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

The 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 contributions 

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 Hampshire, on clear and hazy days.

http://hazecam.net/mtwash_gallery.aspx
NH 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 vistas 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 visibility 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 in, or formed from, emissions when coal or oil is burned. The largest 

sources of this pollution are electrical 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 Technology (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 other 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 requires 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 (SO2) 

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 unit 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 SIP 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 Report 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);

• Similar reductions in SO2 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, particularly NOx and volatile organic 

compounds (VOC), are expected to continue on a downward trend; 

• For the period 2009-2013 (the most recent 5 years 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 already 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 

Reasonable 

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

* 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.

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, further revision of the existing implementation 

plan is not needed at this time. Achieving these goals represents the first major milestone toward 

restoring natural visibility conditions at all Class I areas by the regulatory target year of 2064.
NH Regional Haze 5-Year Progress Report 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, the 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 Campobello 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 tourism 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 Atlantic 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 within 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 Mountains 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 Report 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 here 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

This 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 cirque 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 clear from snow that melts 

well into the summer.

Photo credits: National Park Service, US Fish and Wildlife Service, and wilderness.net
NH Regional Haze 5-Year Progress Report 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 requirements 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 

the 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 with 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 this 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 the 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 provided 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 Haze 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 Report Page vi

5-Year Progress Report Submittal 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 list 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 51.308(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 trends 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 

anthropogenic 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) 

Section 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 report (or the transmittal 

materials) provide the explicit 

determination required by the 

Regional Haze Rule? (all states) 

Section 11
NH Regional Haze 5-Year Progress Report Page vii

TABLE OF CONTENTS

EXECUTIVE SUMMARY.................................................................................................................i

MANE-VU’S CLASS I AREAS ...................................................................................................... iii

SIP SUBMITTAL ...............................................................................................................................v

SECTION 1 – FEDERAL REGIONAL HAZE 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 Assessment .............................................................................7

2.3 Visibility Progress – Detailed Assessment.............................................................................8

2.3.1 Graphical 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 Implementation.....................................................................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......................................................................................20
NH Regional Haze 5-Year Progress Report 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 Prevention of Significant Deterioration ......................................................................22

5.3.3 Agricultural and Forestry Smoke Management ..........................................................22

5.3.4 Measures 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 – EMISSION 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 CHANGES THAT HAVE 

IMPEDED VISIBILITY PROGRESS

8.1 Requirement to Assess whether Emissions Changes Have Impeded Progress....................37

8.2 Assessment...........................................................................................................................37
NH Regional Haze 5-Year Progress Report 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

Figure 4-1 Location of 167 EGU Stacks Contributing the Most to Visibility Impairment 

at MANE-VU Class 1 Areas.........................................................................................19

Figure 6-1 SO2 and NOx Emissions from New Hampshire EGUs in 2002 and 2013.....................28
NH Regional Haze 5-Year Progress Report Page x

LIST OF TABLES

Table 2-1 Observed Visibility 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 SO2 Control Measures at Targeted EGUs in New Hampshire ..........................20

Table 6-1 SO2 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 10-1 IMPROVE Network Site for New Hampshire’s Class I Areas .....................................40

LIST OF ATTACHMENTS

Attachment A Acronyms and Abbreviations

Attachment B Tracking Visibility Progress, 2004-2011

Attachment C Overview of State and Federal Actions 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 Thereto
NH Regional Haze 5-Year Progress Report Page 1

SECTION 1 – FEDERAL REGIONAL 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 future, 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 memorial 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. Nearby Class I Areas

Section 169A of the 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. On 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

REGION

 
NH Regional Haze 5-Year Progress Report Page 2

Figure 1-2. U.S. Regional Planning Organizations

States in the Mid-Atlantic and Northeast region, along with Federal Land Managers (FLMs) 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 report4 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, and 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 equipment 

(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 establish 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 Summary 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 Regional Haze in the Northeast and Mid-Atlantic United States,” August 2006; available 

at http://www.nescaum.org/documents/contributions-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, Rhode Island, and Vermont) plus New York 

and New Jersey.

 
NH Regional Haze 5-Year Progress Report Page 3

1.2.1 General and Procedural Requirements 

The submission of New Hampshire's first 5-year periodic progress 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.

