Publication No. R

- ARD

- 14

- 2



### Revision to the



## New Hampshire State Implementation Plan



# Regional Haze 5

- Year Progress Report

December 16 , 2014

Air Resources Division

Mid

- Atlantic/Northeast Visibility Union (MANE

- VU)ACKNOWLEDGEMENTS

Th e New Hampshire Department of Environmental Services would like to express appreciation to the many staff members of the NESCAUM, MARAMA, and OTC regional organizations and to staff members of the

MANE

- VU states for their invaluable assistance and timely c ontributions to analyses and supporting documents that made possible the preparation

of New Hampshire’s Regional Haze SIP 5

- Year Progress Report

.

ON THE COVER : Split

- image view of Presidential Range and nearby valley from Conway, New Ha mpshire, on clear and hazy days. http://hazecam.net/mtwash_gallery.aspxNH Regional Haze 5

- Year Progress Report Page i

EXECUTIVE SUMMARY

Section 169A of the Clean Air Act (CAA) provides for the protection of visibility at mandatory Class I federal areas. These designated areas include 156 national parks and wilderness areas located throughout the United States. Regional haze obscures vi stas that are integral to the value of

such areas. In 1999, the U.S. Environmental Protection Agency (EPA) adopted the Regional Haze Rule ( published at 64 FR 35714 and codified at 40 CFR 51.300

- 309 ), which calls for state, tribal, and federal agencies to work together to improve visibility in all Class I areas. Two of these areas

– Great Gulf Wilderness Area and Presidential Range

- Dry River Wilderness Area

– are located in New Hampshire’s White Mountain National Forest.

States are required to revise their State Implementation Plans, or SIPs , in order to reduce the pollution that causes visibility impairment and regional haze. 1 These plans establish reasonable progress goals for visibility improvement and include strategies to reduce air pollutant emissions from sources contributing to visib ility impairment at Class I areas.

Regional haze is caused by numerous and diverse air emission sources over a broad geographic area. The predominant cause of haze pollution in the Mid

- Atlantic/Northeast region is sulfate particles (aerosols) present i n, or formed from, emissions when coal or oil is burned. The largest sources of this pollution are ele ctrical generating units (EGUs) located in the eastern half of the

United States.

As a member of the Mid

- Atlantic/Northeast Visibility Union (MANE

- VU), 2 New Hampshire has committed to implementing a long

- term strategy to improve visibility at MANE

- VU’s Class I areas.

The defined long

- term strategy covers the 10

- year period ending in 2018 and includes:

• Timely implementation of Best Available Retrofit T echnology (BART) at specified EGUs;

• Enforceable reductions in sulfur dioxide emissions from targeted EGUs;

• A request for emissions reductions from non

- MANE

- VU states whose emissions contribute to visibility impairment within our region, and

• Evaluation of o ther measures such as reducing the sulfur content of fuel oil, expanding the use of alternative clean fuels, increasing energy efficiency, and further reducing emissions

from coal and wood combustion.

This document addresses 40 CFR 51.308(g) , which requir e s periodic reports evaluating progress

in carrying out New Hampshire’s regional haze plan. The results to date indicate real progress: Control strategies in the SIP are being implemented, power plant emissions of sulfur dioxide (SO 2 ) have declined, and visibility measurements at mandatory Class I federal areas affected by New Hampshire’s emissions are trending in the right direction. More specifically,

• Required sulfur dioxide control measures at New Hampshire ’s two BART units and a third

, targeted un it are installed and operational; and both BART units are operating under new limits for nitrogen oxides (NOx) and particulate matter (PM);

1 New Hampshire’s regional haze SI P revision is available at http://des.nh.gov/organization/divisions/air/do/asab/rhp/index.htm

.

2 MANE

- VU includes the following member states: Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont, and the District of Columbia.NH Regional Haze 5

- Year Progress R eport Page ii

• From 2002 to 2013 , total sulfur dioxide emissions declined by 95 percent for these three

units and by 93 percent for all New Hampshire EGUs reporting to EPA’s Clean Air Markets Division (CAMD ) ;

• S imilar reductions in SO 2 emissions are occurring throughout the MANE

- VU region , the

result of a major shift within the power production sector away from coal toward greater use
of natural gas ;

• Regional emissions of other haze

- causing pollutants, partic ularly NOx and volatile organic compounds (VOC)

, are expected to continue on a downward trend;

• F or the period 2009

- 2013 (the most recent 5 year s of certified monitoring data at the time of this report ), all Class I areas affected by New Hampshire’s regional

- haze

- producing emissions showed visibility improvements relative to 2000

- 2004 on both best and worst visibility days

. In fact, for all such areas, observed haze levels were alre ady better than the 2018 reasonable

progress goals (see table below)

.

Observed Visibility vs. Reasonable Progress Goals ( all values in deciviews)

Class I Area
IMPROVE* Site 2000

- 2004

5

- Year Average 2009

- 2013

5

- Year Average 2013
Annual Average 2018

Reason able Progress Goal
20% Worst Days

Acadia National Park 22.9 17.9 16.5 19.4

Moosehorn Wilderness Area** 21.7 16.8 15.9 19.0

Great Gulf Wilderness Area*** 22.8 16.7 15.0 19.1
Lye Brook Wilderness Area 24.4 18.8 17.5 20.9
Brigantine Wilderness Area 29.0 23.8 21.5 25.1
20% Best Days

Acadia National Park 8.8 7.0 6.3 8.3

Moosehorn Wilderness Area 9.2 6.7 6.4 8.6

Great Gulf Wilderness Area 7.7 5.9 5.4 7.2
Lye Brook Wilderness Area 6.4 4.9 5.4 5.5
Brigantine Wilderness Area 14.3 12.3 11.8 14.3

* IMPROV E = Interagency Monitoring of Protected Visual Environments program.

** The IMPROVE monitor for Moosehorn Wilderness also represents Roosevelt Campobello International Park.

*** The IMPROVE monitor for Great Gulf Wilderness also represents Presidential Ran ge

- Dry River Wilderness Area.

On the basis of the documented progress , NHDES declares that New Hampshire’s Regional Haze

SIP is sufficient in its current form to achieve the necessary emission reductions to meet the 2018 reasonable progress goals for visibility. Therefore, f urther revision of the existing implementation plan is not needed at this time . Achieving t hese goals represent s the first major milestone toward restoring natural visibility conditions at all Class I areas by the regulatory targe t year of 2064

.NH Regional Haze 5

- Year Progress R eport Page iii

MANE

- VU’S CLASS I AREAS

Acadia National Park

People have been drawn to the rugged coast of Maine throughout history. Awed by its beauty and diversity, early 20th

- century visionaries donated the land that became Acadia National Park, t he first national park east of the Mississippi River. The park is home to the tallest mountain on the U.S. Atlantic coast. Today visitors come to Acadia to hike granite peaks, bike historic carriage roads, or relax and enjoy the scenery.

Roosevelt Cam pobello International Park

A memorial to Franklin Delano Roosevelt and symbol of Canadian

- American friendship, Roosevelt Campobello International Park is a combination indoor/outdoor site renowned internationally. Its historic beauty contributes to the to urism in both the

Province of New Brunswick and the State of Maine. Wooded paths and fields offer vistas of nearby islands, bays, and shores.

Brigantine Wilderness

This trailless area, a tidal wetland and shallow bay habitat along New Jersey’s Atlant ic coastline, is one of the most active flyways for migratory water birds in North America. Birdwatchers, binoculars in hand, have zoomed in on close to 300 species, including Atlantic Brant and American Black

Duck.

Great Gulf Wilderness

Cradled wit hin the rugged crescent of New Hampshire's Presidential Range lies the Great Gulf Wilderness. This

steep

- walled bowl begins at Mount Washington and is flanked by Mounts Jefferson, Adams, and Madison. Great

Gulf is the largest cirque in the White Mountain s of New Hampshire; the small and beautiful Spaulding Lake rests at its floor. From the cirque’s low end, the West Branch of the Peabody River flows eastward.NH Regional Haze 5

- Year Progress R eport Page iv

Lye Brook Wilderness

The Lye Brook Wilderness is in the southern Green Mountains

of Vermont . Lye Brook flows through the western half of this wilderness, which ranges from 900 feet to 2,900 feet above sea level. Most of the wilderness is above 2,500 feet, on a high plateau with several ponds and bogs. Waterfalls and rocky

streams are found he re as well as reflecting pools. The western section is extremely steep, facing west

- northwest toward U.S.

Route 7 and Manchester. Four

- and

- a

- half miles of the Appalachian/Long Trail cross the northwest tip of the

wilderness.

Moosehorn Wilderness

Thi s wilderness is located within northern Maine’s Moosehorn National Wildlife Refuge, a refuge and breeding ground for migratory birds, endangered species, and other wildlife. Scientists at Moosehorn have provided valuable

information to stem the decline in the American Woodcock, also called Timberdoodle. Bald eagles frequent the refuge, and black bears and

white

- tailed deer are common. Ducks, geese,

and loons congregate on more than 50 lakes.

Presidential Range/Dry River Wilderness

The large glacial c irque known as Oakes Gulf lies at the headwaters of the Dry River in New Hampshire.

This river

– and just to the east the Rocky Branch

– carve sharply down through the heart of this Wilderness and offer contrast to the surrounding long, high ridgelines of the Southern Presidential Range and Montalban Ridge. The Dry River is something of a misnomer, as anyone who has tried to cross it after a period of even moderate rain can attest. The streams in this wilderness are flashy and

swift and run cold and clea r from snow that melts

well into the summer.

Photo credits: National Park Service, US Fish and Wildlife Service, and wilderness.netNH Regional Haze 5

- Year Progress R eport Page v

SIP SUBMITTAL

Pursuant to the requirements of 40 CFR 51.308 (g), (h), and (i), New Hampshire submits this regional haze progress report as a SIP revision. New Hampshire has adopted this SIP revision in accordance

with federal regulations at 40 CFR 51.102 and 51.103 and state administrative rule Env

- A 204

.

The following sections address requi rements concerning the status of committed control measures, assessment of current emissions and emission reductions, visibility progress, adequacy of current monitoring strategy, and any impediments to visibility improvement. Lastly, NHDES asserts that

t he original regional haze SIP revision is adequate to achieve continued progress toward the goal of achieving natural visibility conditions by 2064 for mandatory Class I federal areas affected by sources in New Hampshire.

New Hampshire’s Regional Haze SIP contains the emission reductions needed to achieve New Hampshire’s share of emission reductions agreed upon through the regional planning process. Furthermore, the SIP ensures that regional

- haze

- causing emissions from New Hampshire will not

interfere wit h the reasonable progress goals for neighboring states' Class I areas. EPA approved New Hampshire’s Regional Haze SIP on August 22, 2013 ( 77 FR 50602 ). New Hampshire

submitted t his SIP to meet the requirements of 40 CFR 51.308 and the visibility

- related requirements of CAA section 110(a)(2) including, but not limited to

, 110(a)(2)(D)(i)(II) and 110(a)(2)(J)

.

Pursuant to 40 CFR 51.308(g) and 40 CFR 51.102, on August 22, 2014, New Hampshire published

notice of a public hearing and a 30

- day public comment period on the regional haze progress report/

SIP revision

. New Hampshire held a public hearing regarding the SIP revision on September 23,

2014. Comments submitted by EPA and th e Federal Land Managers (FLMs) were addressed and are incorporated into the final SIP. Those comments are summarized and included in Attachment

K

. No comments were received from the general public

.

In accordance with 40 CFR 51.308(i), New Hampshire prov ided the Federal Land Managers an opportunity for consultation, in person, at least 60 days before holding any public hearing on this SIP revision. New Hampshire will continue to coordinate with the FLMs on future revisions to New Hampshire’s Regional Haz e SIP. Section 12 of this document provides details of consultation

with the FLMs.

In summary, this 5

- year progress report fulfills all requirements for SIP submittals and periodic progress reports as set forth in 40 CFR 51.102 ; 51. 103; and 51.308 (g), ( h), and (i).NH Regional Haze 5

- Year Progress R eport Page vi

5

- Year Progress Report Su bmittal Checklist

Yes

or No Regulation

Citation Regulation Summary ( not verbatim ) Location in Report Comments

Y 51.308(g)(1) Status of Control Strategies in the Regional Haze SIP: Does the report

include a lis t of measures the state relied upon? (all states) Sections 3, 4, 5

Y 51.308(g)(2) Emissions Reductions from Regional Haze SIP Strategies: Does the report

include estimated reduction estimates for these measures? ( all states) Sections 6, 7

Y 51.30 8(g )(3) Visibility Progress: Does the report

include the summaries of monitored visibility data as required by the Regional Haze Rule? ( states with Class I areas only) Section 2

Y 51.308(g)(4) Emissions Progress: Does the report provide emissions t rends across the entire inventory for a 5

- year period as required by the Regional Haze Rule? (all states) Sections 6, 7

Y 51.308(g)(5) Assessment of Changes Impeding Progress: Does the report include an explicit statement of whether there are anthrop ogenic emissions changes impeding progress? ( all states) Section 8

Y 51.308(g)(6) Assessment of Current Strategy: Does the report include an assessment of whether the state’s haze plan is on track to meet reasonable progress goals? (all states) Se ction 9

Y 51.308(g)(7) Review of Monitoring Strategy: Does the report review the monitoring plan including any non

- IMPROVE monitors the state is using? ( states with Class I areas only) Section 10

Y 51.308(h) Determination of Adequacy:

Does the re port (or the transmittal materials) provide the explicit determination required by the Regional Haze Rule? (all states) Section 11NH Regional Haze 5

- Year Progress R eport Page vii

TABLE OF CONTENTS

EXECUTIVE SUMMARY

................................ ................................ ................................ ................. i

MANE

- VU’S CLASS I AREAS

................................ ................................ ................................ ...... i ii

SIP SUBMITTAL

................................ ................................ ................................ ............................... v

SECTION 1

– FEDERAL REGIONAL HA ZE PROGRAM REQUIREMENTS

1.1 Background

................................ ................................ ................................ ............................ 1

1.2 Summary of the Requirements for Periodic Progress Reports

................................ ............... 2

1.2.1 General and Procedural Requirements

................................ ................................ .......... 3

1.2.2 Required Elements of the Progress Report

................................ ................................ ... 3

1.2.3 Required State Actions

................................ ................................ ................................ .. 4

1.3 MANE

- VU Regional Course of Action

................................ ................................ ................. 4

1.3.1 Requested Action within MANE

- VU

................................ ................................ ........... 5

1.3.2 Requested Action outside MANE

- VU

................................ ................................ .......... 6

SECTION 2

– CHANGES IN VISIBILITY AT CLASS I AREAS IN THE STATE

2.1 Requirements to Track Visibility Progress

................................ ................................ ............ 7

2.2 Visibility Progress

– General Asse ssment

................................ ................................ ............. 7

2.3 Visibility Progress

– Detailed Assessment

................................ ................................ ............. 8

2.3.1 Gr aphical Analysis of Visibility Trends

................................ ................................ ........ 9

2.3.2 Light Extinction Trends from Constituent PM

................................ ........................... 12

SECTION 3

– STATUS OF BART MEASURES IN THE REGIONAL HAZE SIP

3.1 Requirement to Track BART Im plementation

................................ ................................ ..... 14

3.2 Status of BART Measures

................................ ................................ ................................ .... 14

SECTION 4

– STATUS OF CONTROL MEASURES FOR EGUs

4.1 Requirement to Track Implementation of EGU Control Measures

................................ ..... 17

4.2 Focus on Sulfates and EGUs

................................ ................................ ................................ 17

4.3 EGU Control Measures Included in the SIP

................................ ................................ ........ 17

4.3.1 Clean Air Interstate Rule and Cross

- State Air Pollution Rule

................................ .... 18

4.3.2 State

- Specific EGU Control Measures

................................ ................................ ........ 18

4.3.3 Controls on Top 167 EGU Sources

................................ ................................ ............. 19

