintenance	2009 Contingency	Proposed

Federal

New nonroad engine standards	2009 Contingency	Promulgated

a Includes proposed requirements for process heaters, flares, FCCs/FCUs
and leak detection and repair

b Includes proposed requirements for floating roof top sleeves,
degassing, cleaning and landing losses

c Includes state review and action on four new CTGs covering five
categories, including flexible packaging printing materials,
lithographic printing materials,

IV. Non-Quantifiable Emission Reductions Which Improve Air Quality

The non-quantifiable strategies can be grouped into the following
categories:

	Voluntary Strategies,

	Energy Savings and Alternative Energy Strategies,

	Mobile Strategies, and

	Particulate Matter Strategies with Benefits to Reduce Ozone.

New Jersey knows that these control measures will improve the State’s
overall air quality by indirectly decreasing ground-level ozone
concentrations.  As such, these strategies will result in actual air
quality benefits that will be reflected in the monitoring data in both
the Northern New Jersey/New York/Connecticut and Southern New
Jersey/Philadelphia nonattainment areas in the years leading up to 2010.
 New Jersey promotes and supports these measures, within state funding
limits, but is not relying upon or committing to implement them as part
of its 8-hr ozone attainment demonstration.

EPA evaluation:

EPA agrees with New Jersey that there are a number of programs being
implemented primarily for other purposes that will have benefits in
reducing air pollution.  EPA has a policy of permitting states to take a
limited amount of credit in their SIPs for voluntary and/or innovative
control measures, but a state must meet certain criteria if they are to
rely on these reductions for attaining a NAAQS.   Unless New Jersey
follows this guidance, these reductions cannot be credited in its
attainment demonstration.

Summary of Control Measures:

New Jersey has not adopted and implemented all the control measures that
were included in the 2009 BOTW modeling run.  This impacts the results
of that model run.

Surrounding states have, also, not adopted and implemented all the
control measures they included in the 2009 BOTW modeling run.

“Additional Quantifiable Measures” are used for attainment, RFP, or
Contingency purposes, but these have not all been adopted yet.

“Non-quantifiable strategies” are being implemented throughout New
Jersey primarily for other objectives, but will have air quality
benefits.  This is a potential source of emission reductions that could
be relied upon for attaining the 8-hour ozone standard if the New Jersey
documents the reductions and commits to provide back-up reductions
should the measures not result in the calculated emission reductions.

End of TSD and Attachments   January 2009

   New Jersey submits a “State Implementation Plan” (SIP) to EPA for
review.  From EPA’s point of view, New Jersey’s plan is a SIP
submittal that becomes part of the SIP when EPA includes it in the
Federal Code of Regulations.  From New Jersey’s point of view, this
ozone SIP is a part of the overall state plan, adopted by the State, for
attaining national ambient air quality standards.  In this TSD, we will
refer to New Jersey’s SIP submittal as New Jersey does, as a
“SIP”, for consistency with the State’s terminology and ease of
reading.

   The 1997 ozone standard is attained when concentrations are 0.08
parts per million (ppm) or less.  While the standard is defined in parts
per million, modeling and modeling data commonly use parts per billion.
Mathematically, a value less than 85 parts per billion (ppb) is 0.08 ppm
or less.  Therefore, this document often uses 84 ppb as the
concentration of ozone that must be reached to attain the ozone
standard.

   In 2008, EPA established an ozone standard, an eight-hour average
standard in the form of the present standard, but with attainment at
0.075ppm.  Attainment of the 1997 0.08 ppm standard is addressed in New
Jersey’s SIP submittal and this TSD.  The 0.075ppm standard will be
addressed in a future round of SIPs.

  For further details on emissions inventories, see Attachment 2 to this
TSD and the emission inventory portion of EPA Region 2’s Technical
Support Document for EPA(s Notice of Proposed Rulemaking for the New
Jersey State Implementation Plan Revision:  State Implementation Plan
(SIP) Revision for the Attainment and Maintenance of the Ozone National
Ambient Air Quality Standard 8-Hour Ozone Attainment Demonstration
Final, October 29, 2007 - December 2008, included in EPA’s docket for
this proposed action.

   In New Jersey’s SIP, Table ES.1 introduces the concept of upper and
lower bounds for its predicted ozone concentration for the attainment
year.  This concept is separate from the adjustments New Jersey proposed
to make to the modeling system, which will be analyzed later in this
TSD.  New Jersey’s SIP includes a discussion of a range of attainment
year ozone values to address possible uncertainties in the modeling
process that it believes could produce a predicted ozone concentration
higher or lower than the value shown in its SIP and listed in Table 1 of
this document.  We should note that, if the future attainment year ozone
could be more or less the value needed to show attainment, it is equally
likely that these nonattainment areas would not be in attainment by the
attainment year even if the most likely middle value shows attainment.
In that case, to be certain of attainment, one could argue that
additional reductions would be needed to conclusively demonstrate
attainment in these areas.  All predictions are uncertain, but the SIP
shows these uncertainties are mostly evenly distributed about the values
given in the SIP and recorded here.  For this review, attainment will be
determined by EPA’s past practice of focusing on a single attainment
year concentration predicted by the modeling system as New Jersey
applied EPA’s guideline, and these numbers are used in Table 1.

  See section 182 (j) (1) of the Clean Air Act: a “...multi-State
ozone nonattainment area ...

shall ... use photochemical grid modeling or any other analytical method
determined by the administrator, in his discretion, to be at least as
effective.”

  The 2002 base air quality value for the modeling base year is 106 ppb
in the New Jersey’s SIP submittal.  EPA’s guideline method results
in a value of 105.7 ppb.

 Technical Support Document for EPA’s Notice of Proposed Rulemaking
for the New Jersey State Implementation Plan Revision:  State
Implementation Plan (SIP) Revision for the Attainment and Maintenance of
the Ozone National Ambient Air Quality Standard 8-Hour Ozone Attainment
Demonstration Final, October 29, 2007, December 2008.  Included in
EPA’s online docket for this proposed action.

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