This 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 located 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 

impacted 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 reports 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 the 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 conditions 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 visibility 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 years 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 inventory, 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 Report Page 4

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

state that have occurred 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 specified in 40 CFR 51.308(h):

(1) If the state 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 state must provide to the EPA Administrator a negative declaration 

that further revision of the existing implementation plan is not needed at this time.

(2) If the state determines that the implementation plan is or may be inadequate to ensure 

reasonable progress due to emissions from sources in another state(s) which participated in a 

regional planning process, the state must provide notification to the EPA Administrator and 

to the other state(s) which participated in the regional planning process with the states. The 

state must also collaborate with the other state(s) through the regional planning process for 

the purpose of developing additional strategies to address the plan's deficiencies.

(3) Where the state determines that the implementation plan is or may be inadequate to ensure 

reasonable progress due to emissions from sources in another country, the state shall provide 

notification, along with available information, to the EPA Administrator.

(4) Where the state determines that the implementation plan is or may be inadequate to ensure 

reasonable progress due to emissions from sources within the state, the state 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 adopted 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/divisions/air/do/asab/rhp/sip.htm.

 
NH Regional Haze 5-Year Progress Report 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-onthe-Way (BOTW) measures (see Section 7.2.1) as well as the additional control measures 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 effort 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 following 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 (SO2) 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 MANEVU region – comprising 167 stacks in total.

6

 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.

• 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 content 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 sulfur 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 residual 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 

availability.

• Continued evaluation of other control measures, including energy efficiency, alternative 

(clean) fuels, additional measures to reduce SO2 and nitrogen oxide (NOx) emissions from 

all coal-burning facilities by 2018, and 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 implementation of reasonable NOx and SO2 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 Report 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 visibility 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 nonMANE-VU states called for the adoption and implementation of the following emission control 

strategies, as appropriate and necessary:

• Timely implementation of BART requirements.

• A 90% or greater reduction in sulfur dioxide (SO2) 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 MANEVU 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 reasonable controls on non-EGU sources resulting in a 28% reduction in 

non-EGU SO2 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-VU’s low-sulfur fuel oil strategy.8

• Continued evaluation of other control measures, including measures to reduce SO2 and 

nitrogen oxide (NOx) 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 implementation of reasonable NOx and SO2 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 equivalent 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 that 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 Report Page 7

SECTION 2 – CHANGES IN VISIBILITY AT CLASS I AREAS IN THE STATE 

2.1 Requirements to Track Visibility Progress 

The ultimate goal of the Regional Haze Rule is to restore natural visibility conditions 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 Class 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 past 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 values for the 20% 

best (least impaired) and 20% worst (most impaired) days in determining visibility progress.

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 

National 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 speciated 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 MANEVU’s Class I areas versus the corresponding short-term (2018) and long-term (2064) visibility goals. 

The 5-year average deciview values for the periods 2000-2004 and 2009-2013 are presented along 

with visibility improvements. The data indicate 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, the 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 values against

the 2004-2008 mean values for each Class I area. The comparison in Table 2-1 uses 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 improvements 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 improvement is

expected, past rates may not be indicative of future visibility progress.
NH Regional Haze 5-Year Progress Report 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 Area*** 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 last 5-year period for which data

were available at the time of the report.

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 the 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 visibility 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 Report Page 9

• Although the Brigantine Wilderness Area in New Jersey is on track to meet its 2018 

reasonable progress goals, challenges 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

Figures 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 numerical data (through 2011) are found in Table 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 black (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 longterm natural visibility goals. The worst-day glidepath is also called 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 NESCAUM report12 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 resumption of the downtrend. This somewhat irregular pattern may be

explained by meteorological variability and changes in regional emissions in the period after 2007. 

The 5-year averaging of annual deciview values (represented by solid lines) smooths any short-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 For the Brigantine Wilderness Area, whose haze levels on the 20 percent best days during the 2000-2004 baseline 

period were higher than estimated natural conditions on the 20 percent worst days, the no degradation line (representing 

the long-term best-day goal) is higher than the uniform rate of progress line (representing the long-term worst-day goal) 

at dates approaching 2064. This nonsensical situation is an artifact of technical guidance and only represents stated 

visibility goals, not anticipated results.