4.4 Additional Controls on EGUs Expected by 2018

................................ ................................ 20

4.5 EGU Retirements or Replacements

................................ ................................ ...................... 20NH Regional Haze 5

- Year Progress R eport Page viii

SECTION 5

– STATUS OF ADDITIONAL CONTROL MEASURES IN THE SIP

5.1 Requirement to Track Implementation of Other Control Measures

................................ .... 21

5.2 Low

- Sulfur Fuel Oil Strategy

................................ ................................ ............................... 21

5.3 State

- Specific Control Measures

................................ ................................ .......................... 21

5.3.1 Control Measures for NOx Sources

................................ ................................ ............ 21

5.3. 2 Prevent ion of Significant Deterioration

................................ ................................ ...... 22

5.3. 3 Agricultural and Forestry Smoke Management

................................ .......................... 22

5.3.4 Me asures to Mitigate Impacts of Construction Activities

................................ ........... 24

5.3. 5 Rule for Open Source Emissions

................................ ................................ ................ 24

5.3. 6 Miscellaneous Control Measures

................................ ................................ ................ 24

SECTION 6

– EMISSI ON REDUCTIONS RESULTING FROM IMPLEMENTATION OF

CONTROL MEASURES IN THE SIP

6.1 Requirement to Summarize Emission Reductions

................................ ............................... 26

6.2 Emissions Changes since 2002

................................ ................................ ............................ 26

6.3 Emission Reductions from New Hampshire’s EGUs

................................ ........................... 26

SECTION 7

– CHANGES IN EMISSIONS OF HAZE

- CAUSING POLLUTANTS

7.1 Requirement to Analyze and Track Changes in Emissions

................................ ................. 29

7.2 Data Sources for Analysis of Emissions Trends

................................ ................................ .. 29

7.2.1 2002 Modeling Inventory with Projections to 2018

................................ .................... 30

7.2.2 2007 Modeling Inventory with Projections to 2017 and 2020

................................ .... 30

7.2.3 CAMD Reported Emissions

................................ ................................ ........................ 31

7.3 Summary of Regional Emissions Changes

................................ ................................ .......... 31

7.3.1 Sulfur Dioxide

................................ ................................ ................................ ............. 32

7.3.2 Oxides of Nitrogen

................................ ................................ ................................ ...... 32

7.3.3 Fine Particulate Matter

................................ ................................ ................................ 32

7.3.4 Volatile Organic Compounds

................................ ................................ ...................... 33

7.4 Summary of New Hampshire Emissions Changes

................................ ............................... 35

SECTION 8

– ASSESSMENT OF SIGNIFICANT EMISSION CHANGE S THAT HAVE

IMPEDED VISIBILITY PROGRESS

8.1 Requirement to Assess whether Emissions Changes Have Impeded Progress

.................... 37

8.2 Assessment

................................ ................................ ................................ ........................... 37NH Regional Haze 5

- Year Progress R eport Page ix

SECTION 9

– SUFFICIENCY OF SIP TO MEET REASONABLE PROGRESS GOALS

9.1 Requirement to Assess Sufficiency of Plan

................................ ................................ ......... 39

9.2 Assessment

................................ ................................ ................................ ........................... 39

SECTION 10

– MONITORING STRATEGY REVIEW

10.1 Requirement to Review Monitoring Strategy

................................ ................................ .... 40

10.2 Strategy Review

................................ ................................ ................................ ................. 40

SECTION 11

– ADEQUACY OF CURRENT REGIONAL HAZE SIP

11. 1 Requirement to Determine Adequacy of Current SIP

................................ ........................ 41

11.2 Determination of SIP Adequacy : Negative Declaration

................................ ................... 41

SECTION 12

– CONSULTATION WITH FEDERAL LAND MANAGERS

12.1 Requirement to Consult Federal Land Managers

................................ ............................... 42

12.2 Consultation Process

................................ ................................ ................................ .......... 42

LIST OF FIGURES

Figure 1

- 1 Nearby Class I Areas

................................ ................................ ................................ ....... 1

Figure 1

- 2 U.S. Regional Planning Organizations

................................ ................................ ............ 2

Figure 2

- 1 Visibility Progress at Acadia National Park

................................ ................................ .. 10

Figure 2

- 2 Visibility Progress at Moosehorn Wilderness Area

................................ ...................... 10

Figure 2

- 3 Visibility Progress at Great Gulf Wilderness Area

................................ ....................... 11

Figure 2

- 4 Visibility Progress at Lye Brook Wilderness Area

................................ ....................... 11

Figure 2

- 5 Visibility Progress at Brigantine Wilderness Area

................................ ....................... 12

Figure 2

- 6 PM Constituent Contributions to Haze Levels at Acadia National Park

on Best and Worst Visibility Days

................................ ................................ ................ 13

F igure 4

- 1 Location of 167 EGU Stacks Contributing the Most to Visibility Impairment

at MANE

- VU Class 1 Areas

................................ ................................ ......................... 19

Figure 6

- 1 SO 2 and NOx Emissions from New Hampshire EGUs in 2002 and 2013

..................... 28NH Regional Haze 5

- Year Progress R eport Page x

LIST OF TABLES

Table 2

- 1 Observed Visibil ity vs. Established Visibility Goals (deciviews)

................................ .... 8

Table 3

- 1 New Hampshire BART Controls and Implementation Status

................................ ........ 15

Table 4

- 1 Status of New Hampshire EGU Control Measures Included in MANE

- VU Modeling

.... 18

Table 4

- 2 Status of SO 2 Control Measures at Targete d EGU s in New Hampshire

.......................... 20

Table 6

- 1 SO 2 and NOx Emissions from New Hampshire EGUs in 2002 and 2013

..................... 27

Table 7

- 1 Annual Air Pollutant Emissions in the MANE

- VU Region, 2002

- 2020 (tons/year)

.......... 34

Table 7

- 2 Annual Air Pollutant Emissions in New Hampshire, 2002

- 2020 (tons/year)

..................... 36

Table 1 0

- 1 IMPROVE Network Site for New Hampshire’s Class I Areas

................................ ..... 40

LIST OF A TTACHMENT S

Attachment A Acronyms and Abbreviations

Attachment B Tracking Visibility Progress, 2004

- 2011

Attachment C Overview of State and Federal Action s Relative to MANE

- VU Asks

Attachment D Regional Emissions Trends Analysis for MANE

- VU States

Attachment E NH Administrative Rule Env

- A 2302.02 (Amended)

Attachment F Evidence of Plan’s Adoption

Attachment G Evidence of Legal Authority

Attachment H Evidence That New Hampshire Followed All Procedural Requirements

Attachment I Evidence of Public Notice

Attachment J Certification of Public Hearing

Attachment K Compilation of Public Comments and NHDES’s Response TheretoNH Regional Haze 5

- Year Progress Report Page 1

SECTION 1

– FEDERAL REGION AL HAZE PROGRAM REQUIREMENTS

1.1 Background

The federal Clean Air Act (CAA) sets requirements to protect the air

- quality

- related values of national parks and wilderness areas. Specifically, Section 169A of the CAA requires the “prevention of any futur e, and the remedying of any existing

, impairment of visibility in Class I areas which impairment results from manmade air pollution.”

Areas protected by this portion of the law include national parks exceeding 6,000 acres, wilderness

areas and national me morial parks exceeding 5,000 acres, and all international parks in existence on August 7, 1977. There are 156 mandatory Class I federal areas in the United States, of which seven

are in the Mid

- Atlantic and Northeast Region (Figure 1

- 1).

Figure 1

- 1. Nea rby Class I Areas

Section 169A of t he CAA directed the U.S. Environmental Protection Agency (EPA) to promulgate regulations to assure reasonable progress toward meeting the national goal of improved visibility

in Class I areas. O n July 1, 1999, the EPA finalized the Regional Haze Rule ( published at 64 FR

35714 and codified at 40 CFR 51.300

- 309 ). The rule calls for state, tribal, and federal agencies to work together to improve visibility.

Working with the states, 3 EPA designated five Regional Planning Organizations ( RPOs) (Figure 1

- 2) to assist with the coordination and cooperation states needed to address the visibility issue

. New Hampshire is a member of the Mid

- Atlantic/Northeast Visibility Union (MANE

- VU).

3 From this point forward, as used in this report, “state” means either a state or a tribe. Map of


### MANE

- VU
REGIONNH Regional Haze 5

- Year Progress R eport Page 2

Figure 1

- 2. U.S. Regional Planning Organizations

St ates in the Mid

- Atlantic and Northeast region, along with Federal Land Manage rs (FLM s ) and

EPA , worked together through MANE

- VU to develop strategies for reducing the haze that obscures natural vistas at mandatory Class I areas. A NESCAUM report 4 prepared for MANE

- VU determined that the predominant cause of haze pollution in Northeast parks and wilderness areas is sulfate particles (aerosols) present in, or formed from, emissions when coal or oil is burned to provide heat and power to homes, businesses, an d industries. Additional pollutants

– especially oxides of nitrogen and organic carbon

– contribute to regional haze. Sources of these other pollutants include emissions from power plants, boilers, furnaces, motor vehicles, and other fuel

- burning equipme nt (including wood combustion devices), and natural sources such as forest fires.

EPA’s Regional Haze Rule requires states to revise their State Implementation Plans, or SIPs, to reduce the pollution that causes visibility impairment. These plans establi sh reasonable progress goals and emission reduction strategies for various air pollution sources

– including point sources, area sources, and mobile sources (both on

- road and non

- road)

– whose emissions are harmful to visibility

at Class I areas.

1.2 Su mmary of the Requirements for Periodic Progress Reports

40 CFR 51.308(g) requires New Hampshire to submit a report to EPA every 5 years that evaluates progress toward the reasonable progress goal for each mandatory Class I federal area located within

the state and each mandatory Class I federal area located outside the state that may be affected by

emissions from within the state. The 5

- year progress report is intended to fulfill the requirements of 40 CFR 51.308(g), (h), and (i) and must be in the form of a SIP revision that complies with the procedural requirements of 40 CFR 51.102 and 51.103 . The following paragraphs summarize those requirements.

4 NESCAUM, “Contributions to Regio nal Haze in the Northeast and Mid

- Atlantic United States,” August 2006; available

at http://www.nescaum.org/documents/contribution s

- to

- regional

- haze

- in

- the

- northeast

- and

- mid

- atlantic

-- united

- states

. NESCAUM is the Northeast States for Coordinated Air Use Management, a regional association which includes the 6 New England states (Connecticut, Maine, Massachusetts, New Hampshire, Rho de Island, and Vermont) plus New York and New Jersey.NH Regional Haze 5

- Year Progress R eport Page 3

1.2.1 General and Procedural Requirements

The submission of New Hampshire 's first 5

- year periodic pro gress report occurs more than half

- way through the initial 10

- year planning period from 2008 to 2018. Because EPA has accepted January 29, 2010, as the official submittal date of New Hampshire’s first regional haze SIP, the actual regulatory deadline for this progress report is January 29, 2015.

Th is report was prepared and submitted in accordance with the following federal requirements:

• 40 CFR 51.102

– provide notice of SIP public comment periods and hearings;

• 40 CFR 51.103

– submit the SIP revision in accordance with specified requirements;

• 40 CFR 51.308(g)

– evaluate progress toward the reasonable progress goals established in the initial SIP for each mandatory Class I federal area located within the state and each mandatory Class I federal area locat ed outside the state which may be affected by emissions from within the state;

• 40 CFR 51.308(h)

– determine the adequacy of the existing implementation plan; and

• 40 CFR 51.308(i)

– provide continued coordination with other states with Class I areas impac ted by New Hampshire and consult with FLMs at least 60 days prior to any public hearing in order to maintain and improve visibility in Class I areas.

1.2.2 Required Elements of the Progress Report

Pursuant to 40 CFR 51.308(g), periodic progress repor ts must contain at a minimum the following

elements:

(1) A description of the status of implementation of all measures included in the implementation plan for achieving reasonable progress goals for mandatory Class I federal areas both within

and outside th e state.

(2) A summary of the emissions reductions achieved throughout the state through implementation of the measures described in paragraph (1).

(3) For each mandatory Class I federal area within the state, an assessment of the following visibility condit ions and changes, with values for most impaired and least impaired days expressed in terms of 5

- year averages of these annual values:

− the current visibility conditions for the most impaired and least impaired days;

− the difference between current visibilit y conditions for the most impaired and least impaired days and baseline visibility conditions; and

− the change in visibility impairment for the most impaired and least impaired days over the past 5 years.

(4) An analysis tracking the changes over the past 5 y ears in pollutant emissions contributing to visibility impairment from all sources and activities within the state. Emissions changes should be identified by type of source or activity. The analysis must be based on the most recent updated emissions inve ntory, with estimates projected forward as necessary and appropriate, to account for emissions changes during the applicable 5

- year period.NH Regional Haze 5

- Year Progress R eport Page 4

(5) An assessment of any significant changes in anthropogenic emissions within or outside the

state that have occurre d over the past 5 years that have limited or impeded progress in reducing pollutant emissions and improving visibility.

(6) An assessment of whether the current implementation plan elements and strategies are sufficient to enable the state, or other states with mandatory Class I federal areas affected by emissions from the state, to meet all established reasonable progress goals.

(7) For any state with a Class I area, a review of the state’s visibility monitoring strategy and any modifications to the strategy as necessary.

Each of these required elements is addressed in subsequent sections of this report.

1.2.3 Required State Actions

Based on the required calculations and assessments in the progress report, the state must take one of four actions as speci fied in 40 CFR 51.308(h):

(1) If the s tate determines that the existing implementation plan requires no further substantive revision at this time in order to achieve established goals for visibility improvement and emissions reductions, the s tate must provid e to the EPA Administrator a negative declaration that further revision of the existing implementation plan is not needed at this time.

(2) If the s tate determines that the implementation plan is or may be inadequate to ensure reasonable progress due to emi s sions from sources in another s tate(s) which participated in a regional planning process, the s tate must provide notification to the EPA Administrator and

to the other s tate(s) which participated in the regi onal planning process with the states. The

s tate must a lso collaborate with the other s tate(s) through the regional planning process for the purpose of developing additional strategies to address the plan's deficiencies.

(3) Where the s tate determines that the implementation plan is or may be inadequate to ensure reasonable progress due to emissions from s ources in another country, the s tate shall provide notification, along with available information, to the EPA Administrator.

(4) Where the s tate determines that the implementation plan is or may be inadeq uate to ensure reasonable progress due to emi ssions from sources within the state, the s tate shall revise its implementation plan to address the plan's deficiencies within one year.

1.3 MANE

- VU Regional Course of Action

The reasonable progress goals ad opted by the MANE

- VU Class I states represent implementation of the regional course of action set forth by MANE

- VU on June 20, 2007 in two resolutions: “Statement

of the Mid

- Atlantic/Northeast Visibility Union (MANE

- VU) Concerning a Course of Action within

MANE

- VU toward Assuring Reasonable Progress,” and “ Statement of The Mid

- Atlantic/Northeast Visibility Union (MANE

- VU) Concerning a Request for a Course of Action by States Outside of

MANE

- VU toward Assuring Reasonable Progress

. ” These two resolutions are components of what

is commonly known as the MANE

- VU Ask. 5

5 Both statements may be found in Attachment E to New Hampshire’s Regional Haze SIP at http://des.nh.gov/organization/div isions/air/do/asab/rhp/sip.htm

.NH Regional Haze 5

- Year Progress R eport Page 5

MANE

- VU modeling demonstrated that the control strategies for meeting the Reasonable Progress

Goals would enable all MANE

- VU Class I areas to meet their targets for visibility improvement in

2018. These control strategies included On

- the

- Books / On

- the

- Way (OTB/OTW) and Beyond

- on

the

- Way (BOTW) measures (see Section 7.2.1) as well as the additional control measu res described in Sections 1.3.1 and 1.3.2, below.

