New Hampshire 

Regional Haze SIP Revision 

January 29, 2010 

Mid-Atlantic/Northeast Visibility Union (MANE-VU) 

 

Prepared by 

Air Resources Division
New Hampshire Regional Haze SIP Revision Page i 

TABLE OF CONTENTS 

1. THE REGIONAL HAZE ISSUE ...........................................................................................1 

1.1 Regional Haze Planning after Remand of CAIR............................................................2 

1.2 The Basics of Haze.........................................................................................................5 

1.3 Anatomy of Regional Haze ............................................................................................6 

1.4 Regulatory Framework...................................................................................................7 

1.4.1 The Regional Haze Rule........................................................................................8 

1.4.2 State Implementation Plan.....................................................................................9 

1.5 New Hampshire’s Class I Areas....................................................................................11 

1.5.1 Great Gulf Wilderness..........................................................................................12 

1.5.2 Presidential Range - Dry River Wilderness, New Hampshire .............................13 

1.5.3 Monitoring and Recent Visibility Trends.............................................................14 

2. AREAS CONTRIBUTING TO REGIONAL HAZE............................................................16 

2.1 Class I Areas Affected by New Hampshire’s Emission Sources ..................................17 

2.2 States Contributing to Visibility Impairment in New Hampshire’s Class I Areas........18 

3. REGIONAL PLANNING AND CONSULTATION............................................................19 

3.1 Mid-Atlantic / Northeast Visibility Union (MANE-VU)..............................................19 

3.2 Regional Consultation and the “Ask”............................................................................20 

3.2.1 New Hampshire-Specific Consultations...............................................................24 

3.2.2 The MANE-VU “Ask” .........................................................................................26 

3.2.2.1 Meeting the “Ask” – MANE-VU States .....................................................26 

3.2.2.2 Meeting the “Ask” – New Hampshire.........................................................27 

3.2.2.3 Meeting the “Ask” – States outside MANE-VU.........................................27 

3.2.3 Technical Ramifications of Differing Approaches...............................................28 

3.2.4 Consultation Issues...............................................................................................29 

3.2.5 State/Tribe and Federal Land Manager Coordination ..........................................31 

3.2.6 EPA Consultation and Review .............................................................................33 

4. ASSESSMENT OF BASELINE AND NATURAL VISIBILITY CONDITIONS ..............34 

4.1 Calculation Methodology ..............................................................................................34 

4.2 MANE-VU Baseline Visibility .....................................................................................35 

4.3 New Hampshire Class I Areas – Baseline Visibility.....................................................36 

4.4 New Hampshire Class I Areas – Natural Background ..................................................37 

5. AIR MONITORING STRATEGY........................................................................................38 

5.1 IMPROVE Program Objectives ....................................................................................38 

5.2 Monitoring Requirements..............................................................................................38 

5.3 Monitoring Sites for MANE-VU Class I Areas ............................................................40 

5.3.1 Acadia National Park, Maine ...............................................................................40 

5.3.2 Brigantine Wilderness, New Jersey......................................................................41 

5.3.3 Great Gulf Wilderness, New Hampshire..............................................................42 

5.3.4 Presidential Range - Dry River Wilderness, New Hampshire .............................43 
New Hampshire Regional Haze SIP Revision Page ii 

5.3.5 Lye Brook Wilderness, Vermont..........................................................................43 

5.3.6 Moosehorn Wilderness, Maine.............................................................................44 

5.3.7 Roosevelt Campobello International Park, New Brunswick, Canada..................46 

6. EMISSIONS INVENTORY..................................................................................................47 

6.1 Baseline and Future-Year Emissions Inventories for Modeling ...................................47 

6.1.1 Baseline Inventory (2002) ....................................................................................48 

6.1.2 Future-Year Emissions Inventories ......................................................................49 

6.2 Emission Processor Selection and Configuration..........................................................49 

6.3 Inventories for Specific Source Categories ...................................................................50 

6.3.1 Stationary Point Sources.......................................................................................50 

6.3.1.1 Electric Generating Units (EGUs)...............................................................50 

6.3.1.2 Non-EGU Point Sources..............................................................................51 

6.3.2 Stationary Area Sources .......................................................................................52 

6.3.3 Non-Road Mobile Sources ...................................................................................52 

6.3.4 On-Road Mobile Sources .....................................................................................53 

6.3.5 Biogenic Emission Sources ..................................................................................53 

6.4 Summary of Emissions Inventories...............................................................................53 

7. AIR QUALITY MODELING ...............................................................................................55 

7.1 Meteorology ..................................................................................................................55 

7.2 Data Preparations...........................................................................................................57 

7.3 Model Platforms ............................................................................................................57 

7.3.1 CMAQ ..................................................................................................................59 

7.3.2 REMSAD .............................................................................................................59 

7.3.3 CALGRID ............................................................................................................59 

7.3.4 CALPUFF.............................................................................................................60 

8. UNDERSTANDING THE SOURCES OF HAZE-CAUSING POLLUTANTS .................61 

8.1 Fine-Particle Pollutants .................................................................................................61 

8.2 Contributing States and Regions ...................................................................................62 

8.3 Emission Sources and Characteristics ...........................................................................69 

8.3.1 Sulfur Dioxide (SO2) ............................................................................................69 

8.3.2 Volatile Organic Compounds (VOC)...................................................................71 

8.3.3 Oxides of Nitrogen (NOX)....................................................................................73 

8.3.4 Primary Particulate Matter (PM10 and PM2.5).......................................................74 

8.3.5 Ammonia Emissions (NH3)..................................................................................79 

9. BEST AVAILABLE RETROFIT TECHNOLOGY (BART)...............................................82 

9.1 BART Applicability ......................................................................................................82 

9.2 BART-Eligible Sources in New Hampshire..................................................................83 

 9.2.1 Cap-Outs and Shutdowns .....................................................................................83 

9.2.2 Small Source Exemptions.....................................................................................83 

9.2.3 Large Electrical Generating Units ........................................................................83 
New Hampshire Regional Haze SIP Revision Page iii 

9.3 Determination of BART Requirements for BART-Eligible Sources 

and Analysis of Best Retrofit Technologies................................................................84 

9.3.1 BART Determinations and Required Control Levels ..........................................84 

9.3.2 Visibility Improvements Resulting from BART ..................................................87

9.3.3 Bart-Eligible EGUs and the Role of CAIR ..........................................................88 

9.4 Alternatives to BART for Any Source ..........................................................................89 

9.5 BART Enforceable Provisions and Implementation Schedule .....................................89 

10. REASONABLE PROGRESS GOALS ...............................................................................91 

10.1 Calculation of Uniform Rate of Progress ....................................................................91 

10.2 Identification of (Additional) Reasonable Control Measures .....................................92 

10.2.1 Rationale for Determining Reasonable Controls................................................93 

10.2.2 Best Available Retrofit Technology Controls....................................................95 

10.2.3 Low-Sulfur Fuel Strategy...................................................................................96 

10.2.4 Targeted EGU Strategy for SO2 Reductions.....................................................100 

10.2.5 Non-EGU SO2 Emissions Reduction Strategy for Non-MANE-VU States.....106 

10.3 Reasonable Progress Goals for Class I Areas in the State.........................................113 

10.4 Visibility Effects of (Additional) Reasonable Control Measures..............................114 

11. LONG-TERM STRATEGY..............................................................................................116 

11.1 Overview of Strategy Development Process.............................................................116 

11.2 Technical Basis for Strategy Development ...............................................................118 

11.3 Existing Commitments / Expected Measures to Reduce Emissions..........................119 

11.3.1 Controls on EGUs Expected by 2018...............................................................120 

11.3.2 Controls on Non-EGU Point Sources Expected by 2018.................................123 

11.3.3 Controls on Area Sources Expected by 2018...................................................124 

11.3.4 Controls on Mobile Sources Expected by 2018 ...............................................125 

11.3.5 Controls on Non-Road Sources Expected by 2018 ..........................................126 

11.4 Additional Reasonable Measures ..............................................................................127 

11.4.1 BART ...............................................................................................................128 

11.4.2 Low-Sulfur Oil Strategy...................................................................................128 

11.4.3 Targeted EGU Strategy ....................................................................................129 

11.5 Source Retirement and Replacement Schedules .......................................................132 

11.6 Measures to Mitigate the Impacts of Construction Activities...................................132 

11.7 Agricultural and Forestry Smoke Management ........................................................133 

11.8 Estimated Effects of Long-Term Strategy on Visibility............................................133 

11.9 New Hampshire’s Share of Emission Reductions.....................................................139 

11.10 Emission Limitations and Compliance Schedules ..................................................140 

11.11 Enforceability of Emission Limitations and Control Measures ..............................141 

 11.12 Prevention of Significant Deterioration...................................................................143 

12. ADMINISTRATIVE MATERIALS .................................................................................144 
New Hampshire Regional Haze SIP Revision Page iv 

LIST OF FIGURES 

Figure 1.1 Map of CAIR States ...............................................................................................2 

Figure 1.2 Locations of Federally Protected Mandatory Class I Areas................................... 8 

Figure 1.3 Mt. Washington from the Southeast at Sunrise.....................................................11 

Figure 1.4 Location of New Hampshire’s Class I Areas ........................................................12 

Figure 1.5 View of Great Gulf Wilderness from Mt. Washington .........................................12 

Figure 1.6 Views of Great Gulf Wilderness from Lower Elevation on Clear (6 deciview) 

and Hazy (28 deciview) Days................................................................................13 

Figure 1.7 Presidential Range - Dry River Wilderness in Autumn ........................................13 

Figure 1.8 Visibility Trends at Great Gulf and Presidential Range – Dry River Wilderness 

Areas......................................................................................................................14 

Figure 2.1 Measured and Projected Mass Contribution in 2002 and 2018 at Great Gulf 

and Presidential Range - Dry River Wilderness Areas on 20 Percent Worst 

Visibility Days.......................................................................................................17 

Figure 3.1 EPA-Designated Regional Planning Organizations (RPOs) .................................19 

Figure 5.1 Map of Acadia National Park Showing Location of IMPROVE Monitor ............40 

Figure 5.2 Acadia National Park on Clear and Hazy Days.....................................................40 

Figure 5.3 Map of Edwin B. Forsythe National Wildlife Refuge...........................................41 

Figure 5.4 Brigantine Wilderness on Clear and Hazy Days ...................................................41 

Figure 5.5 Map of Great Gulf and Presidential Range - Dry River Wilderness Area 

Showing Location of IMPROVE Monitor ............................................................42 

Figure 5.6 Great Gulf Wilderness on Clear and Hazy Days...................................................42 

Figure 5.7 Upper Elevations of Presidential Range - Dry River Wilderness .........................43 

Figure 5.8 Location of Lye Brook Wilderness IMPROVE Monitor ......................................43 

Figure 5.9 Aerial View of Lye Brook Wilderness and IMPROVE Monitoring Site..............44 

Figure 5.10 Lye Brook Wilderness on Clear and Hazy Days...................................................44 

Figure 5.11 Map of the Baring and Edmunds Divisions of the Moosehorn National Wildlife 

Refuge Showing Location of IMPROVE Monitor................................................45 

Figure 5.12 Moosehorn Wilderness on Clear and Hazy Days..................................................45 

Figure 5.13 Map of Roosevelt Campobello International Park ................................................46 

Figure 5.14 Roosevelt Campobello International Park on Clear and Hazy Days.....................46 

Figure 7.1 Modeling Domains Used in MANE-VU Air Quality Modeling Studies 

with CMAQ...........................................................................................................56 

Figure 7.2 Examples of Processed Model-Ready Emissions..................................................58 

Figure 8.1 Contributions to PM2.5 Extinction at Seven Class I Areas ....................................61 

Figure 8.2 Ranked Sulfate Contributions to Northeast Class I Receptors Based on 

Q/d Method (Mass Basis), by Location of Origin.................................................64 

Figure 8.3 Ranked Sulfate Contributions to Mid-Atlantic Class I Receptors Based on 

Q/d Method (Mass Basis), by Location of Origin.................................................64 

Figure 8.4 Modeled 2002 Contributions to Sulfate at Great Gulf, by State ...........................66 

Figure 8.5 Modeled 2002 Contributions to Sulfate at Brigantine, by State............................66
New Hampshire Regional Haze SIP Revision Page v 

Figure 8.6 Modeled 2002 Contributions to Sulfate at Lye Brook, by State ...........................67 

Figure 8.7 Modeled 2002 Contributions to Sulfate at Acadia, by State .................................67 

Figure 8.8 Modeled 2002 Contributions to Sulfate at Moosehorn, by State ..........................68 

Figure 8.9 Modeled 2002 Contributions to Sulfate at Shenandoah, by State .........................68 

Figure 8.10 Modeled 2002 Contributions to Sulfate at Dolly Sods, by State...........................69

Figure 8.11 Annual Sulfur Dioxide (SO2) Emissions, by State................................................70 

Figure 8.12 2002 Sulfur Dioxide (SO2) Emissions, by State....................................................71 

Figure 8.13 2002 Volatile Organic Carbon (VOC) Emissions, by State ..................................72

Figure 8.14 Annual Nitrogen Oxide (NOX) Emissions, by State..............................................73 

Figure 8.15 2002 Nitrogen Oxide (NOX) Emissions, by State .................................................74 

Figure 8.16 Primary Course Particle (PM10) Emissions, by State ............................................75 

Figure 8.17 Primary Fine Particle (PM2.5) Emissions, by State................................................75 

Figure 8.18 Wood Smoke Source Regional Aggregations.......................................................77 

Figure 8.19 2002 Primary Coarse Particle (PM10) Emissions, by State ...................................78 

Figure 8.20 2002 Primary Fine Particle (PM2.5) Emissions, by State.......................................78 

Figure 8.21 Ammonia (NH3) Emissions, by State....................................................................80 

Figure 8.22 2002 Ammonia (NH3) Emissions, by State...........................................................80 

Figure 10.1 Average Change in 24-hr PM2.5 Due to Low-Sulfur Fuel Strategy (Phases 

1 & 2 Combined) Relative to OTB/OTW (values in μg/m3) ...............................97 

Figure 10.2..Location of 176 EGU Stacks Contributing the Most to Visibility Impairment 

at MANE-VU Class I Areas ................................................................................ 101 

Figure 10.3 Preliminary Estimate of Average Change in 24hr PM2.5 Resulting from a 

90 Percent Reduction in SO2 Emissions from the Top 167 EGU Stacks 

Affecting MANE-VU Class I Areas.................................................................... 102

Figure 10.4 Demonstration of Required and Reasonable Visibility Progress for 

20 Percent Worst Visibility Days ........................................................................115 

Figure 10.5 Demonstration of Required Maintenance or Improvement of Visibility 

for 20 Percent Best Visibility Days .....................................................................115 

Figure 11.1 Expected Visibility Improvement at Great Gulf Wilderness Based on 

Most Recent Projections......................................................................................136 

Figure 11.2 Expected Improvements in Pollutant Concentrations at Great Gulf Wilderness 

on Best and Worst Days ......................................................................................136 

Figure 11.3 Expected Visibility Improvement at Acadia National Park Based on Most 

Recent Projections ...............................................................................................137 

Figure 11.4 Expected Visibility Improvement at Brigantine National Wildlife Refuge 

Based on Most Recent Projections......................................................................137 

Figure 11.5 Expected Visibility Improvement at Lye Brook Wilderness Based on Most 

Recent Projections ...............................................................................................138 

Figure 11.6 Expected Visibility Improvement at Moosehorn National Wildlife Refuge 

Based on Most Recent Projections......................................................................138 
New Hampshire Regional Haze SIP Revision Page vi 

LIST OF TABLES 

Table 1.1 Visibility Monitoring at Great Gulf and Presidential Range - Dry River 

Wilderness Area ....................................................................................................14 

Table 2.1 New Hampshire’s Contributions to Total Annual Average Sulfate Impact 

(Percent, Mass Basis) at Eastern Class I Areas in 2002........................................17 

Table 2.2 Contributions of Individual MANE-VU States and Other Regions to Total 

Annual Average Sulfate Impact (Percent, Mass Basis) at New Hampshire’s 

Class I Areas in 2002.............................................................................................18 

Table 3.1 MANE-VU Members ............................................................................................20 

Table 3.2 MANE-VU Consultation Principles for Regional Haze Planning ........................21 

Table 3.3 Summary of MANE-VU’s Consultations on Regional Haze Planning.................23 

Table 3.4 Class I Area States Requesting Consultation with New Hampshire .....................24 

Table 3.5 States (Listed by Regional Planning Organization) and Provinces Contributing 

to Visibility Impairment at New Hampshire’s Class I Areas ................................25 

Table 4.1 IMPROVE Monitors for MANE-VU Class I Areas..............................................34 

Table 4.2 Summary of Baseline Visibility and Natural Visibility Conditions for the 

20 Percent Best and 20 Percent Worst Visibility Days at MANE-VU 

Class I Areas..........................................................................................................36 

Table 4.3 Baseline Visibility for the 20 Percent Best Days and 20 Percent Worst Days 

during 2000-2004 in New Hampshire Class I Areas.............................................37 

Table 6.1 2002 Emissions Inventory Summary for New Hampshire....................................54 

Table 6.2 2018 OTB/OTW Emissions Inventory Summary for New Hampshire.................54 

Table 6.3 2018 BOTW Emissions Inventory Summary for New Hampshire .......................54 

Table 6.4 2018 Most Recent Emissions Inventory Summary for New Hampshire ..............54 

Table 8.1 Percent Contributions (Mass Basis) of Individual MANE-VU States and Other 

Regions to Total Annual Sulfate Impacts at Northeast Class I Areas (REMSAD) .63 

Table 9.1 BART-Eligible Sources in New Hampshire..........................................................83 

Table 9.2 Emission Reductions Resulting from BART Controls at PSNH Merrimack 

Station Unit MK2 ..................................................................................................86 

Table 9.3 Emission Reductions Resulting from BART Controls at PSNH Newington 

Station Unit NT1 ...................................................................................................86 

Table 9.4 CALPUFF Modeling Results for Merrimack Station Unit MK2: Visibility 

Improvements from BART Controls on the 20% Worst Visibility Days.........................88 

Table 9.5 CALPUFF Modeling Results for Newington Station Unit NT1: Visibility 

Improvements from BART Controls on the 20% Worst Visibility Days.........................88 

Table 9.6 BART Enforceable Provisions and Compliance Schedule for PSNH 

Merrimack Station Unit MK2 ................................................................................90 

Table 9.7 BART Enforceable Provisions and Compliance Schedule for PSNH 

Newington Station Unit NT1.................................................................................90 

Table 10.1 Uniform Rate of Progress Calculation (all values in deciviews) ..........................92 

Table 10.2 Summary of Results from Four-Factor Analysis of Different Source Categories...94 
New Hampshire Regional Haze SIP Revision Page vii 

Table 10.3 Estimated Emissions from BART-Eligible Facilities in MANE-VU States 

(Facilities Likely to be Controlled as a Result of BART Alone) ..........................95 

Table 10.4 Estimated Cost Ranges for SO2 Control Options for Coal-Fired EGU Boilers 

(2006 dollars per ton of SO2 removed)................................................................104 

Table 10.5 Available SO2 Control Options for ICI Boilers...................................................108 

Table 10.6 Estimated Costs of Dry Sorbent Injection (DSI) for ICI Boilers (2006 dollars) ...110 

Table 10.7 Estimated Costs of Flue Gas Desulfurization for ICI Boilers (2006 dollars) ..... 111 

Table 10.8 Reasonable Progress Goals for Great Gulf Wilderness and Presidential 

Range - Dry River Wilderness (all values in deciviews) ....................................113 

Table 11.1 Projected SO2 Emission Reductions from Targeted EGUs in New Hampshire....129 

Table 11.2 SO2 Emissions from Point, Area, and Mobile Sources in New Hampshire ........140 

Table 11.3 SO2 Emissions from Point, Area, and Mobile Sources in all of MANE-VU......140 

LIST OF ATTACHMENTS

ATTACHMENT A EPA Regional Haze Checklist 

ATTACHMENT B MANE-VU Contribution Assessment 

ATTACHMENT C Inter-RPO State/Tribal and FLM Consultation Framework 

ATTACHMENT D Consultation Summaries and Other Documentation 

ATTACHMENT E The MANE-VU “Ask” 

ATTACHMENT F Comments from VISTAS and West Virginia Department of 

Environmental Protection 

ATTACHMENT G MANE-VU Modeling for Reasonable Progress Goals 

ATTACHMENT H Documentation of 2018 Emissions from EGUs in the Eastern United States 

ATTACHMENT I Comments from Federal Land Managers and EPA (with Responses) 

ATTACHMENT J Comments from Other Stakeholders 

ATTACHMENT K MANE-VU Natural Background Visibility Conditions 

ATTACHMENT L MANE-VU Baseline and Natural Background Visibility Conditions 

ATTACHMENT M Technical Support Document for 2002 MANE-VU SIP Modeling 

Inventories, Version 3 

ATTACHMENT N Development of Emission Projections for 2009, 2012, and 2018 for 

NonEGU Point, Area, and Nonroad Sources in the MANE-VU Region 

ATTACHMENT O Development of MANE-VU Mobile Source Projection Inventories for 

SMOKE/MOBILE6 Application 

ATTACHMENT P NYSDEC Technical Support Document TSD-1c 

ATTACHMENT Q MANE-VU 2018 Visibility Projections 

ATTACHMENT R NYSDEC Technical Support Document TSD-1a 

ATTACHMENT S NYSDEC Technical Support Document TSD-1e 
New Hampshire Regional Haze SIP Revision Page viii 

ATTACHMENT T NYSDEC Technical Support Document TSD-1d 

ATTACHMENT U CALGRID Modeling Protocol 

ATTACHMENT V Technical Support Document on Agricultural and Forestry Smoke 

Management in the MANE-VU Region 

ATTACHMENT W MANE-VU Five-Factor Analysis of BART-Eligible Sources 

ATTACHMENT X BART Analyses for Sources in New Hampshire 

ATTACHMENT Y Assessment of Reasonable Progress for Regional Haze in MANE-VU 

Class I Areas 

ATTACHMENT Z Assessment of Control Technology Options for BART-Eligible 

Sources 

ATTACHMENT AA Low-Sulfur Heating Oil in the Northeast States 

ATTACHMENT BB Comparison of CAIR and CAIR Plus Proposal Using the Integrated 

Planning Model (IPM®) 

ATTACHMENT CC The Nature of Fine Particle and Regional Haze Air Quality Problems 

in the MANE-VU Region 

ATTACHMENT DD Technical Support Document on Measures to Mitigate Visibility 

Impacts of Construction Activities in the MANE-VU Region 

ATTACHMENT EE Temporary Permit for PSNH Merrimack Station 

ATTACHMENT FF Revisions to Env-A 1604, Sulfur Content Limitations for Liquid Fuels (Draft) 

ATTACHMENT GG Chapter Env-A 2300, Mitigation of Regional Haze (Draft) 

ATTACHMENT HH Title V Operating Permit for PSNH Merrimack Station (Draft) 

ATTACHMENT II Title V Operating Permit for PSNH Newington Station 

ATTACHMENT JJ Public Notice for SIP Revision 

ATTACHMENT KK Certification of Public Process 

ATTACHMENT LL Evidence of Legal Authority 

ACKNOWLEDGEMENTS 

The New Hampshire Department of Environmental Services would 

like to express appreciation to the dedicated staffs of the NESCAUM, 

MARAMA, and MANE-VU regional organizations and to the 

dedicated staffs of the MANE-VU member states for their invaluable 

assistance and timely contributions in the development of New 

Hampshire’s Regional Haze SIP Revision. 
New Hampshire Regional Haze SIP Revision Page ix 

FOREWORD 

This document revises New Hampshire’s State Implementation Plan (SIP) 

to meet requirements of the Clean Air Act related to protection of 

visibility. SIPs are dynamic documents describing the state’s statutory and 

regulatory (i.e., enforceable) emission control measures that will be 

implemented to ensure compliance with National Ambient Air Quality 

Standards and goals. SIPs must be reviewed and updated periodically to 

stay current with administrative requirements, changing air quality 

conditions, and new or amended federal programs. The terms “SIP” and 

“SIP revision” are sometimes used interchangeably in reference to new or 

revised portions of a state implementation plan. Regional Haze SIP, or 

Regional Haze Plan, refers specifically to that portion of the State 

Implementation Plan which addresses visibility improvement. 
New Hampshire Regional Haze SIP Revision Page 1 

1. THE REGIONAL HAZE ISSUE 

In 1999, the Environmental Protection Agency (EPA) issued regulations to improve visibility 

in 156 national parks and wilderness areas across the United States. The affected areas 

include many of our best known natural places, including the Grand Canyon, Yosemite, 

Yellowstone, Mount Rainier, Shenandoah, the Great Smokies, Acadia, and the Everglades. In 

New Hampshire, the two affected areas are Great Gulf Wilderness and Presidential Range - 

Dry River Wilderness. 

These regulations address visibility impairment in the form of regional haze. Haze is an 

atmospheric phenomenon that obscures the clarity, color, texture, and form of what we see. It 

is caused primarily by anthropogenic (manmade) pollutants but can also be caused by a 

number of natural phenomena, including forest fires, dust storms, and sea spray. Some hazecausing pollutants are emitted directly to the atmosphere by anthropogenic emission sources 

such as electric power plants, factories, automobiles, construction activities, and agricultural 

burning. Others occur when gases emitted to the air (haze precursors) interact to form new 

particles that are carried downwind. 

Emissions from these activities generally span broad geographic areas and can be transported 

hundreds or thousands of miles. Consequently, regional haze occurs in every part of the 

nation. Because of the regional nature of haze, EPA’s regulations require the states to consult 

with one another toward the national goal of improving visibility – specifically, at the 156 

parks and wilderness areas designated under the Clean Air Act as mandatory Class I Federal 

Areas. 

The Regional Haze Rule calls for each state to establish reasonable progress goals for 

visibility improvement and to formulate a long-term strategy for meeting these goals. These 

requirements apply to any state having a Class I area as well as any state that contributes to 

visibility impairment at any (downwind) Class I area. The visibility goals must be designed 

both to improve visibility on the haziest days and to ensure that no degradation occurs on the 

clearest days. 

A state’s long-term strategy must include enforceable emission reduction measures designed 

to meet reasonable progress goals. The first long-term strategy covers the 10-15-year period 

ending in 2018, and subsequent revisions are to be issued every 10 years thereafter. In 

identifying the emission reduction measures to be included in the long-term strategy, states 

should address all types of manmade emissions contributing to visibility degradation in Class 

I areas, including those from mobile sources; stationary sources (such as factories); smaller, 

so-called “area” sources (such as residential wood stoves and small boilers); and prescribed 

fires. 

 

In developing their plans, states can take into account emission reductions attributable to 

ongoing air pollution control programs at the state, regional, or national levels. For most 

states and regions of the country, however, additional emission control measures beyond 

those already on the books will be necessary if national visibility goals are to be achieved. In 

addition, the Regional Haze Rule mandates that control measures be implemented for certain 

existing sources placed into operation between 1962 and 1977. This portion of the rule is 

known as BART, for Best Available Retrofit Technology. 
New Hampshire Regional Haze SIP Revision Page 2 

Each state’s plan for addressing regional haze will take the form of a State Implementation 

Plan (SIP) or SIP revision. New Hampshire’s SIP revision, presented here, was developed 

after extensive consultations with other states and regional planning organizations. In 

particular, New Hampshire contributed to many analyses and reports produced by the member 

states of the Northeast States for Coordinated Air Use Management (NESCAUM) and the 

Mid-Atlantic/Northeast Visibility Union (MANE-VU) for the purpose of coordinated regional 

haze planning. New Hampshire also consulted with states outside the Northeast and with the 

provinces of eastern Canada. 