12 NESCAUM, “Tracking Visibility Progress, 2004-2008,” MANE-VU Technical Memorandum, May 12, 2010; 

available at http://www.nescaum.org/documents/tracking-progress-final-05-12-10.pdf.

 
NH Regional Haze 5-Year Progress Report Page 10

Figure 2-1. Visibility Progress at Acadia National Park

Figure 2-2. Visibility Progress at Moosehorn Wilderness Area
NH Regional Haze 5-Year Progress Report Page 11

Figure 2-3. Visibility Progress at Great Gulf Wilderness Area

Figure 2-4. Visibility Progress at Lye Brook Wilderness Area
NH Regional Haze 5-Year Progress Report Page 12

Figure 2-5. Visibility Progress at Brigantine Wilderness Area

2.3.2 Light Extinction Trends from Constituent PM

In 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 Progress, 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 scattering (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 on 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. Within 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 concentrations 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 Report Page 13

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

Class I areas, followed 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 Days
NH Regional Haze 5-Year Progress Report 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 EPA 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 areas. 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 status 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 within the MANE-VU region. Further visibility 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 SO2 and NOx for certain electricity generating units. However, 

most 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. (See Section 4.3.1 for details.) 

New Hampshire was never a CAIR state and, consequently, did not rely 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 relative to the MANE-VU Ask, including synopses of the individual states’ 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 requirements.

New Hampshire has two units subject to BART, both of which are EGUs owned and operated 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 of
NH Regional Haze 5-Year Progress Report Page 15

existing permit conditions and administrative rules, including New Hampshire Administrative Rule 

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 Controls and Implementation Status

Pollutant BART Controls /

Emission Limitations NH Regulatory Citations ComplianceDeadline Status

PSNH Merrimack Station Unit 2

SO2 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 SO2

percent reduction set at 

maximum sustainable rate, 

but not less than 90% as a 

calendar monthly average

Administrative Rule Env-A 2300: 

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 SO2 reduction. Maximum 

sustainable rate is being evaluated. 

Findings are December 31, 2014,

and will be incorporated as permit 

condition ~ 2015.

NOx 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 (preexisting);

TSP emission limit of 0.08 

lb/MMBtu 

Administrative Rule Env-A 2300: 

Mitigation of Regional Haze, 

paragraph 2302.01(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

SO2 SO2 emission limit of 0.50 

lb/MMBtu, 30-day rolling 

average, applicable 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.

NOx Low-NOx burners, overfire 

air, and water injection (preexisting);

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 Report 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. 

New 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 construction 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 Report Page 17

SECTION 4 – STATUS OF 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 the 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 New Hampshire's 

actions. Note that there 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 Assessment14 produced a conceptual model of regional haze in which 

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 described in Section 2.3.2.

15

The Contribution Assessment found that, in 2002, SO2 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 regions 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 SO2 emissions. In response to these findings, MANE-VU designed its 

long-term strategy to include additional control measures on SO2 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 category contributing to

these emissions, and EPA’s Clean Air Interstate Rule was the strategy of choice for most states to 

reduce SO2 emissions from EGUs by 2018.

4.3 EGU Control Measures Included in the SIP

Since 2002, various control measures to reduce emissions 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 Sections 6 and 7 of this report. The following information 

describes the status of EGU control measures included in the SIP that have been effective in 

reducing regional-haze-causing emissions.

14 See footnote 4.

15 Unlike NESCAUM’s graphical analysis, the Contribution Assessment was based on particle 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 

Eastern United States for MANE-VU’s Regional Haze Modeling,” final report, August 16, 2009; available at 

http://www.marama.org/publications_folder/EGU_Projections_Summary_Final_Aug_2009.pdf.