1.3.1 Requested Action within MANE

- VU

On June 20, 2007, the Mid

- Atlantic and Northeast States agreed to pursue a coordinated course of

action that would assure reasonable progress in reducing regional haze at mandatory Class I federal

areas within the MANE

- VU region . The coordinated effo rt would also leverage the multi

- pollutant benefits that such measures may provide for the protection of public health and the environment.

This course of action went beyond OTB/OTW and BOTW measures to include the adoption and implementation of the follo wing emission control strategies by the MANE

- VU states, as appropriate and necessary:

• Timely implementation of BART requirements.

• A 90% or greater reduction in sulfur dioxide (SO 2 ) emissions from each of the electric generating unit (EGU) stacks identifi ed by MANE

- VU as rea sonably anticipated to cause or contribute to impairment of visibility in each mandatory Class I federal area in the MANE

VU region

– comp rising 167 stacks in total

. 6 If it were determined to be infeasible for a

state to achieve that l evel of reduction from a targeted unit, equivalent alternative measures would be pursued in such state.

• A low

- sulfur fuel oil strategy in the inner zone states (New Jersey, New York, Delaware, and Pennsylvania, or portions thereof) to reduce the sulfur co ntent of: distillate oil to 0.05% sulfur by weight (500 ppm) by no later than 2012, of #4 residual oil to 0.25% sulfur by weight by no later than 2012, of #6 residual oil to 0.3

– 0.5% sulfur by weight by no later than 2012, and to further reduce the sulf ur content of distillate oil to 15 ppm by 2016.

• A low

- sulfur fuel oil strategy in the outer zone states (the remainder of the MANE

- VU region) to reduce the sulfur content of distillate oil to 0.05% sulfur by weight (500 ppm) by no later than 2014, of #4 r esidual oil to 0.25

– 0.5% sulfur by weight by no later than 2018, and of #6 residual oil to no greater than 0.5% sulfur by weight by no later than 2018, and to further reduce the sulfur content of distillate oil to 15 ppm by 2018, depending on supply

avai lability.

• Continued evaluation of other control measures, including energy efficiency, alternative (clean) fuels, additional measures to reduce SO 2 and nitrogen oxide (NO

x ) emissions from

all coal

- burning facilities by 2018, and new source performance sta ndards for wood combustion. These and other measures would be evaluated during the consultation process to determine whether they were reasonable.

This long

- term strategy to reduce and prevent regional haze would allow each state up to ten years
to pursu e adoption and implementation of reasonable NO

x and SO 2 control measures.

Note that NHDES did not include MANE

- VU’s low

- sulfur fuel oil strategy in New Hampshire’s initial regional haze SIP as an enforceable control measure but did include a commitment to evaluate this strategy further for possible implementation by 2018.

6 The list of 167 stacks is available from the web address in the previous footnote

.NH Regional Haze 5

- Year Progress R eport Page 6

1.3.2 Requested Action outside MANE

- VU

Also on June 20, 2007, the MANE

- VU states adopted a statement requesting that states outside the

MANE

- VU region identified as contributing to vi sibility impairment in the MANE

- VU mandatory Class I federal areas pursue a course of action similar to that of the MANE

- VU states. This course

of action would assure reasonable progress toward preventing any future, and remedying any existing, impairment of visibility in those Class I areas . The requested course of action for the non

MANE

- VU states called for the adoption and implementation of the following emission control strategies, as appropriate and necessary:

• Timely implementation of BART requirem ents.

• A 90% or greater reduction in sulfur dioxide (SO 2 ) emissions from each of the electric generating unit (EGU) stacks identified by MANE

- VU as reasonably anticipated to cause or contribute to impairment of visibility in each mandatory Class I federal area in the MANE

VU region

– comprising 167 stacks in total

. 7 If it were determined to be infeasible for a state to achieve that level of reduction from a targeted unit, equivalent alternative measures would be pursued in such state.

• The application of r easonable controls on non

- EGU sources resulting in a 28% reduction in

non

- EGU SO 2 emissions by 2018, relative to on

- the

- books/on

- the

- way 2018 projections used in regional haze planning

– a reduction equivalent to that which would be achieved through MANE

- V U’s low

- sulfur fuel oil strategy. 8

• Continued evaluation of other control measures, including measures to reduce SO 2 and nitrogen oxide (NO

x ) emissions from all coal

- burning facilities by 2018, and promulgation of new source performance standards for wood combustion. These and other measures would be evaluated during the consultation process to determine whether they were

reasonable.

This long

- term strategy to reduce and prevent regional haze would allow each state up to ten years to pursue adoption and i mplementation of reasonable NO

x and SO 2 control measures.

7 See footnote 6

.

8 MANE

- VU requested the 28 percent reduction in emissions from non

- EGU sources outside the MANE

- VU region as being equiv alent to the 2018 projected emission reductions that would result from implementation of the low

- sulfur fuel oil strategy within the MANE

- VU region . This request intentionally omitted reference to specific control measures, as

the MANE

- VU states thought t hat each contributing non

- MANE

- VU state should be allowed to determine the most reasonable way to achieve the requested reduction.NH Regional Haze 5

- Year Progress R eport Page 7

SECTION 2

– CHANGES IN VISIBILITY AT CLASS I AREA S IN THE STATE

2.1 Requirements to Track Visibility Progress

The ultimate goal of the Regional Haze Rule is to restore natural visibility cond itions to each of the 156 Class I areas identified in the 1977 Clean Air Act Amendments by 2064. The regional

haze SIPs must contain measures that make “reasonable progress” toward this goal by reducing anthropogenic emissions that cause haze. For each C lass I area, there are three metrics of visibility that enter into the determination of reasonable progress: 1) baseline conditions, 2) natural conditions (in 2064), and 3) current conditions.

40 CFR 51.308(g)(3) of the Regional Haze Rule requires states with Class I areas to assess the current visibility conditions for the five years of most recent visibility data, compare those conditions to baseline visibility conditions for the 2000

- 2004 period, and assess the change in visibility impairment over the p ast five years for each area. To lessen the influence of year

- to

- year variability, the Regional Haze Rule mandates the use of 5

- year average visibility va lues for the 20% best (least impaired) and 20% worst (most impaired) days in determining visibility p rogress.

Progress in improving visibility at Class I areas is measured via the IMPROVE (Interagency Monitoring of Protected Visual Environments) monitoring network. A coalition composed of the

Nat ional Park Service (NPS), the Fish and Wildlife Service (FWS), the Bureau of Land Management (BLM), the Forest Service (FS) and the USEPA established the IMPROVE program in response to the 1977 CAA amendments. This monitoring network has collected speciat ed fine aerosol and related visibility data in or near Class I federal areas since 1988.

2.2 Visibility Progress

– General Assessment

MANE

- VU states with mandatory Class I federal areas adopted in their regional haze SIPs a set

of goals for visibility improvement by 2018. These intermediate goals were approved by EPA as representing reasonable progress toward the restoration of natural visibility conditions at Class I areas by 2064. Table 2

- 1 presents observed visibility values, expressed in deciviews , for MANE

VU’s Class I areas versus the corresponding short

- term (2018) and long

- term (2064) visibility goals.

The 5

- year average deciview values fo r the periods 2000

- 2004 and 2009

- 2013 are presented along

with visibility improvements. The data indica te that all MANE

- VU Class I areas have seen reduced

haze levels since 2000

- 2004 and are , in fact, already surpassing their 2018 reasonable progress goals.

For the assessment of visibility progress, t he Regional Haze Rule, at 40 CFR 51.308(g)(3), requires

a determination of the change in visibility impairment for the most impaired and least impaired days over the past five years. This would involve a comparison of the 2009

- 2013 mean value s against

the 2004

- 2008 mean value s for each Class I area

. T he compari son in Table 2

- 1 use s the 2000

- 2004

mean values , instead, to provide a better representation of visibility progress since the beginning of

the current planning period

. All sites have seen i mprovements of approximately 5

- 6 deciviews on the 20 percent worst days and approximately 1

- 2 deciviews on the 20 percent best days through

2013

. The observed rates of improvement exceed prior projections and are mainly due to regional

emission reductions of haze

- causing pollutants in the past decade. While continued i mprovement is expected, past rates may not be indicative of future visibility progress.NH Regional Haze 5

- Year Progress R eport Page 8

Table 2

- 1. Observed Visibility vs. Established Visibility Goals (deciviews)

Class I Area

IMPROVE * Site 2000

- 2004

5

- Year Average 2009

- 2013

5

- Year Average Difference = Visibility Improvement 2013

Annual Average 2018

Reasonable Progress Goal 2064 Goal (Natural Visibility)
20% Worst Days

Acadia National Park 22.9 17.9 5.0 16.5 19.4 12.4

Moosehorn Wilderness Area** 21.7 16.8 4.9 15.9 19.0 12.0

Great Gulf Wilderness Ar ea*** 22.8 16.7 6.1 15.0 19.1 12.0
Lye Brook Wilderness Area 24.4 18.8 5.6 17.5 20.9 11.7
Brigantine Wilderness Area 29.0 23.8 5.2 21.5 25.1 12.2
20% Best Days

Acadia National Park 8.8 7.0 1.8 6.3 8.3 4.7

Moosehorn Wilderness Area 9.2 6.7 2.5 6.4 8.6 5.0

Great Gulf Wilderness Area 7.7 5.9 1.8 5.4 7.2 3.7
Lye Brook Wilderness Area 6.4 4.9 1.5 5.4 5.5 2.8
Brigantine Wilderness Area 14.3 12.3 2.0 11.8 14.3 5.5

* IMPROVE = Interagency Monitoring of Protected Visual Environments program.

** The IMPROVE monitor for Moosehorn Wilderness also represents Roosevelt Campobello International Park.

*** The IMPROVE monitor for Great Gulf Wilderness also represents Presidential Range

- Dry River Wilderness Area.

2.3 Visibility Progress

– Detailed Assessment

NESCAUM produced a comprehensive study for MANE

- VU: “Tracking Visibility Progress, 2004

- 2011” ( Attachment B ). The analysis was performed to determine the extent of progress in meeting

short

- term and long

- term visibility goals under the Regional Haze Rule

. This technical document examined visibility data collected from IMPROVE’s Class I area monitors, starting with the historic baseline period of 2000

- 2004 and ending with 2009

- 2011, the la st 5

- year period for which data

were available at the time of the r eport

.

The results of the NESCAUM analysis are summarized as following:

• There are definite downward trends in overall haze levels at the Class I areas in and adjacent

to the MANE

- VU region

. 9

• Based on 5

- year rolling averages demonstrating progress since th e 2000

- 2004 baseline period, the MANE

- VU Class I areas appear to be on track to meet their 2018 reasonable progress goals (RPGs) for both best and worst visibility days.

• The trends in visibility improvement are mainly driven by large reductions in sulfate light extinction and, to a lesser extent, nitrate light extinction.

• Levels of organic carbon mass (OCM) and light absorbing carbon (LAC) appear to be approaching natural background levels on days of best visibility at most of the MANE

- VU

Class I areas.

• In some cases, the levels set by the 2018 reasonable progress goals have already been met, and progress beyond those goals appears achievable.

9 New Hampshire’s regional haze SIP has previously shown that sources in New Hampshire do not contribute significantly to vis ibility impairment in Class I areas outside the MANE

- VU region. The same is true for visibility impairment at Brigantine Wilderness Area, for which New Hampshire’s contribution to total sulfate aerosol is less than 1 percent. References to Brigantine and non

- MANE

- VU Class I areas are included for context only and do not signify any obligation on New Hampshire’s part with respect to visibility at those locations.NH Regional Haze 5

- Year Progress R eport Page 9

• Although the Brigantine Wilderness Area in New Jersey is on track to meet its 2018 reasonable progress goals, challe nges remain. Sulfate light extinction levels are higher at this site than at others across the region. Additional sulfate reductions would be effective in reducing overall haze levels at Brigantine. 10

2.3.1 Graphical Analysis of Visibility Trends

Figu res 2

- 1 through 2

- 5, taken from the NESCAUM study and updated with visibility values for 2012

and 2013

, display the annual average deciview (haze index) levels on the 20 percent worst and 20 percent best visibility days for each MANE

- VU Class I area . The observational data cover the period

2000

- 2013 and are shown in relation to established visibility goals to facilitate interpretation. The

MANE

- VU Class I areas are graphed individually and arranged in approximately north

- to

- south order. Corresponding num erical data ( through 2011 ) are found in Tab le A

- 1 of the NESCAUM report ( Attachment B ).

The visibility graphs have been drawn using the following conventions:

• Blue and purple diamonds represent annual average deciview values for best and worst visibility days, respectively.

• Solid red (worst) and blue (best) lines represent 5

- year

- back rolling averages.

• Red (worst) and black (best) plus signs represent the 2018 reasonable progress goals established in New Hampshire’s regional haze SIP.

• Red (worst) and bla ck (best) dotted lines represent hypothetical glidepaths to meet the 2018 reasonable progress goals.

• Red (worst) and black (best) dashed lines represent hypothetical glidepaths to meet long

term natural visibility goals. The worst

- day glidepath is also ca lled the “uniform rate of progress” line, and the best

- day glidepath is also called the “no degradation” line. 11

• The grey region denotes the range of 20 percent best to 20 percent worst haze levels expected to occur under natural conditions. By design, the uniform rate of progress line intersects with the upper limit of the grey area in 2064.

These figures indicate that, from 2000 to 2013 , haze levels declined on the best and worst days across the entire region. Visibility trends documented in the last NE SCAUM report 12 for the period ending in 2008 largely continued through 2010. Most Class I areas experienced a relatively steep drop in deciview values for the 20 percent worst days between 2007 and 2010

, followed by a brief uptick in haze levels before res umption of t he downtrend

. T his somewhat irregular pattern may be explained by meteorological variability and changes in regional emission s in the period after 2007

. The 5

- year averaging of annual deciview values (represent ed by solid lines) smooths any s hort

- term effects and validates the general trend toward improved visibility on both best and worst days over the period analyzed.

10 See footnote 9

.

11 F or the Brigantine Wilderness Are a , whose haze levels on the 20 perc ent be st days during the 2000

- 2004 baseline period were higher than estimated natural conditions on the 20 percent worst days, the no degradation line (repr esenting the long

- term best

- day goal) is higher than the uniform rate of progress line (representing the l ong

- term worst

- day goal) at dates approaching 2064. Th is nonsensical situation is an artifact of technical guidance and only represents stated visibility goals, not anticipated results.

12 NESCAUM, “ Tracking Visib ility Progress, 2004

- 2008,” MANE

- VU Tec hnic al Memorandum, May 12, 2010;

a vailable at http://www.nescaum.org/documents/tracking

- progress

- final

- 05

- 12

- 10.pdf

.NH Regional Haze 5

- Year Progress R eport Page 10

Figure 2

- 1. Visibility Progress at Acadia National Park

Figure 2

- 2. Visibility Progress at Moosehorn Wilderness AreaNH Regional Haze 5

- Year Progress R eport Page 11

Figure 2

- 3. Visibility Progress at Great Gulf Wilderness Area

F igure 2

- 4. Visibility Progress at Lye Brook Wilderness AreaNH Regional Haze 5

- Year Progress R eport Page 12

Figure 2

- 5. Visibility Progress at Brigantine Wilderness Area

2.3 .2 Light Extinction Trends from Constituent PM

I n addition to analyzing overall visibility trends at the Class I monitor sites, NESCAUM examined the underlying air quality data for changes in particulate matter (PM) constituent contributions to visibility impairment. The report “Tracking Visibility Pro gress, 2004

- 2011” ( Attachment B ) includes a series of figures depicting annual haze levels broken down by PM constituent contributions on the 20 percent best and 20 percent worst visibility days for each Class I area. Individual contributions

are shown as stacked bar charts for sulfate , nitrate, OCM, LAC , soil, course mass, sea salt, and Rayleigh scatte ring (natural light extinction) . The best

- and worst

- day charts for Acadia National Park, reproduced below in Figure 2

- 6, will serve to illustrate. Charts for the other Class I sites may be found in the attached report.