The regulatory, organizational, and technical basis for New Hampshire’s regional haze plan 

will be found in Sections 1 through 8 of this SIP document. The prescriptive elements of 

New Hampshire’s plan – BART provisions, reasonable progress goals, and long-term strategy 

– are described in detail in Sections 9 through 11.

1.1 Regional Haze Planning after Remand of CAIR 

On March 10, 2005, EPA issued the Clean Air Interstate Rule (CAIR). This important federal 

rule was designed to achieve major permanent reductions in sulfur dioxide (SO2) and nitrogen 

oxides (NOX) emissions in the eastern United States through a cap-and-trade system using 

emission allowances. CAIR would permanently cap emissions originating in 28 eastern states 

and the District of Columbia (Figure 1.1). Although New Hampshire was not designated as a 

participating CAIR state, this program would greatly affect future air quality in the state. 

Figure 1.1: Map of CAIR States 

http://www.epa.gov/cair/
New Hampshire Regional Haze SIP Revision Page 3 

According to EPA’s CAIR website, SO2 emissions in the affected states would be reduced by 

more than 70 percent from 2003 levels, and NOX emissions by more than 60 percent from 

2003 levels, upon full implementation of CAIR (see http://www.epa.gov/cair/). Resulting 

improvements in air quality would yield $85 to $100 billion in health benefits and nearly $2 

billion in visibility benefits per year by 2015, and premature mortality would be substantially 

reduced across the eastern U.S. 

On July 11, 2008, the U.S. Court of Appeals for the District of Columbia Circuit found that 

CAIR violated basic provisions of the Clean Air Act. The Court vacated CAIR in its entirety 

and remanded to EPA to promulgate a new rule consistent with the Court’s opinion. EPA 

appealed the decision amid widespread concern that, despite its flaws, some form of CAIR 

was preferable to the sudden regulatory void created by the Court’s decision. Upon 

reconsideration, on December 23, 2008, the Court stayed the vacatur of CAIR but maintained 

the remand to EPA to promulgate a new rule consistent with the Court’s July 11, 2008, 

opinion. The Court did not impose a definitive deadline by which EPA must correct CAIR’s 

flaws, but the Court stated that it does “not intend to grant an indefinite stay of the 

effectiveness” of its decision. 

Because CAIR formed the regulatory underpinnings for most of the emission reductions that 

were to produce visibility improvements in mandatory Class I areas, the vacatur of CAIR 

would have represented a major difficulty for the individual states in attempting to comply 

with the Regional Haze Rule. While all eastern states have depended in varying degree on 

CAIR in the preparation of their regional haze SIPs, some Southeast states have relied almost 

entirely on CAIR to demonstrate compliance with the rule. As a major ramification, the 

vacatur would have immediately invalidated EPA’s determination that CAIR satisfied the 

requirements of BART. 

The U.S. Congress and EPA are considering a number of possible short- and long-term 

regulatory or legislative fixes to improve CAIR. It is too early to know when this process will 

reach a conclusion and what the outcome will dictate for regional haze planning. There may 

be some short-term slippage or loss in projected emission reductions as a consequence of the 

Court’s July 11, 2008, decision. Over the longer term, New Hampshire anticipates that future 

emission control requirements meeting the provisions of a reauthorized Clean Air Act, or its 

successor, will be at least as stringent as CAIR originally would have obtained. As to the 

validity of the already-completed planning components, a number of mitigating circumstances 

apply: 

• Application of BART provisions where the old CAIR previously might have sufficed 

is likely to yield even greater emission reductions from BART-eligible facilities. 

• New Hampshire and many other states have instituted their own emission reduction 

programs through multi-pollutant legislation and other means. New Hampshire 

applauds the efforts of other states and encourages them to follow through with the 

implementation of laws, consent decrees, and other measures that would complement 

emission reductions from CAIR. 

• Strict adherence to the spirit of the Clean Air Act in future national initiatives will 

probably result in emission reductions exceeding those previously projected for CAIR. 

A major limitation of the original CAIR was that it relied on interstate emissions trading 

and did not respond to the specific language of the Clean Air Act, Section 110(a)(2)(D), 

which prohibits any source or activity within a state from impairing the ability of 

another state to meet national air quality standards or visibility requirements. CAIR 
New Hampshire Regional Haze SIP Revision Page 4 

was only one tool, not an all-purpose remedy, for addressing the problem of interstate 

transport of pollutants. 

For these reasons, NHDES believes that future emissions and air quality levels under newCAIR scenarios are not likely to be vastly different from values predicted by MANE-VU’s 

completed modeling, even though that modeling was based on implementation of CAIR as it 

was before the remand. Consequently, the reasonable progress goals and long-term strategy 

developed for New Hampshire’s regional haze SIP still represent a defensible position from 

which to go forward with measures to improve visibility at MANE-VU’s Class I Areas. 

New Hampshire and the other MANE-VU states have maintained all along that the regional 

haze SIPs should look beyond the provisions of CAIR to identify additional emission control 

measures that could be effectively employed to mitigate regional haze. In this respect, New 

Hampshire and the rest of MANE-VU stand apart from some other states in asserting that 

additional measures beyond CAIR are essential to meeting established visibility goals at 

MANE-VU’s Class I Areas. 

In describing New Hampshire’s present situation, it may be helpful to note that the remand of 

CAIR is a complicating factor but not an absolute impediment to making visibility progress in 

the near term. The salient points to consider are as follows: 

• Because New Hampshire is a non-CAIR state, this federal program does not directly 

affect any of New Hampshire’s proposed in-state control strategies for visibility 

improvement. The control measures identified in this regional haze SIP for in-state 

sources should be able to proceed without delay or obstruction. 

• New Hampshire will meet its “fair share” of emissions in comparison with other 

MANE-VU states and the original CAIR states, as New Hampshire’s long-term 

strategy demonstrates (see Section 11). 

• Sources in upwind states release most of the pollutants contributing to visibility 

impairment at New Hampshire’s Class I areas. Therefore, New Hampshire will 

continue to depend on mitigative actions by other states if visibility goals are to be 

achieved for in-state Class I areas. 

• By the time of the first regional haze SIP progress report (expected to be completed in 

20131) the regulatory framework should be clearer; and it is hoped that new modeling 

results will be available. If so, it will then be possible to fine-tune regional haze plans 

to meet the new-CAIR reality. New Hampshire is committed to reviewing and 

updating its regional haze SIP as new information becomes available.

It should be noted that New Hampshire’s Regional Haze SIP includes many references to the 

original CAIR program. These references serve two purposes: 1) They provide historical 

context, and 2) they help to maintain continuity with the large body of completed work – 

much of it based on the old CAIR – that serves as the foundation for regional haze planning in 

the MANE-VU states to date. 

 

1 40 CFR51.308(g) states that the first progress report is due 5 years from the submittal of the initial implementation plan. 

The regional haze SIP was originally due on December 17, 2007. In New Hampshire’s case, it is expected that the first 

progress report will be completed and submitted in 2013, near the midpoint of the 10-year initial planning period from 2008 

to 2018. 
New Hampshire Regional Haze SIP Revision Page 5 

1.2 The Basics of Haze 

Small particles and certain gaseous molecules in the atmosphere cause poor visibility by 

scattering and absorbing light, thereby reducing the amount of visual information about 

distant objects that reaches an observer. Some light scattering by air molecules and naturally 

occurring aerosols occurs even under natural conditions.2

The distribution of particles in the atmosphere depends on meteorological conditions and leads 

to various forms of visibility impairment. When high concentrations of pollutants are well 

mixed in the atmosphere, they form a uniform haze. When temperature inversions trap 

pollutants near the surface, the result can be a sharply demarcated layer of haze. Plume blight – 

a distinct, frequently brownish plume of pollution from a particular emissions source – occurs 

under stable atmospheric conditions, where pollutants take a long time to disperse. 

Visibility impairment can be quantified using three different, but mathematically related 

measures: light extinction per unit distance (e.g., inverse megameters, or Mm-1)

3

; visual range 

(i.e., how far one can see); and deciviews (dv), a useful metric for measuring increments of 

visibility change that are just perceptible to the human eye. Each can be estimated from the 

ambient concentrations of individual particle constituents, taking into account their unique 

light-scattering (or absorbing) properties and making appropriate adjustments for relative 

humidity. Assuming natural conditions, visibility in the Northeast and Mid-Atlantic is 

estimated to be about 23 Mm-1, which corresponds to a visual range of about 106 miles or 8 dv 

(the lower the dv, the better the visibility). Under current polluted conditions in the region, 

average visibility ranges from 103 Mm-1 in the south to 55 Mm-1 in the north; these values 

correspond to a visual range of 24 to 44 miles or 23 to 17 dv, respectively. On the worst 20 

percent of days, visibility impairment in Northeast and Mid-Atlantic Class I areas ranges from 

about 25 to 30 dv. 

The small particles that commonly cause hazy conditions in the East are primarily composed 

of sulfate, nitrate, organic carbon, elemental carbon (soot), and crustal material (e.g., soil dust, 

sea salt, etc.). Of these constituents, only elemental carbon impairs visibility by absorbing 

visible light; the others scatter light. Sulfate, nitrate, and organic carbon4are secondary 

pollutants that form in the atmosphere from precursor pollutants, primarily sulfur dioxide 

(SO2), oxides of nitrogen (NOX), and volatile organic compounds (VOCs), respectively. By 

contrast, soot and crustal material and some organic carbon particles are released directly to 

the atmosphere. Particle constituents also differ in their relative effectiveness at reducing 

visibility. Sulfates and nitrates, for example, contribute disproportionately to haze because of 

their chemical affinity for water. This property allows them to grow rapidly, in the presence 

of moisture, to the optimal particle size for scattering light (i.e., 0.1 to 1 micrometer). 

 

2

 The fact that air molecules scatter more short-wavelength (blue) light accounts for the blue color of the sky. The term 

“aerosol” is defined as a suspension of particles in a gas. In this report, the term refers to particles suspended in the 

atmosphere. 

3

 In units of inverse length. An inverse megameter (Mm-1) is equal to one over one thousand kilometers. 

4

 The term “organic carbon” encompasses a large number of hydrogen and carbon containing molecules. Light scattering 

secondary organic aerosols result from the oxidation of hydrocarbons that are emitted from many different sources, 

ranging from automobiles to solvents, to natural vegetation. Organic carbon can be emitted as a primary particle from 

sources such as wood burning, meat cooking, automobiles, and paved road dust. 
New Hampshire Regional Haze SIP Revision Page 6 

1.3 Anatomy of Regional Haze 

Monitoring data collected over the last decade show that fine particle5concentrations, and 

hence visibility impairment, are generally highest near industrial and highly populated areas 

of the Northeast and Mid-Atlantic. Particle concentrations are lower, and visibility conditions 

are better, at the more northerly Class I sites (such as the Great Gulf and Presidential Range - 

Dry River Wildernesses in New Hampshire), where visibility on the 20 percent best days6is 

close to natural, unpolluted conditions. By contrast, visibility at the more southerly 

Brigantine site in New Jersey is substantially impaired even on the 20 percent clearest days. 

On the 20 percent haziest days, visibility impairment is substantial throughout the region. 

Sulfate is the dominant contributor to fine particle pollution throughout the eastern U.S. On 

the haziest 20 percent of days, it accounts for one-half to two-thirds of total fine particle mass 

and is responsible for about three-quarters of total light extinction at Class I sites in the 

Northeast and Mid-Atlantic. Even on the clearest 20 percent of days, sulfate typically 

constitutes 40 percent or more of total fine particle mass in the region. Moreover, sulfate 

accounts for 60 to 80 percent of the difference in fine particle mass concentrations on hazy 

versus clear days. 

Organic carbon consistently accounts for the next largest fraction of total fine particle mass; 

its contribution typically ranges from 20 to 30 percent on the haziest days. Notably, organic 

carbon accounts for as much as 40 to 50 percent of total mass on the clearest days, indicating 

that biogenic hydrocarbon sources (i.e., vegetation) are important at Class I areas in the region. 

The relative contributions of nitrate, elemental carbon, and fine soil are smaller than those of 

sulfate and organic carbon – typically less than 10 percent of total mass and varying with 

location. However, in some settings such as a monitoring site in Washington, DC,7 nitrate 

plays a considerably larger role, pointing to the importance of local NOX sources to fineparticle pollution in urban environments. 

About half of the worst visibility days in the New Hampshire Class I Areas occur in the 

summer when meteorological conditions are more conducive to the formation of sulfate from 

SO2 and to the oxidation of organic aerosols. The remaining worst visibility days are divided 

nearly equally among spring, winter, and fall. In contrast to sulfate and organic carbon, the 

nitrate contribution is typically higher in the winter months.8 The crustal and elemental 

carbon fractions do not show a clear pattern of seasonal variation. In addition, winter and 

summer transport patterns are different, possibly leading to different contributions from 

upwind pollutant source regions. 

The basis for EPA’s regional haze regulations is recognition that visibility impairment is 

fundamentally a regional phenomenon. Emissions from numerous sources over a broad 

 

5

 “Fine particles” refers throughout this study to particles less than or equal to 2.5 micrometers in diameter, consistent with 

US EPA’s recently proposed fine particle National Ambient Air Quality Standard (NAAQS). 

6

 “20 percent best visibility conditions” are defined throughout this report as the simple average of the lower 20th percentile 

of a cumulative frequency distribution of available data (expressed in deciviews). Similarly, “20 percent worst visibility 

conditions” represent the upper 20th percentile of the same distribution of available data. 

7

 The Washington, DC, site is part of the IMPROVE nationwide monitoring network and is mentioned here for the purposes 

of comparison. 

8

 This is largely due to the fact that the ammonium nitrate bond is more stable at lower temperatures. The role of ammonia 

in combination with both sulfate and nitrate is discussed further in later sections. 
New Hampshire Regional Haze SIP Revision Page 7 

geographic area commonly create hazy conditions across large portions of the eastern U.S. as 

a result of the long-range transport of airborne particles and precursor pollutants in the 

atmosphere. The key sulfate precursor, SO2, for example, has an atmospheric lifetime of 

several days and is known to be subject to transport distances of hundreds of miles. NOX and 

some organic carbon species are also subject to long-range transport, as are small particles of 

soot and crustal material. 

The importance of transport dynamics is well illustrated by a particularly severe haze episode 

that occurred in mid-July of 1999. During this episode, unusually hot and humid conditions 

coincided with the development of a high-pressure system over the Mid-Atlantic States that 

produced atmospheric stagnation over the heavily urbanized, southern portion of the 

northeastern Regional Planning Organization region (i.e., Philadelphia - DC - southern New 

Jersey). At the same time, wind patterns above the area of stagnation brought a steady flow of 

air from the Midwest into the New England states. This set of conditions resulted in several 

days of unusually high concentrations of fine-particle pollution throughout the region. On 

July 17, 1999, ambient sulfate concentrations at Acadia National Park were 40 percent higher 

than any previous measurement at that site since the late 1980s. On the same day, visibility at 

the Burlington, Vermont, airport was limited to just 3 miles. As is often the case, high 

concentrations of ground-level ozone accompanied these severe haze conditions. These 

coinciding conditions occurred because haze and ground-level ozone – although they are 

fundamentally different phenomena – tend to form and accumulate under similar 

meteorological conditions. 

1.4 Regulatory Framework 

In amendments to the Clean Air Act (CAA) in 1977, Congress added Section 169A (42 U.S.C. 

7491), setting forth the following national visibility goal: 

“Congress hereby declares as a national goal the prevention of any future, and the remedying of 

any existing, impairment of visibility in mandatory Class I Federal areas which impairment 

results from manmade air pollution.” 

The "Class I" designation was given to each of 158 areas in existence as of August 1977 that 

met the following criteria: 

• all national parks greater than 6000 acres 

• all national wilderness areas and national memorial parks greater than 5000 acres 

• one international park 

In 1980, Bradwell Bay, Florida, and Rainbow Lake, Wisconsin, were excluded for purposes 

of visibility protection as federal Class I areas. Today, 156 national park and wilderness areas 

remain as Class I visibility protection areas (Figure 1.2). 

Over the following years, modest steps were taken to address the visibility problems in Class I 

areas. The control measures taken mainly addressed plume blight from specific pollution 

sources, a localized phenomenon, and did little to address regional haze issues in the Eastern 

United States. 

When the Clean Air Act was amended, again, in 1990, Congress added Section 169B (42 

U.S.C. 7492), authorizing further research and regular assessments of progress made. In 

1993, the National Academy of Sciences concluded that “current scientific knowledge is 
New Hampshire Regional Haze SIP Revision Page 8 

adequate and control technologies are available for taking regulatory action to improve and 

protect visibility.” 

In addition to authorizing creation of visibility transport commissions and setting forth their 

duties, Section 169B(f) of the CAA mandated creation of the Grand Canyon Visibility 

Transport Commission (GCVTC) to make recommendations to EPA for the region affecting 

the visibility of the Grand Canyon National Park. GCVTC submitted its report to EPA in 

June 1996, following four years of research and policy development. This report, as well as 

the many research reports prepared by the GCVTC, contributed invaluable information to 

EPA in its development of regulations for visibility improvement. 

Figure 1.2: Locations of Federally Protected Mandatory Class I Areas 

1.4.1 The Regional Haze Rule 

The federal requirements that states must meet to achieve national visibility goals are 

contained in Title 40: Protection of Environment, Part 51 – Requirements for Preparation, 

Adoption, and Submittal of Implementation Plans, Subpart P – Protection of Visibility (40 

CFR 51.300-309). Known more simply as the Regional Haze Rule, these regulations were 

adopted on July 1, 1999, and went into effect on August 30, 1999. The rule seeks to address 

the combined visibility effects of various pollution sources over a large geographic region. 

This wide-reaching pollution net means that many states – even those without Class I Areas – 

are required to participate in haze reduction efforts. The specific requirements for States’ 
New Hampshire Regional Haze SIP Revision Page 9 

regional haze SIPs are set forth in 40 CFR 51.308, Regional Haze Program Requirements. 

In consultation with the states and tribes, EPA designated five Regional Planning Organizations 

(RPO) to assist with the coordination and cooperation needed to address the regional haze 

issue. The Mid-Atlantic and Northeast states, joined by the District of Columbia and tribes in 

the Northeast, formed the Mid-Atlantic / Northeast Visibility Union (MANE-VU).9

EPA’s adoption of the Regional Haze Rule was not without controversy and legal challenges. 

On May 24, 2002, the U.S. Court of Appeals for the District of Columbia Circuit ruled on the 

challenge brought by the American Corn Growers Association against the Regional Haze 

Rule. The Court remanded the BART provisions of the rule to EPA and denied industry’s 

challenge to the haze rule goals of achieving natural visibility levels and zero degradation. 

On June 15, 2005, EPA finalized a rule addressing the court’s remand. 

On February 18, 2005, the U.S. Court of Appeals for the D.C. Circuit issued another ruling 

vacating the Regional Haze Rule in part and sustaining it in part. For more information see 

Center for Energy and Economic Development v. EPA, no. 03-1222, (D.C. Cir. Feb. 18, 2005) 

(“CEED v. EPA”). In this case, the court granted a petition challenging provisions of the 

Regional Haze Rule governing the optional emissions trading program for certain Western 

States and Tribes (the WRAP Annex Rule).

In the aftermath of these decisions, EPA’s final rulemaking incorporated the following 

changes to the Regional Haze Rule: 

• Revised the regulatory text in 40 CFR 51.308(e)(2)(i) in response to the CEED court’s 

remand, to 

− Remove the requirement that the determination of BART be based on 

cumulative visibility analyses, and 

− Clarify the process for making such determinations, including the application 

of BART presumptions for electric generating units (EGUs) as contained in 40 

CFR 51, Appendix Y; 

• Added new regulatory text in 40 CFR 51.308(e)(2)(vi) to provide minimum elements 

for cap-and-trade programs in lieu of BART; and 

• Revised regulatory text in 40 CFR 51.309 to reconcile the optional framework for 

certain Western states and tribes to implement the recommendations of the GCVTC 

with the CEED decision. 

1.4.2 State Implementation Plan 

New Hampshire submits this State Implementation Plan revision to meet the requirements of 

EPA’s Regional Haze Rule. To facilitate states’ efforts, EPA prepared a checklist summarizing 

the requirements of the final Regional Haze Rule. Attachment A is a copy of the checklist 

with cross-references to sections of New Hampshire’s Regional Haze SIP showing how the 

requirements have been met.

 

9

 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. A more 

complete description of MANE-VU appears in Section 3 of this SIP. 
New Hampshire Regional Haze SIP Revision Page 10 

New Hampshire’s Regional Haze Plan addresses the core requirements of 40 CFR 51.308(d) and 

the BART components of 40 CFR 50.308(e). In addition, this SIP addresses requirements 

pertaining to regional planning, and state/tribe and Federal Land Manager (FLM) 

coordination and consultation. 

40 CFR 51.308(f) requires the New Hampshire Department of Environmental Services 

(NHDES) to submit periodic revisions to its Regional Haze SIP by July 31, 2018, and every 

ten years thereafter. NHDES acknowledges and will comply with this schedule.

40 CFR 51.308(g) requires NHDES to submit a report to EPA every 5 years that evaluates 

progress toward the reasonable progress goal for each mandatory Class I area located within 

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

emissions from within the state. NHDES will submit the first progress report, in the form of 

a SIP revision, within 5 years from submittal of the initial State Implementation Plan, but in 

no case later than December 31, 2013.

Pursuant to 40 CFR 51.308(d)(4)(v), NHDES will also make periodic updates to the New 

Hampshire’s emissions inventory (see Section 7, Emissions Inventory). NHDES proposes 

to complete these updates to coincide with the progress reports. 

Lastly, pursuant to 40 CFR 51.308(h), NHDES will submit a determination of adequacy of 

its regional haze SIP revision whenever a progress report is submitted. Depending on the 

findings of its five-year review, New Hampshire will take one or more of the following 

actions at that time, whichever actions are appropriate or necessary: 

• If New Hampshire determines that the existing State Implementation Plan requires no 

further substantive revision in order to achieve established goals for visibility 

improvement and emissions reductions, NHDES will provide to the EPA Administrator a 

negative declaration that further revision of the existing plan is not needed. 

• If New Hampshire determines that its implementation plan is or may be inadequate to 

ensure reasonable progress as a result of emissions from sources in one or more other 

state(s) which participated in the regional planning process, New Hampshire will 

provide notification to the EPA Administrator and to those other state(s). New 

Hampshire will also collaborate with the other state(s) through the regional planning 

process, if viable regional organizations exist, for the purpose of developing additional 

strategies to address any such deficiencies in New Hampshire’s plan. 

• If New Hampshire determines that its implementation plan is or may be inadequate to 

ensure reasonable progress as a result of emissions from sources in another country, 

New Hampshire will provide notification, along with available information, to the 

EPA Administrator. 

• If New Hampshire determines that its implementation plan is or may be inadequate to 

ensure reasonable progress as a result of emissions from sources within the state, New 

Hampshire will revise its implementation plan to address the plan’s deficiencies within 

one year from this determination. 
New Hampshire Regional Haze SIP Revision Page 11 

1.5 New Hampshire’s Class I Areas 

In New Hampshire, the U.S. Forest Service manages two Class I wilderness areas: the Great 

Gulf Wilderness and the Presidential Range - Dry River Wilderness, both located in New 

Hampshire’s White Mountain National Forest. 

These Class I areas flank the northern and southern slopes of the nationally renowned Mt. 

Washington, in the Presidential Range of the White Mountains (Figure 1.3). Mt. Washington 

is the highest mountain in the Northeast and attracts visitors (who can climb, drive, or ride to 

its summit) to enjoy expansive views from above tree line. Any action taken to improve 

visibility in the adjacent Great Gulf and Presidential Range-Dry River Wilderness Areas will also 

improve the vistas from the summit of Mt. Washington. The White Mountain National Forest 

is the main tourist attraction in New Hampshire and ranks among the most popular National 

Forests in the country with over 7 million visitors annually (source: U.S. Forest Service, 

http://www.fs.fed.us/r9/forests/white_mountain/about/history/index.php).

Figure 1.3: Mt. Washington from the Southeast at Sunrise 

The Great Gulf Wilderness and the Presidential Range - Dry River Wilderness are two of 156 

protected areas designated in 1977 as mandatory federal Class I areas for the purposes of the 

visibility protection program. Each of these areas covers thousands of acres containing high 

mountain terrain, scenic vistas, and interesting or unique geologic formations and vegetation 

communities. Many species of wildlife are present, including a number of alpine-zone 

residents. Among the alpine fauna are the northern bog lemming and two rare butterfly 

species. Cool, crystal-clear streams, cascades, and high-elevation ponds are common 

throughout the two areas, and the region is full of natural woodland. Hardwoods are most 

abundant on the lower slopes; mixed birches, maples, and spruce-fir dominate the mid-slopes; 

and spruce-fir are most common on the upper mountainsides. The unusual low-elevation tree 

line in the White Mountains of New Hampshire is caused by the high winds and harsh 

conditions this area experiences through the year. The result is a fragile, near-Arctic-tundra 

vegetation at the higher elevations. 

The delicate ecosystems in both wilderness areas have been under stress resulting from years 

of highly acidic precipitation, which has leached plant nutrients from the soils and acidified 

mountain streams and ponds. The damage done by air pollution to Great Gulf and 

Presidential Range - Dry River Wilderness Areas will take decades to repair. 
New Hampshire Regional Haze SIP Revision Page 12 

1.5.1 Great Gulf Wilderness 

The Great Gulf Wilderness is located in Greens Grant in the White Mountain National Forest 

of northern New Hampshire (Figure 1.4). Occupying the northeastern slopes of the 

Presidential Range, Great Gulf covers an area of 5,552 acres and ranges in elevation from 

1,680 to 5,807 feet. 

Figure 1.4: Location of New Hampshire’s Class I Areas 

The Great Gulf Wilderness is formed by a high mountain valley located north-northeast of the 

Mt. Washington summit (Figures 1.5 and 1.6). The valley has steep walls rising from 1,100 

feet to 1,600 feet above the valley floor. The area includes many rivulets that drain eastward 

to the West Fork of the Peabody River. For visitors, the Great Gulf has 21.3 miles of marked 

trails, which offer some of the best views of the ridges and summits of the Presidential Range. 

Great Gulf receives about 20,000 visitors annually.

Figure 1.5: View of Great Gulf Wilderness from Mt. Washington 

 http://www.penemco.com/matthew/
New Hampshire Regional Haze SIP Revision Page 13 

Figure 1.6: Views of Great Gulf Wilderness from Lower Elevation 

on Clear (6 deciview) and Hazy (28 deciview) Days 

1.5.2 Presidential Range - Dry River Wilderness, New Hampshire 

The Presidential Range - Dry River Wilderness is also located in Greens Grant in the White 

Mountain National Forest of northern New Hampshire (Figure 1.4); however, at 27,380 acres, 

it is about five times larger than the Great Gulf Wilderness. Ranging in elevation from 880 to 

5,413 feet, the Presidential Range - Dry River Wilderness constitutes a rugged expanse of 

mountains and valleys lying to the south of Mt. Washington’s summit. On its western side, 

the area flanks other peaks in the Presidential Range, including Mt. Eisenhower and Mt. 