 
NH Regional Haze 5-Year Progress Report 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 SO2

and/or NOX 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 MANEVU 2018 modeling projections. 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 NOX annual, NOx ozone season, and SO2 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 left 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 SO2, annual NOx, and ozoneseason NOx; 3 states for annual SO2 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 SO2 and 1,400,000 tons 

of NOX annually from 2005 levels. These estimates represented a 71 percent reduction in SO2 and 

a 52 percent reduction in NOX 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 requested a rehearing en banc of the CSAPR vacatur. The court denied this request on 

January 24, 2013. The 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, the individual MANE-VU states adopted state-specific emission 

control measures beyond CAIR that will help to reduce emissions of haze-causing pollutants from 

EGUs. The regional modeling used to establish the MANE-VU reasonable progress goals included 

a large number of state control measures, including two New Hampshire regulations affecting local

EGUs. These 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 Modeling

Control Measure Status

Chapter Env-A 2900: Multiple Pollutant Annual Budget Trading and 

Banking Program, capping NOX emissions at 3,644 tons per year, SO2

emissions at 7,289 tons per year, and CO2 emissions at 5,425,866 tons CO2

per year for all existing 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: NOX Budget Trading Program, limiting ozone 

season NOX 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 Report Page 19

4.3.3 Controls on Top 167 EGU Sources

With the focus on sulfate emissions and fossil-fuel-fired power plants, MANE-VU reasoned that 

large reductions in SO2 could be obtained with the addition of cost-effective controls on the largestcontributing EGUs. Appendix D of MANE-VU’s Contribution Assessment identified 167 EGU 

sources 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 PSNH 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 SO2 emissions from each of these sources, or 

equivalent measures where this level of 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 SO2 scrubbers 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, 

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

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

outside MANE-VU to reduce SO2 emissions from the targeted units. The status of New Hampshire’s 

three sources is shown below (Table 4-2).
NH Regional Haze 5-Year Progress Report Page 20

Table 4-2. Status of SO2 Control Measures at Targeted EGUs 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.)

not 

required 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

SO2 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 reduce 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 Program, 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 SO2 at Merrimack Station occurs as a co-benefit of FGD 

for mercury control that simultaneously 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 SO2, 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 SO2 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 SO2. The method(s) of compliance for Schiller Station have not yet been determined 

but could further reduce SO2 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 experienced sharp reductions in utilization, no retirements or replacements of New Hampshire’s

EGUs have occurred or been announced since the regional haze SIP 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 Schiller successfully petitioned EPA for a one-year extension to April 16, 2016.

 
NH Regional Haze 5-Year Progress Report Page 21

SECTION 5 – STATUS OF ADDITIONAL CONTROL MEASURES IN THE SIP

5.1 Requirement 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 SO2 emissions from key 

EGUs (Section 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 course of action, the MANE-VU 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 mainly 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 regard 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 commit 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 progress in surrounding states. Incremental fuel costs and the assurance of fuel supplies 

for the various grades of low-sulfur oil are real, but diminishing, concerns as other states’ programs 

ramp up. To be successful in New Hampshire, any low-sulfur fuel oil requirement would most likely 

be implemented via legislative action rather than NHDES rulemaking. The prospects for such action

are being evaluated at the time of this progress report. 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 oil 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 content 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 2010, 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 for certain NOxemitting 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 boilers, 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 sources. The rule also establishes the criteria and procedures by which a source can 
NH Regional Haze 5-Year Progress Report Page 22

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

allowances. Env-A 1300 was readopted 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 (79 FR 49458).

5.3.2 Prevention of Significant Deterioration

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 quality 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 

codified 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, including 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 readopted with an effective 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 allowing 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 difference 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 wind 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 from 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 Forestry 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 Report 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 region. With respect to PM2.5 emissions, the 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). 

Fires 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 infrequent contributors to regional 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.

Smoke 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 best 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 annual basis, only a small 

fraction of one percent to total light extinction on days of both good and poor visibility.

This is not to say that individual events, including prescribed burns, will not have short-term 

visibility impacts. Such impacts are addressed by the New Hampshire Prescribed Fire Council in 

its recommended standards21 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 smoke 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 White 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 standards.

