west virginia department of environmental protection 

Division of Air Quality 

601 57* Street SE 

Charleston, WV 25304 

Phone: 304.926.0475 + Fax: 304.926.0479 

Joe Manchin 111, Governor 

Stephanie R. Timmermeyer, Cabinet Secretary 

www.wvdep.org 

April 25,2008 

Ms. Angela King 

MANE- W c/o 

MARAMA 

via e-mail 

RE: West Virginia Comments on the 

MANE-VU 20 18 Visibility Projections 

Draft Report 

Dear Ms. King: 

The West Virginia Department of Environmental Protection, Division of Air Quality (DAQ) 

appreciates the opportunity to comment on the Mid-Atlantic/Northeast Visibility Union (MANEVU) 201 8 Visibility Proiections Drafi Report. These comments are being submitted via e-mail to 

the Mid-Atlantic Regional Air Management Association (MARAMA), which is assisting 

MANE-VU. 

West Virginia is a member of the Visibility Improvement - State and Tribal Association of 

the Southeast (VISTAS) regional planning organization and concurs with the comments 

submitted by Barry Stephens, Chair of the VISTAS State and Tribal Air Directors, on behalf of 

the VISTAS members. VISTAS has expended a tremendous amount of resources to assist 

member states in developing their Regional Haze State Implementation Plans (SIPs) and has 

consistently delivered high-quality technical analyses. We strongly believe that the sophisticatea 

professional work completed by VISTAS provides a more than adequate technical basis on 

which members can build their SIPs. Indeed, EPA and the Federal Land Managers have 

universally praised the VISTAS work products and initial SIPs for their technical accuracy and 

comprehensiveness. In addition to the VISTAS comments, DAQ would like to provide 

supplemental comments. 

We would like to emphasize that we expressly notified several MANE-W states at the start 

of the public comment period for our proposed Regional Haze SIP in October 2007. Further, 

though not required, the DAQ at that time provided electronic copies of the full SIP 

documentation, including the emission inventories developed by VISTAS, to the following 

MANE-VU states: Maryland, New Hampshire, New Jersey, Vermont, and Pennsylvania. 

Promoting a healthy environment. 
Letter to Ms. Angela King 

April 25,2008 

page 2 

Although DAQ did receive several substantive comments from New Jersey on other matters, 

no comments received fi-om New Jersey, or any other MANE-VU state, raised any issue 

regarding the emissions inventories used in the SIP modeling. Given subsequent developments, 

the DAQ believes that some of the potential commenters knew, or should have known, that 

significantly different emissions inventories were in process for MANE-VU's visibility 

evaluations. The emissions are clearly the hdamental basis for any such evaluations and should 

be one of the first elements examined upon review because the projected emission changes 

establish the expected rate of progress. Yet no one, including potential MANE-W commenters, 

raised this issue during the formal comment period for our proposed Regional Haze SIP, despite 

proactive outreach efforts. Given the impact on evaluations for Class I areas such as Brigantine 

(NJ), Shenandoah (VA) and Dolly Sods (WV), the DAQ believes that it is inappropriate to 

arbitrarily revise the projected emissions inventory for a regulatory analysis. We believe that the 

approach taken by VISTAS is more suitable and supportable. 

For electric generating units (EGUs), VISTAS states began with the 201 8 emission controls 

projected by the Integrated Planning Model (IPM) version 2.1.9 and adjusted the projections to 

reflect known controls on specific units. West Virginia recommended that the IPM projections be 

used for our EGUs in 201 8, since we did not have any more reliable information available to 

justifj changes. West Virginia did, however, make adjustments to the 2009 IPM projections to 

remove controls that we knew were not scheduled for installation by that date. Ignoring the 

careful application of local knowledge, MANE-VU has inappropriately increased the SO, 

emissions of W.Va.'s EGU sources by 20%, without regard for existing/scheduled controls, and 

without consulting the DAQ. 

MANE-VU also determined that their member states could achieve a 28% reduction in nonEGU SO, emissions by reducing sulfur in fuel oil. Therefore, MANE-W asked VISTAS and the 

Mid-West Regional Planning Organization (MRPO) to reduce SO, emissions from their nonEGUs by 28%. DAQ evaluated potential controls for non-EGUs in our state and determined that 

there were no equivalent reasonably available controls. However, the W.Va. EGUs achieve 

excess emission reductions which more than offset the MANE-W fuel oil "ask." DAQ 

documented this result in our proposed Regional Haze SIP as provided to the MANE-VU states 

identified above. MANE-VU, however, then assumed a 50-60% decrease in SO, emissions from 

industrial boilers in the VISTAS states, including W.Va. This reduction is neither realistic nor 

enforceable and was modeled without consulting DAQ. 

The Regional Haze Rule gives states the authority to define reasonable measures for sources 

within their respective borders and the VISTAS states, including W.Va., provided MANE-W 

with the projected 201 8 VISTAS emission inventory during the interstate consultation process. 

MANE-VU chose not to accept the VISTAS inventory and instead evaluated the benefits of 

potential control strategies that do not reflect the information provided by the VISTAS states. 

Promoting a healthy environment. 
Letter to Ms. Angela King 

April 25,2008 

page 3 

DAQ believes that MANE-W has significantly changed emission control assumptions 

subsequent to the formal RPO consultation meeting, without a sound basis. West Virginia 

strongly recommends that the MANE-VU states use the VISTAS inventories supplied to them 

for our states, rather than the inventory that MANE-VU has adopted. DAQ notes that EPA will 

ultimately determine what control assumptions are appropriate for use in SIPS to demonstrate 

reasonable progress toward visibility improvement. DAQ believes that the MANE-W state SIPS 

are more likely to be federally approvable if the VISTAS inventories are used. 

William Frederick Durham 

Deputy Director 

Assistant Director, Planning 

Division of Air Quality 

Promoting a healthy environment.