Monroe. The wilderness area extends across and beyond the central valley of the Dry River 

to the Saco River, encompassing numerous brooks and smaller, heavily forested mountains 

(Figure 1.7). 

Figure 1.7: Presidential Range - Dry River Wilderness in Autumn. 

 http://www.wilderness.net

As the name suggests, the Dry River is almost without water by late summer but swells 

quickly during heavy rains. There are ten trails in the wilderness area totaling 46.1 miles in 

length. Because of its remote location, this area receives fewer visitors than Great Gulf (about 

7,000 annually). Its southern portion has almost no trails, is very steep and rugged, and offers 

a rare degree of solitude. 

 

 http://www.wilderness.net
New Hampshire Regional Haze SIP Revision Page 14 

1.5.3 Monitoring and Recent Visibility Trends 

Visibility monitoring at Great Gulf Wilderness and Presidential Range - Dry River Wilderness 

is accomplished with instruments located at a single site at Camp Dodge. This monitoring 

station, which represents both wilderness areas, measures and records light scattering, 

aerosols, and relative humidity (Table 1.1). The collected data are compiled and sorted to 

ascertain visibility levels on the 20 percent most and least visibility-impaired days, and this 

information is tracked over time to look for trends in visibility. 

Table 1.1: Visibility Monitoring at Great Gulf and Presidential Range - Dry River 

Wilderness Areas 

Parameter Instrument 

Scattering coefficient Nephelometer 

Aerosol IMPROVE module A 

Aerosol IMPROVE module B 

Aerosol IMPROVE module C 

Aerosol IMPROVE module D 

Meteorology Relative humidity 

Figure 1.8 depicts recent visibility trends (in annual average deciviews) at Great Gulf 

Wilderness and Presidential Range - Dry River Wilderness for the 20 percent most and least 

visibility-impaired days for each year from 1995 to 2004. The graph also shows the 

reconstructed natural background level. The difference between the 20 percent haziest days 

and the natural background level shows the magnitude of the gap that needs to be closed in 

order to attain the national visibility goal established in the Clean Air Act. 

Figure 1.8: Visibility Trends at Great Gulf and Presidential Range - Dry River 

Wilderness Areas
New Hampshire Regional Haze SIP Revision Page 15 

The plotted trend lines serve only as semi-quantitative indicators of baseline conditions for a 

number of reasons: 

• As of 1999, there were no complete years of sampling data for the Great Gulf site; so 

the trend lines represent only the subset of summer months from May or June through 

September. 

• Since the haziest days typically occur in the warmest months, average deciview values 

for the 20 percent most visibility-impaired summertime days would almost certainly 

be higher than the corresponding value for the year as a whole. 

• The short time span of the trend plots (10 years’ worth of data) makes it impossible to 

draw definitive conclusions about recent visibility trends in New Hampshire. 

Despite these caveats, the trend plots do suggest the following: 

• The 20 percent most visibility-impaired days have visibility readings in the order of 10 

deciviews above the worst natural background level; and 

• The 20 percent least visibility-impaired days have visibility readings in the order of 

4 deciviews above the best natural background level. 
New Hampshire Regional Haze SIP Revision Page 16 

2. AREAS CONTRIBUTING TO REGIONAL HAZE 

40 CFR 51.308I(3) of the Regional Haze Rule requires states to determine their contributions 

to visibility impairment at mandatory Class I areas. Through source apportionment modeling 

(more fully described in Section 8, Understanding the Sources of Visibility-Impairing 

Pollutants), MANE-VU has identified and evaluated the major contributors to regional haze at 

MANE-VU Class I Areas as well as Class I areas in nearby Regional Planning Organizations 

(RPOs). The complete findings are contained in a report produced by the Northeast States for 

Coordinated Air Quality Management (NESCAUM) entitled, “Contributions to Regional 

Haze in the Northeast and Mid-Atlantic United States,” August 2006, otherwise known as the 

Contribution Assessment (Attachment B).

The regional modeling performed by MANE-VU included a pollutant tagging scheme to 

produce a comprehensive assessment of the individual contributions from 28 nearby states to 

visibility impairment at the New Hampshire Class I areas and six other nearby Class I areas. 

The modeling also provided a partial accounting of the contributions from several states along 

the western and southern edges of the modeling domain (i.e., boundary conditions) where 

only a portion of the states’ emissions were tracked. Modeling was conducted for the base 

year 2002 and then projected to year 2018, when currently anticipated emission control 

programs would be in place. 

Modeling results indicate that the relative contributions of states within the modeling domain 

will decrease significantly by 2018 as a result of anticipated SO2 emission reductions from 

implementation of existing state programs, applicable portions of the federal Clean Air 

Interstate Rule (CAIR), and additional state and federal control measures described in 

following sections of this document. At the same time, there will be large increases in the 

relative contributions from Canada and the boundary areas. These predicted increases are not 

absolute increases in mass but are due simply to the fact that contributions from outside the 

modeling domain will represent a larger share of the total after the various emission control 

programs within the U.S. portion of the modeling domain have reduced contributions from 

within the domain. 

It is noteworthy that projected SO2 reductions from emission sources in New Hampshire are 

on pace with states enrolled in the CAIR program even though New Hampshire is not 

included in this program. As do many other states, New Hampshire has its own program for 

reducing SO2 emissions.

According to the completed MANE-VU modeling, sulfate concentrations at the Great Gulf and 

Presidential Range - Dry River Wilderness Areas on the 20 percent worst visibility days will 

decline from 7.3 μg/m3 in 2002 (representing the baseline period of 2000-2004) to 4.6 μg/m3 in 

2018. Included in these values is New Hampshire’s own sulfate contribution, which is projected 

to drop from 0.4 μg/m3 in 2002 to 0.3 μg/m3 in 2018. Mirroring the results for sulfate, fine 

particulate matter (PM2.5) concentrations from all sources are projected to fall by a similar 

percentage, from 12.5 μg/m3 in 2002 to 9.2 μg/m3 in 2018. The modeling that produced these 

results is described in Section 7, Air Quality Modeling, and in “2018 Visibility Projections,” 

May 13, 2008 (Attachment Q). The emission control programs responsible for the projected 

visibility improvements are described in Section 11, Long-Term Strategy. 

Figure 2.1 shows the magnitude of the 2002 (measured) and 2018 (projected) sulfate 

concentrations at the Great Gulf and Presidential Range - Dry River Wilderness Areas, as well 

as the relative mass contributions of each state, on the 20 percent worst visibility days. 

Similar findings apply to the other Class I areas (graphical figures for these other sites are 

available in the Contribution Assessment but, for brevity, are not repeated here). 
New Hampshire Regional Haze SIP Revision Page 17 

Figure 2.1: Measured and Projected Mass Contributions in 2002 and 2018 at Great Gulf 

and Presidential Range -Dry River Wilderness Areas on 20 Percent Worst Visibility Days 

2.1 Class I Areas Affected by New Hampshire’s Emission Sources 

Emission sources within New Hampshire have had measurable impacts on visibility at Class I 

areas both within the state and at downwind locations. The magnitude of these impacts is 

described in detail in MANE-VU’s Contribution Assessment (Attachment B). Table 2.1 

briefly lists the affected Class I areas and New Hampshire’s percent contribution to total 

annual sulfate at each area in the 2002 baseline year, as determined from the modeling. 

Table 2.1: New Hampshire’s Contributions to Total Annual Average Sulfate Impact 

(Percent, Mass Basis) at Eastern Class I Areas in 2002 

Mandatory Class I Area(s) Percent Contribution 

Great Gulf Wilderness* & Presidential Range - Dry River Wilderness* 3.95 

Acadia National Park* 2.25 

Moosehorn Wilderness* & Roosevelt Campobello International Park* 1.74 

Lye Brook Wilderness* 1.68 

Brigantine Wilderness* 0.60 

Shenandoah National Park 0.08 

Dolly Sods Wilderness 0.04 

*MANE-VU Class I Area 
New Hampshire Regional Haze SIP Revision Page 18 

Interestingly, New Hampshire’s own SO2 emissions account for only about 4 percent of 

visibility-impairing sulfate in New Hampshire’s Class I Areas and approximately 2 percent of 

visibility-impairing sulfate in the downwind Class I areas of Acadia National Park, 

Moosehorn Wilderness, Roosevelt Campobello International Park, and Lye Brook 

Wilderness. Also, New Hampshire’s emissions account for less than 1 percent of visibilityimpairing sulfate in the more southerly Class I areas of Brigantine Wilderness, Shenandoah 

National Park, and Dolly Sods Wilderness. 

2.2 States Contributing to Visibility Impairment in New Hampshire’s 

Class I Areas 

Through participation in the MANE-VU regional haze planning process, New Hampshire has 

identified the states and Canadian provinces contributing to visibility impairment at New 

Hampshire’s two Class I areas: the Great Gulf Wilderness and the Presidential Range - Dry 

River Wilderness. Table 2.2 lists the states and regions responsible for visibility degradation 

at these Class I areas, and the corresponding percentage contributions to total sulfate impact. 

Taken from MANE-VU’s Contribution Assessment, the data provide clear evidence that the 

large majority of sulfate pollution at New Hampshire’s Class I areas originates from sources 

outside the state and, more significantly, from sources outside the MANE-VU region. Note 

that “other” sources contribute nearly a quarter of the total sulfate impact. These sources 

represent all emissions from outside the modeling domain (i.e., boundary conditions, 

including emissions coming primarily from regions lying west of the Mississippi River). 

Table 2.2: Contributions of Individual MANE-VU States and Other Regions to Total 

Annual Average Sulfate Impact (Percent, Mass Basis) at New Hampshire’s Class I 

Areas in 2002

State or Region Percent 

Contribution 

Pennsylvania 8.30 

New York 5.68 

New Hampshire 3.95 

Massachusetts 3.11 

Maine 2.33 

Maryland 1.92 

New Jersey 0.89 

Delaware 0.63 

Connecticut 0.48 

Vermont 0.41 

Rhode Island 0.11 

District of Columbia 0.01 

MANE-VU 27.83 

MRPO 20.10 

VISTAS 12.04 

CenRAP 1.65 

Canada 14.84 

Other 23.54 

Note: Indicated percent 

contributions from, 

VISTAS, CenRAP, and 

Canada apply only to 

those portions lying within 

the modeling domain (see 

Figure 7.1). Actual 

contributions, especially 

from CenRAP, would be 

higher than stated. 
New Hampshire Regional Haze SIP Revision Page 19 

3. REGIONAL PLANNING AND CONSULTATION 

In 1999, EPA and affected states/tribes agreed to create five Regional Planning Organizations 

(RPOs) to facilitate interstate coordination on State Implementation Plans (SIPs) addressing 

regional haze. The RPOs, and states/tribes within each RPO, are required to consult on 

emission management strategies toward visibility improvement in affected Class I areas. As 

shown in the accompanying map (Figure 3.1), the five RPOs are MANE-VU (MidAtlantic/Northeast Visibility Union), VISTAS (Visibility Improvement State and Tribal 

Association of the Southeast), MRPO (Midwest Regional Planning Organization), CenRAP 

(Central Regional Air Planning Association), and WRAP (Western Regional Air Partnership). 

New Hampshire is a member of MANE-VU. 

Figure 3.1: EPA-Designated Regional Planning Organizations (RPOs). 

3.1 Mid-Atlantic / Northeast Visibility Union (MANE-VU) 

MANE-VU’s work is managed by the Ozone Transport Commission (OTC) and carried out 

by OTC, the Mid-Atlantic Regional Air Management Association (MARAMA), and the 

Northeast States for Coordinated Air Use Management (NESCAUM). The states, tribes, and 

federal agencies comprising MANE-VU are listed in Table 3.1. Individuals from the member 

states, tribes, and agencies, along with professional staff from OTC, MARAMA, and 

NESCAUM, make up the various committees and workgroups. MANE-VU also established a 

Policy Advisory Group (PAG) to provide advice to decision-makers on policy questions. 

EPA, Federal Land Managers, states, and tribes are represented on the PAG, which meets on 

an as-needed basis. 
New Hampshire Regional Haze SIP Revision Page 20 

Table 3.1: MANE-VU Members 

Connecticut Rhode Island 

Delaware Vermont 

Maine District of Columbia 

Maryland Penobscot Nation 

Massachusetts St. Regis Mohawk Tribe 

New Hampshire U.S. Environmental Protection Agency* 

New Jersey U.S. Fish and Wildlife Service* 

New York U.S. Forest Service* 

Pennsylvania U.S. National Park Service* 

 *Non-voting member 

Since its inception on July 24, 2001, MANE-VU has created an active committee structure to 

address both technical and non-technical issues related to regional haze. The primary 

committees are the Technical Support Committee (TSC) and the Communications Committee, 

While the work of these committees are instrumental to policies and programs, all policy 

decisions reside with and are made by the MANE-VU Board. 

The TSC is charged with assessing the nature and magnitude of the regional haze problem 

within MANE-VU, interpreting the results of technical work, and reporting on such work to 

the MANE-VU Board. This committee has evolved to function as a valuable resource on all 

technical projects and issues for MANE-VU. The TSC has established a process to ensure 

that important regional-haze-related projects are completed in a timely fashion, and members 

are kept informed of all MANE-VU tasks and duties. In addition to the formal working 

committees, there are three standing workgroups of the TSC assigned by topic area: the Emissions 

Inventory Workgroup, the Modeling Workgroup, and the Monitoring/Data Analysis 

Workgroup. 

The Communications Committee is charged with developing approaches to inform the public 

about the regional haze problem and making recommendations to the MANE-VU Board to 

facilitate that goal. This committee oversees the production of MANE-VU’s newsletter and 

outreach tools, both for stakeholders and the public, regarding regional issues affecting 

MANE-VU’s members. 

3.2 Regional Consultation and the “Ask” 

On May 10, 2006, MANE-VU adopted the Inter-RPO State/Tribal and FLM Consultation 

Framework (Attachment C). That document set forth the principles presented in Table 3.2. 

The MANE-VU states and tribes applied these principles to the regional haze consultation and 

SIP development process. Issues addressed included regional haze baseline assessments, 

natural background levels, and development of reasonable progress goals – described at 

length in later sections of this SIP. 
New Hampshire Regional Haze SIP Revision Page 21 

Table 3.2: MANE-VU Consultation Principles for Regional Haze Planning 

1. All State, Tribal, RPO, and Federal participants are committed to continuing dialogue and 

information sharing in order to create understanding of the respective concerns and needs of 

the parties. 

2. Continuous documentation of all communications is necessary to develop a record for inclusion 

in the SIP submittal to EPA. 

3. States alone have the authority to undertake specific measures under their SIP. This inter-RPO 

framework is designed solely to facilitate needed communication, coordination and cooperation 

among jurisdictions but does not establish binding obligation on the part of participating 

agencies. 

4. There are two areas which require State-to-State and/or State-to-Tribal consultations (“formal” 

consultations): (i) development of the reasonable progress goal for a Class I area, and (ii) 

development of long-term strategies. While it is anticipated that the formal consultation will 

cover the technical components that make up each of these policy decision areas, there may be 

a need for the RPOs, in coordination with their State and Tribal members, to have informal 

consultations on these technical considerations. 

5. During both the formal and informal inter-RPO consultations, it is anticipated that the States 

and Tribes will work collectively to facilitate the consultation process through their respective 

RPOs, when feasible. 

6. Technical analyses will be transparent, when possible, and will reflect the most up-to-date 

information and best scientific methods for the decision needed within the resources available. 

7. The State with the Class I area retains the responsibility to establish reasonable progress goals. 

The RPOs will make reasonable efforts to facilitate the development of a consensus among the 

State with a Class I area and other States affecting that area. In instances where the State with 

the Class I area can not agree with such other States that the goal provides for reasonable 

progress, actions taken to resolve the disagreement must be included in the State’s regional 

haze implementation plan (or plan revisions) submitted to the EPA Administrator as required 

under 40 CFR §51.308(d)(1)(iv). 

8. All States whose emissions are reasonably anticipated to contribute to visibility impairment in a 

Class I area, must provide the Federal Land Manager (“FLM”) agency for that Class I area with 

an opportunity for consultation, in person, on their regional haze implementation plans. The 

States/Tribes will pursue the development of a memorandum of understanding to expedite the 

submission and consideration of the FLMs’ comments on the reasonable progress goals and 

related implementation plans. As required under 40 CFR §51.308(i)(3), the plan or plan 

revision must include a description of how the State addressed any FLM comments. 

9. States/Tribes will consult with the affected FLMs to protect the air resources of the State/Tribe 

and Class I areas in accordance with the FLM coordination requirements specified in 40 CFR 

§51.308(i) and other consultation procedures developed by consensus. 

10. The consultation process is designed to share information, define and document issues, develop 

a range of options, solicit feedback on options, develop consensus advice if possible, and 

facilitate informed decisions by the Class I States. 

11. The collaborators, including States, Tribes and affected FLMs, will promptly respond to other 

RPOs’/States’/Tribes’ requests for comments. 
New Hampshire Regional Haze SIP Revision Page 22 

The following points offer a snapshot of several important ways in which MANE-VU 

member states and tribes have cooperatively addressed regional haze: 

• Prioritization: MANE-VU developed a process to coordinate MARAMA, OTC, and 

NESCAUM staff in developing budget priorities, project rankings, and the eventual 

federal grant requests. 

• Issue Coordination: MANE-VU established a conference call and meeting schedule 

for each of its committees and workgroups. In addition, its MANE-VU directors 

regularly discussed pertinent issues. 

• SIP Policy and Planning: MANE-VU states/tribes collaborated on the development of 

a regional haze SIP template and the technical aspects of the SIP development process. 

• Capacity Building: To educate its staff and members, MANE-VU included technical 

presentations on conference calls and organized workshops with nationally recognized 

experts. Presentations on data analysis, Best Available Retrofit Technology (BART) 

applicability, inventory topics, modeling, and control measures were effective education 

and coordination tools. 

• Routine Operations: MANE-VU staff at OTC, MARAMA, and NESCAUM established 

a coordinated approach to budget tracking, project deliverables and due dates, 

workgroup meetings, inter-RPO consultations, etc. 

Both formal and informal consultations within MANE-VU have been ongoing since the 

organization’s establishment in 2001; but the bulk of formal consultation took place in 2007, 

as outlined in Table 3.3. Further documentation of consultation meetings and calls is included 

in Attachment D. 
New Hampshire Regional Haze SIP Revision Page 23 

Table 3.3: Summary of MANE-VU’s Consultations on Regional Haze Planning

1.1.7 New Hampshire’s Consultations 

40 CFR Section 51.308(d)(3)(i) requires the State of New Hampshire to consult with other 

states/tribes to develop coordinated emission management strategies. This requirement 

applies both when emissions from a state/tribe are reasonably anticipated to contribute to 

visibility impairment in Class I areas outside the state/tribe and when emissions from other 

states/tribes are reasonably anticipated to contribute to visibility impairment at mandatory 

Class I areas within a state/tribe. 

New Hampshire consulted with other states/tribes by participating in the MANE-VU and 

inter-RPO processes leading to the creation of coordinated strategies on regional haze. This 

coordinated effort considered the individual and aggregated impacts of states’/tribes’ 

emissions on Class I areas within and outside the states/tribes. 

As described in Section 2.0, Areas Contributing to Regional Haze, emissions originating in 

New Hampshire have had, and will continue to have, impacts on other Class I areas in the 

region. Accordingly, New Hampshire has entered into consultations with the states and 

provinces in which the affected Class I areas are located (Table 2.1). 

Table 2.1: Class I Areas States Requesting Consultation with New Hampshire 

Class I Federal Area State / Province 

 Great Gulf Wilderness New Hampshire 

 Presidential Range Dry River Wilderness New Hampshire 

 Acadia National Park Maine 

 Moosehorn Wilderness Maine 

 Roosevelt Campobello International Park Maine / New Brunswick 

 Lye Brook Wilderness Vermont 

 Brigantine Wilderness New Jersey 

The listed states represent only a fraction of those with whom New Hampshire has entered 

into consultations on regional haze. Through the MANE-VU process, more than twenty states 

and Canadian provinces have been identified as contributing to visibility degradation in New 

Hampshire’s two Class I areas: the Great Gulf Wilderness and the Presidential Range - Dry 

River Wilderness. On April 2, 2007, NHDES sent letters formally requesting consultation 

under the Regional Haze Rule to states and Canadian provinces – specifically, those shown 

via modeling to contribute at least 2 percent of visibility-impairing sulfates at Class I Areas in 

New Hampshire (refer to the Contribution Assessment, Attachment B), and all other states 

located within MANE-VU 

MANE-VU Intra-Regional Consultation Meeting, March 1, 2007: 

MANE-VU members reviewed the requirements for regional haze plans, preliminary modeling results, 

the work being done to prepare the MANE-VU report on reasonable progress factors, and control 

strategy options under review. 

MANE-VU Intra-State Consultation Meeting, June 7, 2007: 

The MANE-VU Class I states adopted a statement of principles, and all MANE-VU members discussed 

draft statements concerning reasonable controls within and outside of MANE-VU. Federal Land 

Managers also attended the meeting, which was open to stakeholders. 

MANE-VU Conference Call, June 20, 2007: 

The MANE-VU states concluded discussions of statements concerning reasonable controls within and 

outside MANE-VU and agreed on the statements called the MANE-VU “Ask” (see Part 3.2.2 of this 

SIP), including a statement concerning controls within MANE-VU, a statement concerning controls 

outside MANE-VU, and a statement requesting a course of action by the U.S. EPA. Federal Land 

Managers also participated in the call. Upon approval, all statements as well as the statement of 

principles adopted on June 7 were posted and publicly available on the MANE-VU website. The 

MANE-VU Ask was determined to represent New Hampshire’s needs for meeting Regional Haze rule 

requirements and was thus adopted as the New Hampshire Ask. 

MANE-VU Class I States’ Consultation Open Technical Call, July 19, 2007: 

The MANE-VU/New Hampshire Ask was presented to states in other RPOs, RPO staff, and Federal 

Land Managers; and an opportunity was provided to request further information. This call was intended

to provide information to facilitate informed discussion at follow-up meetings. 

MANE-VU Consultation Meeting with MRPO, August 6, 2007: 

This meeting, held at LADCO offices in Chicago, was attended by representatives of MANE-VU and 

MRPO states as well as staff. The meeting provided an opportunity to formally present the MANE-VU/ 

New Hampshire Ask to MRPO states and to consult with them on the reasonableness of the requested 

controls. Federal Land Manager agencies also attended the meeting. 

MANE-VU Consultation Meeting with VISTAS, August 20, 2007: 

This meeting, held at State of Georgia offices in Atlanta, was attended by representatives of MANE-VU 

and VISTAS states. The meeting provided an opportunity to formally present the MANE-VU/New 

Hampshire Ask to VISTAS states and to consult with them on the reasonableness of the requested 

controls. Federal Land Manager agencies also attended the meeting. 

MANE-VU / MRPO Consultation Conference Call, September 13, 2007: 

As a follow-up to the meeting held on August 6 in Chicago, this call provided an opportunity for 

MANE-VU to clarify further what was being asked of the MRPO states. The flexibility in the Ask was 

explained. MRPO and MANE-VU staff agreed to work together to facilitate discussion of further 

controls on ICI boilers and EGUs. 

MANE-VU Air Directors’ Consultation Conference Call, September 26, 2007: 

MANE-VU members clarified their understanding of the Ask and provided direction to modeling staff 

regarding interpretation of the Ask for purposes of estimating visibility impacts of the requested controls. 
New Hampshire Regional Haze SIP Revision Page 24 

3.2.1 New Hampshire-Specific Consultations 

40 CFR 51.308(d)(3)(i) of the Regional Haze Rule requires the State of New Hampshire to 

consult with other states/tribes to develop coordinated emission management strategies. This 

requirement applies both when emissions from a state/tribe are reasonably anticipated to 

contribute to visibility impairment in Class I areas outside the state/tribe and when emissions 

from other states/tribes are reasonably anticipated to contribute to visibility impairment at 

mandatory Class I areas within a state/tribe. 

New Hampshire consulted with other states/tribes by participating in the MANE-VU and 

inter-RPO processes leading to the creation of coordinated strategies on regional haze. This 

coordinated effort considered the individual and aggregated impacts of states’/tribes’ 

emissions on Class I areas within and outside the states/tribes. 

As described in Section 2, Areas Contributing to Regional Haze, emissions originating in 

New Hampshire have had, and will continue to have, impacts on other Class I areas in the 

region. Accordingly, New Hampshire has entered into consultations with the states and 

provinces in which the affected Class I areas are located (Table 3.4). 

Table 3.4: Class I Area States Requesting Consultation with New Hampshire 

Class I Federal Area State / Province 

 Great Gulf Wilderness New Hampshire 

 Presidential Range - Dry River Wilderness New Hampshire 

 Acadia National Park Maine 

 Moosehorn Wilderness Maine 

 Roosevelt Campobello International Park Maine / New Brunswick 

 Lye Brook Wilderness Vermont 

 Brigantine Wilderness New Jersey 

The listed states represent only a fraction of those with whom New Hampshire has entered 

into consultations on regional haze. Through the MANE-VU process, more than twenty states 

and Canadian provinces have been identified as contributing to visibility degradation in New 

Hampshire’s two Class I areas: the Great Gulf Wilderness and the Presidential Range - Dry 

River Wilderness. On April 2, 2007, NHDES sent letters formally requesting consultation 

under the Regional Haze Rule to states and Canadian provinces – specifically, those shown 

via modeling to contribute at least 2 percent of visibility-impairing sulfates at Class I Areas in 

New Hampshire (refer to Contribution Assessment, Attachment B), and all other states located 

within MANE-VU. 

To maintain consistency within MANE-VU, every MANE-VU member was requested to 

consult with New Hampshire. Several states outside MANE-VU were also requested to join 

this consultation in response to the findings of MANE-VU’s evaluations. In addition, the 

Canadian Provinces of Ontario and Quebec were invited to join in informal consultation with 

New Hampshire, although they are under no legal obligation to meet U.S. requirements. 

Table 3.5 provides a complete listing of states, provinces, and regional planning organizations 

invited to participate in consultations with New Hampshire on measures to mitigate regional 

haze. Note that all MANE-VU states with Class I areas have similarly requested consultation 

with New Hampshire on the regional haze issue. 
New Hampshire Regional Haze SIP Revision Page 25 

Table 3.5: States (Listed by Regional Planning Organization) and Provinces 

Contributing to Visibility Impairment at New Hampshire’s Class I Areas 

MANE-VU VISTAS MRPO International 

Connecticut Georgia Illinois Ontario, Canada 

Delaware Kentucky Indiana Quebec, Canada 

District of Columbia North Carolina Michigan 

Maine South Carolina Ohio 

Maryland Tennessee 

Massachusetts Virginia 

New Jersey West Virginia 

New York 

Pennsylvania 

Rhode Island 

Vermont 

As a result of the invitation to consult, Ontario, Canada, invited representatives of NHDES, 

Vermont Department of Environmental Conservation (VTDEC), Maine Department of 

Environmental Protection (MEDEP), New York Department of Environmental Conservation 

(NYDEC), and NESCAUM to join the Shared Air Summit in Toronto on June 12, 2007, 

followed by an informal consultation meeting with representatives from Ontario on June 13, 

2007. At these meetings, Ontario announced its plan to shut down all coal electrical generation 

and challenged participating states to pursue similar goals. Considerable discussion took 

place regarding trans-border air pollution transport and its affect on human health. 