These graphical analyses confirm that improving visibility at MANE

- VU Class I areas is due primarily to reductions in sulfate impacts on the most impaired days. At the same time, a general decline in sulfate, OCM, and nitrate impacts has resulted in improving visibility on the least impaired days.

NESCAUM’s charts reveal that, for the two Class I area monitors in Maine (Acadia and Moosehorn), the average contribution from sulfate aerosol o n the 20 percent worst days has fallen steadily since the baseline years of 2000

- 2004. At the other MANE

- VU sites, a similar trend in

sulfate contribution occurred until around 2008

- 2009, after which there were no notable changes in sulfate impact. Withi n the MANE

- VU region overall, sulfate’s contribution to total light extinction on the 20 percent worst days declined from about 60

- 75 percent to about 45

- 55 percent, depending

on the Class I area location, over the period examined. As the absolute concent rations of sulfate aerosol have decreased, the other contributors to light extinction have assumed greater importance on a percentage basis.NH Regional Haze 5

- Year Progress R eport Page 13

In summary, sulfate continues to be the largest contributor to light extinction at all MANE

- VU Class I areas, follo wed by OCM, nitrate, and light

- absorbing carbon. Light extinction from soil and sea salt, which help indicate the extent to which natural processes contribute to overall haze levels, is relatively insignificant by comparison. Based on NESCAUM’s analyses, reductions in sulfate and nitrate aerosols appear to be the main cause of trending improvements in best

- and worst

- day visibility. Additional details are available in the attached NESCAUM report.

Figure 2

- 6. PM Constituent Contributions to Haze Levels at Acadia National Park on Best and Worst Visibility DaysNH Regional Haze 5

- Year Progress R eport Page 14

SECTION 3

– STATUS OF BART MEASURES IN THE REGIONAL HAZE SIP

3.1 Requirement to Track BART Implementation

In the 1977 Amendments to the CAA, the U.S. Congress directed E PA and the states to identify existing major stationary sources that had been in operation for no more than 15 years and that caused or contributed to visibility impairment in national parks and wilderness areas designated as mandatory Class I federal area s. Those sources were to install and operate best available retrofit technology (BART) to reduce their impacts on Class I areas.

40 CFR 51.308(g)(1) of the Regional Haze Rule requires that the state’s 5

- year progress report describe the implementation st atus of all measures included in the SIP for achieving reasonable progress goals for Class I areas within and outside the state. As noted in Section 1, New Hampshire

and the other MANE

- VU Class I states relied in part on the timely implementation of BART to meet these goals. Affected sources are required to comply with any BART determinations as expeditiously as practicable, but no later than five years after EPA’s approval of the SIP. New Hampshire’s regional haze SIP revision was more specific in that it required the state’s two BART sources to implement BART control measures by July 1, 2013.

Thus, MANE

- VU’s Class I areas are already benefiting from implementation of BART controls in New Hampshire and elsewhere with in the MANE

- VU region. Further visib ility benefits are likely to

accrue from new emission controls at BART

- eligible facilities located in states outside the MANE

- VU region . However, the previously conducted MANE

- VU modeling associated with the determination of reasonable progress goals did not account for BART control measures in the non

- MANE

- VU states

. Consequently, the modeled visibility projections for MANE

- VU’s Class I areas do not include the additional visibility improvements that would result from such external efforts.

3.2 Status of BART Measures

EPA regulations and guidance allowed states to rely on the Clean Air Interstate Rule (CAIR) as satisfying BART requirements for SO 2 and NOx for certain ele ctricity generating units

. However,

m os t CAIR states in the MANE

- VU region made individual determinations for BART

- eligible

EGUs instead of more broadly relying on CAIR to meet the requirements of BART

. CAIR was challenged in court and remanded to EPA for revision. In 2011, EPA replaced CAIR with the

Cross

- State Air Pollution Rule (CSAPR)

. CSAPR itself was challenged, then vacated , and finally

reinstated following an appeal by EPA to the U.S. Supreme Court . (S ee Section 4.3.1 for details

. )

New Hampshire was never a CAIR sta te and, consequently, did not r e ly on this program to meet
SIP requirements for in

- state BART

- eligible units. However, New Hampshire has counted on the emission reductions that BART would produce in upwind states and therefore has an interest in the

final resolution of CAIR/CSAPR

.

Attachment C is a memorandum from Paul Miller of NESCAUM to MANE

- VU summarizing

states’ actions re lative to the M ANE

- VU Ask

, includ ing synopses of the individual stat es’ BART

determinations and implementation status as of March 28, 2013

. The memo includes a few

instances in which states employed alternatives to BART to fulfill regional haze SIP requirement s

. New Hampshire has two units subject to BART, both of which are EGUs owned and oper ated by Public Service of New Hampshire (PSNH): Merrimack Station Unit 2 and Newington Station Unit 1. The BART control measures for these units are enforceable through a combination ofNH Regional Haze 5

- Year Progress R eport Page 15

existing permit conditions and administrative rules, including New H ampshire Administrative R ule

Env

- A 2300: Mitigation of Regional Haze , which was adopted into the SIP with an effective date of September 21, 2012 (Table 3

- 1). 13

Table 3

- 1. New Hampshire BART Cont rols and Implementation Status

Pollutant BART Controls /

Emission Limitations NH Regulatory Citations Compliance

Deadline Status

PSNH Merrimack Station Unit 2

SO 2 Fuel sulfur limits Administrative Rule Env

- A 1604.01:

Maximum Sulfur Content

Allowable in Coal N.A. Pre

- existing requirement

Flue gas desulfurization (FGD), with required SO 2 percent reduction set at maximum sustainable rate,

but not less than 90% as a calendar monthly average Administrative Rule Env

- A 230 0: Mitigation of Regional Haze, paragraph 2302.01(b)(1);

Temporary permit for FGD system (TP

- 0008) July 1, 2013 FGD is currently operating with 90 +
percent SO 2 r eduction. Maximum sustainable rate is being evaluated. Findings are December 31, 2014

, and w ill be incorporated as permit

condition ~ 2015.

NO x SCR (pre

- existing);

NOx emission limit of 0.30 lb/MMBtu, 30

- day rolling

average Administrative Rule Env

- A 2300: Mitigation of Regional Haze, paragraph 2302.01(b)(2) July 1, 2013 Emission limit is in effect.

Reference to Env

- A 2300 will be included in facility’s Title V operating permit (TV

- 0055) ~ 2015.

PM Two ESPs in series (pre

existing);

TSP emission limit of 0.08

lb/MMBtu Administrative Rule Env

- A 2300: Mitigation of Regional Haze, paragraph 2 302.01(b)(3) July 1, 2013 Emission limit is in effect.

Reference to Env

- A 2300 will be included in facility’s Title V operating permit (TV

- 0055) ~ 2015.

PSNH Newington Station Unit 1

SO 2 SO 2 emission limit of 0.50 lb/MMBtu, 30

- day rolling

average, ap plicable to any fuel type or mix Administrative Rule Env

- A 2300: Mitigation of Regional Haze, paragraph 2302.02(a) July 1, 2013 Emission limit is in effect.

Reference to Env

- A 2300 will be included in facility’s Title V operating permit (TV

- 0054) ~ 2015.

NO x Low

- NOx burners, overfire air, and water injection (pre

existing);

NOx emission limits of 0.35

lb/MMBtu with oil and 0.25 lb/MMBtu with oil/gas, 24

- hour calendar day average Administrative Rule Env

- A 2300: Mitigation of Regional Haze, paragraph 2302 .02(b) N.A. (Existing

controls are BART.) Emission limit is in effect

. Reference to Env

- A 2300 will be included in facility’s Title V operating permit (TV

- 0054) ~ 2015.

PM Electrostatic precipitator (pre

- existing);

TSP emission limit of 0.04

lb/MMBtu Administrative Rule Env

- A 2300: Mitigation of Regional Haze, paragraph 2302.02(c) N.A. (Existing

controls are BART.) TSP emission limit is revised

. Associated rule revision is

submitted for inclusion in the SIP

. Reference to Env

- A 2300 will be

included in facility’s Title V operating permit (TV

- 0054) ~ 2015.

13 A revision to Env

- A 2302.02 provides for a new, lower TSP emission limit of 0.04 lb/MMBtu for Newington Station

, as listed in the table

. The adopted rule is submitted herewith for SIP approval ; see Attachment E

.NH Regional Haze 5

- Year Progress R eport Page 16

40 CFR 51.308(e)(1)(v) requires that each source subject to BART maintain the required control equipment and establish procedures to ensure such equipment is properly operated and maintained.

N ew Hampshire’s SIP meets this requirement by including in the Title V operating permit for each BART source provisions to ensure proper operation and maintenance of the control equipment. Note that, because New Hampshire does not have a merged constructio n permitting and Title V permitting program, requirements related to BART first need to be placed into a state temporary permit ( i.e. , construction permit) before they can be incorporated subsequently into a Title V operating permit.NH Regional Haze 5

- Year Progress R eport Page 17

SECTION 4

– STATUS O F CONTROL MEASURES FOR EGUs

4.1 Requirement to Track Implementation of EGU Control Measures

As noted in the preceding section, 40 CFR 51.308(g)(1) requires that the 5

- year progress report describe the implementation status of all measures included in t he SIP for achieving reasonable progress goals for Class I areas within and outside the state. Section 1 of this report outlines the strategy adopted by New Hampshire and the other MANE

- VU states for achieving these goals. The

MANE

- VU strategy relies in part on emission reductions by 2018 from the top 167 (targeted) EGU sources or equivalent control measures in the states where those sources are located. This section

describes the status of those and other EGU control measures , with emphasis on N ew H amps hire 's

actions

. Note that th ere is some overlap between units subject to BART ( see Section 3) and the

EGUs covered in this section

.

4.2 Focus on Sulfates and EGUs

The MANE

- VU Contribution Assessment 14 produced a conceptual model of regional haze in wh ich sulfate emerged as the most important constituent of haze

- forming fine particle pollution and the principal cause of visibility impairment across the region. This model is supported by NESCAUM’s

more recent analysis of light extinction trends describe d in Section 2.3.2

. 15

The Contribution Assessment found that , in 2002, SO 2 emissions originating within MANE

- VU were responsible for approximately 25 percent of total sulfate aerosol at MANE

- VU Class I areas.

Sources in the Southeast and Great Lakes regio ns were responsible for about 15 to 25 percent each. Sources in the Midwest and Canada were responsible for most of the remainder. Point sources dominated the inventory of SO 2 emissions. In response to these findings , MANE

- VU designed its long

- term stra tegy to include additional control measures on SO 2 sources within the MANE

- VU region and in neighboring states that contribute significantly to regional haze at MANE

- VU Class I Areas. Electrical generating units were identified as the largest source categ ory contributing to these emissions, and EPA’s Clean Air Interstate Rule was the strategy of choice for most states to

reduce SO 2 emissions from EGUs by 2018.

4.3 EGU Control Measures Included in the SIP

Since 2002, various control measures to reduce e missions from EGUs have been realized through a number of mechanisms, including CAIR, individual state programs, federal consent agreements,

and source

- specific permitting actions. The EGU emissions used in MANE

- VU’s modeling to help

determine reasonable progress goals are described in an August 2009 document. 16 Changes in

emissions since 2002 are summarized in Section s 6 and 7 of this report. The following information

describes the status of EGU control measures included in the SIP that have been effecti ve in reducing regional

- haze

- causing emissions.

14 See footnote 4

.

15 Unlike NESCAUM’s graphical analysis , t he Contr ibution Assessment was based on pa rticle mass. Light extinction and particle mass are two different ways of representing visibility impairment and do not yield identical results.

16 Alpine Geophysics, LLC and MARAMA, “Documentation of 2018 Emissions from Electric Generating Units in the

Ea stern United States for MANE

- VU’s Regional Haze Modeling,” final report, August 16, 2009 ; available at http://www.marama.org/publications_folder/EGU_Projecti ons_Summary_Final_Aug_2009.pdf

.NH Regional Haze 5

- Year Progress R eport Page 18

4.3.1 Clean Air Interstate Rule and Cross

- State Air Pollution Rule

On May 12, 2005, the EPA promulgated CAIR, which required reductions in emissions of SO 2 and/or NO X from large fossil

- fuel

- fired EGUs in 27 eastern states, including MANE

- VU members Massachusetts, Connecticut, New York, New Jersey, Pennsylvania, Delaware, and Maryland, plus the District of Columbia. These emission reductions were among the many inputs to the MANE

VU 2018 modeling projectio ns. The U.S. Court of Appeals for the D.C. Circuit ruled on petitions for review of CAIR and CAIR federal implementation plans, including their provisions establishing

the CAIR NO X annual, NOx ozone season, and SO 2 trading programs. On July 11, 2008, the court issued an opinion vacating and remanding these rules. However, parties to the litigation requested rehearing of aspects of the court's decision, including the vacatur. The court’s subsequent ruling of December 23, 2008, to remand without vacatur l eft CAIR in place until EPA issued a new rule to replace CAIR in accordance with the July 11, 2008, decision.

In separate actions on July 6, 2011, and December 15, 2011, followed by a number of technical revisions and minor adjustments, the EPA finalized CSAPR as a replacement for CAIR. It was EPA’s intention that, beginning in 2012, CSAPR would require 28 states in the eastern half of the United States to reduce power plant emissions: 20 states for annual SO 2 , annual NOx, and ozone

season NOx; 3 states for annual SO 2 and annual NOx; and 5 states for ozone

- season NOx only.

The affected MANE

- VU states were New York, New Jersey, Pennsylvania, and Maryland

. EPA estimated that CSAPR would reduce EGU emissions by 6,500,000 tons of SO 2 and 1,400,000 tons

of N O X annually from 2005 levels. These estimates represented a 71 percent reduction in SO 2 and a 52 percent reduction in NO X in the covered states.

On August 17, 2012, the U.S. Court of Appeals for the D.C. Circuit vacated CSAPR. On October 5, 2012, EPA re quested a rehearing en banc of the CSAPR vacatur. The court denied this request on January 24, 2013. T he U.S. Supreme Court agreed to hear EPA’s appeal of the lower court’s ruling, and, on April 29, 2014

, reversed the D.C. Circuit opinion vacating CSAPR

. This program will now be implemented under a revised schedule beginning in 2015.

4.3.2 State

- Specific EGU Control Measures

As a complement to federal actions, t he individual MANE

- VU states adopted state

- specific emission

control measures beyond CAIR that will help to reduce emissions of haze

- causi ng pollutants from

EGUs

. The regional modeling used to establish the MANE

- VU reasonable progress goals included a large number of s tate control measures, including two New Hampshire regulations affecting local

EGUs

. The se are listed in Table 4

- 1 along with brief descriptions of their current status

.

Table 4

- 1. Status of New Hampshire EGU Control Measures Included in MANE

- VU Modelin g

Control Measure Status

Chapter Env

- A 2900: Multiple Pollutant Annual Budget Trading and Banking Program , capping NO X emissions at 3,644 tons per year, SO 2 emissions at 7,289 tons per year, and CO 2 emissions at 5,425,866 tons CO 2 per year for all existin g fossil

- fuel fired steam units by December 31, 2006. Effective May 13, 2003; readopted October 1, 2011; not submitted to or approved by EPA as SIP revision.

