State of Rhode Island 

Department of Environmental Management 

of Air Resources 

In Re: Adoption of the "Rhode Island Regional Haze State Implementation Plan Revision" 

DECISION 

Introduction 

On 30 June 2009 a notice was published in the Providence Journal-Bulletin and was mailed to 

interested parties announcing a public hearing and comment period to accept comments on the 

proposed adoption of the "Rhode Island Regional Haze State Implementation Plan Revision." 

The public hearing was held on 30 July 2009 in Room 300 of the Department of Environmental 

Management (RI DEM) Building, 235 Promenade Street, Providence, Rhode Island . The public 

comment period closed at 4 :00 PM on 30 July 2009. 

This State Implementation Plan (SIP) Revision addresses Environmental Protection Agency 

(EPA) requirements that states that contribute to visibility impairment in one or more Federal 

Class I Areas (national parks and wilderness areas) prepare plans consistent with the national 

goal of restoring visibility in those areas to natural conditions. Although Rhode Island does not 

have any Class I Areas, the EPA has determined that emissions from sources in the State 

contribute to visibility impairment in Class I areas in nearby states . 

As required by the EPA rule (40 CFR 51 .300-309), the proposed SIP revision includes a longterm strategy with emissions control measures that constitute Rhode Island's share of the 

emission reductions needed to meet visibility goals in the region . The measures included in 

Rhode Island's strategy include participation in a regional low-sulfur fuel oil program and, if 

approved by the Rhode Island General Assembly, adoption of restrictions on outdoor wood 

boilers. 

Response to Comments 

This section will present the Rhode Island Department of Environmental Management's (RI 

DEM's) response to the comments received during the public comment period . No comments 

were received at the public hearing. Each comment has been paraphrased and is followed by RI 

DEM's response. 
Comment: The American Lung Association in Rhode Island (ALARI) supports adoption of 

the Regional Haze SIP Revision. The same pollutants which contribute to haze are of concern 

for their impact on public health, whether as irritating gases or as particles. We support control 

efforts on sulfur compounds (including reducing the sulfur content of fuels both for heating and 

in mobile sources), nitrogen oxides, VOCs, and particulate matter (especially the most respirable 

particles-PMZ_5) . Making our air healthy to breathe, as well as improving visibility, requires 

cooperation outside our borders, and we commend RIDEM's Office of Air Resources for their 

close regional cooperation with NESCAUM, MANE-VU, and the Ozone Transport Commission, 

The American Lung Association nationally is working on the contribution to our regional air 

pollution problems from states outside those cooperating areas as we work to make the air in 

those areas healthier for all breathers there and downwind. (ALARI) 

Response: RI DEM appreciates ALARI's support and will implement emissions control 

programs as indicated in the SIP revision . 

Comment: Although the Outdoor Wood Boiler (OWB) bill is apparently not going to make it 

out of the legislature this session, there needs to be continued attention focused on this issue to 

try to prevent the installation of additional uncontrolled OWBs and deal with the immediate 

health consequences of existing OWBs. Woodburning is likely to continue to be a viable and 

popular source of heat for many people throughout the Northeast, but the devices, whether 

OWBs or EPA-certified woodstoves, should be as low-emitting as possible . The American Lung 

Association of New England is working on OWBs as a priority. (ALARI) 

Response : RI DEM agrees that OWBs are a significant concern and will continue to support 

legislation to require regulation of those boilers on a state and/or local level. 

Comment: Another ALA of New England regional priority is pollution from mobile sources, 

both on-road and off-road . ALA in RI is closely involved in efforts to reduce diesel exhaust, and 

we again commend the Office of Air Resources for the successful effort to get federal stimulus 

funding to clean up diesel-powered state vehicles, and all the other cooperative efforts with other 

governmental agencies (including RI DOT) and with a range of stakeholders including the Rhode 

Island Diesel Pollution Initiative to get both voluntary policy changes and laws/ordinances. 

RIDEM has endorsed the Green Construction Initiative which includes dust mitigation and 

control as well as anti-idling and particulate filter criteria. (ALARI) 

Response : RI DEM appreciates ALARI's support in this area. 

Comment: The Audubon Society of Rhode Island concurs with the figures on pages 15 and 

16 of the SIP revision that appear to show that, due to Rhode Island's prevailing downwind 

location from the Brigantine and Shenandoah Class I areas, Rhode Island does not contribute to 
regional haze at those locations and that Rhode Island's contribution to regional haze at Acadia 

and Lye Brook, which are downwind of Rhode Island, is low . (Audubon Society of Rhode Island 

(ASRI) 

Response: RI DEM agrees that the State contribution to regional haze at all Class I areas is 

minimal . 

Comment: The SIP Revision states that 40 CFR 51 .308(f) requires the RI DEM to submit 

periodic revisions to its Regional Haze SIP by July 31, 2018, and every ten years thereafter and 

that RI DEM acknowledges and will comply with this schedule. In the future, will elevated 

ambient temperatures over a longer season, as predicted under global climate projections, have 

an impact on production of haze? How is this factor accounted in the plan? Rhode Island's lack 

of contribution does not seem to warrant a change in the SIP on this matter, but on the national 

level increased ambient temperatures might call for higher contributors to have more frequent 

review . (ASRI) 

Response: As suggested by the commenter, Rhode Island's impacts on regional haze levels 

in Class I areas are very small and will likely remain insignificant in the future . Climate change 

was not considered in the modeling conducted in support of the MANE-VU regional haze SIPs, 

but may be a consideration in modeling done in the future in support of periodic revisions . The 

revision schedule is, as stated in the comment, set out in the federal regulation; comments on that 

schedule should be directed to the EPA. 