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 recommendation 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 quality 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 Report 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 earthmoving activities and heavy vehicular 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 baseline 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 largely 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 proximity 

of construction activities, and construction activities occurring in the immediate vicinity of MANEVU 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 

progress 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 establishes 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-bynotification 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 

NHDES and the town, rather than undergoing a more extensive permit process each time. The 

amended rule requires emissions testing of all new 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, effective 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 visibility 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 construction 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 

implied at this time:
NH Regional Haze 5-Year Progress Report 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 

SO2, NOx, and PM. The option exists to expand such programs 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

adopted 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 many Northeast

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

• Wood combustion standards: In addition to passage of a state law22 regulating outdoor wood

boilers, other measures to control particulate emissions from small wood combustion devices 

are under consideration. At the federal level, EPA has proposed new source performance 

standards (NSPS) for 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 Report Page 26

SECTION 6 –EMISSION REDUCTIONS RESULTING FROM 

IMPLEMENTATION OF CONTROL MEASURES IN THE SIP

6.1 Requirement to Summarize Emission Reductions

40 CFR 51.308(g)(2) requires that the progress report summarize the emission reductions achieved 

throughout the state by implementation of the measures included in the SIP to meet reasonable 

progress goals for mandatory Class I federal areas.

6.2 Emissions Changes since 2002

Emissions reductions described in this section are constructed from 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 SIPs and compares those values to the 

latest available estimates for the major categories 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 approximately 

as follows: sulfur dioxide, 16%; nitrogen oxides, 13%; direct fine particulate 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 2007 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 on the way before the states’ 

regional haze SIPs were completed, but not to control measures arising from those SIP revisions

(which were completed after 2007). The emission reductions and attendant air quality benefits 

emanating from the regional haze SIPs have begun only recently and, for the most part, are not 

readily quantifiable thus far.

6.3 Emission Reductions from New Hampshire’s EGUs 

Electrical generating units are recognized as the largest group of SO2 emitters and thus the leading 

contributors 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 mandated 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 SO2 and NOx annual emissions – along with heat input, gross 

load, and operating time – as recorded in 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 SO2 and NOx emissions from New Hampshire EGUs are also shown graphically 

in Figure 6-1.
NH Regional Haze 5-Year Progress Report Page 27

Table 6-1. SO2 and NOx Emissions from New Hampshire EGUs in 2002 and 2013

Year Facility Name Facility ID 

(ORISPL)

Unit

ID

SO2

(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 15,873,049 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 3,692,785 321,005 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 3,936,700 318,110 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 Schiller 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, http://ampd.epa.gov/ampd/. The annual unit-level emissions data for this summary were 

downloaded on August 19, 2014.

SO2 and NOx emissions for all New Hampshire EGUs in the CAMD database were lower in 2013

than in 2002 by approximately 40,800 and 4,200 tons per year, respectively. These amounts

equate to emission reductions of 93 and 61 percent. For the three targeted EGUs, the corresponding

SO2 and NOx reductions were approximately 34,200 and 2,700 tons per year, or 95 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 a 
NH Regional Haze 5-Year Progress Report 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 2013 CAMD data show that the two units emitted 1,401 

tons of SO2 versus a gross heat input of 14,663528 MMBtu. This translates to an average annual 

emission rate of 0.19 lb/MMBtu with the emission controls in place. For comparison, the average 

SO2 emission rate (calculated from the data in Table 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 SO2 removal efficiency of the new control equipment is estimated to be at least 90 percent.

This finding is supported 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 was 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 SO2 removal efficiency in the vicinity of 94 

percent.

Figure 6-1. SO2 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 Report Page 29

SECTION 7 – CHANGES IN EMISSIONS OF HAZE-CAUSING POLLUTANTS 

7.1 Requirement to Analyze and Track Changes 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 

sources and activities within the state. 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 with 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, mobile, area, non-road, and MAR25), 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 data 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 making 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. Inconsistencies 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 factors, unanticipated shutdowns or new sources, and introduction of 

new control measures.

Note that two different EPA models were used to calculate mobile source emissions: 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 Report Page 30

7.2.1 2002 Modeling Inventory with Projections to 2018

MARAMA prepared the 2002-based modeling inventory suite and released it in final version in 

2006. The future-year 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 measures that were 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 accounted for all emission control

measures in the OTB/OTW scenario plus additional controls that states committed 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 for this emissions trends analysis. Several versions of the 

2002-based inventory suite were prepared, with improvements made to the emissions estimates in

each successive run. The last and best of these is MANE-VU Version 3.3. This is the version that 

was used to perform air quality modeling and is the one used for this emissions trends analysis.