Formal inter-regional consultation meetings took place on August 6, 2007, in Rosemont, 

Illinois, (for Midwestern states) and on August 20, 2007, in Atlanta, Georgia, (for Southern 

states). Consultation continues with the Midwestern states, seeking common approaches for 

reducing power plant emissions beyond the levels defined under the original CAIR rule, 

controls on industrial boilers, and cleaner-burning fuels for mobile sources. Ongoing 

consultation with MRPO focuses mainly on the health benefits of reducing ozone and small 

particulate emissions; however, the control measures being considered would also result in 

visibility improvements. 

Throughout the consultation process, New Hampshire was guided by the principals contained 

in a resolution adopted by the MANE-VU Class I states on June 7, 2007. In the resolution, 

the Class I states agreed to set reasonable progress goals for 2018 that would provide visibility 

improvement at least as great as that which would be achieved under a uniform rate of 

progress to reach natural visibility conditions by 2064. The goals would be set by the Class I 

states at levels reflecting implementation of measures determined to be reasonable after 

consultation with the contributing states. At the same time, the Class I states recognized that 

each state should be given the flexibility to choose other measures that achieve the same or 

greater benefits. 

The final results of New Hampshire’s consultation efforts will ultimately rest with the 

individual states as they develop and implement their own regional haze SIPs. The other 

MANE-VU states have agreed to incorporate certain control measures into their SIPs, but 

most of these plans are still under development. For the non-MANE-VU states, New 

Hampshire has the expectation that the same or equivalent control measures will be included 

in those states plans. However, some states – particularly those within the VISTAS region – 
New Hampshire Regional Haze SIP Revision Page 26 

have already submitted draft SIPs that do not go as far in controlling emissions as MANE-VU 

would like. See Subpart 3.2.2.3 and Part 3.2.4, below, for further discussion related to the 

non-MANE-VU states. 

3.2.2 The MANE-VU “Ask” 

In addition to having a set of guiding principles for consultation (as described in Table 3.2, 

above), MANE-VU needed a consistent technical basis for emission control strategies to 

combat regional haze. After much research and analysis, on June 20, 2007, MANE-VU 

adopted the following pair of documents (available in Attachment E), which provide the 

technical basis for consultation among the interested parties and define the basic strategies for 

controlling pollutants that cause visibility impairment at Class I areas in the eastern U.S.: 

• “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.” 

Together, these documents are known as the MANE-VU “Ask.” Because New Hampshire 

agrees in total to the language and substance of these documents, the MANE-VU’s Ask is 

also the New Hampshire Ask. The particular emission management strategies that comprise 

the Ask are described in Subparts 3.2.2.1 through 3.2.2.3, below. 

3.2.2.1 Meeting the “Ask” – MANE-VU States 

The member states of MANE-VU have stated their intention to meet the terms of the Ask in 

their individual State Implementation Plans. The Ask for member states promises that each 

state will pursue the adoption and implementation of the following emission management 

strategies, as appropriate and necessary: 

• Timely implementation of BART requirements, in accordance with 40 CFR 

51.308(e). 

• 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 reduce the sulfur content of distillate oil 

further to 15 ppm by 2016; 

• A low-sulfur fuel oil strategy in the outer zone states (the remainder of the MANEVU 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 reduce the sulfur content of distillate oil further to 15 ppm by 

2018, depending on supply availability; 

• A targeted EGU strategy for the top 100 electric generating unit (EGU) emission 

points, or stacks, identified by MANE-VU as contributing to visibility impairment at 

each mandatory Class I area in the MANE-VU region. (The combined list for all 
New Hampshire Regional Haze SIP Revision Page 27 

seven MANE-VU Class I Areas contains 167 distinct emission points. Consequently, 

this strategy is sometimes referred to as the 167-stack strategy.) The targeted EGU 

strategy calls for a 90-percent or greater reduction in sulfur dioxide (SO2) emissions 

from all identified units. If it is infeasible to achieve that level of reduction from these 

specific units, equivalent alternative measures will be investigated in such state; and 

• Continued evaluation of other control measures, including improvements in energy 

efficiency, use of alternative (clean) fuels, further control 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 will 

be evaluated during the consultation process to determine whether they are reasonable 

strategies to pursue. 

 NHDES supports the SIPs of each of its fellow MANE-VU states, provided that these 

commitments are incorporated into approvable State Implementation Plans. 

3.2.2.2 Meeting the “Ask” – New Hampshire 

New Hampshire, being a MANE-VU member state, adopted the Ask at the MANE-VU Board 

meeting on June 7, 2007. New Hampshire intends to meet the terms of this agreement by 

controlling its two in-state BART-eligible sources with timely control strategies as well as 

pursuing the low-sulfur fuel oil strategy. Both BART-eligible sources also fall on the list of 

the top 167 contributing EGU emission points. 

The larger of these facilities (Merrimack Station Unit MK2) will be controlled with scrubber 

technology by 2013 to comply with New Hampshire law. The other facility, a smaller, oilfired unit (Newington Station Unit NT1), will control fuel sulfur levels under BART 

requirements to reduce SO2 emissions. NHDES has determined that controlling the latter 

facility to the 90-percent level of the Ask is not reasonable at this time and will seek alternative 

measures to achieve the equivalent overall reduction in SO2 emissions. The facility has low 

utilization (about 5 percent in 2007), making it cost-ineffective to retrofit with scrubber 

technology. NHDES anticipates that controls installed at Merrimack Station, the largest SO2

source within the state, will result in reductions greater than the 90 percent specified under the 

Ask, thereby offsetting, at least partially, the expected lesser control level at the oil-fired unit. 

Additional reductions in SO2 emissions are planned through the use of lower-sulfur fuels 

across a variety of source categories, including industrial, commercial, and institutional (ICI) 

boilers and home heating units. For more details, refer to Section 11, Long-Term Strategy. 

3.2.2.3 Meeting the “Ask” – States outside MANE-VU

New Hampshire agrees with the MANE-VU Ask for consulting states outside the MANE-VU 

region. This Ask requests the affected states to pursue adoption and implementation of the 

following control strategies, as appropriate and necessary: 

• Timely implementation of BART requirements, as described for the MANE-VU 

states; 

• A targeted EGU strategy, as described for the MANE-VU states, for the top 167 EGU 

stacks contributing the most to visibility impairment at mandatory Class I areas in the 

MANE-VU region, or an equivalent SO2 emission reduction within each state; 
New Hampshire Regional Haze SIP Revision Page 28 

• Installation of reasonable control measures on non-EGU sources by 2018 to achieve 

an additional 28 percent reduction in non-EGU SO2 emissions beyond current on-thebooks/on-the-way (OTB/OTW) measures, resulting in an emission reduction that is 

equivalent to that from MANE-VU’s low-sulfur fuel oil strategy (see Section 11, 

Long-Term Strategy); 

• Continued evaluation of other control measures, including additional reductions in 

SO2 and NOX emissions from all coal-burning facilities by 2018 and promulgation of 

new source performance standards for wood combustion. These and other measures 

will be evaluated during the consultation process to determine whether they are 

reasonable strategies to pursue. 

 NHDES looks for each consulting state to address specifically, in its Regional Haze 

SIP, each element of the MANE-VU Ask. 

NHDES is concerned that non-MANE-VU states may be inclined not to adopt MANE-VU’s 

Ask because of the associated costs, potential conflicts, and relative lack of perceived benefits 

within their jurisdictions. On the basis of consultations held, MANE-VU members believe 

that some non-MANE-VU states will choose not to pursue reductions beyond CAIR controls 

and other measures pertaining to BART requirements. New Hampshire understands that, 

among non-MANE-VU states that have already submitted their regional haze SIPs to EPA, a 

number of the affected states have decided not to address major elements of the MANE-VU 

Ask in their plans. 

There are some positive developments, however. Many states of the MRPO are working with 

MANE-VU states to investigate the potential for widespread use of low-sulfur fuel oil and 

installation of emission controls on ICI boilers within their region. The Midwest states would 

be more likely than Southeast states to adopt a low-sulfur oil strategy because the VISTAS 

states do not have the same extent of fuel oil usage and lack the inventory infrastructure found 

in more northerly states. Both MRPO and VISTAS claim that a substantial portion of the top 

167 contributing EGU stacks will be controlled. However, instead of taking concrete actions on 

uncontrolled or under-controlled facilities, many of these states appear to be satisfied with 

meeting CAIR-equivalent requirements and not looking beyond this level of emission controls for 

additional emission reductions. Further discussion of these issues is provided in Part 3.2.4, below. 

3.2.3 Technical Ramifications of Differing Approaches 

MANE-VU states intended to develop a modeling platform that was common in terms of 

meteorology and emissions with each of the other nearby RPOs. The RPOs worked hard to 

form a common set of emissions with similar developmental assumptions. Even with the best 

of intentions, it became difficult to keep up with each RPO’s updates and corrections. Each 

rendition of emissions inventory improved its quality, but even a single update to one RPO’s 

emissions required each of the other RPOs to adopt the updates. With each rendition, the 

revised emissions had to be re-blended with the full set of emission files for all associated 

RPOs in the modeling domain. Because each rendition put previous modeling efforts out of 

date, and a single modeling run could take more than a month to complete, inventory updates 

have contributed to SIP delays. The emission inventory conflicts have been excessively timeconsuming and caused most states to miss the official filing date of December 17, 2007.
New Hampshire Regional Haze SIP Revision Page 29 

The RPOs also took differing perspectives on which version of the EGU dispatching model to 

use. At the beginning of the process, International’s Integrated Planning Model (IPM®) version 

2.1.9 was available, and EPA agreed to its use for emissions preparation. Subsequently, IPM 

version 3.0 became available and was preferred by some users because of its updated fuel 

costs. MRPO adopted IPM v3.0 for its use, but VISTAS stayed with IPM v2.1.9. Rather than 

develop non-comparative datasets for its previous IPM analyses, MANE-VU opted also to 

remain with IPM v2.1.9. Therefore, for the three eastern RPOs, differing emissions 

assumptions eventually worked their way into the final set of modeling assumptions. 

MANE-VU’s most recent visibility projections take into account on-the-books/on-the-way 

(OTB/OTW) emissions control programs for 2018, and go further by including additional 

reasonable controls in the region, as developed through the MANE-VU Ask. It should be 

noted that other RPOs may not have included such measures in their final modeling and, as a 

result, may have been able to complete their analyses ahead of New Hampshire’s. Where that 

is the case, those states’ modeling results will be inconsistent with meeting the terms of the 

Ask – a situation that may not be adequately addressed in their individual SIPs. 

3.2.4 Consultation Issues 

40 CFR 51.308(d)(1)(iv) of the Regional Haze Rule describes another consultation 

requirement for Class I states. If a contributing state does not agree with a Class I state on its 

reasonable progress goal, the Class I state must describe in its SIP submittal the actions taken 

to resolve the disagreement. 

While states without Class I areas are required to consult at the request of states with Class I 

areas, the Regional Haze Rule does not actually require the states to agree on a common 

course of action. Instead, if agreement cannot be reached, the disagreement needs to be 

described in each state’s SIP along with a description of what actions were taken to resolve the 

disagreement. Most states willingly consulted with NHDES and took New Hampshire’s 

regional haze Ask under serious consideration. In fact, all of the MANE-VU states worked 

together to strategize on how to develop a common approach to meeting the Ask. All states 

involved in these discussions found that working together helped them to develop plans that 

would produce region-wide visibility and health benefits. In particular, reductions in SO2

emissions, because they would yield lower ambient concentrations of fine particle (PM2.5) 

pollution, would help all MANE-VU states in meeting the NAAQS and would have direct 

benefits to public health and welfare. 

A few non-MANE-VU states did not respond to New Hampshire’s consultation requests or 

responded by downplaying the magnitude of their states’ contributions to visibility 

impairment at New Hampshire’s Class I areas. Some states claimed that CAIR alone set the 

standard for reasonableness. By this rationale, any measure more expensive than CAIR on a 

cost-per-ton basis would not be reasonable. A uniform rate of progress was all that some 

states felt was required; and if that set of conditions could be met with CAIR, then no other 

measures needed to be considered. Also a concern for New Hampshire is the possibility that 

some states may have performed modeling for establishment of reasonable progress goals 

without including the effects of a rigorous BART determination for the non-EGU sector. It is 

apparent that the various regions of the country have differing interpretations of how the 

Regional Haze Rule should be applied. 
New Hampshire Regional Haze SIP Revision Page 30 

In a letter to MANE-VU dated April 25, 2008 (Attachment F), VISTAS indicated that for its 

member states, most actions exceeding CAIR requirements would not be reasonable. MANEVU has taken a more rigorous position with respect to additional control measures – including 

the belief that controls on ICI boilers and use of low-sulfur fuels are reasonable measures and

that it is not reasonable to assume reductions from EGUs for planning purposes unless they 

are explicitly incorporated into a State Implementation Plan. More specifically, MANE-VU 

believes that a sector-wide average of 50-percent control on coal-fired boilers and 75-percent 

control on oil-fired boilers are reasonable targets that can be achieved cost-effectively. Also, 

MANE-VU believes that low sulfur fuels – even though they are less widely available in the 

Southeast U.S. than in the Northeast – still represent a reasonable control measure in light of 

the widespread requirement for use of such fuels throughout the MANE-VU region. The 

reasonableness of these additional controls is examined more fully in Section 10, Reasonable 

Progress Goals. 

During the consultation process, disagreements such as these were worked through to the 

maximum extent possible, and the results of these consultations are summarized below: 

• Situation: BART analyses and projected controls were not fully incorporated into the 

VISTAS emissions inventory provided to MANE-VU. VISTAS stated that they 

would further review BART-applicable controls.

→ Outcome: In MANE-VU’s modeling to determine reasonable progress goals, 

MANE-VU made no adjustments to controls in the VISTAS region to reflect 

application of BART beyond the information that VISTAS provided. 

• Situation: The low-sulfur fuel oil strategy adopted by MANE-VU elicited concerns 

from MRPO and VISTAS as not being reasonable because of the limited availability 

of low-sulfur fuel oil and the historically lower usage of this fuel within their regions. 

→ Outcome: MANE-VU agreed to modify the Ask to reflect greater flexibility in 

providing for alternative measures that would produce a comparable rate of 

emission reductions. Accordingly, the Ask for non-MANE-VU states was 

modified to provide for an overall 28 percent reduction in SO2 emissions wherever 

they were found to be reasonable. In MANE-VU’s modeling to determine 

reasonable progress goals, SO2 emissions from non-EGU sources in non-MANEVU contributing states were reduced by this same amount. 

• Situation: MANE-VU received no response from other RPOs concerning non-EGU 

control measures that they did consider reasonable.

→ Outcome: As a default position, MANE-VU’s modeling included emission 

adjustments for those regions based on MANE-VU’s own analyses of what 

constituted reasonable control measures from non-EGU sources (see Section 10 , 

Reasonable Progress Goals). 

• Situation: The targeted EGU strategy was thought by some non-MANE-VU states to 

be too restrictive and too difficult to achieve. MANE-VU recognized that a 100-percent 

compliance with this portion of the Ask was unlikely to occur because the CAIR 

trading market would probably dominate. However, MANE-VU had hoped that nonMANE-VU states would make a more concerted effort toward meeting this request. 

MANE-VU did receive a partial list of facilities that were expected to comply. 
New Hampshire Regional Haze SIP Revision Page 31 

→ Outcome: For the top contributing EGU stacks located within the MANE-VU, 

MRPO, and VISTAS regions, expected emission reductions resulting from the Ask 

were distributed among facilities on the basis of recommendations received during 

inter- and intra-regional consultations. To maintain the CAIR emissions budget as 

predicted by the modeling, excess emission reductions (also predicted by the 

modeling) were uniformly added back to EGUs in all three regions. 

While the original CAIR rule would have been the primary determinant of which EGUs among 

the top 167 stacks are to be fitted with emission controls, at the same time, MANE-VU 

recognized that these units are the primary sources affecting visibility in the MANE-VU 

states. For the initial planning, MANE-VU has allowed flexibility as to how other RPOs meet 

the Ask. However, MANE-VU expects that, over time, these actual facilities will need to be 

controlled if significant improvements in visibility at affected Class I areas are to be realized. 

MANE-VU believes that the goals of the Ask will be attained only by means of binding 

obligations to EGU emission reductions beyond the levels of control that CAIR originally 

would have provided. MANE-VU therefore maintains that additional federal action is needed 

to achieve the visibility benefits shown to be feasible through sensitivity modeling (see 

Attachment G, “MANE-VU Modeling for Reasonable Progress Goals: Model Performance 

Evaluation, Pollution Apportionment, and Control Measure Benefits,” February 7, 2008) and 

demonstrated to be available at reasonable cost (see Attachment H, Alpine Geophysics, LLC, 

“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). 

MANE-VU’s position on this issue is formally expressed in its “Statement of the MidAtlantic / Northeast Visibility Union (MANE-VU) Concerning a Request for a Course of 

Action by the U.S. Environmental Protection Agency (EPA) toward Assuring Reasonable 

Progress,” adopted June 20, 2007. This statement, more commonly known as MANE-VU’s 

National Ask, is included in Attachment E. 

Although other RPOs did not adopt all of the same philosophies or processes for their regional 

haze SIPs, the consultation process maintains a central role in regional haze planning. New 

Hampshire is pleased with the significant opportunities identified for ongoing consultation 

with other states concerning long-term strategies not only for regional haze mitigation but also 

for improved air quality in general. 

3.2.5 State/Tribe and Federal Land Manager Coordination 

New Hampshire will continue to coordinate and consult with the Federal Land Managers 

during the development of future progress reports and plan revisions, as well as during the 

implementation of programs having the potential to contribute to visibility impairment in the 

mandatory Class I areas. 

40 CFR 51.308(i) of the Regional Haze Rule requires coordination between states/tribes and 

the Federal Land Managers (FLMs). Opportunities have been provided by MANE-VU for 

FLMs to review and comment on each of the technical documents developed by MANE-VU 

and included in this SIP. New Hampshire has identified agency contacts to the FLMs as 

required under 40 CFR 51.308(i)(1). New Hampshire has consulted with the FLMs in the 

development of this plan and, in accordance with 40 CFR 51.308(i)(2), has provided the 
New Hampshire Regional Haze SIP Revision Page 32 

FLMs an opportunity for consultation, in person, at least 60 days prior to holding any public 

hearing on the SIP. The draft SIP was submitted to the FLMs on August 1, 2008, for review 

and comment. 

Pursuant to 40 CFR 51.308(i)(3), New Hampshire has requested and received comments on the 

regional haze SIP from the Federal Land Managers. NHDES received preliminary comments 

from the U.S. Department of the Interior (DOI), National Park Service (NPS) and U.S. Fish 

and Wildlife Service (FWS) on August 27, 2008, and from the U.S. Department of Agriculture, 

U.S. Forest Service (USFS) on August 28, 2008. Formal comments from DOI – NPS and 

FWS on the SIP were received in a letter dated September 26, 2008. Conference calls to discuss 

the agencies’ comments took place on August 28 and September 18, 2008, with representatives 

from NPS, USFS, USFWS, EPA, and NHDES in attendance. Following these consultations, 

NHDES revised the draft implementation plan to address the agencies’ comments. A public 

hearing on the draft final SIP was held at NHDES headquarters on Wednesday, June 24, 

2009. The U.S. Department of the Interior, National Park Service provided final written 

comments during the public comment period, which ended on June 26, 2009. 

A compilation of comments received, responses by NHDES, and summaries of conference 

calls is presented in Attachment I of this plan. All of these documents were made available 

for public review during the public comment period. (Note: The MANE-VU states also 

received comments from other stakeholders during the planning process; their comments can 

be found in Attachment J.) 

The comments submitted by the FLMs were both general and specific. The reviewing 

agencies found New Hampshire’s Regional Haze SIP to be well written and comprehensive. 

The uncertainty surrounding CAIR and discrepancies in modeling (especially inclusion of the 

MANE-VU Ask) between MANE-VU and other RPOs were identified as broad topics for 

further discussion through the consultation process. Comments of a specific nature were 

relatively minor for the most part. The agencies requested that NHDES provide additional 

information in support of New Hampshire’s BART analyses. NHDES’s responses to the 

agencies’ comments are addressed point-by-point in the response document contained in 

Attachment I. 

40 CFR 51.308(i)(4) requires procedures for continuing consultation between the states/tribes 

and FLMs on the implementation of the visibility protection program. In particular, New 

Hampshire will consult with the designated visibility protection program coordinators for the 

National Park Service, U. S. Fish and Wildlife Service, and U.S. Forest Service, periodically 

and as circumstances require, on the following implementation items: 

1. Status of emissions strategies identified in the SIP as contributing to improvements in 

the worst-day visibility; 

2. Summary of major new source permits issued; 

3. Status of New Hampshire’s actions toward completing any future assessments or 

rulemakings on sources identified as probable contributors to visibility impairment, 

but not directly addressed in the most recent SIP revision; 

4. Any changes to the monitoring strategy or status of monitoring stations that might 

affect tracking of reasonable progress; 
New Hampshire Regional Haze SIP Revision Page 33 

5. Work underway for preparing the 5-year SIP review and/or 10-year SIP revision, 

including any items where the FLMs’ consideration or support is requested; and 

6. Summary of topics discussed in ongoing communications (e.g., meetings, emails, etc.) 

between New Hampshire and the FLMs regarding implementation of the visibility 

improvement program. 

3.2.6 EPA Consultation and Review 

New Hampshire has consulted with EPA on many occasions in the course of regional haze 

modeling and plan development, and EPA has provided specific input regarding completion 

of the SIP. On July 10, 2008, NHDES received written comments from EPA on an early SIP 

draft that was submitted to the agency for preliminary review. On October 24, 2008, NHDES 

received additional written comments from EPA on a modified version that was identical to 

the draft SIP reviewed by the FLMs. Following the public hearing, in a letter dated June 26, 

2009, EPA provided formal comments on the draft final SIP. 

New Hampshire has addressed EPA’s comments by making appropriate amendments to the 

SIP, all of which are incorporated into the present document. EPA’s specific comments and 

NHDES’s responses are included in Attachment I. 
New Hampshire Regional Haze SIP Revision Page 34 

4. ASSESSMENT OF BASELINE AND NATURAL VISIBILITY CONDITIONS 

Pursuant to 40 CFR 51.308(d)(2) of the Regional Haze Rule, states must determine baseline and 

natural visibility conditions for each Class I area within their jurisdictions. This information 

allows states to assess current levels of visibility degradation and provides a basis for setting 

reasonable progress goals toward restoration of natural visibility conditions in Class I areas. 

The effectiveness of any plan to reduce regional haze in Class I areas is dependent on the 

availability of reliable data. The Interagency Monitoring of Protected Visual Environments 

(IMPROVE) program was established in 1985 to provide the data necessary to support the 

creation of Federal and State implementation plans for the protection of visibility in Class I 

areas. IMPROVE has made it possible to assess current visibility conditions, track changes in 

visibility, and identify the chemical species and emission sources responsible for visibility 

impairment. In particular, IMPROVE data were used to calculate baseline and natural 

conditions for MANE-VU Class I Areas. 

The IMPROVE monitors listed in Table 4.1 provide data representative of Class I Areas in 

the MANE-VU region. 

Table 4.1: IMPROVE Monitors for MANE-VU Class I Areas 

IMPROVE Site / Location Class I Area(s) Served Latitude, 

Longitude State 

ACAD1 

Acadia National Park Acadia National Park 44.38, -68.26 Maine 

MOOS1 

Moosehorn Wilderness 

Moosehorn Wilderness; 

Roosevelt Campobello 

International Park 

45.13, -67.27 Maine 

GRGU1 

Great Gulf Wilderness 

Great Gulf Wilderness; 

Presidential Range - Dry 

River Wilderness 

44.31, -71.22 New Hampshire 

LYBR1 

Lye Brook Wilderness Lye Brook Wilderness 43.15, -73.13 Vermont 

BRIG1 

Brigantine National 

Wildlife Refuge 

Brigantine National 

Wildlife Refuge 39.47, -74.45 New Jersey 

 http://www.vista.circa.colostate.edu/views/; http://vista.cira.colostate.edu/improve/

4.1 Calculation Methodology 

In September 2003, EPA issued guidance for the calculation of natural background and 

baseline visibility conditions. The guidance provided a default method and described certain 

refinements that states might consider in order to tailor their estimates to any Class I areas not 

adequately represented by the default method. At that time, MANE-VU calculated natural 

visibility for each of the MANE-VU Class I Areas using the default method for the 20 percent 

best and 20 percent worst visibility days. MANE-VU also evaluated ways to refine the 

estimates. Potential refinements included 1) increasing the multiplier used to calculate 

impairment attributed to carbon, 2) adjusting the formula used to calculate the 20 percent best 
New Hampshire Regional Haze SIP Revision Page 35 

and worst visibility days, and 3) accounting for visibility impairment caused by sea salt at 

coastal sites. However, MANE-VU found that these refinements did not significantly 

improve the accuracy of the estimates, and MANE-VU states desired a consistent approach to 

visibility assessment. Therefore, default estimates were used with the understanding that this 

methodology would be reconsidered upon demonstrated improvements in the science. 

Once the technical analysis of visibility conditions was complete, MANE-VU provided an 

opportunity to comment to federal agencies and stakeholders. The proposed approach to 

visibility assessment was posted on the MANE-VU website on March 17, 2004, and a 

stakeholder briefing was held on the same day. Comments were received from the Electric 

Power Research Institute (EPRI), the Midwest Ozone Group (MOG), the Appalachian 

Mountain Club, the National Parks Conservation Association, the National Park Service, and 

the US Forest Service. 

Several comments supported the proposed approach in general; other comments were divided 

among four main topics: 1) the equation used to calculate visibility, 2) the statistical technique 

used to estimate the 20 percent best and worst visibility days, 3) the inclusion of 

transboundary effects and fires, and 4) the timing as to when new information should be 

included. All comments were reviewed and summarized by MANE-VU; and air directors 

were briefed on comments, proposed response options, and implications. Attachment J 

provides a compilation of comments received and a summary of stakeholders’ comments. 

MANE-VU’s position on natural background conditions was presented in a report issued in 

June 2004 (see Attachment K, “Natural Background Visibility Conditions: Considerations and 

Proposed Approach to the Calculation of Natural Background Visibility Conditions at 

MANE-VU Class I Areas,” June 10, 2004). The report stated, “Refinements to other aspects 

of the default method (e.g., refinements to the assumed distribution or treatment of Rayleigh 

extinction, inclusion of sea salt, and improved assumptions about the chemical composition of 

the organic fraction) may be warranted prior to submission of SIPs depending on the degree to 

which scientific consensus is formed around a specific approach...” 

In 2006, the IMPROVE Steering Committee adopted an alternative reconstructed extinction 

equation to revise certain aspects of the default method. The scientific basis for these 

revisions was well understood, and the Committee determined that the revisions improved the 

performance of the equation at reproducing observed visibility at Class I sites. 

In 2006, MANE-VU conducted an assessment of the default and alternative approaches for 

calculation of baseline and natural background conditions at MANE-VU Class I Areas. 

Based on that assessment, in December 2006, MANE-VU recommended adoption of the 

alternative reconstructed extinction equation for use in the regional haze SIPs. (See 

Attachment L, “Baseline and Natural Background Visibility Conditions: Considerations and 

Proposed Approach to the Calculation of Baseline and Natural Background Visibility 

Conditions at MANE-VU Class I Areas,” December 2006.) MANE-VU will continue to 

participate in further research efforts on this topic and will reconsider the calculation 

methodology as scientific understanding evolves. 

