west virginia department of environmental protection

Division ofAir Quality 601 57* Street SE Charleston,WV 25304 Phone: 304.926.0475 

### + Fax: 304.926.0479 Joe Manchin 111, Governor StephanieR. 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 ofAir Quality (DAQ) appreciatesthe opportunityto comment on the Mid-Atlantic/NortheastVisibility Union (MANEVU) 

### 2018 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 submittedby 

### Barry Stephens, Chair of the VISTAS State and Tribal Air Directors, on behalf of the VISTAS members. VISTAS has expended a tremendous amount ofresources 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 severalMANE-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 ofthe full SIP documentation, including the emission inventories developedby 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 othermatters,

no commentsreceived fi-omNew Jersey, or any otherMANE-VU state, raised any issue regarding the emissions inventoriesused in the SIP modeling. Given subsequent developments, the DAQ believes that some ofthe potential commentersknew, or should have known, that significantlydifferent emissions inventories were in process for MANE-VU's visibility evaluations. The emissions are clearly the hdamentalbasis for any such evaluations and should be one of the first elements examinedupon review because the projected emission changes establish the expected rate ofprogress. Yet no one, includingpotential 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 inappropriateto arbitrarilyrevise the projected emissions inventory for a regulatory analysis.We believe that the approachtaken by VISTAS is more suitable and supportable.

For electricgeneratingunits (EGUs), VISTAS statesbegan with the 2018 emission controls projected by the Integrated Planning Model (IPM) version 2.1.9 and adjustedthe projections to reflect known controls on specific units. West Virginiarecommended that the 

### IPM projections be used for our EGUs in 201

### 8, sincewe did not have any more reliable information available to justifj changes. West Virginia did, however, make adjustmentsto the 2009 IPM projections to

remove controls that we knew were not scheduled for installationby that date. Ignoringthe careful application of local knowledge, MANE-VU has inappropriatelyincreased the SO, emissions ofW.Va.'s EGU sourcesby 20%,without regard for existing/scheduledcontrols, and without consulting the DAQ.

MANE-VU also determinedthat their member states could achieve a 28% reduction in nonEGU SO, emissionsby 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 consultingDAQ.

The Regional Haze Rule gives states the authorityto 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 consultationprocess. 

### 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-Whas significantlychanged emission control assumptions subsequent to the formal RPO 

### consultation meeting, without a sound basis. West Virginia stronglyrecommends that the MANE-VU states use the VISTAS inventories suppliedto them for our states, rather than the inventorythat MANE-VU has adopted. DAQ notes that EPA 

### will ultimately determinewhat control assumptions are appropriate for use in SIPS to demonstrate reasonable progress toward visibilityimprovement. DAQ believes that the 

### MANE-W state SIPS

are more likelyto be federallyapprovable if the VISTAS inventories are used.

William Frederick Durham Deputy Director Assistant Director, Planning Division ofAir Quality



### Promoting 

### a healthy 

### environment.