Details on the methods and assumptions behind the 2002-based inventory suite are found in 

documentation for the base year inventory26 and future projections.27

7.2.2 2007 Modeling 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 categories 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) Levels 1, 2, and 3 

modeling.) For those runs, future-year EGU projections had not yet been completed. Therefore, for 

modeling purposes, provisional EGU estimates for year 2020 were prepared that were based on the 

CSAPR emission caps (as then established). Improved future-year modeling inventories for electric 

generating units are being developed in a separate effort lead by the Eastern Regional Technical 

Advisory Committee (ERTAC)28 and are not included here.

On-road emissions were available only for base year 2007 and future year 2020. 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. Those 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://www.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 Non-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-yearemissions-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 Report 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, 2017 and 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 “future base case.”

• OTC Control Measures – These projections accounted for all emission control measures in 

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

had 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 for this emissions trends analysis. Several 

versions of the 2007-based inventory suite were prepared, with improvements made to the 

emissions 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 emissions trends analysis. 

The methods and assumptions employed in preparing the 2007-based inventory suite are described

in documentation for the base year inventory29 and future projections.30

7.2.3 CAMD Reported Emissions

EPA’s CAMD is responsible for implementing 40 CFR 75, which requires hourly emissions 

monitoring and reporting by any major source that participates in an emissions cap-and-trade 

program under the Acid Rain Control Program, the NOX Budget Trading Program, or CAIR. All 

sources participating in the CAMD programs are required to submit unit-level emissions of NOx, 

SO2, and 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. Only 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 emissions that cause regional haze by

comparing emissions data from the referenced 2002 and 2007 baseline inventories and the 2013

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: NOx, SO2, PM2.5 and VOC. Emissions in tons per year are listed by source 

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

29 AMEC Environment & 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/emissionsinventory/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/emissionsinventory/2007-emissions-and-projections/future-year-inventory-version-3.

 
NH Regional Haze 5-Year Progress Report Page 32

three data sources used for the analysis. The blue 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 some general observations on regional emissions trends as 

revealed by the data presented.

7.3.1 Sulfur Dioxide

Regional SO2 emissions are dominated by the EGU sector, accounting for about three-fourths of all 

such emissions in 2002 and 2007, but projected to be reduced to half by 2018. SO2 emissions from 

EGUs were markedly lower in 2013 than in either of the baseline years. The decline from 2002 to 

2007 was about 10 percent, but from 2002 to 2013 exceeded 80 percent. Actual 2013 emissions from 

the EGU sector were already below the projected 2018 emissions.

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

will assume a growing proportion of the total SO2 inventory. Note that there is negligible effect from

any changes in methodologies for the calculation of SO2 emissions 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 SO2 emission reductions are not a 

temporary phenomenon, and the downward trend in regional SO2 emissions is expected to continue.

7.3.2 Oxides of Nitrogen

Regional NOx emissions 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 SO2 emissions, 

tabulated values for the EGU sector indicate sizeable decreases in NOx emissions from 2002 to

2007 (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 revision in calculation 

methodology when it switched from MOBILE6 to MOVES as the preferred on-road emissions model.

This change occurred between completion of the two different inventory suites. As a result, direct 

comparison of the 2002-based and 2007-based on-road mobile datasets complicates the analysis of

emission trends within this sector. However, when examined separately, each dataset projects a 

decrease in NOx emissions in the range of 40-60 percent between base year and future year.

Despite any uncertainties 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 particulate matter is regionally dominated by area sources, 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 PM2.5

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 PM2.5 

emissions from the lesser contributing sectors – namely EGUs and mobile sources – also changed, 

making straight comparisons of the datasets difficult.
NH Regional Haze 5-Year Progress Report Page 33

Overall, the trend for directly emitted fine particulate matter is not well-defined. Emissions from

some source categories remain largely unchanged, while others, especially those dominated by 

engines, are projected to show reductions. Net changes in direct PM2.5 emissions are anticipated to 

be small and of limited consequence to regional haze; total annual emissions of fine PM2.5 are the 

lowest among the four pollutants analyzed and represent no more than 5-10 percent of the total 

inventory of emissions in any year.

7.3.4 Volatile Organic Compounds

Most regional VOC emissions originate from biogenic sources, which will remain largely

unchanged over the foreseeable future. The summarized inventories in Table 7-1 include only 

anthropogenic emissions and thus do not count biogenic emissions in the category totals.