Chapter Env

- A 3200 : NO X Budget Trading Program , limiting ozone

season NO X emissions on all fossil

- fuel

- fired EGUs greater than 15 MW to 0.15 lb/MMBtu, effective November 2, 2007. Effective July 17, 1998; readopted November 2, 2007; approved by EPA as SIP revision November 14, 2000.NH Regional Haze 5

- Year Progress R eport Page 19

4.3.3 Controls on Top 167 EGU Sources

With the focus on sulfate em issions and fossil

- fuel

- fired power plants, MANE

- VU reasoned that large reductions in SO 2 could be obtained with the addition of cost

- effective controls on the largest

contributing EGUs . Appendix D of MANE

- VU’s Contribution Assessment identified 167 EGU

s ources in the Northeast, Southeast, and Midwest whose 2002 emissions were most responsible for visibility impairment at MANE

- VU Class I areas (Figure 4

- 1). Three New Hampshire EGUs were among the listed units: PSNH Merrimack Station Units 1 and 2, and PSN H Newington Station Unit 1. (Note that Merrimack 2 and Newington 1 are also BART units

– see Section 3.) MANE

- VU’s long

- term strategy called for a 90 percent reduction in SO 2 emissions from each of these sources, or equivalent measures where this level o f reduction was infeasible for an identified unit.

Figure 4

- 1. Location of 167 EGU Stacks Contributing the Most to Visibility Impairment at MANE

- VU Class I Areas

Note: Some facilities have more than one stack.

Emission controls such as SO 2 scrubb ers have already been placed on many of the 167 targeted EGUs, while other units have seen lower utilization or been shut down entirely . As expected,

m easurable visibility improvements have occurred at Class I areas as a result of these actions.

Attachme nt C includes summary descriptions of the actions taken by individual states within and

outside MANE

- VU to reduce SO 2 emissions from the targeted units. The status of New Hampshire’s

three s ources is shown below (Table 4

- 2 ).NH Regional Haze 5

- Year Progress R eport Page 20

Table 4

- 2

. Status of SO 2 C ontrol Measures at Targeted EGU s in New Hampshire

Facility Name / Unit Fuel Type Control

Method BART
Controls Control

Deadline Control
Status 2002

- 2013
Emission
Reductions *

Merrimack Station (ORISPL 2364) Unit 1 coal scrubber, 90% control (min.) n o t

re quired July 1, 2013 implemented 9,390 tons/year

(96%)

Merrimack Station (ORISPL 2364) Unit 2 coal scrubber, 90% control (min.) yes July 1, 2013 implemented 19,866 tons/year

(95 %)

Newington Station (ORISPL 8002) Unit 1 fuel oil/ natural gas 0.50 lb/MMBtu

SO 2 emission limit yes July 1, 2013 implemented 4,897 tons/year

(94 %)

* See Table 6

- 1 for details.

4.4 Additional Controls on EGUs Expected by 2018

New Hampshire’s long

- term strategy for regional haze did not identify additional controls on EGUs

to r educe haze

- causing emissions beyond those measures already described in Sections 3 and 4. However, it should be mentioned that the flue gas desulfurization system for Merrimack Station has its origins in state law RSA 125

- O: Multiple Pollutant Reduction P rogram , which requires the reduction of mercury emissions by at least 80 percent from New Hampshire's fossil

- fuel

- fired power plants . The 90

- percent

- plus removal of SO 2 at Merrimack Station occurs as a co

- benefit of FGD for mercury control that simultaneo usly fulfills New Hampshire’s separate obligations under BART and the targeted EGU strategy.

More specifically, RSA 125

- O set limits on the aggregate mercury emissions from PSNH’s

Merrimack and Schiller Stations. 17 Although Schiller has no post

- combustion emission controls for either mercury or SO 2 , the Merrimack Station scrubber, because of its size and performance,

allows both plants to meet the statute’s 80

- percent reduction requirement on combined mercury

emissions. Note that RSA 125

- O: Sections 1 and 3, requiring an integrated, multi

- pollutant reduction strategy for certain power plants, were submitted to EPA on September 13, 2013, as part of New Hampshire's infrastructure SIP for the 2010 SO 2 NAAQS.

Aside from this state standard, fossil

- fuel

- fired EGUs will be required to meet EPA’s Mercury and Air Toxic Standards (MATS) for power plants by April 16, 2015, 18 and the 2010 primary 1

- hour NAAQS for SO 2 . The method(s) of compliance for Schiller Station have not yet been determined

but could further redu ce SO 2 emissions in New Hampshire that contribute to regional haze.

4.5 EGU Retirements or Replacements

40 CFR 51.308(d)(3)(v)(D) of the Regional Haze Rule requires New Hampshire to consider source retirement and replacement schedules in its long

- term strategy. Of particular interest is the future disposition of New Hampshire’s fossil

- fuel

- fired EGUs. While recent developments in the oil and gas industry have forced rapid changes in the power production sector, and some generating units have experienc ed sharp reductions in utilization, no retirements or replacements of New Hampshire’s EGUs have occurred or been announced since the regional haze S IP was first submitted in 2010.

17 Schiller Station, which has two coal

- fired units and one wood

- fired unit, is a smaller plant than either Merrimack Station or Newington Station and is not listed among New Hampshire’s BART units or targeted EGUs.

18 Schil ler successfully petitioned EPA for a one

- year extension to April 16, 2016.NH Regional Haze 5

- Year Progress R eport Page 21

S ECTION 5

– STATUS OF ADDITIONAL CONTROL MEASURES IN THE SIP

5.1 Require ment to Track Implementation of Other Control Measures

As previously described, the New Hampshire long

- term strategy for visibility improvement includes the timely implementation of BART controls (Section 3), reductions in SO 2 emissions from key EGUs (Sec tion 4), and consideration of additional control measures. In compliance with 40 CFR 51.308(g)(1), this section reports on the status of additional controls not covered in Sections 3 and 4

.

5.2 Low

- Sulfur Fuel Oil Strategy

In pursuing a regional cour se of action

, the MANE

- V U states developed a low

- sulfur fuel oil

strategy to be implemented within the region by 2018. As described in Section 1.3.1, this strategy

would reduce the sulfur content of distillate and residual fuel oils

, which are used main ly for domestic space heating and for powering industrial, commercial, and institutional boilers. Several MANE

- VU states have already adopted statutes or regulations implementing this strategy. Summary descriptions

of individual states’ efforts in this reg ard are included in Attachment C

.

New Hampshire did not commit to implementing the low

- sulfur fuel oil strategy in its regional haze

SIP but did co mmit to further evaluation of this strategy for possible implementation by 2018

. Accordingly, New Hampshire maintains an interest in pursuing the low

- sulfur fuel oil strategy and is monitoring pr ogress in surrounding states . Incremental fuel costs and the assurance of fuel supplies for the various grades of low

- sulfur oil are real , but diminishing

, concern s as other states’ programs

ramp up. To be successful in New Hampshire, a ny low

- sulfur fuel oil requirement would most likely be implemented via legislative actio n rather than NHDES rulemaking. The prospects for such action

are being evaluated at the time of this progress rep ort

. A low

- sulfur requirement could set fuel sulfur

content limits at levels varying between 25 and 90 percent or more below current standards

, depending on the fuel grade

.

Whether or not New Hampshire implements the low

- sulfur fuel oi l strategy, there will be visibility benefits resulting from regional adoption of this strategy. Should all neighboring states implement this strategy in full

, it is anticipated that New Hampshire ’s fuel oil supply would simply default to

low

- sulfur conte nt in response to market conditions

.

5.3 State

- Specific Control Measures

This section discusses implementation of additional state

- specific control measures relevant to New Hampshire’s regional haze SIP.

5.3.1 Control Measures for NOx Sources

In 2 010, New Hampshire readopted, with minor amendments, administrative rule Env

- A 1300 : Nitrogen Oxides (NOx) Reasonably Available Control Technology (RACT). Previously numbered and approved into the SIP as Env

- A 1211, this rule establishes RACT standards fo r certain NOx

emitting stationary sources located in New Hampshire, to comply with sections 172(c)(1) and 182(b)(2) of the CAA. The rule is applicable to the following stationary source categories: utility boilers, steam electric boilers, industrial boil ers , auxiliary boilers, combustion turbines, internal combustion engines, asphalt plant rotary dryers, incinerators, wallboard dryers, calcining mills, calciners, gypsum rock dryers, emergency generators, load shaving units, and miscellaneous stationary s ources. The rule also establishes the criteria and procedures by which a source canNH Regional Haze 5

- Year Progress R eport Page 22

request alternative RACT emission limits and sets conditions for the use of NOx emission

allowances. Env

- A 1300 was re adopted with an effective date of October 31, 2010, and subsequently submitted to EPA as a SIP revision

. EPA’s approval of this SIP revision was signed on July 29, 2014 ( 7 9 FR 49458 )

.

5.3.2 Prevention of Significant Deteriorati on

Class I areas are protected under Title I, Part C of the CAA, which addresses Prevention of Significant Deterioration of Air Quality (PSD). In particular, section 160 of this part establishes the purpose “to preserve, protect, and enhance the air qual ity in national parks, national wilderness areas, national monuments, national seashores, and other areas of special national or regional natural, recreational, scenic, or historic value.” PSD is applicable to all major sources (or existing sources making a major modification) located in an area that is in attainment of the National Ambient Air Quality Standards. All areas of New Hampshire are subject to PSD.

Administrative rule Env

- A 619: Prevention of Significant Deterioration , which was previously

cod ified as Env

- A 623 and approved as a SIP revision on December 27, 2002, spells out the PSD requirements of New Hampshire’s statewide permit system. The PSD permitting process requires modeling analyses to assess the potential air quality impacts, includin g those to visibility, at Class I areas. PSD permit applicants may conduct such analyses in consultation with NHDES and the

relevant FLM. The most recent revisions to Env

- A 600: Statewide Permit System , including Env

- A 619, were re adopted with an effecti ve date of September 1, 2012. NHDES submitted the amended rule to EPA for SIP approval on November 15, 2012.

New Hampshire has received and processed only one PSD permit application since the original regional haze SIP submission. On December 16, 2009

, Laidlaw Berlin BioPower, LLC ( a.k.a. Burgess BioPower), Berlin, NH, filed an initial application for a proposed wood

- fired power plant. Following a change in project ownership and NHDES’s detailed review of the application, a temporary permit was issued a llowing construction to proceed

. 19

Visibility modeling was performed as part of the application process for the BioPower facility. Initial modeling showed that the potential existed for the biomass boiler’s exhaust plume to cause a

noticeable color differ ence when viewed against the sky from inside nearby Class I areas. Subsequent , more

- refined modeling showed that the meteorological conditions that might produce this effect would persist for no more than three hours at a time. Based on the strongest win d speed in the modeled meteorological data set, it was estimated that the shortest transport time to the Class I areas was five hours. This would not be enough time for a visible plume to reach those areas before full dispersion. Thus it was concluded fr om the modeling results that the power plant would not impair visibility at New Hampshire’s Class I areas.

5.3. 3 Agricultural and Forestry Smoke Management

40 CFR 51.308(d)(3)(v)(E) requires each state to consider smoke management techniques related to agricultural and forestry management in developing the long

- term strategy to improve visibility at

Class I areas. MANE

- VU’s analysis of smoke management in the context of regional haze is documented in “Technical Support Document on Agricultural and F orestry Smoke Management in

19 Permit No. TP

- 0054, issued on July 26, 2010; reissued on November 18, 2011, and November 30, 2012; viewable at http://www2.des.state.nh.us/OneStopPub/Air/330079013712

- 0175TypePermit.pdf

.NH Regional Haze 5

- Year Progress R eport Page 23

the MANE

- VU Region,” September 1, 2006. 20 As that report notes, fires used for resource benefits are of far less significance to the total inventory of fine

- particle pollutant emissions than other

sources of wood smoke in the re gion. With respect to PM 2.5 emissions, t he largest wood smoke source categories in the MANE

- VU region are residential wood combustion (73 percent); open burning (15 percent); and industrial, commercial, and institutional wood combustion (9 percent).

Fire s that are covered under smoke management plans, including agricultural and prescribed forest burning, constitute less than one percent of total wood smoke emissions in the MANE

- VU states

.

Wildfires within the region are also relatively small and infreq uent contributors to regio nal PM

emissions. MANE

- VU’s Class I areas are occasionally affected by wildfire smoke emissions from other regions, such as occurred from lightning

- induced forest fires in Quebec Province in July 2002 and May 2010 . These natural wildfire smoke emissions are not considered controllable

– and, in fact, are counted as part of natural background conditions. In any case, unplanned fires make up only a minor fraction of wood burning emissions.

Smok e from all sources accounts for only a small percentage of the fine

- particle mass that is the cause of regional haze. As documented in MANE

- VU’s Contribution Assessment, elemental carbon, the main ingredient of smoke, contributed 3 to 4 percent of fine

- particle mass on days of

worst and bes t visibility. Additionally, elemental carbon absorbs light more readily than it scatters light. When all facts are considered, it is reasonable to conclude that smoke emissions from controlled agricultural and forestry burning contribute, on an average a nnual basis , only a small fraction of one percent to total light extinction on days of both good and poor visibility.

This is no t to say that individual events, including prescribed burns

, will not have short

- term visibility impacts. Such impacts are add ressed by the New Hampshire Prescribed Fire Council in

its recommended standards 21 for planning and implementing prescribed burns. The U.S. Forest

Service and NHDES are members of the council and assisted in the development of these standards. Chapter 10 of the standards, which covers smoke management and air quality, recommends as follows: “ The burn plan will screen for all smoke sensitive features within one and five miles of the planned burn, and identify measures for minimizing negative impacts of smok e to these features.” Class I areas are not specifically identified as smoke sensitive features. However, both of New Hampshire’s Class I areas are within the Wh ite Mountain National Forest; thus, the FLM (in this

case, the U.S. Forest Service) would be informed of any planned burn in nearby lands. For any prescribed fire within the WMNF, the burn plan would have to meet the FLM’s own requirements for protection of Class I areas, which are more stringent than the New Hampshire Prescribed Fire

Council’s s tandards.

Chapter 13 of the Fire Council’s recommended standards includes a section on air quality, with

references to the CAA

, the NAAQS

, PSD , and the Regional Haze Rule. The two Class I areas in New Hampshire are identified by name, and the following r ecommendation is made: “If any prescribed fires take place that could affect Class I Airsheds, the New Hampshire Department of Environmental Services Air Resources Division should be contacted early in the planning process.” Also, NHDES’s real

- time air q uality monitoring website ( http://www2.des.state.nh.us/airdata/ ) is listed as a resource to help prescribed fire planners determine optimal times to conduct burns.

20 Available as Attachment V to New Hampshire’s Regional Haze SIP at http ://des.nh.gov/organization/divisions/air/do/asab/rhp/documents/v.pdf

.

21 NH Prescribed Fire Council, “Planning for Prescribed Burning in New Hampshire,” June 28, 2011; available at http://extension.unh.edu/resources/files/Resource001886_Rep2781.pdf

.NH Regional Haze 5

- Year Progress R eport Page 24

5.3.4 Measures to Mitigate Impacts of Construction Activities

40 CFR 51.308(d)(3)(v)(B) of the Regional Haze Rule requires each state to consider measures to mitigate the impacts of construction activities on regional haze. Fugitive emissions caused by earth

moving activities and heavy vehic ular traffic are the main concerns. However, MANE

- VU’s

Contribution Assessment found that crustal material plays only a very minor role in visibility impairment at MANE

- VU Class I areas. On the 20 percent best visibility days during the 2000

- 2004 baselin e period, crustal material accounted for 6 to 11 percent of particle

- related light

extinction at MANE

- VU Class I Areas. On the 20 percent worst

- visibility days, however, the ratio was reduced to 2 to 3 percent. Furthermore, the crustal fraction is largel y made up of pollutants of natural origin (e.g., soil or sea salt) that are not targeted under the Regional Haze Rule.

Nevertheless, the crustal fraction at any given location can be heavily influenced by the proxi mity of construction activities, and co nstruction activities occurring in the immediate vicinity of MANE

VU Class I Areas could have a noticeable effect on visibility. NHDES does not perceive that construction activities are an ongoing or significant impediment to meeting the 2018 reasonable

p rogress goals for Class I areas in the region. Consequently, no additional control measures tied directly to construction activities are proposed at this time.