Comment: Rhode Island's 2009 legislation providing an incentive to incorporate vegetable 

oil in diesel fuels should reduce sulfur and particulate emissions. Does increased use of 

vegetable oil have any impact on non sulfur and particulate contributors to smog? (ASRI) 

Response: RI DEM assumes that the comment is referring to biodiesel, which is made from 

vegetable oil through a process called transesterification . Use of biodiesel, rather than diesel, 

results in significantly lower emissions of sulfur oxides (SO,), particulate matter (PM) and 

carbon monoxide (CO). The effect on oxides of nitrogen (NOc) and volatile organic compound 

(VOC) emissions is not as clear. NO, emissions may be very slightly reduced or may be the 

same as with diesel and VOC emissions could be higher than with diesel . 

Comment: Review of wood boiler regulations and other wood burning home-heating options, 

as well as oil home heating may be in order. What is the potential for filters in various homeheating arrangements? (ASRI) 

Response: The oil used for home heating, as well as in the commercial and industrial sectors, 

will be covered by the low sulfur fuel restrictions . As discussed in the SIP Revision, RI DEM is 
committed to adopting outdoor wood boiler regulations pending legislative approval of requirements for that source category . Wood stoves sold in the State are subject to federal emissions limits that require that they be certified to be low-emitting . 

Comment: Although small, RI's percent on-road mobile source PM contribution is relatively 

high in comparison to that in other states . Is this due to an older, less well-serviced fleet? I have 

observed some horrendous plumes of black smoke coming from snow plows and other 

transportation dump trucks . State agencies should reduce fleet emissions of particulate matter. 

Since particulate matter is a significant component of haze problem, regulation construction 

equipment for particulate emissions, as has the Providence City Council would be good on state 

level. (ASRI) 

Response: Figures 8 .19 and 8.29 show, for each MANE-VU state, both the total PM1o and 

PM2.5 emissions (gray circles) and the percentage breakdown of those emissions by source 

category. Rhode Island's PM emissions are, as stated in the comment, very low relative to other 

states. The percentage of those emissions that come from mobile sources is somewhat higher 

than in some other states, but that is because Rhode Island has very low emissions from the 

stationary source categories, particularly point sources, relative to other states, not because the 

mobile source category is disproportionately higher. 

There are two ongoing efforts to address the diesel fleet in Rhode Island . The first involves 

several grants we have recently received to cover the cost of retrofitting state and municipal 

equipment with particulate emissions reduction devices. It will take some time to address all 

vehicles in the entire fleet. 

The second is the initiation of an annual diesel emissions inspection program that will probably 

start in July 2010 or January 2011 . This will involve an opacity test of the vehicles under a "snap 

accelerator" test, meant to find the heavy smokers as mentioned in the comment. 

Additionally, a bill aimed at construction equipment was considered in the 2009 session of the 

General Assembly. The bill did not pass but was replaced by the establishment of a Senate study 

commission that could recommend the bill again early next legislative session . This could pave 

the way to a state contract requirement for retrofit devices on all diesel equipment used on state 

highway projects, paid for using construction project funds 

Comment: Attachment AA - "Low Sulfur Heating Oil" in the Northeast was not included on 

the CD with the appendices for the SIP sent to the US Environmental Protection Agency (EPA) 

(USEPA). . 

Response: The attachment was omitted in error and will be included with the final submittal . 
Comment: Section 2.0 refers to =10 CFR 51 .308I(3). The correct reference is 40 CFR 

51 .308(d)(3). (EPA) 

Response: This typographical error has been corrected. 

Comment: Section 8 .3 states that the emissions data and graphics presented in that section are 

from MANE-VU 2002 Baseline Emissions Inventory, Version 2.0 . However, Figures 8 .11, 8 .14, 

8.16 and 8.17 indicated that the data are from Version 3 .0 . Please resolve this discrepancy. 

(EPA) 

Response~ ThP ~~-n hics ~n flint section actually use Version 3 .0 data. The introductory 

paragraph in Section 8.3 was corrected in response to this comment. 

Comment: In Sectic . . , 1 .10, the RI SIP commits to adopting the MANE-VU low-sulfur fuel 

oil requirements by January 1, 2012 with a compliance date for Phase I of 2014 and for Phase II 

of 2018 . In Section 10.2 .3, Phase I is defined as a limit of 500 ppm sulfur for distillate (#1 and 

#2) oil and a limit of 2,500-5,000 ppm for residual oils (#4, #5 and #6). Phase II is defined as a 

limitation of 15 ppm for distillate . However, in Section 11 .4, the SIP states that the residual oil 

restrictions would be adopted by 2018 (in Phase II). Please clarify the timing for the residua'. - ~' 

restrictions . (EPA) 

Response: The dates in 11 .4 are from Ask, so the discussion in 10 .2 .3 was changed to be 

consistent with those dates (residual oil limitation moved to Phase II - 2018). 

Decision 

It is the decision of the Hearing Officer to adopt the proposed "Rhode Island Regional Haze State 

Implementation Plan Revision" with the revisions noted above. The final Plan is appended to 

this Decision. 

Date DouglVs McVay,o 

Hearing Officer