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

that coming from residential wood combustion. As in the case of direct PM2.5, changes occurred in 

both VOC estimation methodology and VOC emission factors for the residential wood combustion

subcategory. These technical adjustments resulted in generally lower emissions estimates for the 

2007-based inventory suite than for the 2002-based version. The calculation methodology also 

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

VOC. All of these changes make direct comparisons 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 combined.
NH Regional Haze 5-Year Progress Report Page 34

Table 7-1. Annual Air Pollutant Emissions 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 Non-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

Non-road MAR(4) 32,123 30,318 --- 4,870 8,172 4,183

Non-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 --- 194,832 263,954 194,868

On-road Mobile(4) 1,308,235 1,175,916 --- --- 303,956 471,558

Non-road MAR(4) 137,733 173,855 --- 127,391 111,425 118,025

Non-road NMIM(4) 289,392 263,931 --- 153,553 158,843 135,962

Total 2,668,916 2,333,286 --- --- 1,180,664 ---

Direct PM2.5

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

Non-road MAR(4) 7,929 7,430 --- 3,906 7,927 3,503

Non-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

Non-road MAR(4) 14,026 19,066 --- 17,057 14,962 16,962

Non-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 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 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 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 completed by states. 

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

methodologies. Non-road MAR includes commercial marine vessels, airports, and railroad locomotives. Non-road

NMIM (National Mobile Inventory Model) includes equipment in EPA’s NMIM/NON-ROAD model.
NH Regional Haze 5-Year Progress Report 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 emissions inventories for SO2, NOx, PM2.5 and VOC. Note 

that the column labeled 2013 shows the aggregated annual SO2 and NOx emissions for that year for 

all New Hampshire EGUs participating in the CAMD programs. Both the aggregated and unit-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:

• Historically, most of New Hampshire’s SO2 emissions originated from the EGU source 

category. There was little change in EGU emissions between 2002 and 2007, but SO2

emissions from this sector in 2013 were more than 90 percent below the baseline – easily 

surpassing projected reductions. As projected for 2018, SO2 emissions 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 in New Hampshire, 

as in the entire 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. Area sources of NOx play 

a somewhat larger role in New Hampshire than they do in the region as a whole, but for 

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 PM2.5 in New 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 emissions 

from area sources are not projected to change much by 2018, but new emission controls on 

engines will have the intended effect of reducing VOC emissions from mobile sources. 

Largely because 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.

Note on mobile emissions: The 2020 MOVES analyses produced anomalous results for on-road 

mobile emissions for several states, including New Hampshire. Extensive 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 Hampshire 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: SO2, 542 tons/year; NOx, 30,342 tons/year; PM2.5, 3,010 tons/year; 

VOC, 14,629 tons/year.
NH Regional Haze 5-Year Progress Report Page 36

Table 7-2. Annual Air Pollutant Emissions 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*

Non-road MAR(4) 220 545 --- 81 226 46

Non-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*

Non-road MAR(4) 1,776 1,454 --- 1,306 1,723 1,286

Non-road NMIM(4) 8,104 8,548 --- 5,521 4,558 5,268

Total 64,625 56,110 --- --- 30,369 ---

Direct PM2.5

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*

Non-road MAR(4) 95 62 --- 46 98 45

Non-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*

Non-road MAR(4) 142 195 --- 175 158 178

Non-road NMIM(4) 22,231 17,105 --- 11,028 14,807 9,783

Total 106,425 54,120 --- --- 85,288 ---

(1) This 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 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 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 completed by states. 

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

methodologies. Non-road MAR includes commercial marine vessels, airports, and railroad locomotives. Non-road

NMIM (National Mobile Inventory Model) includes equipment in EPA’s NMIM/NON-ROAD model.