Of relevance to construction activities is New Hampshire administrative rule Env

- A 2800 : Sand & Gravel Sources; Non

- metallic Mineral Processing Plants; Cement & Concrete Sources , which was readopted with amendments, effective on October 1, 2010. NHDES sent the amended rule to EPA with a request for SIP approval on March 31, 2011. This rule establ ishes particulate matter, visible emissions, and fugitive dust standards for cement/concrete sources and sand/gravel sources. The rule revisions serve to 1) distinguish sources at which non

- metallic minerals are subject to crushing or grinding from other sand and gravel sources, 2) separate the PM and visible emissions standards for

non

- metallic mineral processing plants from those for other sources, and 3) establish a permit

- by

notification for non

- metallic mineral processing plants to replace the General State Permit option. The permit

- by

- notification enables an operator to move a mobile crusher with only a notice to

NH DES and the town, rather than undergoing a more extensive permit process each time. The amended rule requires emissions testing of all n ew equipment as well as existing equipment not previously tested.

5.3.5 Rule for Open Source Emissions

New Hampshire readopted administrative rule Env

- A 1000: Prevention, Abatement, and Control of Open Source Air Pollution , with minor amendments, effec tive on May 1, 2011. It was submitted to EPA for SIP approval on Aug. 9, 2011. This rule establishes requirements for open burning, fugitive dust, and firefighter instruction and training activities. Although the rule does not make direct

reference to v isibility protection, the requirements it places on managing particulate emissions have, as one effect, that of protecting visibility. The open source rule aligns well with efforts to manage emissions from controlled agricultural and forestry burns and co nstruction activities.

5.3.6 Miscellaneous Control Measures

New Hampshire is considering various other control measures that could be incorporated into the state’s long

- term strategy to mitigate regional haze but for which no commitment is made or imp lied at this time:NH Regional Haze 5

- Year Progress R eport Page 25

• Energy efficiency: A number of in

- state energy efficiency programs are already reducing electric demand and, consequently, the power plants emissions that cause haze

– mainly

SO 2 , NOx, and PM. The option exists to expand such pr ograms and to make them a formal part of New Hampshire’s SIP.

• Alternative clean fuels: New Hampshire has joined 10 other Northeast states in studying the possible implementation of a regional low

- carbon fuel standard (LCFS) similar to the LCFS adopt ed by California. Such a measure would improve the efficiency of transportation fuels and reduce tailpipe emissions that contribute to regional haze. In the absence of a broader national program, interest in a low

- carbon fuels standard remains high in ma ny Northeast

states, but support for a clean fuels program in New Hampshire is uncertain.

• Wood combustion standards: In addition to passage of a state law 22 regulating outdoor wood boilers, other measures to control particulate emissions from small w ood combustion devices

are under consideration

. At the federal level

, EPA has proposed new source performance standards (NSPS) fo r new residential wood heaters to reflect improvements in wood heater technologies and to broaden the range of devices covered by the regulation

. 23

22 See HB 1405, Chapter 362, Laws of 2008; available at www.gencourt.state.nh.us/legislation/2008/HB1405.html

.

23 See 79 FR 6330

.NH Regional Haze 5

- Year Progress R eport Page 26

SECTION 6

– EMISSION REDUCTIONS RESULTING FROM

IMPLEMENTATION OF CONTROL MEASURES IN THE SIP

6.1 Re quirement to Summarize Emission Reductions

40 CFR 51.308(g)(2) requires that the progres s report summarize the emission redu ctions a chieved throughout the s tate by implementation of the measures included in the SIP to meet reasonable

p rogress goals for mandatory Class I federal areas

.

6.2 Emissions Changes since 2002

Emissions reductions describ ed in this section are constructed fr om emissions inventory data presented in Section 7. That section lists the 2002 and 2018 MANE

- VU regional emissions

estimates developed for the member states’ regional haze SIP s and compares those values to the

latest available estimates for the major cat egories of emissions sources. Although the estimates from one year to another are not always directly comparable because of differences in estimation methodology, rough approximations of emission reductions are still possible. From 2002 to 2007 (the most recent 5

- year interval for which data are sufficiently complete to allow comparisons )

, the

overall reductions in haze

- causing pollutants throughout the MANE

- VU region were approximate ly

as follows : sulfur dioxide, 16 % ; nitrogen oxide s, 13 %; direct fine p articulate matter

, 7 %; and volatile organic carbon, 33 %.

The emissions estimates used to derive these regional emission reductions are found in Table 7

- 1

as the 2002 and 200 7 category totals

. Similar reductions, on a percentage basis, occur for emissions originating from New Hampshire sources (Table 7

- 2 )

. The changes in both state and regional emissions during this period may be attributed to market forces in the power production sector and

to emission control programs that were already on the books or o n the way before the states’ regional haze SIPs were completed

, but not to control measures arising from th ose SIP revisions (which were completed after 2007 )

. The emission reductions and attendant air quality benefits emanating from the regional haze SIP s have begun only recently and, for the most part, are not readily quantifiable thus far

.

6.3 Emission Reduction s f rom New Hampshire’s EGUs

Electrical generating units are recognized as the largest group of SO 2 emitters and thus the leading

contributo rs to regional haze. This source category is one for which emission reductions are more reliably determined than most because of federal reporting requirements for the power production

sector

. Several New Hampshire EGUs that participate in federally mand ated air pollution control programs (such as the Acid Rain Program) are required to report to EPA’s Clean Air Markets Division (CAMD). Table 6

- 1 lists the SO 2 and NOx annual emissions

– along with heat input, gross load, and operating time

– as recorded i n the CAMD database for all reporting units in 2002 and

2013

. The table is divided into two groups: units identified as being among the top 167 EGU sources affecting MANE

- VU Class I areas ( i.e. , targeted EGUs

– see Subsection 4.4 ), and all other units.

The total annual SO 2 and NOx emissions from New Hampshire EGUs are also shown graphically

in Figure 6

- 1

.NH Regional Haze 5

- Year Progress R eport Page 27

Table 6

- 1. SO 2 and NOx Emissions from New Hampshire EGUs in 2002 and 2013

Year Facility Name Facility ID (ORISPL) Unit

ID SO 2 (tons) NOx (tons) Heat Input (MMBtu) Gross Load (MW

- hr) Operating Time (hr)

TARGETED EGUs

2002 Merrimack 2364 1 9,754.4 962.0 8,754,397 810,636 6,989

2002 Merrimack 2364 2 20,902.5 2,871.2 22,013,515 2,208,431 7,180

2002 Newington 8002 1 5,225.7 942.7 9,658,944 725,096 3,085
35,882.6 4,775.9 40,426,856 3,744,163

2013 Merrimack 2364 1 364.1 584.5 4,078,240 404,937 3,792

2013 Merrimack 2364 2 1,036.4 1,359.0 10,585,288 1,032,003 3,384

2013 Newington 8002 1 328.6 86.1 1,209,521 87,799 772
1,729.1 2,029.6 15,8 73,049 1,524,739

Emission Reductions, 2002

- 2013 34,153.5 2,746.3

95.2% 57.5%

ALL OTHER UNITS

2002 EP Newington Energy, LLC 55661 1 6. 1 151.1 4,302,511 318,729 3,391

2002 EP Newington Energy, LLC 55661 2 5.3 51.1 3,692,78 5 321,005 2,541

2002 Lost Nation 2362 CT1 5.7 21,580 768 83

2002 Merrimack 2364 CT1 7.4 23,711 1,149 99

2002 Merrimack 2364 CT2 6.6 21,447 964 90

2002 Schiller 2367 4 2,608.4 675.4 3,773,920 294,220 7,134

2002 Schiller 2367 5 2,796.5 598.7 3,936,70 0 318,110 7,538

2002 Schiller 2367 6 2,647.6 573.9 3,714,776 323,051 7,768

2002 Schiller 2367 CT1 19.2 47,477 2,047 168

2002 White Lake 2369 CT1 8.3 25,776 1,104 107
8,063.9 2,083.4 19,513,327 1,579,275

2013 EP Newington Energy, LLC 55661 1 1.2 17.6 2,288,855 308,832 1,451

2013 EP Newington Energy, LLC 55661 2 1.4 21.7 2,971,802 371,865 1,954

2013 Granite Ridge Energy 55170 1 4.0 55.4 13,290,207 1,149,716 6,371

2013 Granite Ridge Energy 55170 2 3.6 48.7 12,072,594 1,052,791 5,816

2013 Schill er 2367 4 804.2 165.2 1,233,100 104,242 3,041

2013 Schiller 2367 5 2.1 177.5 5,305,054 370,028 8,124

2013 Schiller 2367 6 621.1 143.3 1,066,811 89,975 2,418
1,437.6 629.4 38,228,423 3,447,449

Emission Reductions, 2002

- 2013 6,626.3 1,468.0

82. 2% 70.0%

ALL UNITS COMBINED

2002 43,946.5 6,873.3 59,987,539 5,325,310

2013 3,166.7 2,659.0 54,101,472 4,972,188

Emission Reductions, 2002

- 2013 40,779.8 4,214.3

92.8% 61.3%

Source: EPA CAMD, ht tp://ampd.epa.gov/ampd/

. The annual unit

- level emissions data for this summary were downloaded on August 19, 2014.

SO 2 and NOx emissions for all New Hampshire EGUs in the CAMD database were lower in 2013 than in 2002 by approximately 40,800 and 4, 2 00 tons per year, respectively. These amounts
equate to emission reductions of 9 3 and 6 1 percent. For the three targeted EGUs, the corresponding

SO 2 and NOx reductions were approximately 34, 2 00 and 2, 7 00 tons per year, or 9 5 and 58 percent.
The reductions in both pollutants occurred as gross load declined by 6.6 percent for all New Hampshire EGUs over the same interval . The major cause of the emission reductions was aNH Regional Haze 5

- Year Progress R eport Page 28

regional shift away from coal

- fired power (Merrimack and Schiller Stations) and oil

- fired power (Newington Station) to EGUs running on natural gas (EP Newington Energy). Another important factor was operation of the recently installed flue gas desulfurization system (FGD, or scrubber) at
Merrimack Station

.

The FGD system at Merrimack Station is required to remove 90 percent or more of sulfur dioxide

emissions . The scrubber began operation well in advance of the July 1, 2013, control deadline ( and was functional during most of 2012 )

. The 201 3 CAMD data show that the two units emitted 1,401

t ons of SO 2 versus a gross heat input of 14,663528 MMBtu. This translates to an average a nnual

emission rate of 0.1 9 lb/MMBtu with the emission controls in place. For comparison, the average

SO 2 emission rate (calculated from the data in T able 6

- 1 ) was 2. 0 lb/MMBtu in 2002, the baseline year, when the facility had no post

- combustion controls for this pollutant. On this simple basis alone, the SO 2 removal efficiency of the new control equipment is estimated to be at least 90 percent.

This finding is suppo rted by stack test data obtained in conjunction with a quality assurance audit of the continuous emissions monitoring system (CEMS) for Merrimack Station. 24 Unit 1 was tested on January 29, 2013, at an uncontrolled emission rate of 3.67 lb/MMBtu. Unit 2 w as tested on January 25, 2013, at an uncontrolled emission rate of 3.45 lb/MMBtu. Controlled emissions from the common stack in the period from February 1 to March 13, 2013, were measured at 0.23 lb/MMBtu. Taken together, these results indicate an SO 2 re moval efficiency in the vicinity of 94

percent.

Figure 6

- 1. SO 2 and NOx Emissions from New Hampshire EGUs in 2002 and 2013

24 EPA requires certification of CEMS where the data are used to demonstrate compliance with emission standards on

a continuous basis. The certification tests must be performed by an independent entity, which temporarily installs an independent CEMS to collect emissions data in parallel with the plant CEMS. This procedure is known as a Relative Accuracy Test Audit (RATA).NH Regional Haze 5

- Year Progress R eport Page 29

SECTION 7

– CHANGES IN EMISSIONS OF HAZE

- CAUSING POLLUTANTS

7.1 Requirement to Analyze and Track Cha nges in Emissions

Section 40 CFR 51.308(g)(4) of the Regional Haze Rule requires each state to analyze and track changes over the past five years in pollutant emissions contributing to visibility impairment from all

sou rces and activities within the s tate . Emissions changes are to be identified by type of source or activity. The analysis must be based on the most recent updated emissions inventory, with estimates projected forward as necessary and appropriate, to account for emissions changes during the applicable 5

- year period.

7.2 Data Sources for Analysis of Emissions Trends

MARAMA recently analyzed the regional emissions trends in a technical support document developed for MANE

- VU (Attachment D )

. This document compiled emissions estimates for the years 2002, 2007, 2010, 2017, 2018, and 2020 and was produced by integrating data from multiple

sources , including the following :

• The 2002 baseline modeling inventory with a projection to 2018 (MANE

- VU Version 3.3),

• The 2007 baseline modeling inventory w ith projections to 2017 and 2020 (MARAMA Version 3), and

• The 2010 US EPA CAMD actual emissions as reported by the emitting entities

.

Exhibit 2.1 in the MARAMA document lists the specific data sources, by source category (EGU point, non

- EGU point, m obile, a rea, n on

- road , and MAR 25 )

, that were used for developing the baseline and projection inventories identified above

.

For this regional haze progress report, NHDES has rearranged the emissions summary tables from MARAMA’s analysis and substituted 2013 CAMD d ata in place of the 2010 CAMD data. The results appear in Tables 7

- 1 and Tables 7

- 2 at the end of this section. The first table presents the

MANE

- VU regional emissions , and the second table presents New Hampshire’s emissions.

Caution is advised in makin g direct comparisons among different data sources and across years

. As described in the MARAMA document, for any pollutant or source category, there are variations among the data sources in the manner of accrual and treatment of the data. Inconsistencie s from

one data source to another arise from differences in the specific emissions sources included in the

inventories

, differences in calculation methodologies (e.g., assumptions about growth and control

rates )

, changes in emissions factor s , unantic ipated shutdowns or new sources, and introduction of

new control measures

.

Note that two different EPA models were used to calculate mobile source emission s : the MOBILE6.2

model was used for the 2002 and 2018 emissions estimates; and MOVES was used for the 2007

, 2017, and 2020 estimates

. Estimates between models are not directly comparable.

25 Includes commercial marine vessels, airports, and railroad locomotives

.NH Regional Haze 5

- Year Progress R eport Page 30

7.2.1 2002 Modeling Inventory with Projections to 2018

MARAMA prepared t he 2002

- based modeling inventory suite and released it in final version in

2006. The future

- ye ar emission projections for 2009 and 2018 were developed from the 2002

baseline emissions inventory. The 2018 projections included two scenarios :

• On

- the

- Books / On

- the

- Way (OTB/OTW)

– These projections accounted for all emission

control measure s that wer e fully adopted into federal or individual state regulations or SIPs.

On

- the

- way controls included the CAIR. Modelers often refer to this scenario as the “ future

base case .”

• Beyond

- on

- the

- Way (BOTW)

– These projections account ed for all emission control

measu res in the OTB/OTW scenario plus additional controls that states commit ted to adopt

or pursue as part of the SIP process. Modelers often refer to this scenario as the “future

control case.”

The BOTW projection for 2018 was used f or this emi ssion s t rend s analysis . Several versions of the

2002

- based inventory suite were prepared, with i mprovements made to the emissions estimates in

each successive run . T he last and best of these is MANE

- VU Version 3.3. This is the version that

was used to perform a ir quality modeling and is the one used for this emission s trend s analysis.

Details on the methods and assumptions behind the 2002

- based inventory suite are found in documentation for the base year inventory 26 and future projections. 27

7.2.2 2007 Modelin g Inventory with Projections to 2017 and 2020

The 2007

- based inventory suite was prepared by MARAMA and finalized in 2012. Future

- year projections for 2013, 2017

, and 2020 were developed from the 2007 baseline emissions inventory

for all source categorie s except electric generation and on

- road mobile

.