4.2 MANE-VU Baseline Visibility 

The IMPROVE program has calculated the 20 percent best and 20 percent worst baseline 

(2000-2004) and natural visibility conditions using the EPA-approved alternative method 

described above for each MANE-VU Class I Area. The data are posted on the Visibility 
New Hampshire Regional Haze SIP Revision Page 36 

Information Exchange Web System (VIEWS) operated by the regional planning organizations. 

The information can be accessed at http://vista.cira.colostate.edu/views/) and is summarized 

in Table 4.2 below. Displayed are the five-year average baseline visibility values for the 

period 2000-2004, natural visibility levels, and the difference between baseline and natural 

visibility values for each of the MANE-VU Class I Areas. The difference columns (best and 

worst) are of particular interest because they describe the magnitude of visibility impairment 

attributable to manmade emissions, which are the focus of the Regional Haze Rule. 

The five-year averages for 20 percent best and worst visibility were calculated in accordance 

with 40 CFR 51.308(d)(2), as detailed in NESCAUM’s Baseline and Natural Background 

document found in Attachment L. 

Table 4.2: Summary of Baseline Visibility and Natural Visibility Conditions for the 

20 Percent Best and 20 Percent Worst Visibility Days at MANE-VU Class I Areas 

2000-2004 Baseline 

(deciviews) 

Natural Conditions 

(deciviews) 

Difference 

(deciviews) Class I Area(s) 

Best 

20%

Worst 

20%

Best 

20%

Worst 

20%

Best 

20%

Worst 

20%

Acadia National Park 8.8 22.9 4.7 12.4 4.1 10.5 

Moosehorn Wilderness and 

Roosevelt Campobello International Park 9.2 21.7 5.0 12.0 4.1 9.7 

Great Gulf Wilderness and 

Presidential Range - Dry River Wilderness 10 7.7 22.8 3.7 12.0 3.9 10.8 

Lye Brook Wilderness 6.4 24.5 2.8 11.7 3.6 12.7 

Brigantine Wilderness 14.3 29.0 5.5 12.2 8.8 16.8 

 Source: VIEWS (http://vista.circa.colostate.edu/views/), prepared on 6/22/2007 

4.3 New Hampshire Class I Areas – Baseline Visibility 

As indicated in the table above, the 2001-2004 baseline visibility for the Great Gulf and 

Presidential Range - Dry River Wilderness Class I areas was 7.7 deciviews for the 20 percent 

best visibility days and 22.8 deciviews for the 20 percent worst visibility days. These are 

average values based on data collected at the Great Gulf (GRGU1) IMPROVE monitoring 

site. As described in Section 5, Monitoring Strategy of this SIP, New Hampshire accepts 

designation of this monitoring site as representative of the Great Gulf and Presidential Range - 

Dry River Wilderness Areas in accordance with 40 CFR 51.308(d)(2)(i). (The two wilderness 

areas are close enough together that a single monitor suffices.) 

Tables 4.3 and 4.4 list the baseline visibility for the 20 percent best and 20 percent worst 

visibility days for each year of the period 2000-2004, from which the valid four-year average 

values in Table 4.2 were calculated. The averages were determined in accordance with 40 

CFR 51.308(d)(2), as detailed in the NESCAUM Baseline and Natural Background document 

found in Attachment L of this SIP. The deciview visibility values for best and worst days 

were obtained from data included in Attachment L. 

 

10 Deciview values based on 4-year average for 2001-2004 (data collection in 2000 was for summer only).
New Hampshire Regional Haze SIP Revision Page 37 

Table 4.3: Baseline Visibility for the 20 Percent Best Days and 20 Percent Worst Days 

During 2000-2004 in New Hampshire Class I Areas 

Baseline Visibility (deciviews) 

Class I Area(s) Year 

20% Best 20% Worst 

Footnote

2000 7.4 20.0 11

2001 8.3 23.3 

2002 7.8 24.8 

2003 6.9 21.6 

2004 7.7 21.6 

Great Gulf Wilderness and 

Presidential Range - Dry River Wilderness 

 Average 7.7 22.8 12

Source: VIEWS (http://vista.circa.colostate.edu/views) 

4.4 New Hampshire Class I Areas – Natural Background 

Natural background refers to the visibility conditions that existed before human activities 

affected air quality in the region. Consistent with the stated visibility goals of the Clean Air 

Act, natural background is identified as the visibility target to be reached by 2064 in each Class 

I area. 

The Great Gulf and Presidential Range - Dry River Wilderness Class I areas have an estimated 

natural background visibility of 3.7 deciviews on the 20 percent best days and 12.0 deciviews 

on the 20 percent worst days. These best and worst 20 percent visibility values were 

calculated using the above-referenced EPA guidelines and approved alternative method 

described in NESCAUM’s Baseline and Natural Background document (Attachment L). 

 

11 Approximate values, based on summer-only observations.

12 Based on 4 valid years, 2001-2004
New Hampshire Regional Haze SIP Revision Page 38 

5. AIR MONITORING STRATEGY 

In the mid-1980’s, the Interagency Monitoring of Protected Visual Environments 

(IMPROVE) program was established to measure visibility impairment in mandatory Class I 

areas throughout the United States. The monitoring sites are operated and maintained through 

a formal cooperative relationship between the U.S. EPA, National Park Service, U.S. Fish and 

Wildlife Service, Bureau of Land Management, and U.S. Forest Service. In 1991, several 

additional organizations joined the effort: State and Territorial Air Pollution Program 

Administrators and the Association of Local Air Pollution Control Officials (which have since 

merged under the name National Association of Clean Air Agencies), Western States Air 

Resources Council, Mid-Atlantic Regional Air Management Association, and Northeast 

States for Coordinated Air Use Management. 

5.1 IMPROVE Program Objectives 

The IMPROVE program provides scientific documentation of the visual air quality of 

America’s wilderness areas and national parks. Many individuals and organizations – land 

managers; industry planners; scientists, including university researchers; public interest 

groups; and air quality regulators – use the data collected at IMPROVE sites to understand 

and protect the visual air quality resource in Class I areas. Major objectives of the IMPROVE 

program include the following: 

• Establish current visibility and aerosol conditions in mandatory Class I areas; 

• Identify chemical species and emission sources responsible for existing anthropogenic 

visibility impairment; 

• Document long-term trends for assessing progress towards the national visibility goals; 

• Provide regional haze monitoring for all visibility-protected federal Class I areas 

where practical, as required by EPA’s Regional Haze Rule. 

5.2 Monitoring Requirements 

EPA’s Regional Haze Rule establishes air monitoring requirements that affected states must 

meet to assess visibility impairment caused by regional haze in Class I areas. The following 

describes how New Hampshire is complying with specific sections of the rule: 

• 40 CFR 51.308(d)(4) requires a monitoring strategy for measuring, characterizing, and 

reporting regional haze / visibility impairment that is representative of all mandatory Class 

I areas. (Note that this monitoring strategy must be coordinated with the additional 

requirements of 40 CFR 51.305, which is not applicable to New Hampshire.) New 

Hampshire’s monitoring strategy relies on participation in the IMPROVE network and 

Visibility Information Exchange Web System (VIEWS). NHDES will evaluate the 

monitoring network periodically and make appropriate adjustments to it as necessary, 

consistent with the IMPROVE program objectives stated above. However, New 

Hampshire’s commitment to following this strategy and providing continuing 

assessments of progress toward national visibility goals at mandatory Class I Areas will 

remain contingent on sufficient federal funding in support of monitoring program 

requirements and associated databases. In the event that existing funding sources are 

eliminated or curtailed, New Hampshire will consult with the FLMs on the most 

practicable course of action. 
New Hampshire Regional Haze SIP Revision Page 39 

• 40 CFR 51.308(d)(4)(i) requires states to establish additional monitoring sites or 

equipment as needed to assess whether reasonable progress goals are being achieved 

toward visibility improvement at mandatory Class I areas. At this time, the current 

monitors are sufficient to make this assessment. New Hampshire’s commitment to 

maintain the current level of monitoring, and to expand monitoring or analysis should 

such action become necessary, will remain contingent on federal funding assistance. 

• 40 CFR 51.308(d)(4)(ii) requires each affected state to include procedures by which 

monitoring data and other information are used to determine the state’s contribution of 

emissions to visibility impairment at mandatory Class I areas both within and outside 

the state. New Hampshire’s estimated contributions are summarized in Subsection 2.1 

of this SIP and are documented in a detailed technical analysis prepared by 

NESCAUM entitled, “Contributions to Regional Haze in the Northeast and MidAtlantic United States,” August 2006 (Attachment B). The NESCAUM study used 

various tools and techniques to assess the contributions of individual states and 

regions to visibility degradation in Class I areas within and outside MANE-VU. 

• 40 CFR 51.308(d)(4)(iv) requires a state to submit visibility monitoring data annually 

for each Class I area and, if possible, to provide the data in electronic format. The Federal 

Land Manager submits the data, and the data are posted on the VIEWS website. 

• 40 CFR 51.308(d)(4)(v) requires a statewide inventory of emissions of pollutants that 

are reasonably anticipated to cause or contribute to visibility impairment in mandatory 

Class I areas within New Hampshire. Section 6, Emissions Inventory, addresses this 

requirement. 

• 40 CFR 51.308(d)(4)(vi) requires that SIPs provide other elements, including 

reporting, recordkeeping, and other measures necessary to assess and report on 

visibility. While NHDES believes the current IMPROVE network is sufficient to 

adequately measure and report progress toward the regional haze goals set for New 

Hampshire’s and other Class I areas, NHDES in the past has found additional 

monitoring information to be useful in assessing patterns of regional visibility and fine 

particle pollution. Examples of these data sources include: 

− The MANE-VU RAIN network, which provides continuous, speciated 

information on rural aerosol characteristics and visibility parameters; 

− The EPA CASTNET program, which has provided complementary rural fine 

particle speciation data at non-Class I sites; 

− The EPA Speciation Trends Network (STN), which provides speciated, urban 

fine particle data to help develop a comprehensive picture of local and 

regional sources; 

− State-operated rural and urban speciation sites using IMPROVE or Speciation 

Trends Network (STN) methods (the latter program comprising 54 monitoring 

stations located mainly in or near larger metropolitan areas); and 

− The Supersites program, which has undertaken special studies to expand knowledge 

of the processes that control fine particle formation and transport in the region. 

Assuming that these resources will continue to be available and that fiscal realities will 

allow, New Hampshire will continue using these and other data sources for the 

purposes of understanding visibility impairment and documenting progress toward 

national visibility goals for Class I areas under the Regional Haze Rule.
New Hampshire Regional Haze SIP Revision Page 40 

Acadia National Park IMPROVE Site

Created by Tom Downs, MEDEP 4/17/07

IMPROVE MONITOR LOCATION

ACADIA NATIONAL PARK

LEGEND

http://www.maine.gov/dep/air/meteorology/images/Acadia.jpg

Figure 5.1: Map of Acadia National Park Showing 

Location of IMPROVE Monitor

5.3 Monitoring Sites for MANE-VU Class I Areas 

IMPROVE monitoring sites have been established for each of the Class I areas in the region. 

The Great Gulf Wilderness and Presidential Range - Dry River Wilderness share a single 

monitoring site. Each of the other MANE-VU Class I Areas has its own monitoring site. 

5.3.1 Acadia National Park, Maine 

The IMPROVE monitor for Acadia National Park (ACAD1) is located at park headquarters, 

near Bar Harbor, Maine, at elevation 157 meters, latitude 44.38 ̊, and longitude -68.26 ̊. This 

monitor is operated and maintained by the National Park Service. New Hampshire considers the 

ACAD1 site as adequate for assessing reasonable progress toward visibility goals at Acadia 

National Park, and no additional monitoring sites or equipment are necessary at this time. 

 

Figure 5.2: Acadia National Park on Clear and Hazy Days 

 

http://www.hazecam.net/class1/acadia.html
New Hampshire Regional Haze SIP Revision Page 41 

5.3.2 Brigantine Wilderness, New Jersey 

The IMPROVE monitor for the Brigantine Wilderness (BRIG1) is located at the Edwin B. 

Forsythe National Wildlife Refuge Headquarters in Oceanville, New Jersey, at elevation 5 

meters, latitude 39.47 ̊, and longitude -74.45 ̊. This monitor is operated and maintained by the 

U.S. Fish & Wildlife Service. New Hampshire considers the BRIG1 site as adequate for 

assessing reasonable progress toward visibility goals at the Brigantine Wilderness, and no 

additional monitoring sites or equipment are necessary at this time. 

Figure 5.3: Map of Edwin B. Forsythe National Wildlife Refuge 

 

http://www.fws.gov/northeast/forsythe/MAP.htm

Figure 5.4: Brigantine Wilderness on Clear and Hazy Days 

 

 http://www.hazecam.net/class1/brigantine.html
New Hampshire Regional Haze SIP Revision Page 42 

IMPROVE MONITOR SITE

5.3.3 Great Gulf Wilderness, New Hampshire 

The IMPROVE monitor for the Great Gulf Wilderness (GRGU1) is located at Camp Dodge, 

in the mid-northern area of Greens Grant in the White Mountain National Forest. The 

monitor site lies just east and south of where Route 16 crosses the Greens Grant / Martins 

Location boundary, south of Gorham, New Hampshire, at elevation 454 meters, latitude 

44.31 ̊, and longitude of -71.22 ̊. This monitor, which also represents the Presidential Range - 

Dry River Wilderness (see 5.3.4 below), is operated and maintained by the U.S. Forest 

Service. New Hampshire considers the GRGU1 site as adequate for assessing reasonable 

progress toward visibility goals at the Great Gulf Wilderness, and no additional monitoring 

sites or equipment are necessary at this time. 

Figure 5.5: Map of Great Gulf and Presidential Range - Dry River Wilderness Areas 

Showing Location of IMPROVE Monitor 

http://www.maine.gov/dep/air/meteorology/images/NHclass1.jpg

Figure 5.6: Great Gulf Wilderness on Clear and Hazy Days 

 

http://www.wilderness.net
New Hampshire Regional Haze SIP Revision Page 43 

5.3.4 Presidential Range - Dry River Wilderness, New Hampshire 

The IMPROVE monitor for the Presidential Range - Dry River Wilderness is also the monitor 

for Great Gulf Wilderness (GRGU1), as described above. New Hampshire considers the 

GRGU1 site as adequate for assessing reasonable progress toward visibility goals at the 

Presidential Range - Dry River Wilderness, and no additional monitoring sites or equipment 

are necessary at this time. 

Figure 5.7: Upper Elevations of Presidential Range - Dry River Wilderness 

http://www.fs.fed.us/r9/forests/white_mountain/recreation/wilderness/

5.3.5 Lye Brook Wilderness, Vermont 

The IMPROVE monitor for the Lye Brook Wilderness (LYBR1) is located on Mount 

Equinox at the windmills in Manchester, Vermont, at elevation 1015 meters, latitude 43.15 ̊, 

and longitude of -73.13 ̊. The monitor does not lie within the wilderness area but is situated 

on a mountain peak across the valley to the west of the wilderness area. The IMPROVE site 

and the Lye Brook Wilderness are at similar elevations. The monitor is operated and 

maintained by the U.S. Forest Service. New Hampshire considers the LYBR1 site as adequate 

for assessing reasonable progress toward visibility goals at the Lye Brook Wilderness, and no 

additional monitoring sites or equipment are necessary at this time. 

Figure 5.8: Location of Lye Brook Wilderness IMPROVE Monitor 

http://www.wilderness.net/index.cfm?fuse=NWPS&sec=stateView&state=NH&map=menhvt

IMPROVE MONITOR 

SITE
New Hampshire Regional Haze SIP Revision Page 44 

Figure 5.9: Aerial View of Lye Brook Wilderness IMPROVE Monitoring Site 

sources: GoogleEarth; and Paul Wishinski, Vermont DEC, Air Pollution Control Division

Figure 5.10: Lye Brook Wilderness on Clear and Hazy Days 

 

 http://www.hazecam.net/class1/lye.html

5.3.6 Moosehorn Wilderness, Maine 

The IMPROVE monitor for the Moosehorn Wilderness (MOOS1) is located near McConvey 

Road, about one mile northeast of the National Wildlife Refuge Baring (ME) Unit 

Headquarters, at elevation 78 meters, latitude 45.13 ̊, and longitude -67.27 ̊. This monitor 

also represents the Roosevelt Campobello International Park in New Brunswick, Canada. The 

monitor is operated and maintained by the U.S. Fish & Wildlife Service. New Hampshire 

considers the MOOS1 site as adequate for assessing reasonable progress toward visibility 

goals at the Moosehorn Wilderness, and no additional monitoring sites or equipment are 

necessary at this time. 

IMPROVE MONITOR SITE 

APPROX. WILDERNESS 

BOUNDARY 
New Hampshire Regional Haze SIP Revision Page 45 

Figure 5.11: Map of the Baring and Edmunds Divisions of the Moosehorn National 

Wildlife Refuge Showing Location of IMPROVE Monitor 

Figure 5.12: Moosehorn Wilderness on Clear and Hazy Days 

 

 http://www.hazecam.net/moosehorn.html
New Hampshire Regional Haze SIP Revision Page 46 

5.3.7 Roosevelt Campobello International Park, New Brunswick, Canada 

The IMPROVE monitor for Roosevelt Campobello International Park is also the monitor for 

the Moosehorn Wilderness (MOOS1), as described above. New Hampshire considers the 

MOOS1 site as adequate for assessing reasonable progress toward visibility goals at Roosevelt 

Campobello International Park, and no additional monitoring sites or equipment are necessary 

at this time. 

Figure 5.13: Map of Roosevelt Campobello International Park 

 http://www.maine.gov/dep/air/meteorology/images/rcip.jpg

Figure 5.14: Roosevelt Campobello International Park on Clear and Hazy Days 

source: Chessie Johnson 
New Hampshire Regional Haze SIP Revision Page 47 

6. EMISSIONS INVENTORY 

40 CFR 51.308(d)(4)(v) of EPA’s Regional Haze Rule requires a statewide emissions 

inventory of pollutants that are reasonably anticipated to cause or contribute to visibility 

impairment in any mandatory Class I area. The inventory must include emissions for a 

baseline year, future (projected) year, and the most recent year for which high-quality data are 

available. New Hampshire’s baseline year, 2002, is also the most recent year for which data 

are available. The pollutants inventoried by New Hampshire include nitrogen oxides (NOX), 

sulfur dioxides (SO2), volatile organic compounds (VOCs), fine particles (particulate matter 

less than 2.5 micrometers in diameter, or PM2.5), coarse particles (particulate matter less than 

10 micrometers in diameter, or PM10), and ammonia (NH3). The following source categories 

were included in New Hampshire’s emissions inventory: stationary point sources, stationary 

area sources, on-road mobile sources, non-road mobile sources, and biogenic sources. These 

emissions categories are discussed further in Subsection 7.3, Model Platforms. 

6.1 Baseline and Future-Year Emissions Inventories for Modeling 

40 CFR 51.308(d) (3) (iii) of EPA’s Regional Haze Rule requires the State of New Hampshire 

to identify the baseline emissions inventory on which emission control strategies are founded. 

The baseline inventory is intended to be used for assessing progress in making emission 

reductions. In accordance with EPA’s guidance memorandum “2002 Base Year Emission 

Inventory SIP Planning: 8-hour Ozone, PM2.5, and Regional Haze Programs,” November 18, 

2002, all of the MANE-VU states are using 2002 as the baseline year for regional haze. 

Previously, on July 5, 2006, New Hampshire submitted its 2002 baseline inventory to EPA to 

meet its implementation planning obligations under the 8-hour ozone program. It should be 

noted, however, that emissions inventories are not static documents, but are constantly revised 

and updated to reflect the input of better emissions estimates as they become available. With 

contractor assistance, MARAMA developed a 2002 baseline modeling inventory using the 

inventories that New Hampshire and other states submitted to EPA to meet their SIP 

obligations and the requirements of the Consolidated Emissions Reporting Rule (CERR). To 

create the 2002 baseline inventory for modeling, MARAMA and its contractor qualityassured and augmented states’ inventories and generated the necessary input files for the 

emissions processing model. As described in Part 6.1.1 below, work on this effort underwent 

several versions. Therefore, the 2002 baseline emissions summarized in this document may 

differ slightly from New Hampshire’s original 2002 baseline inventory submittal. 

Future-year inventories for 2009, 2012, and 2018 were projected from the 2002 base year. 

These future-year emissions inventories include emissions growth due to projected increases in 

economic activity as well as emissions reductions expected from the implementation of control 

measures. While the 2009 and 2012 emissions projections were originally developed in support 

of New Hampshire’s and other states’ ozone attainment demonstrations, the inventory for 2018 

(the year targeted by the Regional Haze Rule) was developed for the specific purposes of regional 

haze SIP planning. Therefore, although the 2009 and 2012 projected inventories are mentioned in 

subsequent sections, only the 2002 baseline inventory and 2018 projected inventory are described 

below in Subsection 6.4, Summary of Emissions Inventories. 
New Hampshire Regional Haze SIP Revision Page 48 

Accurate baseline and future-year emissions inventories are crucial to the analyses required 

for the regional haze SIP process. These emissions inventories were used to drive the air 

quality modeling simulations undertaken to assess the visibility improvements that would 

result from possible control measures. Air quality modeling was also used to perform a 

pollution apportionment, which evaluates the contribution to visibility impairment by 

geographic region and emission source sector. 

To be compatible with the air quality modeling simulations, the baseline and future-year 

emissions inventories were processed with the Sparse Matrix Operator Kernel Emissions 

(SMOKE) emissions pre-processor for subsequent input into the CMAQ and REMSAD air 

quality models described in Subsection 7.3. Further description of the base and future-year 

emissions inventories is provided below. 

6.1.1 Baseline Inventory (2002) 

The starting point for the 2002 baseline emissions inventory was the 2002 inventory 

submittals that were made to EPA by state and local agencies as part of the Consolidated 

Emissions Reporting Rule (CERR). With contractor assistance (E.H. Pechan & Associates, 

Inc.,), MANE-VU then coordinated and quality-assured the 2002 inventory data, and prepared 

it for input into the SMOKE emissions model. The 2002 emissions from non-MANE-VU areas 

within the modeling domain were obtained from other Regional Planning Organizations for 

their corresponding areas. These Regional Planning Organizations included the Visibility 

Improvement State and Tribal Association of the Southeast (VISTAS), the Midwest Regional 

Planning Organization (MRPO), and the Central Regional Air Planning Association 

(CenRAP). 

The 2002 baseline inventory went through several iterations. Work on Version 1 of the 2002 

MANE-VU inventory began in April 2004, and the final inventory and SMOKE input files 

were completed during January 2005. Work on Version 2 (covering the period of April 

through September 2005) involved incorporating revisions requested by some MANE-VU 

state/local agencies on the point, area, and on-road categories. Work on Version 3 (covering 

the period from December 2005 through April 2006) included additional revisions to the 

point, area, and on-road categories as requested by some states. Thus, the Version 3 inventory 

for point, area, and on-road sources was built upon Versions 1 and 2. This work also included 

development of the biogenic inventory. In Version 3, the non-road inventory was completely 

redone because of changes that EPA made to the NONROAD2005 non-road mobile 

emissions model. 

Version 3 of the MANE-VU 2002 baseline emissions inventory was used in the regional air 

quality modeling simulations. Further description of the data sources, methods, and results 

for this version of the 2002 baseline inventory is presented in E.H. Pechan & Associates, Inc., 

“Technical Support Document for 2002 MANE-VU SIP Modeling Inventories, Version 3, 

November 20, 2006, also known as the Baseline Emissions Report (Attachment M). 

Emissions inventory data files are available on the MARAMA website at: 

http://www.marama.org/visibility/EI_Projects/index.html. 
New Hampshire Regional Haze SIP Revision Page 49 

6.1.2 Future-Year Emissions Inventories 

Future-year emissions inventories are provided in MACTEC’s technical support document, 

“Development of Emissions Projections for 2009, 2012, and 2018 for NonEGU Point, Area, 

and Nonroad Sources in the MANE-VU Region,” Final Report, February 28, 2007, also 

known as the Emission Projections Report (Attachment N). This document describes the data 

sources, methods, and modeling results for three future years, five emission source sectors, 

two emission control scenarios, seven pollutants, and eleven states plus the District of 

Columbia. The following summarizes the basic framework of the future-year inventories that 

were developed: 

• Projection years: 2009, 2012, and 2018; 

• Emission source sectors: point-source electric generating units (EGUs), point-source 

non-electric generating units (non-EGUs), area sources, non-road mobile sources, and 

on-road mobile sources. 

• Emission control scenarios: 

- A combined on-the-books/on-the-way (OTB/OTW) control strategy accounting 

for emission control regulations already in place as of June 15, 2005, as well as 

some emission control regulations that are not yet finalized but are expected to 

achieve additional emission reductions by 2009; and

- A beyond-on-the-way (BOTW) scenario to account for Phase 1 implementation 

of a low-sulfur fuel strategy for non-EGU sources and controls from potential 

new regulations that may be necessary to meet attainment and other regional 

air quality goals, mainly for ozone. 

- An updated scenario (sometimes referred to as “best-and-final”) to account for 

additional potentially reasonable control measures. For the MANE-VU region, 

these include: SO2 reductions at a set of 167 EGUs which were identified as 

contributing to visibility impairment at northeast Class I areas; Phase 2 

implementation of a low-sulfur fuel strategy for non-EGU sources; and 

implementation of a Best Available Retrofit Technology (BART) strategy for 

BART-eligible sources not controlled under other programs. 

(Note: Refer to Section 11, Long-Term Strategy, for detailed descriptions of specific 

control strategies.) 

• Pollutants: ammonia, carbon monoxide (CO), oxides of nitrogen (NOX), sulfur 

dioxide (SO2), volatile organic compounds (VOCs), fine particulate matter (PM2.5, 

sum of filterable and condensable components), and coarse particulate matter (PM10, 

sum of filterable and condensable components). 

• States: Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, 

New Jersey, New York, Pennsylvania, Rhode Island, and Vermont, plus the District of 

Columbia (all members of the MANE-VU region). 

6.2 Emission Processor Selection and Configuration 

The Sparse Matrix Operator Kernel Emissions (SMOKE) model was used to format the 

emissions inventories for use with the air quality models that are discussed in Subsection 7.3. 

SMOKE is primarily an emissions processing system, as opposed to a true emissions 

inventory preparation system, in which emissions estimates are simulated from “first 

principles.” This means that, with the exception of mobile and biogenic sources, SMOKE’s 
New Hampshire Regional Haze SIP Revision Page 50 

purpose is to provide an efficient, modern tool for converting emissions inventory data into 

the formatted emissions files required for a photochemical air quality model. The SMOKE 

emissions processing that was performed in support of the air quality modeling for regional 

haze is described further in Subsection 7.2. 

6.3 Inventories for Specific Source Categories 

There are five emission source classifications in the emissions inventory, as follows: 

• Stationary point, 

• Stationary area, 

• Non-road mobile, 

• On-road mobile, and 

• Biogenic. 

