The New Jersey Department of Environmental Protection (NJDEP) held its quarterly Industrial Stakeholders Group (ISG) meeting on June 5, 2026. During the meeting, NJDEP provided updates on the following topics:
- Environmental Justice Updates
- Permit Status Updates
- Air Quality Forecasting and Emergency Generator Testing
- Modeling Protocol Template Update
- Update to Conveyor System Guidance
- Open Discussion
The following sections provide a summary of each of the topics discussed:
Environmental Justice Updates
NJDEP provided insight into the ongoing implementation of Environmental Justice (EJ) requirements, including the Facility-Wide Risk Assessment (FWRA) process and the parallel review of EJ permits. The agency emphasized that many EJ reviews are dependent on modeling approval before a complete EJ Impact Statement (EJIS) can be finalized. Therefore, the EJ process will work in parallel with the air permit application review process to help streamline the process.
To help applicants, NJDEP has created a flow chart to help explain the parallel review process.
Currently, 39 applications have triggered EJ, with only a small portion reaching final decision so far. Many projects remain in process, with several awaiting initial EJIS submittals or revisions. NJDEP also emphasized that some applicants were able to offset emissions increases with decreases in other processes in their air permits to avoid EJ applicability. This can be done by placing operational limitations on processes or installing emission controls avoid a net increase in facility-wide emissions.
Another important note is that Jillian Alexander will be transitioning out of environmental justice projects with Thomas Loop taking her place.
Permit Status Updates
NJDEP presented an overview of permit workload trends, including a gradual decline in pending permits across both operating permits and minor source permits. Specifically, pending operating permits have decreased by approximately 19%, while PCP permits have declined by about 13%.
Despite this progress, NJDEP emphasized that deficiency notices continue to outpace final permit decisions. This indicates that application quality remains a significant factor in processing delays.
To facilitate a decrease in the number of deficient applications and allow NJDEP to more efficiently finalize permit actions, NJDEP will be requiring applicants to submit an administrative completeness checklist with their applications to demonstrate a complete application. The checklist (anticipated to be required beginning in October 2026) will be based on type of application and will include elements such as complete, unlocked potential-to-emit calculations, evaluation of risk assessment, complete RADIUS forms, etc.
Air Quality Forecasting and Emergency Generator Testing
NJDEP provided a refresher on air quality forecasting procedures, particularly as they relate to emergency generator testing.
Key forecasting requirements include:
- Weekday forecasts: Submitted by 9:00 AM for two-day outlooks
- Weekend forecasts: Four-day outlook issued on Fridays
- Updates: May be issued around 3:00 PM, with availability on AirNow after 4:00 PM
Facilities were reminded to check forecasts proactively, especially when scheduling generator testing to ensure that they are not testing on unhealthy air quality days.
Regarding emergency generators, NJDEP clarified that as long as the forecast posted the day before was not unhealthy, facilities can test their emergency generators. Facilities should rely on the forecast posted at 4 PM the day before testing. Trinity recommends that facilities utilize screenshots or the snipping tool to take a photo of the forecast the day before and store it with the generator testing logs.
Modeling Protocol Template Update
NJDEP provided an update on the modeling protocol template initiative (model inputs & narrative), which aims to standardize modeling submissions across applicants.
The templates are designed to:
- Ensure all required information is included
- Improve consistency in modeling analyses
- Reduce back-and-forth during review
As with the application checklists, NJDEP signaled that these templates will likely become mandatory in the near future, reinforcing the agency’s push toward standardized, complete submissions.
Update to Conveyor System Guidance
NJDEP’s guidance on conveyor permitting advises that each conveyor must be permitted as a separate piece of equipment if separated by non-conveyer equipment such as hoppers, screeners, etc. In the past, this guidance extended to portable units such as jaw crushers and portable screeners. NJDEP posted an updated guidance document dated May 27, 2026, clarifying that these portable units may be permitted as one piece of equipment, as long as they are self-contained, delivered from the manufacturer as one unit, and cannot be separated for use elsewhere. To save on renewal costs, facilities can choose to submit air permit modifications to consolidate affected portable equipment into one piece of equipment.
General Discussion
Aside from the topics discussed above, it was also announced that Section Chief Joel Leon will be retiring this summer. No update was provided on his replacement.
Please reach out to our Princeton Office at 609.318.5500 should you want to discuss any of the information contained in this article in more detail.