The MANE

- VU states used the 2007

- based inventory suite to perform air quality screening modeling

in 2011 through 2013

. (This is known as the Ozone Transport Commission (OTC) Level s 1, 2, and 3 modeling.) For tho se runs
, future

- year EGU projections had not yet been completed. Therefore, f or modeling purposes, provisional EGU estimates for year 2020 were prepared that were based on the

CSAPR emission caps ( as then established ). Improved future

- year modelin g inventories for elect ric generating units are being develop ed in a separate effort lead by the Eastern Regional Technical

Ad visory Committee (ERTAC) 28 and are not included here.

On

- road emissions were available only for base year 2007 and future year 202 0. Use of the MOVES model proved so resource

- intensive that no funds were available to develop a 2017 on

- road inventory projection

. In a separate effort, NESCAUM developed a 2007 on

- road inventory using the MOVES model to support air quality modeling. T hose runs were further revised by Virginia to adjust for the

26 E.H. Pechan & Associates, Inc., “ Technical Support Document for 2002 MANE

- VU SIP Modeling Inventories, Version 3,” November 2006; available at http://w ww.marama.org/technical

- center/emissions

- inventory/2002

- inventory

- and

- projections/mane

- vu

- 2002

- emissions

- inventory

.

27 MACTEC Federal Programs, Inc., “Development of Emission Projections for 2009, 2012, and 2018 for NonEGU Point, Area, and N on

- road Sources in the MANE

- VU Region,” February 2007; available at http://www.marama.org/technical

- center/emissions

- inventory/ 2002

- inventory

- and

- projections/mane

- vu

- future

- year

emissions

- inventory

.

28 Information on the Electric Generating Utility Growth Model is available at http://www.ertac.us/index_egu.html

.NH Regional Haze 5

- Year Progress R eport Page 31

altitude at which temperature was measured. This adjusted MOVES run was used by the OTC for

its Level 3 screening modeling and also for this analysis.

Two scenarios for each projection year

, 20 17 a nd 2020

, were prepared :

• On

- the

- Books / On

- the

- Way (OTB/OTW)

– These projections accounted for all emission control measures that were fully adopted into federal or individual state regulations or SIPs.

Modelers often refer to this scenario as the “fu ture base case.”

• OTC Control Measures

– These projectio ns accounted for all emission control measures in

the OTB/OTW scenario plus the application of various contro l measures for which the OTC

ha d developed model rules. Note that , at the time, states had not fully committed to adopting

these measures through the SIP process.

The 2017 and 2020 OTB/OTW projections were used f or this emission s trend s analysis. Several

versions of the 2007

- based inventory suite were prepared , with improvements made to the

e missions estimates in each successive run. The last and best of these is MARAMA Version 3.

This is the version that was used for OTC ’s Level 3 modeling and for this emission s trend s analysis.

The methods and assumptions employed in preparing the 2007

- based inventory suite are described in documentation for the base year inventory 29 and future projections. 30

7.2.3 CAMD Reported Emissions

EP A’s CAMD is responsible for implementing 40 CFR 75, which requires hourly emiss ions monitoring and reporting by a ny major sourc e that participates i n an emissions cap

- and

- trade program under the Acid Rain Control Program, the NO X Budget Trading Program, or CAIR

. All sources participating in the CAMD programs are required to submit unit

- level emissions of NOx,

SO 2 , a nd other information such as heat input, periodically to EPA. The agency reviews and certifies the submitted information before posting it at http://www.epa.gov/airmarkets/

. Most of the

sources reporting to CAMD are traditional power plants that sell electricity to the electrical grid.

Other source types, such as petroleum refineries and cement kilns, are also required to report hourly

emissions data to CAMD

. O nly the EGU data were used in this analysis of emissions changes

.

7.3 Summary of Regional Emissions Changes

For this progress report, NHDES has identified trends in the e mission s that cause regional haze by comparing emissions data from the referenced 2002 and 2007 baseline inventories and the 201 3

CAMD database against projected emissions data from the 2017, 2018, and 2020 future inventories.

Table 7

- 1 provides a summary of emissions for the entire MANE

- VU region for the four major pollutants of interest: N Ox , SO 2 , PM 2.5 and VOC

. Emissions in to ns per year are listed by source category and inventory year

. Notes and color coding have been added to distinguish among the

29 AMEC Environmen t & Infrastructure and SRA International, Inc., “ Technical Support Document for the Development of the 2007 Emissions Inventory for Regional Air Quality Modeling in the Northeast / Mid

- Atlantic Region, Version 3.3,” January 23, 2012 ; available at http://www.marama.org/technical

- center/emissions

inventory/2007

- emissions

- and

- projections/version

- 3

- 2007

- emissions

- inventory

.

30 AMEC Environment & Infrastructure and SRA International, Inc., “ Technical Support Document for the Development of the 2017/2020 Emission Inventories for Regional Air Quality Modeling in the Northeast / Mid

- Atlantic Region , Version 3.3,” January 23, 2012 ; available at http://www.marama.org/technical

- center/emissions

inventory/2007

- emissions

- and

- projections/future

- year

- inv entory

- version

- 3

.NH Regional Haze 5

- Year Progress R eport Page 32

three data sources used for the analysis. The b lue columns are from the 2002

- based inventory suite,

the tan columns are from the 2007

- based inventory suite

, and the gray column is from the 2013

CAMD database . The following are s ome general observations on regional emissions trends as revealed by th e data presented

.

7.3.1 Sulfur Dioxide

Regional SO 2 emissions are dominated by the EGU s ector, accounting for about three

- fourths of all such emissions in 2002 and 2007, but projected to be reduced to half by 2018

. SO 2 emissions from

EGUs were markedly lower in 2013 than in either of the baseline years . T he decline from 2002 to
2007 was abo ut 10 percent, but from 2002 to 2013 exceeded 80 percent

. Actual 2013 emissions from

the EGU sector were already below the project ed 2018 emissions.

As regional efforts to reduce EGU emission s come to fruition , the contributions from other sectors

will a ssume a growing proportion of the total SO 2 inventory. Note that there is negligible effect from

any chang e s in methodolog ies for the calculation of SO 2 emission s among the two inventory suites and

CAMD

. (This is one exception in which the comparison of values between one dataset and another

may be reasonable

. ) All evidence indicates that the observed SO 2 emission reductions are not a

temporary phenomenon, and the downward trend in regional SO 2 emissions is expected to continue

.

7.3.2 Oxides of Nitrogen

Regi onal NOx emission s are dominated by two source categories

– on

- road mobile and EGU point

– with the former category representing half of all NOx in the baseline years

. As with SO 2 emissions,

t abulated values for the EGU sector indicate sizeable decrease s in NOx emissions from 2002 to

20 07 ( by about one

- quarter ) and from 2002 to 2013 ( by about one

- half)

. The 2018 projection anticipates a further decline in NOx emissions from EGUs

.

With respect to the on

- road mobile category, EPA introduced a major revisio n in calculation methodology when it switched from MOBILE6 to MOVES as the preferred on

- road emissions mode l

. This change occurred between completion of the two different inventory suite s

. As a result

, direct comparison of the 2002

- based and 2007

- based o n

- road mobile datasets complicates the analysis of

emission trends with in this sector

. However, when e xamined separately , each dataset projects a

decrease in NOx emissions in the range of 40

- 60 percent between base year and future year

.

Despite any uncer tainties arising from an incomplete EGU inventory suite and a revision in mobile emissions calculation methodology, there is a clear trend toward lower NOx emissions from all

sources in the MANE

- VU region.

7.3.3 Fine Particulate Matter

Directly emitted fine pa rticulate matter is regionally dominated by area source s , in particular by

residential wood combustion

, in all years inventoried. For the residential wood combustion subcategory , changes in both estimation methodology and emission factors for direct PM 2.5 occurred between completion of the two inventory suites

. This resulted in generally lower emissions estimates for the 2007 inventory suite. The methodologies used to estimate PM 2.5 emissions from the lesser contributing sectors

– namely EGU s and mobile sources

– also changed

, making straight comparison s of the datasets difficult

.NH Regional Haze 5

- Year Progress R eport Page 33

Overall, the tr end for directly emitted fine particulate matter is not well

- defined. Emissions from

some source categories remain largely unchanged, while others, especially t hose dominated by engines, are projected to show reductions. Net c hanges in direct PM 2.5 emissions are anticipated to

be small and of limited consequence to regional haze ; total annual emissions of fine PM 2.5 are the

lowest among the four pollutants analy zed and represent no more than 5

- 10 percent of the total inventory of emissions in any year

.

7.3.4 Volatile Organic Compounds

Most r egional VOC emissions originate from biogenic sources , which will remain largely unchanged over the foreseeable future

. The sum marized inventories in Table 7

- 1 include only anthropogenic emissions and thus do not count biogen ic emission s in the category totals.

For anthropogenic emissions

, the area source sector is the largest contributor to VOC , with much of

that coming from res idential wood combustion

. As in the case of direct PM 2.5 , changes occurred in

both VOC estimation methodology and VOC emission factors for the residential wood combustion subcategory . These technical adjustments result ed in generally lower emissions esti mates for the

2007

- based inventory suite than for the 2002

- based version

. The calculation methodology also

ch anged for mobile sources , which are next after area sources in emissions contributions to regional

VOC

. All of t hese changes make direct comparis ons of VOC emissions between inventory suites

difficult. However, when examined separately

, each inventory suite shows declining emissions for the most important VOC source categories and substantial reductions in VOC emissions for all source categories c ombined

.NH Regional Haze 5

- Year Progress R eport Page 34

Table 7

- 1

. Annual Air Pollutant Emission s in the MANE

- VU Region, 2002

- 2020 (tons/year )

Category 2002 2007 2013 2017 2018 2020

Data Source: (1)(a) (1)(b) (1)(c) (1)(b) (1)(a) (1)(b)

Sulfur Dioxide Point EGU(2) 1,670,176 1,546,335 315,675

- -- 365,024

--- Point N on

- EGU(3) 239,400 129,615

--- 112,784 201,478 112,828
Area(4) 316,287 212,471

--- 119,215 190,437 116,511

On

- road Mobile(4) 40,092 8,974

--- --- 8,756 7,202

N on

- road MAR(4) 32,123 30,318

--- 4,870 8,172 4,183

N on

- road NMIM(4) 24, 774 14,167

--- 420 466 443

Total 2,322,851 1,941,879

--- --- 774,333

--- Oxides of Nitrogen Point EGU(2) 453,395 338,488 185,672

--- 168,268

--- Point Non

- EGU(3) 213,414 174,043

--- 169,188 174,218 169,668
Area(4) 266,747 207,054

--- 194,832 263,954 1 94,868

On

- road Mobile(4) 1,308,235 1,175,916

--- --- 303,956 471,558

N on

- road MAR(4) 137,733 173,855

--- 127,391 111,425 118,025

N on

- road NMIM(4) 289,392 263,931

--- 153,553 158,843 135,962

Total 2,668,916 2,333,286

--- --- 1,180,664

--- Direct PM 2.5 Point EGU(2) 20,670 44,921

--- --- 51,109

--- Point Non

- EGU(3) 33,948 29,881

--- 29,659 38,393 29,868
Area(4) 332,676 259,938

--- 262,887 339,518 264,959

On

- road Mobile(4) 22,108 45,616

--- --- 9,189 28,365

N on

- road MAR(4) 7,929 7,430

--- 3,906 7,927 3,503

N on

- road NMIM(4) 27,922 24,701

--- 16,536 15,952 14,421

Total 445,253 412,486

--- --- 462,087

--- Volatile Organic Compounds Point EGU(2) 11,943 4,975

--- --- 4,344

--- Point Non

- EGU(3) 92,562 68,003

--- 68,099 103,727 68,005
Area(4) 1,366,735 784,233

--- 702,289 1,334,175 696,125

On

- road Mobile(4) 789,560 600,638

--- --- 269,979 269,647

N on

- road MAR(4) 14,026 19,066

--- 17,057 14,962 16,962

N on

- road NMIM(4) 557,536 412,890

--- 244,126 364,980 222,226

Total 2,832,364 1,889,805

--- --- 2,092, 168

---

(1) This summary i s assembled from three sources

– see Section 7.2 of report :
(a) 2002 MANE

- VU V3.3, with projection to 2018 (blue columns);

(b) 2007 MARAMA V3, with projections to 2017 and 2020 (tan columns); and

(c) CAMD actual 201 3 emissions as reported to EPA (gray column)

. Data for this summary were downloaded

from http://ampd.epa.gov/ampd/ on August 18 , 2014

. (2) Data meet or exceed target of 90% completeness across all years for most states. Datasets for units w ith incomplete data have been completed by states or units have been removed so that consistency of data is maintained across all years

. (3) Data do not meet target of 90% completeness across all years. Total represents data for all units completed by sta tes.

(4) Data are identical to modeled inventory and TSD for most states. No revisions were made to correct inconsistent methodologies. N on

- road MAR includes commercial marine vessels, airports, and railroad locomotives. N on

- road NMIM ( National Mobile Inventory Model) includes equipment in EPA’s NMIM/N ON

- ROAD model.NH Regional Haze 5

- Year Progress R eport Page 35

7.4 Summary of New Hampshire Emissions Changes

Presented in the same format as the tabulation of regional emissions above, Table 7

- 2 summarizes

data from New Hampshire’s annual emissio ns inventories for SO 2 , NOx, PM 2.5 and VOC. Note

that the column labeled 2013 shows the aggregated annual SO 2 and NOx emissions for that year for

all New Hampshire EGUs participating in the CAMD programs

. Both the aggregated and u nit

- level

emissions for New Hampshire’s EGUs appeared earlier with additional details in Table 6

- 1.

To a large degree, emission changes in New Hampshire mirror those within the entire MANE

- VU region. Some general observations on statewide emissions trends are as follows :

• Histo rically, most of New Hampshire’s SO 2 emissions originate d from the EGU source category

. There was little change in EGU emissions between 2002 and 2007, but SO 2 emissions from this sector in 2013 were more than 90 percent below the baseline

– easily

surpas sing projected reductions. A s projected for 2018 , SO 2 e mission s from all sources in New Hampshire would be less than one

- third of baseline emissions.

• On

- road mobile sources represent about half of baseline NOx emissions i n New Hampshire

, as in the entir e MANE

- VU region. Both the state and regional inventories project that, by 2018, on

- road mobile NOx will be reduced by more than three

- fourths and NOx from all sources will be reduced by more than one

- half from 2002 levels. A rea sources of NOx play

a som ewhat larger role in New Hampshire than they do in the region as a whole

, but f or point sources of NOx the opposite is true.

• As in the regional trends analysis of particulate matter emissions , little change is projected

for emissions of direct PM 2.5 in Ne w Hampshire. The area source category will continue to

dominate emissions for this pollutant.

• Area sources and mobile sources (on

- and non

- road combined) each account for roughly half

of total VOC emissions in New Hampshire and the MANE

- VU region . VOC e missions from area sources are not projected to change much by 2018, but new emission controls on engines will have the intended eff ect of reducing VOC emission s from mobile sources. Largely b ecause of emission reductions in the mobile source categories, total VOC emissions in New Hampshire and the region are projected to decline by 20 percent or more between

2002 and 2018.

