DEP Will Hold An Important Public Hearing On NJ’s Clean Air Plan For Fine Particulate Pollution (PM 2.5)

Posted on February 10, 2023 by Bill Wolfe

DEP Must Withdraw Plan In Light Of Current Science & EPA Proposed Lower NAAQS

Gov. Murphy’s Climate And Environmental Justice Policies Are Ignored

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[Update below]

This is a quick note. [* I corrected my error on the scheduling of the public hearing]

I recently wrote briefly about this issue here, which provides some background information:

DEP recently quietly submitted NJ’s State Implementation Plan (SIP) for fine particulate known as PM 2.5 to EPA for review and approval.

I requested that DEP hold a public hearing, which they are legally required to do if someone requests one. I was told by DEP yesterday that DEP will hold a “virtual” public hearing on Feb. 14 on the DEP’s proposed SIP PM 2.5 plan submission to EPA for approval. Please register to testify here:

  • February 14, 2023 @ 10 AM – Link to join meeting:
  • Call In: 1 856-338-7074
  • Phone conference ID: 640 213 715#

The hearing provides a good opportunity to educate the public, generate press, and begin to reform the DEP’s air quality program in light of climate science, EJ policies, and advances in science on adverse health effects of ultra fine particulates.

EPA recently proposed revisions in the federal NAAQS for PM 2.5 that would make NJ   non-compliance worse.

The Gov. and DEP are now holding hearings on the urban heat island effect, and that involves PM 2.5 strategies.

I am recommending the following, which I urge you to support:

DEP Must Withdraw and strengthen the plan in light of the following:

a) advances in science document more serious health effects at lower levels of exposure, particularly in EJ communities;

b) EPA’s proposed revision to lower the NAAQS for PM 2.5

c) DEP’s current development of an “Urban Heat Island” strategy

d) advances in climate science that project more adverse impacts of PM 2.5 and ozone

e) failure of the current DEP ambient air quality monitoring network to assess ambient conditions in the locations where people are actually exposed to pollution (e.g. at 5 feet elevation, street exposure) and failure to adequately monitor EJ communities.

DEP SIP fails to make enforceable commitments to upgrade the current monitoring network in these important regards.

f) ongoing regulatory development to attain the aspirational goals of the Global Warming Response Act, which impact PM 2.5 attainment and involve coordinated strategies.

g) the DEP’s emissions inventory fails to reflect the DEP’s current and proposed expansion of fine particulate generating prescribed burns in NJ’ forests. According to EPA:

Wildland fire, which encompass both wildfire and prescribed fire, accounts for over 30% of emissions of primary PM2.5emissions (U.S. EPA, 2021).

h) the current NJ SIP transportation conformity analysis is flawed, outdated, and fails to reflect current science on PM 2.5 and fails to fully inventory, model, or capture projected increases from major road expansions and increasing VMT and related transportation emissions.

i) recently approved and pending fossil infrastructure project emissions are not included in the inventory.

j) the control strategies felt o reflect “advances in the art” as required under NJ Air Pollution Control Act.

Finally, the California Air Resource Board (CARB) has been developing science and regulatory strategies for PM 2.5 and ultra-fine particulates. I request that the DEP publish and consider CARB policies and recommendations and conduct a side by side comparison between CARB and the DEP SIP strategies so that the public can be adequately informed.

[Update: 3/10/23:

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