Stationary point sources are large sources that emit greater than a specified tonnage per year, 

as described below. Stationary area sources are those sources whose individual emissions 

are relatively small (i.e., dry cleaners, service stations, agricultural areas, fires, etc.), but 

because of the large number of these sources, their collective emissions are significant. Nonroad mobile sources are equipment that can move but do not use the roadways (i.e., lawn 

mowers, construction equipment, railroad locomotives, marine vessels, aircraft, etc.). Onroad mobile sources include automobiles, trucks, buses, and motorcycles that use the 

roadway system. Biogenic sources include the off-gassing of natural sources such as trees, 

crops, grasses, and natural decay of plants. 

The subsections below give an overview of each of the source categories and the methods that 

were used to develop their corresponding baseline and future-year emissions estimates. All 

emissions data were prepared for modeling in accordance with EPA guidance. 

6.3.1 Stationary Point Sources 

Point source emissions are emissions from large individual sources. Generally, point sources 

have permits to operate, and their emissions are individually calculated based on sourcespecific parameters. Emissions estimates for point sources are usually made on a regular 

basis, and the largest point sources are inventoried annually. Sources with emissions greater 

than or equal to 100 tons per year (tpy) of a criteria pollutant, 10 tpy of a single hazardous air 

pollutant (HAP), or 25 tpy for total HAPs are considered to be major sources. Emissions 

from smaller point sources are also calculated individually but less frequently. Point sources 

are further subdivided into EGUs and non-EGUs. 

6.3.1.1 Electric Generating Units (EGUs) 

The base-year inventory for EGU sources were based on 2002 continuous emissions 

monitoring (CEM) data reported to EPA in compliance with the Acid Rain Program or 2002 

state emissions inventory data. The CEM data provided actual hourly emission values used in 

the modeling of SO2 and NOX emissions from these large sources. See Chapter II, Section 

A.2.a.i of the “Technical Support Document for 2002 MANE-VU SIP Modeling Inventories,” 

Version 3 (Attachment M) for a discussion of the quality assurance steps performed on the 

CEM data that were included in the 2002 baseline modeling inventory. Emissions of other 

pollutants (e.g., VOCs, CO, NH3, and PM2.5) were provided by the states in most instances. 
New Hampshire Regional Haze SIP Revision Page 51 

Future-year inventories of EGU emissions for 2009, 2012 and 2018 were developed using 

ICF International’s Integrated Planning Model (IPM®) to forecast growth in electric demand 

and replacement of older, less efficient and more polluting power plants with newer, more 

efficient and cleaner units. This effort was undertaken by an inter-RPO workgroup. While 

the output of the IPM model predicts that a certain number of older plants will be replaced by 

newer units to meet future electric growth and state-specific NOX and SO2 caps, New 

Hampshire did not directly rely on the closure of any particular plant in establishing the 2018 

inventory upon which the reasonable progress goals were set. 

The IPM model results do not provide a reliable basis upon which to predict EGU closures. 

Specific plant closures in the New Hampshire are addressed in Section 10, Reasonable 

Progress Goals. Preliminary modeling was performed with unchanged IPM 2.1.9 model 

results. However, prior to the most recent modeling, future-year EGU inventories were 

adjusted as follows: 

• First, IPM predictions were reviewed by permitting and enforcement staff of the 

MANE-VU states. In many cases, staff believed that the IPM shutdown predictions 

were unlikely to occur. In particular, many oil-fired EGUs in urban areas were 

predicted to be shut down by IPM. Similar source information was solicited from 

states in both VISTAS and MRPO. As a result of this model validation, the IPM 

modeling output was adjusted before the most recent modeling to reflect staff 

knowledge of specific plant status in MANE-VU, VISTAS, and MRPO states. Where 

expected EGU operating status was contrary to what was predicted by IPM modeling, 

the future-year emissions inventory was adjusted to reflect the expected operation of 

those plants. 

• Second, as a result of inter- and intra-RPO consultations, MANE-VU agreed to pursue 

certain emission control measures (see Section 3, Regional Planning). For EGUs, the 

agreed-upon approach was to pursue emission reductions from each of the top 167 

stacks located in MANE-VU, MRPO, and VISTAS that contributed the most to 

visibility impairment at any Class I area in the MANE-VU region. This approach, 

known as the targeted EGU strategy, is further described in Section 11 of this SIP. 

6.3.1.2 Non-EGU Point Sources 

The primary basis for the 2002 baseline non-EGU emissions inventory was data reported by 

state and local agencies for the CERR. As described in Part 6.1.1, MANE-VU’s contractor, 

E.H. Pechan & Associates (Pechan), coordinated the quality assurance of the inventory and 

prepared the necessary files for input into the SMOKE emissions model. Further information 

on the preparation of the MANE-VU 2002 baseline point source modeling emissions inventory 

can be found in Chapter II of the Baseline Emissions Report (Attachment M). 

Projected non-EGU point source emissions were developed for the MANE-VU region by 

MACTEC Federal Programs, Inc. under contract to Mid-Atlantic Regional Air Management 

Association (MARAMA). The specific methodologies that were employed are described in 

Section 2 of the Emission Projections Report (Attachment N). MACTEC used state-supplied 

growth factor data, where available, to project future-year emissions. Where state-supplied 

data were not available, MACTEC used EPA’s Economic Growth and Analysis System, 

Version 5.0 (EGAS 5.0) to develop applicable growth factors for the non-EGU component. 

MACTEC also incorporated the applicable federal and state emissions control programs to 

account for the expected emissions reductions that will take place under the OTB/OTW and 

BOTW scenarios. 
New Hampshire Regional Haze SIP Revision Page 52 

6.3.2 Stationary Area Sources 

Stationary area sources include sources whose individual emissions are relatively small but, 

because the number of sources is large, their collective emissions are significant. Some 

examples include dry cleaners, service stations, and residential heating. For each area source, 

emissions are estimated by multiplying an appropriate emission factor by some known indicator 

of collective activity, such as fuel usage, number of households, or population. 

The area source emissions inventory submittals made for the CERR became the basis for the 

area source portion of the 2002 baseline inventory. MANE-VU’s consultant, Pechan, 

prepared the area source modeling inventory using the CERR submittals as a starting point. 

Pechan quality-assured the inventory and augmented it with additional data, including 

MANE-VU-sponsored inventories for categories such as residential wood combustion and 

open burning. Details on the preparation of MANE-VU’s 2002 baseline area source emissions 

inventory can be found in Chapter III of the Baseline Emissions Report (Attachment M). 

In similar fashion, MACTEC prepared future-year area source emission projections for the 

MANE-VU region. The specific methodologies employed are described in Section 3 of the 

Emission Projections Report (Attachment N). MACTEC applied growth factors to the 2002 

baseline area source inventory using state-supplied data, where available, or using the EGAS 

5.0 growth factor model. MACTEC also accounted for the appropriate control strategies in 

the future year projections. 

6.3.3 Non-Road Mobile Sources 

Non-road mobile sources are equipment that can move but do not typically use the roadways, 

such as construction equipment, aircraft, railroad locomotives, and lawn & garden equipment. 

For the majority of non-road mobile sources, emissions are estimated using the EPA’s 

NONROAD model. Aircraft, railroad locomotives, and commercial marine vessels are not 

included in the NONROAD model; and their emissions are estimated using applicable 

references and methodologies. Again, Pechan prepared the 2002 baseline modeling inventory 

using the state and local CERR submittals as a starting point. Details on the preparation of 

the 2002 baseline non-road inventory are described in Chapter IV of the Baseline Emissions 

Report (Attachment M). 

Future-year non-road mobile source emissions were projected for the MANE-VU region by 

MACTEC. The methodologies employed are discussed in Section 4 of the Emission 

Projections Report (Attachment N). MACTEC used EPA’s NONROAD2005 non-road 

vehicle emissions model as contained in EPA’s National Mobile Inventory Model (NMIM). 

Since the calendar year is an explicit input into the NONROAD model, future-year emissions 

for non-road vehicles could be calculated directly for the applicable projection years. For the 

non-road vehicle types that are not included in the NONROAD model (i.e. aircraft, 

locomotives, and commercial marine vessels), MACTEC used the 2002 baseline inventory 

and the projected inventories that EPA developed for these categories for the Clean Air 

Interstate Rule (CAIR) to develop emission ratios and subsequent combined growth and 

control factors. Since the future years for the CAIR projections did not precisely match those 

required for the purposes of ozone, particulate matter, and regional haze analyses (i.e. 2009, 

2012, and 2018), MACTEC used linear interpolation to develop factors for the required future 

years. 
New Hampshire Regional Haze SIP Revision Page 53 

6.3.4 On-Road Mobile Sources 

The on-road emissions source category consists of vehicles that are meant to travel on public 

roadways, including cars, trucks, buses, and motorcycles. The basic methodology used for 

on-road mobile source calculations is to multiply vehicle-miles-traveled (VMT) by emission 

factors developed using the EPA’s MOBILE6 motor vehicle emission factors model. The onroad mobile category requires that SMOKE model inputs be prepared instead of the 

SMOKE/IDA emissions data format that is required by the other emission source categories. 

Therefore, for the 2002 baseline inventory, Pechan prepared the necessary VMT and 

MOBILE6 inputs in SMOKE format. 

Projected on-road mobile source inventories were developed by NESCAUM for the MANEVU region for ozone, particulate matter, and regional haze SIP purposes. As with the other 

emissions source categories, projected on-road mobile inventories were developed for 

calendar years 2009, 2012, and 2018. As part of this effort, MANE-VU member states were 

asked to provide VMT data and MOBILE6 model inputs for the applicable calendar years. 

Using the inputs supplied by the MANE-VU member states, NESCAUM compiled and 

generated the required SMOKE/MOBILE6 emissions model inputs. Further details regarding 

the on-road mobile source projections can be found in NESCAUM’s “Technical 

Memorandum, Development of MANE-VU Mobile Source Projection Inventories for 

SMOKE/MOBILE6 Application,” June 2006 (Attachment O). 

6.3.5 Biogenic Emission Sources 

For the purposes of the 2002 baseline modeling emissions inventory, biogenic emissions were 

calculated for the modeling domain by the New York State Department of Environmental 

Conservation (NYSDEC). NYSDEC used the Biogenic Emissions Inventory System (BEIS) 

Version 3.12 as contained within the SMOKE emissions processing model. Biogenic 

emissions estimates were made for CO, nitrous oxide (NO) and VOCs. Further details about 

the biogenic emissions processing can be found in NYSDEC’s technical support document 

TSD-1c, “Emission Processing for the Revised 2002 OTC Regional and Urban 12 km Base 

Case Simulations,” September 19, 2006 (Appendix P), and in Chapter VI of Pechan’s 

“Technical Support Document for 2002 MANE-VU SIP Modeling Inventories,” Version 3, 

November 20, 2006 (Appendix M). Biogenic emissions were assumed to remain constant for 

the future-years analysis – a reasonable approximation reflecting the expectation that most of 

the region will remain heavily forested for the duration of the planning period. 

6.4 Summary of Emissions Inventories 

New Hampshire’s baseline and future-year emissions inventories are summarized in Tables 

6.1 through 6.4, below. All values are reported in tons per year (tpy). The three different 

emissions inventories for 2018 represent the emission control scenarios described under the 

third bullet in Part 6.1.2 of this section. 
New Hampshire Regional Haze SIP Revision Page 54 

Table 6.1: 2002 Emissions Inventory Summary for New Hampshire (tpy) 

Emission Sector VOC NOX PM2.5 PM10 NH3 SO2

Point 1,599 9,759 2,938 3,332 74 46,560

Area 65,370 10,960 17,532 43,328 2,158 7,072

Mobile 16,762 33,283 562 814 1,447 777

Non-Road Mobile 22,376 9,912 965 1,058 9 891

Biogenic 141,894 482 -- -- -- --

TOTAL 248,001 64,396 21,997 48,532 3,688 55,300

Table 6.2: 2018 OTB/OTW Emissions Inventory Summary for New Hampshire (tpy) 

Emission Sector VOC NOX PM2.5 PM10 NH3 SO2

Point 1,367 4,524 3,208 3,397 184 10,583

Area 64,368 12,430 18,316 49,801 2,789 7,421

Mobile 6,564 7,671 263 282 1,916 537

Non-Road Mobile 15,003 6,344 634 697 11 246

Biogenic 141,894 482 -- -- -- --

TOTAL 229,196 31,451 22,421 54,177 4,900 18,787

Table 6.3: 2018 BOTW Emissions Inventory Summary for New Hampshire (tpy) 

Emission Sector VOC NOX PM2.5 PM10 NH3 SO2

Point 1,292 4,258 3,208 3,397 184 10,568

Area 62,650 12,180 18,087 49,544 2,789 3,118

Mobile 6,564 7,671 263 282 1,916 537

Non-Road Mobile 15,003 6,344 634 698 12 246

Biogenic 141,894 482 -- -- -- --

TOTAL 227,403 30,935 22,192 53,921 4,901 14,469

Table 6.4: 2018 Most Recent Emissions Inventory Summary for New Hampshire (tpy) 

Emission Sector VOC NOX PM2.5 PM10 NH3 SO2

Point 1,291 4,258 3,208 3,397 184 11,849

Area 62,649 12,180 14,993 21,775 2,789 972

Mobile 6,564 7,671 263 282 1,916 537

Non-Road Mobile 15,003 6,344 634 697 11 246

Biogenic 141,894 482 -- -- -- --

TOTAL 227,401 30,935 19,098 26,15113 4,900 13,604

 

13 An adjustment factor was applied during the processing of emissions data to restate fugitive particulate matter emissions. 

Grid models have been found to overestimate fugitive dust impacts when compared with ambient samples; therefore, an 

adjustment is typically applied to account for the removal of particles by vegetation and other terrain features. The 

summary emissions for PM10 in Table 6.4 reflect this adjustment. Comparable adjustments were not made to PM10 values 

listed in Tables 6.1 through 6.3.
New Hampshire Regional Haze SIP Revision Page 55 

7. AIR QUALITY MODELING 

Air quality modeling to assess regional haze has been performed cooperatively between New 

Hampshire and its regional planning organization, MANE-VU, with major modeling being 

conducted by NESCAUM and screening modeling being conducted by NHDES. These 

modeling efforts include emissions processing, meteorological input analysis, and chemical 

transport modeling to perform regional air quality simulations for calendar year 2002 and 

several future periods, including the primary target date, 2018, for this SIP. Modeling was 

conducted in order to assess contributions from upwind areas as well as New Hampshire’s 

contribution to Class I areas in downwind states. Further, the modeling evaluated visibility 

benefits of specific control measures being considered to achieve reasonable progress goals 

and establish a long-term emissions management strategy for MANE-VU Class I Areas. 

Several modeling tools were utilized for these analyses: 

• The Fifth-Generation Pennsylvania State University/National Center for Atmospheric 

Research (NCAR) Mesoscale Model (MM5) was used to derive the required 

meteorological inputs for the air quality simulations.

• The Sparse Matrix Operator Kernel Emissions (SMOKE) emissions modeling system 

was used to process and format the emissions inventories for input into the air quality 

models.

• The Community Mesoscale Air Quality model (CMAQ) was used for the primary SIP 

modeling.

• The Regional Model for Aerosols and Deposition (REMSAD) was used during 

contribution apportionment. 

• The California Puff Model (CALPUFF) was used to assess the contribution of 

individual states’ emissions to sulfate levels at selected Class I receptor sites. 

• The CALGRID photochemical grid model was used to perform screening-level 

analyses of emission control strategies. 

Each of these tools has been evaluated and found to perform adequately. The SIP-pertinent 

modeling underwent full performance testing, and the results were found to meet the 

specifications of EPA modeling guidance. 

For more details on the regional haze modeling, refer to the NESCAUM report, “MANE-VU 

Modeling for Reasonable Progress Goals: Model Performance Evaluation, Pollution 

Apportionment, and Control Measure Benefits,” February 7, 2008 (Attachment G). The 

detailed modeling approach for the most recent 2018 projections can be found in 

NESCAUM’s “2018 Visibility Projections,” May 13, 2008 (Attachment Q). 

7.1 Meteorology 

The meteorological inputs for the air quality simulations were developed by the University of 

Maryland (UMD) using the MM5 meteorological modeling system. Meteorological inputs 

were generated for 2002 to correspond with the baseline emissions inventory and analysis 

year. The MM5 simulations were performed on a nested grid (Figure 7.1). The modeling 

domain is composed of a 36-km, 145 x 102 continental grid and a nested 12-km, 172 x 172 
New Hampshire Regional Haze SIP Revision Page 56 

grid encompassing the eastern United States and parts of Canada. In cooperation with the 

New York State Department of Conservation (NYSDEC), an assessment was made for the 

period of May-September 2002 to compare the MM5 predictions with observations from a 

variety of data sources, including: 

• Surface observations from the National Weather Service and the Clean Air Status and 

Trends Network (CASTNET), 

• Wind-profiler measurements from the Cooperative Agency Profilers (CAP) network, 

• Satellite cloud image data from the UMD Department of Atmospheric and Oceanic 

Science, and 

• Precipitation data from the Earth Observing Laboratory at NCAR. 

Further details regarding the MM5 meteorological processing and the modeling domain can 

be found in NYSDEC’s technical support document TSD-1a, “Meteorological Modeling 

Using Penn State/NCAR 5th Generation Mesoscale Model (MM5),” February 1, 2006 

(Attachment R), and in the NESCAUM report, “MANE-VU Modeling for Reasonable 

Progress Goals, Model Performance Evaluation, Pollution Apportionment, and Control 

Measure Benefits,” November 27, 2007 (Attachment G). 

Figure 7.1: Modeling Domains Used in MANE-VU Air Quality 

Modeling Studies with CMAQ

Note: Outer (blue) domain is 36-km grid. Inner (red) domain is 12-km grid. Gridlines are shown at 180-km intervals 

(5×5 36-km cells and 15×5 12-km cells). 
New Hampshire Regional Haze SIP Revision Page 57 

7.2 Data Preparations 

Emissions data were prepared for input into the CMAQ and REMSAD air quality models 

using the SMOKE emissions modeling system. SMOKE supports point, area, mobile (both 

on-road and non-road), and biogenic emissions. The SMOKE emissions modeling system 

uses flexible processing to apply chemical speciation as well as temporal and spatial allocation 

to the emissions inventories. SMOKE incorporates the Biogenic Emission Inventory System 

(BEIS) and EPA’s MOBILE6 motor vehicle emission factor model to process biogenic and 

on-road mobile emissions, respectively. Vector-matrix multiplication is used during the final 

processing step to merge the various emissions components into a single model-ready 

emissions file. Examples of processed emissions outputs are shown in Figure 7.2. 

Further details on the SMOKE processing conducted in support of the air quality simulations 

is provided in NYSDEC’s technical support document TSD-1c, “Emission Processing for the 

Revised 2002 OTC Regional and Urban 12 km Base Case Simulations,” September 19, 2006 

(Attachment P), and in NESCAUM’s report, “MANE-VU Modeling for Reasonable Progress 

Goals, Model Performance Evaluation, Pollution Apportionment, and Control Measure 

Benefits,” February 7, 2008 (Attachment G). Additional details on the emissions inventory 

preparation can be found in Section 6 of this report. 

7.3 Model Platforms 

Two regional-scale air quality models, CMAQ and REMSAD, were used for the air quality 

simulations that directly supported the regional haze SIP effort. CMAQ was developed by 

EPA and was used to perform the primary SIP-related modeling. The CMAQ modeling 

simulations were also an important tool for the 8-hour ozone SIP process. REMSAD was 

developed by ICF Consulting/Systems Applications International with support from EPA. 

REMSAD was used by NESCAUM to perform a source apportionment (contribution 

assessment) analysis. All of the air quality simulations that were used in the SIP efforts were 

performed on the 12-km eastern modeling domain shown in Figure 7.1, above. 

NYSDEC performed an extensive model performance analysis to evaluate CMAQ model 

predictions against observations of ozone, PM2.5, and other pollutant species. This model 

performance evaluation is described in detail in NYSDEC’s technical support document TSD1e, “CMAQ Model Performance and Assessment, 8-Hr OTC Ozone Modeling,” February 23, 

2006 (Attachment S). A model performance evaluation for PM2.5 species, aerosol extinction 

coefficient, and the haze index is provided in NESCAUM’s report, “MANE-VU Modeling for 

Reasonable Progress Goals, Model Performance Evaluation, Pollution Apportionment, and 

Control Measure Benefits,” February 7, 2008 (Attachment G). 
New Hampshire Regional Haze SIP Revision Page 58 

Figure 7.2: Examples of Processed Model-Ready Emissions: (a) SO2 from Point, 

(b) NO2 from Area, (c) NO2 from On-Road, (d) NO2 from Non-Road, 

(e) Isoprene from Biogenic, and (f) SO2 from all Source Categories 
New Hampshire Regional Haze SIP Revision Page 59 

7.3.1 CMAQ 

The CMAQ air quality simulations were performed cooperatively among five modeling 

centers: NYSDEC, the New Jersey Department of Environmental Protection (NJDEP) in 

association with Rutgers University, the Virginia Department of Environmental Quality 

(VADEQ), UMD, and NESCAUM. NYSDEC also performed an annual 2002 CMAQ 

simulation on the 36-km domain shown in Figure 7.1; this simulation was used to derive the 

boundary conditions for the inner 12-km eastern modeling domain. Boundary conditions for 

the 36-km simulations were obtained from a run of the GEOS-Chem (Goddard Earth 

Observing System) global chemistry transport model that was performed by researchers at 

Harvard University. The technical options that were used in performing the CMAQ 

simulations are described in detail in NYSDEC’s technical support document TSD-1d, “8hr 

Ozone Modeling Using the SMOKE/CMAQ System,” February 1, 2006 (Attachment T). 

Further technical details regarding the CMAQ model and its execution are also provided in 

NESCAUM’s report, “MANE-VU Modeling for Reasonable Progress Goals, Model 

Performance Evaluation, Pollution Apportionment, and Control Measure Benefits,” February 

7, 2008 (Attachment G). 

7.3.2 REMSAD 

The REMSAD modeling simulations were used to produce the contribution assessment 

required by the Regional Haze Rule. REMSAD’s species tagging capability makes it an 

important tool for this purpose. The REMSAD model simulations were performed on the 

same 12-km eastern modeling domain as shown in Figure 7.1. NESCAUM’s report, 

“MANE-VU Modeling for Reasonable Progress Goals, Model Performance Evaluation, 

Pollution Apportionment, and Control Measure Benefits,” February 7, 2008 (Attachment G), 

further describes the REMSAD model and its application to the regional haze SIP efforts. 

7.3.3 CALGRID 

In addition to the SIP-quality modeling platforms described above, another modeling platform 

was developed for use as a screening tool to evaluate additional control strategies or to 

perform sensitivity analyses. The CALGRID model was selected as the basis for this 

platform. CALGRID is a grid-based photochemical air quality model that is designed to be 

run in a Windows environment. In order to make the CALGRID model the best possible tool 

to supplement the SIP-quality CMAQ and REMSAD modeling, the current version of the 

CALGRID platform was set up to be run with the same set of inputs as the SIP-quality 

models. The CALGRID air quality simulations were run on the same 12-km eastern 

modeling domain that was used for CMAQ and REMSAD. This model’s performance was 

comparable to the performance of the already evaluated CMAQ and REMSAD models and 

was thus determined to perform adequately. 

Conversion utilities were developed to reformat the meteorological inputs, the boundary 

conditions, and the emissions data for use with the CALGRID modeling platform. Premerged SMOKE emissions files were obtained from the modeling centers and reformatted for 

input into Emission Processor version 6 (EMSPROC6), the emissions pre-processor for the 

CALGRID modeling system. EMSPROC6 allows the CALGRID user to adjust emissions 

temporally, geographically, and by emissions category for control strategy analysis. The premerged SMOKE files that were obtained from the modeling centers were broken down into 

the biogenic, point, area, non-road, and on-road emissions categories. These files by 
New Hampshire Regional Haze SIP Revision Page 60 

component were then converted for use with EMSPROC6, thus giving CALGRID users the 

flexibility to analyze a wide variety of emissions control strategies. Additional information 

on the CALGRID modeling platform can be found in NHDES’ “Modeling Protocol for the 

OTC CALGRID Screening-Level Modeling Platform for the Evaluation of Ozone,” May 23, 

2007 (Attachment U). 

7.3.4 CALPUFF 

CALPUFF is a non-steady-state Lagrangian puff model that simulates the dispersion, 

transport, and chemical transformation of atmospheric pollutants. Two parallel CALPUFF 

modeling platforms were developed by the Vermont Department of Environmental 

Conservation (VTDEC) and the Maryland Department of the Environment (MDE). The 

VTDEC CALPUFF modeling platform utilized meteorological observation data from the 

National Weather Service (NWS) to drive the CALMET meteorological model. The MDE 

platform utilized the same MM5 meteorological inputs that were used in the modeling done in 

support of the ozone and regional haze SIPs. These two platforms were run in parallel to 

evaluate individual states’ contributions to sulfate levels at Northeast and Mid-Atlantic Class I 

areas. The CALPUFF modeling effort is described in detail in NESCAUM’s report, 

“Contributions to Regional Haze in the Northeast and Mid-Atlantic United States,” August 

2006 (Attachment B). 

References

Center for Environmental Modeling for Policy Development, University of North Carolina at 

Chapel Hill. Sparse Matrix Operator Kernel Emissions (SMOKE) Model. 

http://www.smoke-model.org/index.cfm. 

Community Modeling and Analysis System (CMAS) Center, University of North Carolina at 

Chapel Hill. Community Multiscale Air Quality (CMAQ) Modeling System. 

http://www.cmaq-model.org. 

ICF International/Systems Applications International. Regional Modeling System for 

Aerosols and Deposition (REMSAD). http://remsad.saintl.com. 

Pennsylvania State University/National Center for Atmospheric Research. Mesoscale Model 

(MM5). http://www.mmm.ucar.edu/mm5/mm5-home.html. 

Scire, J.S., Strimaitis, D.G., and Yamartino, R.J. A User’s Guide for the CALPUFF 

Dispersion Model (Version 5). January 2000. 
New Hampshire Regional Haze SIP Revision Page 61 

#

#

#

#

#

#

#

Contributions to PM2.5 Extinction at 7 Sites

20% Worst Visibility Days (2000-2004)

Soil

Sea Salt

OC

EC

Nitrate

Sulfate

0

20

40

60

80

100

120

140

160

180

100

120

140

160

180

Extinction (Mm-1)

Dolly Sods

Shenandoah

Brigantine

Lye Brook

Great Gulf

Acadia

Moosehorn

8. UNDERSTANDING THE SOURCES OF HAZE-CAUSING POLLUTANTS 

This section explores the origins, quantities, and roles of visibility-impairing pollutants 

emitted in the eastern United States and Canada that contribute significantly to regional haze at 

MANE-VU’s mandatory Class I areas. 

8.1 Fine-Particle Pollutants 

The pollutants primarily responsible for fine particle formation, and thus contributing to 

regional haze, include SO2, NOX, VOCs, NH3, PM10, and PM2.5. The MANE-VU Contribution 

Assessment (Attachment B), finalized in August 2006, reflects a conceptual model in which 

sulfate emerges as the most important single constituent of haze-forming fine particle 

pollution and the principle cause of visibility impairment across the Northeast region. Sulfate 

alone accounts for anywhere from 1⁄2 to 2⁄3 of total fine particle mass on the 20 percent haziest 

days at MANE-VU Class I Areas. This translates to about 2⁄3 to 3⁄4 of visibility extinction on 

those days. 

Visibility extinction is a measure of the ability of particles to scatter and absorb light. 