N

ote on mobile emissions : The 2020 MOVES analyses produced anomalous results for on

- road mobile emissions for several states, includ ing New Hampshire . E xtensive review by NESCAUM /

MARAMA was unable to determine the cause of these anomalies

. Subsequently , NHDES performed an independent series of MOVES runs to obtain more reliable projections of on

- road

mobile emissions for New Hampsh ire in the year 2020

. These adjusted values are the ones which appear in the last column of Table 7.2. The original, uncorrected on

- road mobile values for New Hampshire were as follows: SO 2 , 542 t ons/year; NOx, 30,342 tons/year; PM 2.5 , 3,010 tons/year; VOC, 14,629 tons/year.NH Regional Haze 5

- Year Progress R eport Page 36

Table 7

- 2 . Ann ual Air Pollutant Emission s in New Hampshire, 2002

- 2020 (tons/year )

Category 2002 2007 2013 2017 2018 2020

Data Source: (1)(a) (1)(b) (1)(c) (1)(b) (1)(a) (1)(b)

Sulfur Dioxide Point EGU(2) 43,962 42,524 3,167

--- 10,766

--- Point Non

- EGU(3) 5,607 2,743

--- 2,655 3,086 2,658
Area(4) 7,076 5,283

--- 4,176 3,123 3,991

On

- road Mobile(4) 777 275

--- --- 537 105*

N on

- road MAR(4) 220 545

--- 81 226 46

N on

- road NMIM(4) 668 440

--- 16 16 18

Total 58,310 51,810

-- - --- 17,753

--- Oxides of Nitrogen Point EGU(2) 6,894 4,754 2,659

--- 3,089

--- Point Non

- EGU(3) 3,576 2,694

--- 3,388 1,086 3,467
Area(4) 10,992 4,737

--- 4,152 12,243 4,111

On

- road Mobile(4) 33,283 33,923

--- --- 7,671 10,523*

N on

- road MAR(4) 1,77 6 1,454

--- 1,306 1,723 1,286

N on

- road NMIM(4) 8,104 8,548

--- 5,521 4,558 5,268

Total 64,625 56,110

--- --- 30,369

--- Direct PM 2.5 Point EGU(2) 1,973 602

--- --- 2,156

--- Point Non

- EGU(3) 426 499

--- 1,169 940 1,179
Area(4) 17,534 8,623

--- 8,598 18,089 8,633

On

- road Mobile(4) 562 1,424

--- --- 263 459*

N on

- road MAR(4) 95 62

--- 46 98 45

N on

- road NMIM(4) 868 798

--- 558 534 493

Total 21,459 12,008

--- --- 22,080

--- Volatile Organic Compounds Point EGU(2) 101 110

--- --- 73

--- Point Non

- EGU (3) 1,815 768

--- 1,445 998 1,431
Area(4) 65,374 22,343

--- 20,894 62,687 20,807

On

- road Mobile(4) 16,762 13,599

--- --- 6,564 5,085*

N on

- road MAR(4) 142 195

--- 175 158 178

N on

- road NMIM(4) 22,231 17,105

--- 11,028 14,807 9,783

Total 106,425 54,120

- -- --- 85,288

---

(1) T his summary is assembled from three sources

– see Section 7.2 of report: (a) 2002 MANE

- VU V3.3, with projection to 2018 (blue columns); (b) 2007 MARAMA V3, with projections to 2017 and 2020 (tan columns); and (c) CAMD actual 2013 emissions as r eported to EPA (gray column)

. Data for this summary were downloaded

from http://ampd.epa.gov/ampd/ on August 18 , 2014

. (2) Data meet or exceed target of 90% completeness across all years for most states. Datasets f or units with incomplete data have been completed by states or units have been removed so that consistency of data is maintained across all years.

(3) Data do not meet target of 90% completeness across all years. Total represents data for all units compl eted by states.

(4) Data are identical to modeled inventory and TSD for most states. No revisions were made to correct inconsistent methodologies. N on

- road MAR includes commercial marine vessels, airports, and railroad locomotives. N on

- road NMIM ( Nati onal Mobile Inventory Model) includes equipment in EPA’s NMIM/N ON

- ROAD model.

* Adjusted value

– see note on mobile emissions in Section 7.4 of report

.NH Regional Haze 5

- Year Progress R eport Page 37

SECTION 8

– ASSESSMENT OF SIGNIFICANT EMISSIONS

CHANGES THAT HAVE IMPEDED VISIBILITY PROGRESS

8.1 R equirement to As sess whether Emissions Changes H ave Impeded Progress

Section 40 CFR 51.308(g)(5) of the Regional Haze Rule requires an assessment of any significant changes in anthropogenic e missions within or outside the s tate that have occurred over the past 5 years that have limited or impeded progress in reducing po llutant emissions and improving visibility.

8.2 Assessment

The Regional Haze Rule provides no specific definition of what constitutes a significant change in

emissions that would hinde r progress in reducing regional haze. It is reasonable to assume that a significant change in emissions that impedes visibility progress could come about in any of three

ways: 1) an unanticipated increase in emissions from one or more existing source s, 2) the unanticipated addition of one or more new source s, and 3) failure of one or more existing sources to
adhere to expected emission reductions in accordance with the applicable SIP

.

With respect to the first two possibilities, there are no new major sou rces or existing sources in New Hampshire that have significantly increased emissions of haze

- causing pollutants. The noteworthy exception is gas

- fired power plants, whose output has replaced electrical generation by coal

- fired

units. However, t he net ef fect of this realignment among EGUs has been a reduction in the total emissions of the major pollutants that impair visibility , especially sulfur dioxide

. (See Section 6.3.) Similar changes in the power sector have occurred in upwind states, to the benef it of visibility in New Hampshire

. It is uncertain whether such benefit will be permanent. NHDES knows of no significant emission changes attributable to new or existing sources in other states that are impeding visibility progress at New Hampshire’s Cla ss I areas.

As to the third possibility, all of New Hampshire’s major sources included in the regional haze plan ( i.e. , the BART units and targeted EGUs) already have control measure s in place that are operating

to reduce emissions as required in the SIP. (See Section s 3, 4, and 6 .) NHDES is not in a position to certify that all other states that contribute to visibility impairment at New Hampshire’s Class I

areas have adhered to the scheduled emission reductions as promised in their respective regional

haze SIPs. Many of the emission reductions included in states’ SIPs were scheduled to occur in a stepwise fashion ( e.g. , in 2010 or 2014 or 2018) rather than in a continuous manner . Therefore, not
all control measures will have been implemented in the ea rliest years of the planning period. As

described elsewhere in this report, haze

- causing emissions have been o n a general decline throughout the MANE

- VU region since 2002.

The following additional observations are relevant to the assessment of visibility progress as planned under New Hampshire ’s regional haze SIP:

• The regional transport of air pollutants, especially SO 2 and NOx, is an ongoing issue that CSAPR, the replacement rule for CAIR, addresses in part . The implementation of MATS

and the revised S O 2 NAAQS may help to mitigate the delay in the implementation of

CSAPR , at least for the control of SO 2 emissions. However, any setback in implementing a comprehensive regional or national program to address air pollution transport would slow

the rate of visibility progress throughout MANE

- VU

.NH Regional Haze 5

- Year Progress R eport Page 38

• S ome EGUs in upwind states are either not operating or are limiting operation of their existing air pollution control devices, and have elected instead to achieve compliance with

federal requirements through the p urchase of CAIR allowances (program now expired)

. While lawful , this practice has caused NOx emissions from some EGUs to exceed past levels, resulting in higher levels of NOx in portions of the O zone T ransport R egion , which

includes all of the MANE

- VU sta tes

. This finding was the subject of a recent statement 31

from the O TC requesting that EPA take corrective action

.

• NHDES anticipates that interstate transport of air pollutants will not impede visibility improvement to such an extent as to prevent Class I areas in New Hampshire and other states affected by New Hampshire’s emissions from meeting their near

- term visibility objectives

. However, over the longer term, the statutory goal of re

- establishing natural visibility conditions by the 2064 target date w ill demand that interstate transport, as a continuing impediment to visibility progress

, be resolved. V isibility tracking thus far

indicate s that all five MANE

- VU Class I areas affected by New Hampshire’s emissions are

on course or ahead of schedule to ac hieve their reasonable progress goals for 2018. (See Section 2.)

31 Ozone Transport Commission, “Statement from The Ozone Transport Commission Requesting the Use and Operation of Existing Control Devices Installed at Electric Generating Units,” June 13, 2013.NH Regional Haze 5

- Year Progress R eport Page 39

SECTION 9

– SUFFICIENCY OF SIP TO MEET REASONABLE PROGRESS GOALS

9.1 Requirement to Assess Sufficiency of Plan

Section 40 CFR 51.308(g)(6) of the Regional Haze Rule requires an assess ment of whether the current implementation plan elements and strategie s are sufficient to enable the state, or other states

with mandatory Class I federal areas affected by emissions from the s tate, to meet all established reasonable progress goals.

9. 2 Assessment

O n the basis of the analyses described in this r eport, NHDES asserts that the New Hampshire Regional Haze SIP

, as most recently amended on August 26, 2011, is sufficient to meet the 2018 reasonable progress goal s established for the two mandat ory Class I federal areas in the state and for

the five other Class I areas in the MANE

- VU states affected by emissions originating in New Hampshire. Visibility improvements to date indicate that New Hampshire is on track to meet these interim progress go als toward the national goal of restoring natural visibility conditions by 2064 as promulgated under the Regional Haze Rule.NH Regional Haze 5

- Year Progress R eport Page 40

SECTION 10

– MONITORING STRATEGY REVIEW

10.1 Requirement to Review Monitoring Strategy

Section 40 CFR 51.308(g)(7) of the Regio nal Haze Rules requires that ea ch state with a mandatory

Class I federal area review the state’s visibility monitoring strategy and the need for a ny modifications

to it

. The original visibility monitoring strategy for New Hampshire’s Class I areas is desc ribed in

detail in Section 5 of the regional haze SIP.

10.2 Strategy Review

New Hampshire’s visibility monitoring strategy relies upon participation in the Interagency Monitoring of Protected Visual Environments (IMPROVE) network. 32 The IMPROVE monitor for the Great Gulf Wilderness (GRGU1) is located at Camp Dodge, a p proximately 1 mile east of the wilderness boundary, in New Hampshire’s White Mountain National Forest (Table 10

- 1)

. This monitor also serves as the monitor for the Presidential Range

- Dry River Wilderness, whose northern

most limit lies only 5 miles southwest of the monitor location

. It should be mentioned that New Hampshire has two other (recently added ) IMPROVE sites, located at NHDES’s monitoring stations

at Pack Monadnock and Londonde rry ; but neither is considered representative of the Class I areas.

Table 10

- 1. IMPROVE Network Site for New Hampshire’s Class I Area s

Site Name Site Code Latitude Longitude Elev. (m) Dates of Operation

Great Gulf Wilderness GRGU 1 44.31°

- 71.22°. 454 J une 10, 1995

- present

As the central component of New Hampshire’s visibility monitoring strategy, the IMPROVE network

monitor GRGU 1 has been in service since 1995. This monitor was deemed adequate in the SIP to

meet EPA’s Regional Haze Program requir ements for the state’s two mandatory Class I federal

areas

. Section 2 of this report provides a summary of visibili ty data developed from air quality

measurements gathered by this monitor since 2000.

For this progress report

, New Hampshire has evaluated the monitoring network for any needed changes from th e original network described in the regional haze SIP

. In reviewing the record,

NHDES notes that t he visibility database contains ga ps in the data for GRGU 1 in both 2009 and

2010 . These gaps rendered t he data incomplete for those years

, in accordance with established protocol. While NHDES regularly reviews the IMPROVE data , this agency has no direct involvement in the operation and maintenance of the IMPROVE network . GRGU 1 is operated under the manage ment of the U.S. Forest Service.

The USFS has advised that the data gaps for GRGU1 were due to temporary problems with electricity delivery to the IMPROVE shed, which is located on an unmaintained road, during

winter conditions

. In periods w hen GRGU1 has had continuous functional ity

, it has shown itself to

be adequate for assessing reasonable progress toward visibility goals at New Hampshire’s Class I

areas

. There is no indication of a need for additional monitoring sites or equipment , unless redundancy is the purpose

.

32 A description of the IMPROVE program is a vailable at http://vista.cira.colostate.edu/improve/

.NH Regional Haze 5

- Year Progress R eport Page 41

SECTION 11

– ADEQUACY OF CURRENT REGIONAL HAZE SIP

11.1 Requirement to Determine Adequacy of Current SIP

Section 40 CFR 51.308(h) of the R egional Haze Rule requires the s tate to determine the adequacy of its regional haze SIP on the b asis of the information pr esented in its 5

- year progress report.

11.2 Determination of SIP Adequacy : Negative Declaration

Based on the evaluations conducted for this report, NHDES declares that the existing SIP is adequate for continued reasonable prog ress towards natural visibility conditions at all mandatory

Class I federal areas affected by emissions from New Hampshire. Further revision of the existing implementation plan is therefore not needed at this time

. T his conclusion is supported by several

and various findings, which may be summarized as follows :

• The Visibility Record: Since 2000

- 2004

, visibility has improved at all locations in the

MANE

- VU region , including New Hampshire’ s Class I areas. The 5

- year average deciview values indicate a gen eral trend toward improved visibility on both best and worst days, and all areas appear to be on track to meet or surpass their 2018 reasonable progress goals.

• Sulfate Emissions: Su lfate accounted for one

- half to two

- thirds of total fine particle mass on the haziest days at MANE

- VU Class I areas in 2000

- 2004 . R eductions in emissions of this pollutant appear to be the biggest reason for trending improvements in visibility. It is projected

that SO 2 emissions from all sources in the region will decrease by two

- thirds or more over the period from 2002 to 2018, with most of those reductions coming from the EGU sector.

Between 2002 and 2013 , New Hampshire’s EGU s reduced SO 2 emissions by 93 percent in the aggregate

. Seismic changes in the industry have caused a shift away from coal

- fired

power production, the source of most SO 2 emissions in the region

.

• Controls on EGUs: Emission controls have already been implemented to control SO 2 , NOx, and particulate matter emissions at New Hampshire’s two BART unit s and a third, targeted

unit

. A f lue gas desulfurization system is operational and currently reducing SO 2 emissions by more than 90 percent at PSNH’s Merrimack Station , where two of the three units are

located

. PSNH’s Newington Station is using lower

- sulfur f uels.

• NOx Emissions: A regional reduction in NOx emissions has been the second

- largest factor

in visibility improvements in the MANE

- VU region thus far

. Federal programs for mobile

sources , which contribute the most to NOx emissions across the region

, w ill further reduce

NOx emissions and help to improve visibility in the years ahead.

• Other Emissions : Total emissions of fine particulate matter do not appear to be increasing, and emissions of VOC are projected to decline. Current controls and managemen t practices

for construction activities and prescribed agricultural and forestry burns serve to mitigate visibility impacts . Any impacts from these activities are likely to be short

- lived and of relatively minor consequence for nearby Class I areas

.

• Im pediments to Progress: Possible impediments to continued visibility progress

– especially

unresolved aspects of inters tate air pollution transport

– do not appear to be great enough at this time to prevent Class I areas affected by New Hampshire’s emissio ns from meeting

the ir respective 2018 reasonable progress goals.NH Regional Haze 5

- Year Progress R eport Page 42

SECTION 12

– CONSULTATION WITH FEDERAL LAND MANAGERS

12.1 Requirement to Consult Federal Land Managers

T he Regional Haze Rule at 40 CFR 51.308(i) requires that the state provide the FLMs responsible for Class I areas affected by emissions originating within the state an opportunity for consultation, in person, at least 60 days prior to any public hearing on the 5

- year progress report SIP revision

.

12.2 Consultation Process

NHDE S sent a preliminary draft of the SIP revision to the FLMs and EPA for review purposes on May 22, 2014. A conference call with representatives from the National Park Service, the U.S. Fish and Wildlife Service, the U.S. Forest Service, EPA region I, and NHDES was held on July 17, 2014 (see notes in Attachment K). After receiving comments from the FLMs and EPA

, NHDES revised the preliminary draft and reissued the document as a proposed SIP revision in keeping with EPA’s usual requirements for public review.

NHD ES notified the FLMs and EPA of a public hearing to be held on September 23, 2014 , and sent
the proposed SIP revision to the FLMs and EPA as part of the public review process and comment period , which closed on October 3 , 2014

. Comments submitted by the F LMs and EPA were addressed and incorporated into the final SIP revision before its submission to EPA for approval.

C omments received from the FLMs and EPA are included in Attachment K along with NHDES’s

responses.

Ne w Hampshire will continue to coordinat e and consu lt with the FLM s on future regional haze SIP

revisions and on the implementation of programs having the potential to affect visibility at the state’s mandatory Class I federal areas

.