* Adjusted value – see note on mobile emissions in Section 7.4 of report.
NH Regional Haze 5-Year Progress Report Page 37

SECTION 8 – ASSESSMENT OF SIGNIFICANT EMISSIONS 

CHANGES THAT HAVE IMPEDED VISIBILITY PROGRESS

8.1 Requirement to Assess whether Emissions Changes Have Impeded Progress

Section 40 CFR 51.308(g)(5) of the Regional Haze Rule requires an assessment of any significant 

changes in anthropogenic emissions within or outside the state that have occurred over the past 5 

years that have limited or impeded progress in reducing pollutant 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 hinder 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 sources, 2) the

unanticipated addition of one or more new sources, 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 sources 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, the net effect 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 benefit 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 Class 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 measures in place that are operating

to reduce emissions as required in the SIP. (See Sections 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 earliest years of the planning period. As 

described elsewhere in this report, haze-causing emissions have been on 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 SO2 and NOx, is an ongoing issue that 

CSAPR, the replacement rule for CAIR, addresses in part. The implementation of MATS 

and the revised SO2 NAAQS may help to mitigate the delay in the implementation of 

CSAPR, at least for the control of SO2 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 Report Page 38

• Some 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 purchase 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 Ozone Transport Region, which 

includes all of the MANE-VU states. This finding was the subject of a recent statement31

from the OTC 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 will demand that interstate transport, as a 

continuing impediment to visibility progress, be resolved. Visibility tracking thus far 

indicates that all five MANE-VU Class I areas affected by New Hampshire’s emissions are 

on course or ahead of schedule to achieve 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 Report 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 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.

9.2 Assessment

On the basis of the analyses described in this report, 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 goals established for the two mandatory 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 goals toward the national goal of restoring natural visibility conditions by 2064 as 

promulgated under the Regional Haze Rule.
NH Regional Haze 5-Year Progress Report Page 40

SECTION 10 – MONITORING STRATEGY REVIEW

10.1 Requirement to Review Monitoring Strategy

Section 40 CFR 51.308(g)(7) of the Regional Haze Rules requires that each state with a mandatory 

Class I federal area review the state’s visibility monitoring strategy and the need for any modifications

to it. The original visibility monitoring strategy for New Hampshire’s Class I areas is described 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, approximately 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 northernmost 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 Londonderry; but neither is considered representative of the Class I areas.

Table 10-1. IMPROVE Network Site for New Hampshire’s Class I Areas

Site Name Site Code Latitude Longitude Elev. (m) Dates of Operation

Great Gulf Wilderness GRGU1 44.31° -71.22°. 454 June 10, 1995 - present

As the central component of New Hampshire’s visibility monitoring strategy, the IMPROVE network

monitor GRGU1 has been in service since 1995. This monitor was deemed adequate in the SIP to 

meet EPA’s Regional Haze Program requirements for the state’s two mandatory Class I federal 

areas. Section 2 of this report provides a summary of visibility 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 the original network described in the regional haze SIP. In reviewing the record, 

NHDES notes that the visibility database contains gaps in the data for GRGU1 in both 2009 and 

2010. These gaps rendered the 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. GRGU1 is operated 

under the management 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 when GRGU1 has had continuous functionality, 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 available at http://vista.cira.colostate.edu/improve/.

 
NH Regional Haze 5-Year Progress Report 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 Regional Haze Rule requires the state to determine the adequacy 

of its regional haze SIP on the basis of the information presented 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 progress 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. This 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 general 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: Sulfate 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. Reductions in emissions of this 

pollutant appear to be the biggest reason for trending improvements in visibility. It is projected

that SO2 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 EGUs reduced SO2 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 SO2 emissions in the region.

• Controls on EGUs: Emission controls have already been implemented to control SO2, NOx, 

and particulate matter emissions at New Hampshire’s two BART units and a third, targeted 

unit. A flue gas desulfurization system is operational and currently reducing SO2 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 fuels.

• 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, will 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 management 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. 

• Impediments to Progress: Possible impediments to continued visibility progress – especially 

unresolved aspects of interstate air pollution transport – do not appear to be great enough at 

this time to prevent Class I areas affected by New Hampshire’s emissions from meeting 

their respective 2018 reasonable progress goals.
NH Regional Haze 5-Year Progress Report Page 42

SECTION 12 – CONSULTATION WITH FEDERAL LAND MANAGERS

12.1 Requirement to Consult Federal Land Managers

The 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

NHDES 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.

NHDES 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 FLMs and EPA were 

addressed and incorporated into the final SIP revision before its submission to EPA for approval. 

Comments received from the FLMs and EPA are included in Attachment K along with NHDES’s 

responses.

New Hampshire will continue to coordinate and consult with the FLMs 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.