Extinction is expressed in units of inverse mega-meters (Mm-1). Figure 8.1 shows the 

dominance of sulfate in visibility extinction calculated from 2000-2004 baseline data for 

seven Northeast Class I Areas. 

Figure 8.1: Contributions to PM2.5 Extinction at Seven Class I Areas 
New Hampshire Regional Haze SIP Revision Page 62 

Given the dominant role of sulfate in the formation of regional haze in the Northeast and MidAtlantic Regions, MANE-VU concluded that an effective emissions management approach 

would rely heavily on broad-based regional SO2 control measures in the eastern United States. 

The focus on SO2 as MANE-VU’s first priority makes sense not only because of its dominant 

role in regional haze but also because its emission sources are well understood. Moreover, the 

control measures needed for SO2 emission reductions are readily available, cost-effective, and 

could be implemented quickly. On the basis of the scientific evidence, it is apparent that the 

bulk of haze-causing pollution can be eliminated by pursuing SO2 emission controls. 

Organic carbon was found to be the next largest contributor to haze after sulfate. In 

comparison with sulfate, the emission sources of organic carbon, are diverse, variable, more 

diffuse, and less well understood; and the problem of controlling organic carbon emissions is 

exceedingly complex. For these reasons, MANE-VU considered organic carbon to be the 

subject of possible future control measures but not a specific target pollutant in the initial 

strategy to mitigate regional haze. 

8.2 Contributing States and Regions 

The MANE-VU Contribution Assessment used various modeling techniques, air quality data 

analysis, and emissions inventory analysis to identify source categories and states that 

contribute to visibility impairment in MANE-VU and nearby Class I areas. Based on 

estimates obtained by several evaluation methods, emissions that originated within MANEVU states contributed approximately one-fourth of the total sulfate aerosol recorded at New 

Hampshire’s Class I areas in 2002. More specifically, four different estimation methods 

yielded the following contribution ranges: MANE-VU, 21-28 percent; MRPO, 20-27 percent; 

VISTAS, 12-18 percent; CenRAP, 2-5 percent; Canada, 7-19 percent; and all other regions, 

23-24 percent (see Tables 8.1, 8.2, 8.3, and 8.5 of the Contribution Assessment for details). 

It should be pointed out that the listed values for VISTAS, CenRAP, and Canada understate 

the actually percentage contributions from those regions because they count only emissions 

originating within the modeling domain (see Figure 7.1). Actual contributions, especially in 

the case of CenRAP, would be considerably higher than stated. Differences between actual 

and stated values are lumped into “Other.” 

These findings highlight the importance of emissions from outside MANE-VU to visibility 

impairment inside the region. Note that, although there is some variation in the contribution 

estimates among the different assessment methods employed, there is a general consistency of 

results from one method to another. 

Table 8.1 displays the results of just one of the methods used (the REMSAD model) to assess 

state-by-state and regional contributions to annual sulfate impacts in nine Class I areas. 
New Hampshire Regional Haze SIP Revision Page 63 

Table 8.1: Percent Contributions (Mass Basis) of Individual MANE-VU States and Other 

Regions to Total Annual Sulfate Impacts at Northeast Class I Areas (REMSAD) 

Mandatory Class I Area 

Contributing 

State or Region Acadia 

ME 

Brigantine 

NJ 

Dolly Sods 

WV 

Great Gulf &

Presidential 

Range - Dry 

River, NH 

Lye Brook 

VT 

Moosehorn

& Roosevelt 

Campobello

ME 

Shenandoah 

VA 

Connecticut 0.76 0.53 0.04 0.48 0.55 0.56 0.08

Delaware 0.96 3.20 0.30 0.63 0.93 0.71 0.61

District of Columbia 0.01 0.04 0.01 0.01 0.02 0.01 0.04

Maine 6.54 0.16 0.01 2.33 0.31 8.01 0.02

Maryland 2.20 4.98 2.39 1.92 2.66 1.60 4.84

Massachusetts 10.11 2.73 0.18 3.11 2.45 6.78 0.35

New Hampshire 2.25 0.60 0.04 3.95 1.68 1.74 0.08

New Jersey 1.40 4.04 0.27 0.89 1.44 1.03 0.48

New York 4.74 5.57 1.32 5.68 9.00 3.83 2.03

Pennsylvania 6.81 12.84 10.23 8.30 11.72 5.53 12.05

Rhode Island 0.28 0.10 0.01 0.11 0.06 0.19 0.01

Vermont 0.13 0.06 0.00 0.41 0.95 0.09 0.01

MANE-VU 36.17 34.83 14.81 27.83 31.78 30.08 20.59

MRPO 11.98 18.16 30.26 20.10 21.48 10.40 26.84

VISTAS 8.49 21.99 36.75 12.04 13.65 6.69 33.86

CenRAP 0.88 1.12 1.58 1.65 1.67 0.82 1.48

Canada 8.69 7.11 3.90 14.84 12.43 7.85 4.75

Other 33.79 16.78 12.70 23.54 18.99 44.17 12.48

Note: Indicated percent contributions from, VISTAS, CenRAP, and Canada apply only to those portions lying within the modeling 

domain (see Figure 7.1). Actual contributions, especially from CenRAP, would be higher than stated. 

 Source: Table 8-1 of the MANE-VU Contribution Assessment 

Figures 8.2 and 8.3, also borrowed from the Contribution Assessment, illustrate another 

method for identifying and ranking states’ contributions to sulfate at Class I areas using the 

2002 data. This simple technique for deducing the relative impact of emissions from specific 

point sources on specific receptor sites involves calculating the ratio of annual emissions (Q) 

to source-receptor distance (d). The ratio (Q/d) is then multiplied by a factor to account for 

the frequency effect of prevailing winds. The use of this technique is explained in the 

Contribution Assessment (see pages 4-12 to 4-17 of Attachment B).
New Hampshire Regional Haze SIP Revision Page 64 

Figure 8.2: Ranked Sulfate Contributions to Northeast Class I Receptors Based on 

Q/d Method (Mass Basis), by Location of Origin 

0.00

0.10

0.20

0.30

0.40

0.50

0.60

0.70

CanadaPAOHINNYMIWVILGAMAKYNCVAMDALTNTXMOFLWINJMESCNHDEKSMNIACTOKMSLANEVTARRIDC

Annual Average Contribution (μg/m3 SO4)

Acadia

Great Gulf

Lye Brook

Moosehorn

Figure 8.3: Ranked Sulfate Contributions to Mid-Atlantic Class I Receptors Based on 

Q/d Method (Mass Basis), by Location of Origin 

0.00

0.10

0.20

0.30

0.40

0.50

0.60

0.70

OHPAWVNCCanadaMDINVAKYGANYILTNMIALNJTXFLDESCMOWIMAMSKSMNOKIALACTNHARNEMEDCRIVT

Annual Average Contribution (

μg/m3 SO4)

Brigantine

Dolly Sods

Shenandoah

The first of the Q/d plots covers the four northern Class I areas with IMPROVE monitoring in 

MANE-VU. The second covers one Class I area in the southern part of MANE-VU and two 

neighboring Class I areas in the VISTAS region. Observe, again, the comparative importance 

of emissions from Canada and from states outside the MANE-VU region. 
New Hampshire Regional Haze SIP Revision Page 65 

The ranking of emission contributions to visibility impairment in the MANE-VU Class I 

Areas by methods such as these has direct relevance to the consultation process described 

previously in Section 3, Regional Planning and Consultation. Using results from the 

REMSAD model, MANE-VU applied the following three criteria to identify states and 

regions for the purposes of consultation on regional haze: 

1. Any state/region that contributed 0.1 μg/m3

 sulfate or greater on the 20 percent worst 

visibility days in the base year (2002), 

2. Any state/region that contributed at least 2 percent of total sulfate observed on the 20 

percent worst visibility days in 2002, and 

3. Any state/region among the top ten contributors on the 20 percent worst visibility days 

in 2002. 

For the purposes of deciding how broadly to consult, the MANE-VU States settled on 

the second of the three criteria: any state/region that contributed at least 2 percent of 

total sulfate observed on the 20 percent worst visibility days in 2002. 

In Figures 8.4 through 8.10, below, states and regions meeting the three listed criteria are 

identified graphically for seven Class I areas: Shenandoah and Dolly Sods are Class I areas in 

the VISTAS region that are impacted by emissions from MANE-VU states; the other five 

Class I areas are in MANE-VU. Note that the IMPROVE monitor at Great Gulf also 

represents the Presidential Range - Dry River Wilderness, and the IMPROVE monitor at 

Moosehorn also represents Roosevelt Campobello International Park. 

Each figure has the following components: 

• On the left is a single bar graph of the IMPROVE-monitored PM2.5 mass concentration 

(μg/m3

) by constituent species for the baseline years 2000-2004. The yellow, bottom 

portion of the bar represents the measured sulfate concentration. 

• The middle component of each figure provides a bar graph of the 2002 total sulfate 

contribution of each state or region as estimated by REMSAD. 

• Finally, the right segment contains three maps showing which states meet the criteria 

described above. 

Connecticut, Rhode Island, Vermont, and the District of Columbia were not identified as 

being among the political or regional units contributing at least 2 percent of sulfate at any of 

the seven Class I areas. However, as participants in MANE-VU, those entities have agreed to 

pursue adoption of regional control measures aimed at visibility improvement on the haziest 

days and prevention of visibility degradation on the clearest days. 
New Hampshire Regional Haze SIP Revision Page 66 

Figure 8.4: Modeled 2002 Contributions to Sulfate at Great Gulf, by State 

Great Gulf 

20% Worst Days

0

2

4

6

8

10

12

Great Gulf

Sulfate Nitrate EC OC Sea Salt Soil

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Great Gulf

CA NA DA

CENRA P

SE_BC

W_BC

N_BC

DC

MS

V T

RI

ME

CT

DE

A L

NJ

WI

SC

TN

V A

IL

MD

GA

NH

KY

NC

MI

WV

IN

MA

NY

PA

OH IMPROVE mass 00-04 REMSAD 2002 Contribution to Sulfate Threshold options

0.1 μg/m3 Sulfate

2 % of Sulfate

Top 10 States

μg/m3

#

#

#

Figure 8.5: Modeled 2002 Contributions to Sulfate at Brigantine, by State 

Brigantine

20% Worst Days

0

5

10

15

20

25

Brigantine

Sulfate Nitrate EC OC Sea Salt Soil

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Brigantine

CA NA DA

CENRA P

SE_BC

W_BC

N_BC

V T

RI

ME

DC

MS

CT

NH

MA

WI

NY

A L

IL

SC

MI

KY

TN

IN

NJ

DE

GA

WV

MD

V A

NC

OH

PA

0.1 μg/m3 Sulfate

2 % of Sulfate

Top 10 States

IMPROVE mass 00-04 REMSAD 2002 Contribution to Sulfate Threshold options

μg/m3

#

#

#
New Hampshire Regional Haze SIP Revision Page 67 

Figure 8.6: Modeled 2002 Contributions to Sulfate at Lye Brook, by State 

Lye Brook 

20% Worst Days

0

2

4

6

8

10

12

14

16

Lye Brook

Sulfate Nitrate EC OC Sea Salt Soil

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Lye Brook

CANA DA

CENRAP

SE_BC

W_BC

N_BC

DC

RI

MS

ME

CT

V T

NH

WI

DE

SC

A L

NJ

IL

MA

TN

GA

MI

KY

V A

IN

NC

MD

WV

NY

OH

PA

0.1 μg/m3 Sulfate

2 % of Sulfate

Top 10 States

IMPROVE mass 00-04 REMSAD 2002 Contribution to Sulfate Threshold options

μg/m3

#

#

#

Figure 8.7: Modeled 2002 Contributions to Sulfate at Acadia, by State 

Acadia 

20% Worst Days

0

2

4

6

8

10

12

Acadia

Sulfate Nitrate EC OC Sea Salt Soil

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

A cadia

CA NA DA

CENRA P

SE_BC

W_BC

N_BC

DC

MS

VT

RI

AL

DE

WI

CT

TN

GA

SC

NJ

VA

IL

KY

MD

MI

NC

NH

IN

WV

ME

NY

PA

OH

MA

0.1 μg/m3 Sulfate

2 % of Sulfate

Top 10 States

IMPROVE mass 00-04 REMSAD 2002 Contribution to Sulfate Threshold options

μg/m3

#

#

#
New Hampshire Regional Haze SIP Revision Page 68 

Figure 8.8: Modeled 2002 Contributions to Sulfate at Moosehorn, by State 

Moosehorn 

20% Worst Days

0

2

4

6

8

10

12

Moosehorn

Sulfate Nitrate EC OC Sea Salt Soil

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Moosehorn

CA NA DA

CENRAP

SE_BC

W_BC

N_BC

MS

DC

VT

RI

AL

CT

WI

DE

SC

TN

GA

NJ

VA

MI

IL

KY

NH

MD

NC

IN

WV

ME

NY

OH

PA

MA

0.1 μg/m3 Sulfate

2 % of Sulfate

Top 10 States

IMPROVE mass 00-04 REMSAD 2002 Contribution to Sulfate Threshold options

μg/m3

#

#

#

Figure 8.9: Modeled 2002 Contributions to Sulfate at Shenandoah, by State 

Shenandoah 

20% Worst Days

0

2

4

6

8

10

12

14

16

18

20

Shenandoah

Sulfate Nitrate EC OC Sea Salt Soil

IMPROVE mass 00-04

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Shenandoah

CANADA

CENRAP

SE_BC

W_BC

N_BC

VT

RI

ME

DC

MS

NH

CT

MA

NJ

DE

SC

WI

AL

TN

IL

GA

NY

NC

MI

MD

VA

KY

IN

WV

PA

OH Threshold options

0.1 μg/m3 Sulfate

2 % of Sulfate

Top 10 States

REMSAD 2002 Contribution to Sulfate

#

#

#

μg/m3
New Hampshire Regional Haze SIP Revision Page 69 

Figure 8.10: Modeled 2002 Contributions to Sulfate at Dolly Sods, by State 

Dolly Sods 

20% Worst Days

0

2

4

6

8

10

12

14

16

18

20

Dolly Sods

Sulfate Nitrate EC OC Sea Salt Soil

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Dolly Sods

CA NA DA

CENRA P

SE_BC

W_BC

N_BC

RI

V T

ME

DC

CT

NH

MA

MS

DE

NJ

WI

NY

MD

SC

MI

IL

V A

A L

TN

NC

GA

IN

KY

PA

WV

OH

0.1 μg/m3 Sulfate

2 % of Sulfate

Top 10 States

IMPROVE mass 00-04 REMSAD 2002 Contribution to Sulfate Threshold options

#

#

#

μg/m3

8.3 Emission Sources and Characteristics 

As previously mentioned, the major pollutants responsible for regional haze are SO2, NOX, 

VOCs, NH3, PM10, and PM2.5. The following is a description of the sources (e.g., point, area, 

and mobile) and characteristics of pollutant emissions contributing to haze in the eastern 

United States. Emissions data and graphics presented for the purposes of this section are 

taken from the MANE-VU 2002 Baseline Emissions Inventory, Version 2.0 (note that the 

more recent MANE-VU 2002 Baseline Emissions Inventory, Version 3.0, released in April 

2006, has superseded Version 2.0 for modeling purposes). Although the emissions inventory 

database also includes carbon monoxide (CO), this primary pollutant is not considered here 

because it does not contribute to regional haze. 

8.3.1 Sulfur Dioxide (SO2) 

SO2 is the primary precursor pollutant for sulfate particles. Sulfate particles commonly 

account for more than 50 percent of particle-related light extinction at northeastern Class I 

areas on the clearest days and for as much as 80 percent or more on the haziest days. Hence, 

SO2 emissions are an obvious target of opportunity for reducing regional haze in the eastern 

United States. Combustion of coal and, to a lesser extent, of certain petroleum products 

accounts for most anthropogenic SO2 emissions. In fact, in 1998, a single source category – 

coal-burning power plants – was responsible for two-thirds of total SO2 emissions nationwide 

(NESCAUM, 2001a). 

Figure 8.11 shows SO2 emissions in the MANE-VU states as extracted from the 2002 

MANE-VU inventory (MARAMA, 2005). Most states in the region showed declines in 

annual SO2 emissions through 2002 compared with those from previous inventories. 
New Hampshire Regional Haze SIP Revision Page 70 

This decline can be attributed in part to implementation of Phase 2 of the Acid Rain Program, 

which in 2000 further reduced allowable emissions below Phase 1 levels and extended emission 

limits to a greater number of power plants. 

Figure 8.11: Annual Sulfur Dioxide (SO2) Emissions, by State 

0.0

0.2

0.4

0.6

0.8

1.0

1.2

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

million t/y

MV 2002 v.3

The bar graph in Figure 8.12 displays the percentage contributions from different emission 

source categories to annual SO2 emissions in the MANE-VU states in 2002. The chart shows 

that point sources – consisting mainly of stationary combustion sources for generating 

electricity, industrial power, and heat – dominate SO2 emissions in the region. Smaller 

stationary combustion sources, referred to collectively as area sources, are another important 

source category in the MANE-VU states. These include smaller industrial, commercial, and 

institutional boilers as well as residential heating sources. By contrast, on-road and non-road 

mobile sources make a relatively minor contribution to overall SO2 emissions in the region 

(NESCAUM, 2001a). 
New Hampshire Regional Haze SIP Revision Page 71 

Figure 8.12: 2002 Sulfur Dioxide (SO2) Emissions, by State 

Bar Graph = Percentage Fractions of Four Source Categories 

Line Graph = Total Annual Emissions (106 tpy) 

0%

25%

50%

75%

100%

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

0.0

0.2

0.4

0.6

0.8

1.0

1.2

million t/y

AREA NONROAD ONROAD POINT Emission

8.3.2 Volatile Organic Compounds (VOC) 

Existing emissions inventories generally refer to volatile organic compounds (VOCs) as 

hydrocarbons whose volatility and reactivity in the atmosphere make them particularly important 

to ozone formation. From a regional haze perspective, there is less concern with the volatile 

organic gases emitted directly to the atmosphere than with the secondary organic aerosols 

(SOAs) that VOCs form after undergoing condensation and oxidation. Thus the VOC 

inventory category is of interest primarily because of the organic carbon component of PM2.5. 

After sulfate, organic carbon generally accounts for the next largest share of fine particle mass 

and particle-related light extinction at northeastern Class I sites. The term organic carbon 

encompasses a large number and variety of chemical compounds that may be emitted directly 

from emission sources as components of primary PM or that may form in the atmosphere as 

secondary pollutants. The organic carbon present at Class I areas includes a mix of species, 

including pollutants originating from anthropogenic (i.e., manmade) sources as well as 

biogenic hydrocarbons emitted by vegetation. Recent efforts to cut back on manmade organic 

carbon emissions have been undertaken mainly for the purpose of reducing summertime 

ozone formation in urban centers. Future efforts to make further reductions in organic carbon 

emissions may be driven by programs that address fine particles and visibility. 

Understanding the source regions and transport dynamics for organic carbon in MANE-VU 

and nearby Class I areas is likely to be more complex than for sulfate. This complexity 

derives from the large number and diversity of organic carbon species, the wide variation in 

their transport characteristics, and the fact that a given species may undergo numerous 

complex chemical reactions in the atmosphere. Thus, the organic carbon contribution to 
New Hampshire Regional Haze SIP Revision Page 72 

visibility impairment at most Class I areas in the region is likely to include manmade 

pollution from nearby sources, manmade pollution transported from a distance, and biogenic 

emissions – especially terpenes from coniferous forests. 

As shown in Figure 8.13, the VOC inventory is dominated by mobile (on- and off-road) 

sources and area sources. Mobile sources of VOCs include evaporative emissions from 

transportation fuels and exhaust emissions from gasoline passenger vehicles and dieselpowered, heavy-duty vehicles. VOC emissions may also originate from a variety of area 

sources (including those that use organic solvents, architectural coatings, and dry cleaning 

fluids) as well as from some point sources (e.g., industrial facilities and petroleum refineries). 

Biogenic VOCs (not included in Figure 8.13) may play an important role within the rural 

settings typical of Class I areas. The oxidation of hydrocarbon molecules containing seven or 

more carbon atoms is generally the most significant pathway for the formation of lightscattering organic aerosol particles (Odum et al., 1997). Smaller reactive hydrocarbons that 

may contribute significantly to urban smog (ozone) are less likely to play a role in organic 

aerosol formation, although it is noted that high ozone levels can have an indirect effect on 

visibility by promoting the oxidation of other available hydrocarbons, including biogenic 

emissions (NESCAUM, 2001a). In short, further work is needed to characterize the organic 

carbon contribution to regional haze in the MANE-VU states and to develop emissions 

inventories that will be of greater value for visibility planning purposes. As pointed out in 

Subsection 8.1, above, organic carbon could be the subject of future control measures to 

mitigate regional haze but is not the focus of initial planning. 

Figure 8.13: 2002 Volatile Organic Carbon (VOC) Emissions, by State 

Bar Graph = Percentage Fractions of Four Source Categories 

Line Graph = Total Annual Emissions (106 tpy) 

0%

25%

50%

75%

100%

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

0.0

0.2

0.4

0.6

0.8

1.0

1.2

million t/y

AREA NONROAD ONROAD POINT Emission
New Hampshire Regional Haze SIP Revision Page 73 

8.3.3 Oxides of Nitrogen (NOX) 

NOX emissions contribute to visibility impairment in the eastern U.S. by forming lightscattering nitrate particles. Nitrate generally accounts for a substantially smaller fraction of 

fine particle mass and related light extinction than sulfate and organic carbon at northeastern 

Class I areas. Notably, nitrate may play a more important role in urban settings and in the 

wintertime. In addition, NOX may have an indirect effect on summertime visibility by virtue 

of its role in the formation of ozone, which in turn promotes the formation of secondary 

organic aerosols (NESCAUM, 2001a). 

Since 1980, nationwide emissions of NOX from all sources have shown little change. 

Emissions increased by 2 percent between 1989 and 1998 (EPA, 2000a). To a large extent, 

increases from the industrial and transportation sectors have been offset by emission 

reductions from power plant combustion sources implemented during the same time period. 

Figure 8.14 shows NOX emissions in 2002 for each state in the MANE-VU region. In the 

several years just prior to 2002, most MANE-VU states experienced declining NOX

emissions. 

Mobile sources and power plants generally dominate state and national NOX emissions 

inventories. Nationally, power plants account for more than one-quarter of all NOX

emissions, amounting to over six million tons annually. The electric sector plays an even 

larger role in parts of the industrial Midwest, where power plants contribute significantly to 

NOX emissions. By contrast, mobile sources dominate the NOX inventories for more 

urbanized MANE-VU states, as shown in Figure 8.15. In these states, on-road mobile sources 

(i.e., highway vehicles) represent the largest NOX source category. Emissions from non-road 

(i.e., off-highway) mobile sources, primarily diesel-powered engines, also make up a substantial 

fraction of the inventory. 

Figure 8.14: Annual Nitrogen Oxide (NOX) Emissions, by State 

0.0

0.2

0.4

0.6

0.8

1.0

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

million t/y

MV 2002 v.3
New Hampshire Regional Haze SIP Revision Page 74 

Figure 8.15: 2002 Nitrogen Oxide (NOX) Emissions, by State 

Bar Graph = Percentage Fractions of Four Source Categories 

Line Graph = Total Annual Emissions (106 tpy) 

0%

25%

50%

75%

100%

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

0.0

0.3

0.6

0.9

million t/y

AREA NONROAD ONROAD POINT Emission

8.3.4 Primary Particulate Matter (PM10 and PM2.5) 

Directly emitted, or “primary,” particles (as distinct from secondary particles that form in the 

atmosphere through chemical reactions involving precursor pollutants such as SO2 and NOX) 

can also contribute to regional haze. For regulatory purposes, a distinction is made between 

particulate matter (PM) with an aerodynamic diameter less than or equal to 10 micrometers 

(PM10) and smaller particles with an aerodynamic diameter less than or equal to 2.5 

micrometers (PM2.5). 

Figures 8.16 and 8.17 show PM10 and PM2.5 emissions, respectively, for the MANE-VU states 

as reported for the 2002 base year. Most states showed a steady decline in annual PM10

emissions in the years leading up to the 2002 inventory. By contrast, emission trends for 

primary PM2.5 were more variable. 

Crustal sources are significant contributors of primary PM emissions. This category includes 

fugitive dust emissions from construction activities, paved and unpaved roads, and 

agricultural tilling. Typically, monitors estimate PM10 emissions from these types of sources by 

measuring the horizontal flux of particulate mass at a fixed downwind sampling location 

within perhaps 10 meters of a road or field. Comparisons between estimated emission rates 

for fine particles using these types of measurement techniques and observed concentrations of 

crustal matter in the ambient air at downwind receptor sites suggest that physical or chemical 

processes remove a significant fraction of crustal material relatively quickly. As a result, it 

rarely entrains into layers of the atmosphere where it can be transported to downwind receptor 

locations. Because of this discrepancy between estimated emissions and observed ambient 

concentrations, modelers typically reduce estimates of total PM2.5 emissions from all crustal 
New Hampshire Regional Haze SIP Revision Page 75 

sources by applying a factor of 0.15 to 0.25 to the total PM2.5 emissions before including them 

in modeling analyses. 

Figure 8.16: Primary Coarse Particle (PM10) Emissions, by State 

0.0

0.1

0.2

0.3

0.4

0.5

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

million t/y

MV 2002 v.3

Figure 8.17: Primary Fine Particle (PM2.5) Emissions, by State

0.00

0.02

0.04

0.06

0.08

0.10

0.12

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

million t/y

MV 2002 v.3
New Hampshire Regional Haze SIP Revision Page 76 

From a regional haze perspective, crustal material generally does not play a major role. On 

the 20 percent best visibility days during the baseline period (2000-2004), crustal PM 

accounted for six to eleven percent of particle-related light extinction at MANE-VU Class I 

sites. On the 20 percent worst visibility days, however, crustal material generally plays a 

much smaller role, ranging from two to three percent visibility extinction, than other hazeforming pollutants. Moreover, the crustal fraction includes materials of natural origin, such as 

soil or sea salt, that is not targeted under the Regional Haze Rule. Of course, the crustal 

fraction can be influenced by construction, agricultural practices, and road maintenance 

(including wintertime salting). Thus, to the extent that these types of activities are found to 

affect visibility at Northeastern Class I areas, control measures to reduce coarse and fine 

particulate matter deriving from crustal material may prove beneficial and are within the 

purview of EPA or state agencies. 

Experience from the western United States, where the crustal component has played a more 

significant role in overall particulate levels, may be applicable to the extent that it is relevant 

to the situation in the eastern states. In addition, a few areas in the Northeast, such as New 

Haven, Connecticut, and Presque Isle, Maine, have had some experience with the control of 

dust and road-salt stemming from regulatory obligations related to their past non-attainment 

status with respect to the NAAQS for PM10. 

Current emissions inventories for the entire MANE-VU area indicate that residential wood 

combustion represents 25 percent of primary fine particle emissions in the region. This 

finding implies that rural sources can play an important role as well as contributions from the 

region’s many populous urban areas. An important consideration in this regard is that 

residential wood combustion occurs mainly in the winter months, while managed or 

prescribed burning activities occur largely in other seasons. The latter category includes 

agricultural field-burning, prescribed burning of forested areas, and miscellaneous burning 

activities such as construction waste burning. Particulate emissions from many of these 

sources can be managed by limiting allowed burning activities to times when favorable 

meteorological conditions can efficiently disperse the emissions. 

Although data are currently lacking, New Hampshire and other MANE-VU states are concerned 

about the growing use of residential wood stoves by homeowners seeking alternatives to 

petroleum-based fuels for home heating. Recent, localized problems with smoke emissions 

from outdoor wood boilers (wood-fired hydronic heaters) prompted the New Hampshire 

legislature, in August 2008, to pass a law that tightens requirements on the sale, installation, 

and use of these devices. NHDES will keep close watch on smoke emissions from the 

residential sector to determine whether additional control measures on this source category 

may be necessary in the next few years. 

Figure 8.18, taken from Appendix B of the MANE-VU Contribution Assessment, represents 

the results of source apportionment and trajectory analyses on wood smoke in the area 

extending from the Gulf States to the Northeast. The green-highlighted portion of the map 

depicts the wood smoke source region in the Northeast states. The stars on the map represent 

air monitor sites (including those at several Class I areas) whose data sets were determined to 

be useful to the modeling analysis. Although New Hampshire’s Great Gulf Wilderness was 

not specifically analyzed, it is believed that the green portion of the map adequately 

characterizes the wood smoke source region in the vicinity of this Class I area. 
New Hampshire Regional Haze SIP Revision Page 77 

Figure 8.18: Wood Smoke Source Regional Aggregations

Northeast: ACAD, PMRC, LYBR 

Mid-Atlantic: WASH, SHEN, JARI 

Southeast: GRSM, MACA 

MANE-VU’s “Technical Support Document on Agricultural and Forestry Smoke 

Management in the MANE-VU Region,” September 1, 2006 (Attachment V), concluded that 

fire from land management activities was not a major contributor to regional haze in MANEVU Class I Areas, and that the majority of emissions from fires were from residential wood 

combustion. 

Figures 8.19 and 8.20 show that area sources dominate primary PM emissions. (EPA’s 

National Emissions Inventory categorizes residential wood combustion and some other 

combustion sources as area sources.) The relative contribution of point sources is larger in the 

primary PM2.5 inventory than in the primary PM10 inventory because the crustal component of 

particulate emissions (consisting mainly of larger, or coarse, particles) contributes more to 

overall PM10 levels than to PM2.5 levels. At the same time, pollution control equipment 

commonly installed at large point sources is usually more efficient at capturing coarse particle 

emissions. 
New Hampshire Regional Haze SIP Revision Page 78 

Figure 8.19: 2002 Primary Coarse Particle (PM10) Emissions, by State 

Bar Graph = Percentage Fractions of Four Source Categories 

Line Graph = Total Annual Emissions (106 tpy) 

0%

25%

50%

75%

100%

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

0.0

0.2

0.4

0.6

million t/y

AREA NONROAD ONROAD POINT Emission

Figure 8.20: 2002 Primary Fine Particle (PM2.5) Emissions, by State 

Bar Graph = Percentage Fractions of Four Source Categories 

Line Graph = Total Annual Emissions (106 tpy) 

0%

25%

50%

75%

100%

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

0.00

0.02

0.04

0.06

0.08

0.10

0.12

million t/y

AREA NONROAD ONROAD POINT Emission
New Hampshire Regional Haze SIP Revision Page 79 

8.3.5 Ammonia Emissions (NH3) 

Because ammonium sulfate ((NH3)2SO4) and ammonium nitrate (NH3NO3) are significant 

contributors to atmospheric light scattering and fine particle mass, knowledge of ammonia 

emission sources is important to the development of effective regional haze reduction 

strategies. According to 1998 estimates, livestock agriculture and fertilizer use accounted for 

approximately 86 percent of all ammonia emissions to the atmosphere (EPA, 2000b). 

However, improved ammonia inventory data are needed as inputs to the photochemical 

models used to simulate fine particle formation and transport in the eastern United States. 

States were not required to include ammonia in their emissions data collection efforts until 

fairly recently (see the Consolidated Emissions Reporting Rule, 67 CFR 39602, June 10, 

2002). Therefore, emissions data for ammonia do not exist at the same level of detail or 

reliability as exists for other pollutants. 

Ammonium ion (formed from ammonia emissions to the atmosphere) is an important 

constituent of airborne particulate matter, typically accounting for 10–20 percent of total fine 

particle mass. Reductions in ammonium ion concentrations can be instrumental to controlling 

regional haze because such reductions yield proportionately greater reductions in fine particle 

mass. Ansari and Pandis (1998) showed that a 1 μg/m3

 reduction in ammonium ion could result 

in up to a 4 μg/m3 reduction in fine particulate matter. Decision makers, however, must weigh 

the benefits of ammonia reduction against the significant role it plays in neutralizing acidic 

aerosol.14

To address the need for improved ammonia inventories, MARAMA, NESCAUM, and EPA 

funded researchers at Carnegie Mellon University (CMU) in Pittsburgh to develop a regional 

ammonia inventory (Davidson et al., 1999). This study focused on three issues with respect 

to current emission estimates: 1) a wide range of ammonia emission factors, 2) inadequate 

temporal and spatial resolution of ammonia emissions estimates, and 3) a lack of standardized 

ammonia source categories. 

The CMU project established an inventory framework with source categories, emission 

factors, and activity data that are readily accessible to the user. With this framework, users 

can obtain data in a variety of formats15 and can make updates easily, allowing additional 

ammonia sources to be added or emission factors to be replaced as better information 

becomes available (Strader et al., 2000; NESCAUM, 2001b). 

Figures 8.21 and 8.22 show estimated ammonia emissions for the MANE-VU states in 2002. 

Area and on-road mobile sources dominate the ammonia inventory data. Specifically, 

emissions from agricultural sources and livestock production account for the largest share of 

estimated ammonia emissions in the MANE-VU region, except in the District of Columbia. 

The two other sources contributing significant emissions are wastewater treatment systems 

and gasoline exhaust from highway vehicles. 

 

14 SO2

 reacts in the atmosphere to form sulfuric acid (H2SO4). Ammonia can partially or fully neutralize this strong acid to 

form ammonium bisulfate or ammonium sulfate. If planners focus future control strategies on ammonia and do not 

achieve corresponding SO2

 reductions, fine particles formed in the atmosphere will be substantially more acidic than those 

presently observed. 

15 For example, the user will have the flexibility to choose the temporal resolution of the output emissions data or to spatially 

attribute emissions based on land-use data. 
New Hampshire Regional Haze SIP Revision Page 80 

Figure 8.21: Ammonia (NH3) Emissions, by State 

0.00

0.02

0.04

0.06

0.08

0.10

0.12

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

million t/y

MV 2002 v.3

Figure 8.22: 2002 Ammonia (NH3) Emissions, by State 

Bar Graph = Percentage Fractions of Four Source Categories 

Line Graph = Total Annual Emissions (106

 tpy) 

0%

25%

50%

75%

100%

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

0.00

0.01

0.02

0.03

0.04

0.05

0.06

0.07

0.08

0.09

0.10

million t/y

AREA NONROAD ONROAD POINT Emission
New Hampshire Regional Haze SIP Revision Page 81 

References 

Ansari, A. S., and Pandis, S.N., “Response of inorganic PM to precursor concentrations,”

Environ. Sci. Technol., 32, 2706-2714, 1998. 

Davidson, C., Strader, R., Pandis, S., and Robinson, A., Preliminary Proposal to MARAMA and 

NESCAUM: Development of an Ammonia Emissions Inventory for the Mid-Atlantic States and 

New England. Carnegie Mellon University, Pittsburgh, PA, January 7, 1999. 

Duyzer, J., “Dry Deposition of Ammonia and Ammonium Aerosols over Heathland,” J. 

Geophys. Res., 99(D9):18,757 – 18,763, 1994. 

EPA, National Air Quality and Emission Trends Report, 1998, EPA 454/R-00-003 (available 

online), 2000a. http://www.epa.gov/oar/aqtrnd98/. 

EPA, National Air Pollutant Trends, 1900 – 1998, EPA 454/R-00-002 (available online), 

2000b. http://www.epa.gov/ttn/chief/trends/trends98/trends98.pdf. 

EPA, Emissions Inventories, 2005. http://www.epa.gov/ttn/chief/eiinformation.html. 

MARAMA, MANE-VU 2002 Emissions Inventory, 2007. 

http://www.marama.org/visibility/Inventory%20Summary/2002EmissionsInventory.htm. 

NESCAUM, “Regional Haze and Visibility in the Northeast and Mid-Atlantic States,” 

January 2001a. 

NESCAUM, “Development of an Improved Ammonia Emissions Inventory for the United 

States,” December 2001b. 

Odum, J.R., Jungkamp, T.P.W., Griffin, R.J., Flagan, R.C., and Seinfeld, J.H., “The Atmospheric 

Aerosol-forming Potential of Whole Gasoline Vapor,” Science, 276, 96-99, 1997.

Strader, R., Anderson, N., and Davidson, C., Development of an Ammonia Inventory for the 

Mid-Atlantic States and New England, Progress Report, October 18, 2000. 

http://marama.org/rt_center/MARAMAprogress10-18-00.pdf. 
New Hampshire Regional Haze SIP Revision Page 82 

9. BEST AVAILABLE RETROFIT TECHNOLOGY (BART) 

In the Regional Haze Rule, EPA included provisions for reducing emissions of visibilityimpairing pollutants from large sources that, because of their age, were exempted from new 

source performance standards (NSPS) established under the Clean Air Act. These provisions, 

known as Best Available Retrofit Technology, or BART, are published in 40 CFR 51.308(e). 

Under this part of the rule, New Hampshire is required to submit an implementation plan 

containing emission limitations representing Best Available Retrofit Technology and 

schedules for compliance with BART for each BART-eligible source that may reasonably be 

anticipated to cause or contribute to any impairment of visibility in any mandatory Class I 

area. This requirement applies unless New Hampshire demonstrates that an emissions trading 

program or other alternative will achieve greater reasonable progress toward natural visibility 

conditions. New Hampshire, with the help of the MANE-VU Regional Planning Organization, 

has developed a strategy meeting the requirements of BART. This section of the SIP 

specifically addresses how New Hampshire’s plan satisfies BART requirements. A more 

general description of BART implementation within MANE-VU is presented later in Part 

10.2.2 of Section 10, Reasonable Progress Goals. 

The BART provisions of the Regional Haze Rule require states to develop an inventory of 

sources within each state that would be eligible for BART controls. The rule also: 

• Outlines methods to determine whether a source is “reasonably anticipated to cause or 

contribute to haze,” 

• Defines the methodology for conducting BART control analysis, 

• Provides presumptive performance levels for electricity generating units (EGUs) at 

fossil-fuel-fired power plants larger than 750 megawatts (all BART-eligible EGUs in 

New Hampshire are below this size); and 

• Provides a justification for the use of the Clean Air Interstate Rule (CAIR) as meeting 

BART requirements for CAIR-affected electrical generating units (EGUs). (Note: With 

the pending redesign of CAIR, EPA’s previous determination of regulatory 

equivalency is invalid. New Hampshire has always held that, because the old CAIR 

requirements were not source-specific, they should not, in the general case, be 

considered equivalent to BART requirements, which are source-specific. The location 

of a source remains an important factor in assessing and controlling visibility impacts.) 

Beyond the specific elements listed above, EPA has allowed the states a great deal of 

flexibility in implementing the BART program. Because of the collective importance of 

BART sources to the management of regional haze, the MANE-VU Board decided, in June 

2004, that a BART determination would be made by the member states for each BARTeligible source, without exception. Consequently, New Hampshire has completed a BART 

analysis on all BART-eligible sources in the state. This process includes consideration of 

the available technology, potential improvements in visibility, and other factors described 

later in this section. 

9.1 BART Applicability 

The BART requirements pertain to large facilities in each of 26 source categories that meet 

certain criteria, including industrial boilers, pulp and paper mills, cement kilns, and other large 
New Hampshire Regional Haze SIP Revision Page 83 

stationary sources. The BART program applies to units installed and operated between 1962 

and 1977 with the potential to emit more than 250 tons per year of a visibility-impairing 

pollutant. Each BART-eligible unit must undergo a case-by-case analysis to determine whether 

new emission restrictions are appropriate to limit the unit’s impact on visibility at Class I areas. 

9.2 BART-Eligible Sources in New Hampshire 

A list of New Hampshire’s BART-eligible sources is presented in Table 9.1. These sources 

were identified using the methodology contained in 40 CFR Part 51, Appendix Y – Guidelines 

for BART Determinations under the Regional Haze Rule, adopted July 6, 2005. 

 

Table 9.1: BART-Eligible Sources in New Hampshire 

MANE-VU 

BART ID Source and Unit BART Pollutants Location 

NH1 Public Service of New Hampshire 

Merrimack Station Unit MK2

320-MW EGU 

SO2

NOX

PM 

Bow, NH 

NH2 Public Service of New Hampshire 

Newington Station Unit NT1

400-MW EGU 

SO2

NOX

PM 

Newington, NH 

Note: Both BART-eligible sources are located at power plants smaller than the 750-MW minimum 

size for which EPA has provided presumptive performance levels. 

9.2.1 Cap-Outs and Shutdowns 

Many facilities in the MANE-VU region are relatively small emission sources with potential 

emissions exceeding the BART applicability threshold of 250 tons per year of haze-causing 

pollutants but whose actual emissions are well below 250 tons in any year. Some of these 

facilities may have accepted an enforceable permit limitation restricting their emissions to less 

than 250 tons per year. Any otherwise BART-eligible facility may be allowed to “cap-out” of 

BART by accepting enforceable permit limits. In addition, some BART-eligible facilities 

within the region may have permanently shut down. In New Hampshire, no BART-eligible 

facilities capped out or permanently shut down to avoid BART.

9.2.2 Small Source Exemptions 

As provided in 40 CFR 51.308(e)(1)(ii)I of the Regional Haze Rule, a state is not required to 

make a BART determination for either SO2 or NOX if a BART-eligible source has the 

potential to emit less than 40 tons per year of these pollutants, or for PM10 if a BART-eligible 

source emits less than 15 tons per year of this pollutant. No BART-eligible sources in New 

Hampshire have been exempted from the BART determination process. 

9.2.3 Large Electrical Generating Units 

Under 40 CFR 51.308(e)(1)(ii)(B), the determination of BART for large EGUs at fossil-fuelfired power plants having a total generating capacity greater than 750 megawatts must follow 

the guidelines presented in 40 CFR Part 51, Appendix Y. This part of the rule defines the 

process for making BART determinations on a case-by-case basis. (States are not required to 
New Hampshire Regional Haze SIP Revision Page 84 

use this process when making BART determinations for other types of sources.) Because all 

BART-eligible EGUs in New Hampshire are installed at power plants smaller than 750 

MW, they are not subject to the guidelines of 40 CFR Part 51, Appendix Y. However, as 

discussed in Subsection 9.4 below, NHDES has conducted a source-specific BART analysis 

using the Appendix Y guidelines for each of these EGUs.

9.3 Determination of BART Requirements for BART-Eligible Sources 

and Analysis of Best Retrofit Technologies 

40 CFR 51.308(e)(1)(ii)(A) requires that, for each BART-eligible source within the state, any 

BART determination must be based on an analysis of the best system of continuous emission 

control technology available and the associated emission reductions achievable. In addition to 

considering available technologies, this analysis must evaluate five specific factors for each 

source: 

1. The costs of compliance, 

2. The energy and non-air quality environmental impacts of compliance, 

3. Any existing pollution control technology in use at the source, 

4. The remaining useful life of the source, and 

5. The degree of visibility improvement which may reasonably be anticipated from 

the use of BART. 

NESCAUM examined, from a regional perspective, the various options available to MANEVU states for meeting these requirements. The findings are contained in the NESCAUM 

report “Five-Factor Analysis of BART Eligible Sources: Survey of Options for Conducting 

BART Determinations,” June 1, 2007 (Attachment W). 

9.3.1 BART Determinations and Required Control Levels 

NHDES has performed BART determinations for all BART-eligible sources in New Hampshire. 

The BART level of control for each source was taken to be that level of continuous emission 

reductions that would be achieved by installation of the best retrofit system, after considering 

the technology available, the costs of compliance, the energy and non-air quality environmental 

impacts of compliance, any pollution control equipment in use or in existence at the source, 

the remaining useful life of the source, and the degree of improvement in visibility which may 

reasonably be anticipated to result from the use of such technology. 

For its BART determinations on each BART-eligible source, NHDES used the method in 40 

CFR Part 51, Appendix Y, Guidelines for BART Determinations under the Regional Haze 

Rule. Because all BART-eligible EGUs located in New Hampshire are less than 750 MW in 

capacity, NHDES performed case-by-case BART analyses on these units. Detailed BART 

analyses for New Hampshire’s two BART sources, PSNH Merrimack Station Unit MK2 and 

PSNH Newington Station Unit NT1, are presented in Attachment X. The application of 

BART to these two sources yields estimated emission reductions from the 2002 baseline year 

in the following amounts: 

• Approximately 21,000 tons per year of sulfur dioxide, 

• No additional reduction in nitrogen oxides (existing controls = BART), and 

• No additional reduction in particulate matter (existing controls = BART). 
New Hampshire Regional Haze SIP Revision Page 85 

Tables 9.2 and 9.3 summarize the BART determinations for the two BART-eligible sources in 

New Hampshire for the visibility-impairing pollutants SO2, NOX, and PM. Included in these 

tables are the baseline (2002 actual) and BART control levels, BART emission limits, and 

annual emissions before and after BART implementation. 

In Table 9.2, the BART control level for sulfur dioxide, for PSNH Merrimack station Unit 

MK2, is stated as 90 percent. This control level is based on implementation of New 

Hampshire’s Multiple Pollutant Reduction Program, RSA-125-O, which requires the 

installation and operation of a flue gas desulfurization, or scrubber, system on both units at 

this facility. Because the scrubber will be optimized for mercury emission reductions, Unit 

MK2 may not experience the typical SO2 removal efficiency of 95 percent associated with 

new FGD technology. Consequently, a more conservative SO2 control level of 90 percent 

was established as an operating condition in the facility’s air permit. (The Multiple Pollutant 

Reduction Program requires the scrubber to operate at a sustained control level of 80 percent 

or greater for mercury emission reductions.) The required SO2 control level effectively means 

that actual SO2 emission reductions must exceed 90 percent on average. To the extent that 

these higher SO2 removal rates can be realized, they will be applied against the less than 90-

percent SO2 reduction expected at Newington Station in order to fulfill the state’s 

commitment to the MANE-VU targeted EGU strategy. 

For PSNH Newington Station Unit NT1, the BART control level for sulfur dioxide is based 

on a proposed emission limitation of 0.50 lb/MMBtu, applicable to all fuels and fuel mixtures. 

(The boiler can be fired with either natural gas or liquid fuel (i.e., residual fuel oil or biofuel), 

or it can be co-fired with both types of fuel at the same time.) Note that SO2 emissions from 

this unit may be further reduced with the planned introduction of 0.5-percent-sulfur residual 

fuel oil by 2018 upon implementation of MANE-VU’s low-sulfur oil strategy (contingent on 

fuel availability and cost). See Parts 10.2.3 and 11.4.2 of this SIP for a detailed description of 

this control measure. 
New Hampshire Regional Haze SIP Revision Page 86 

Table 9.2: Emission Reductions Resulting from BART Controls 

at PSNH Merrimack Station Unit MK2 

Pollutant BART Controls 

Baseline 

Capacity 

Factor 

(%) 

2002 

Baseline 

Emissions 

(tpy) 

Baseline 

Control 

Level 

(%) 

BART 

Control 

Level 

(%) 

BART 

Emission Limit 

Est. 2002 

Emissions 

after BART 

(tpy) 

Est. 2002 

Emission 

Reductions

(tpy) 

SO2 Flue gas 

desulfurization 

(FGD) (in progress)

72 20,902 40 16 90 17

(as initially 

modeled)

10% of uncontrolled 

SO2 emissions, 

calendar monthly avg. 

2,090 18,812 

NOX Selective catalytic 

reduction (SCR) 

(existing)

72 2,871 85 85 

(same as 

baseline) 

0.37 lb/MMBtu, 

calendar monthly avg. 

(≈ RACT limit)

2,871 0 

PM Two electrostatic 

precipitators (ESPs)

in series (existing) 

72 210 99 99 

(same as 

baseline) 

0.08 lb/MMBtu 

total suspended 

particulate (TSP) 18

210 0 

 

Table 9.3: Emission Reductions Resulting from BART Controls 

at PSNH Newington Station Unit NT1 

Pollutant BART Controls 

Baseline 

Capacity 

Factor 

(%) 

2002 

Baseline 

Emissions 

(tpy) 

Baseline 

Control 

Level 

(%) 

BART 

Control 

Level 

(%) 

BART 

Emission Limit 

Est. 2002 

Emissions 

after BART 

(tpy) 

Est. 2002 

Emission 

Reductions

(tpy) 

SO2 SO2 emission 

limitation 

(proposed) 

19 19 5,226 0 67 20 0.50 lb/MMBtu, 

calendar monthly avg. 

1,742 3,484 21

NOX Overfire air and 

water injection 

(existing) 

19 943 33 22 33 

(same as 

baseline) 

0.35 lb/MMBtu (oil)

and 0.25 lb/MMBtu 

(oil/gas), daily avg. 

(= RACT limit)

943 0 

PM ESP (existing) 19 196 42 / 93 23 42 / 93 

(same as 

baseline) 

0.22 lb/MMBtu 

total suspended 

particulate (TSP) 

196 0 

 

16 The 40% baseline level of control for Unit MK2 is based on a switch to a lower-sulfur coal that occurred in 1994. 

17 For modeling purposes, a control level of 90% from baseline 2002 SO2

 emissions has been applied as a conservative 

estimate of expected performance. The actual rate of reduction from baseline 2002 emissions will vary, depending on the 

sulfur content of coal used in future years. Unit MK2 will continue to be subject to Title V operating permit conditions 

that limit coal sulfur content to 2.0 lb/MMBtu gross heat content and that require SO2 emissions to be controlled to no 

more than 10 percent of the uncontrolled SO2

 emission rate (i.e., 90% SO2 removal). 

18 This revised emission limit will simultaneously apply to Units MK1 and MK2. (Unit MK1 is not a BART-eligible source). 

19 The current Title V operating permit for PSNH Newington Station limits the annual capacity factor for Unit NT1 to 66.2%. 

This capacity factor limit is expressed as a restriction on the maximum annual heat input rating for the unit. 

20 Minimum expected reduction based on 100% use of residual fuel oil at 0.4% actual sulfur content, or a 50:50 ratio (Btu basis) 

of natural gas to residual fuel oil at 0.8% actual sulfur content. 

21 Additional emission reductions beyond the stated value may occur with a switch to 0.5% low-sulfur oil upon implementation of 

MANE-VU’s low-sulfur oil strategy by no later than 2018. 

22 The baseline level of NOX control was calculated by comparing emission test results from October 1992 (0.371 lb/MMBtu) to 

test results from 2001 (0.249 lb/MMBtu) after a number of NOX reduction projects were completed on Unit NT1. 

23 The lower value is based on a 2001 stack test value of 0.058 lb/MMBtu and an AP42 uncontrolled emission factor of 0.103 

lb/MMBtu. The higher value is the stated efficiency under normal operating conditions from a 1971 Buell Envirotech Corp. 

performance specification for this unit; maximum efficiency under design conditions is stated as 98 percent. 
New Hampshire Regional Haze SIP Revision Page 87 

9.3.2 Visibility Improvements Resulting from BART 

NHDES used the CALGRID photochemical model to perform a screening-level analysis of 

the anticipated effects of BART controls at New Hampshire’s two BART-eligible sources 

(see Part 7.3.3 for a description of the CALGRID modeling platform). Separate CALGRID 

modeling runs were conducted to examine the effects of selected emission control measures 

on each of these sources. One run assessed the effects of installing scrubber technology on 

Unit MK-2 at PSNH Merrimack Station. The second run assessed the effects of switching to 

lower-sulfur residual fuel oil for Unit NT-1 at PSNH Newington Station. Both simulations 

were performed for the full summer modeling episode (May 15 to September 15, 2002) and 

used the 2018 BOTW emissions inventory scenario as a baseline (see Part 6.1.2 for a 

description of all future-year emissions inventories). The CALGRID model outputs took the 

form of ambient concentration reductions for SO2, PM2.5, and other haze-related pollutant 

within the region. NHDES post-processed the modeled concentration reductions to estimate 

the corresponding visibility improvements at Class I areas. 

Based on the CALGRID modeling results, the installation of scrubber technology on 

Merrimack Station Unit MK-2 is expected to reduce maximum predicted 24-hour average 

SO2 concentration impacts by up to 21 μg/m3 (8 ppb by volume) and maximum predicted 24-

hour average PM2.5 concentration impacts by up to 1 μg/m3

. The largest modeled pollutant 

concentration reductions occur within a 50-kilometer radius of the facility, an area which does 

not contain any federal Class I areas. For the affected Class I areas (located 100 to 500 

kilometers away), reductions in the maximum predicted concentrations of SO2, PM2.5, and 

other haze-related pollutants, combined, are expected to yield a nominal improvement in 

visibility (about 0.1 deciview) on direct-impact hazy days. 

For Newington Station Unit NT1, switching to lower-sulfur residual fuel oil is expected to 

reduce maximum predicted 24-hour average SO2 concentration impacts by 2 μg/m3 and 

maximum predicted 24-hour average PM2.5 concentration impacts by 0.1 μg/m3. At the 

affected Class I areas, reductions in the maximum predicted concentrations of SO2, PM2.5, and 

other haze-related pollutants, combined, would yield negligible visibility improvement. 

In recognition of EPA’s preferred methodology for assessing visibility impacts, NHDES also 

conducted a limited set of CALPUFF modeling runs for the New Hampshire BART-eligible 

sources under controlled and uncontrolled conditions. Results were tabulated for the average 

of the 20% worst visibility (about 22.8 dv) modeled days at each nearby Class 1 area. The 

BART guidelines suggest that models be used in a “relative” way to estimate the expected 

visibility benefits of BART controls. NHDES normalized the CALPUFF modeling results 

and then applied predicted concentrations to a logarithmic best-fit equation to the actual 

observed PM2.5-to-deciview relationship measured at Acadia NP, Great Gulf NW, and Lye 

Brook NW. Thus, CALPUFF was applied in a relative way using real data as the basis. The 

CALPUFF-predicted visibility benefits from BART controls on the 20% worst visibility days 

are shown in Tables 9-4 and 9-5 for New Hampshire’s two BART facilities: 
New Hampshire Regional Haze SIP Revision Page 88 

Table 9-4. CALPUFF Modeling Results for Merrimack Station Unit MK2: 

Visibility Improvements from BART Controls on the 20% Worst Visibility Days 

Pollutant Control Level Acadia NP Great Gulf NW Lye Brook 

SO2 90% with FGD 0.17 dv 0.15 dv 0.08 dv 

NOx Additional 25% 

with SCR upgrade 0.02 dv 0.01 dv < 0.01 dv 

PM 99% with upgraded controls < 0.01 dv* < 0.01 dv* < 0.01 dv* 

Table 9-5. CALPUFF Modeling Results for Newington Station Unit NT1: 

Visibility Improvements from BART Controls on the 20% Worst Visibility Days 

Pollutant Control Level Acadia NP Great Gulf NW Lye Brook 

1.0%-S Residual Fuel Oil 

(50% sulfur reduction**) 0.05 dv 0.04 dv 0.02 dv 

0.5%-S Residual Fuel Oil 

(75% sulfur reduction**) 0.07 dv 0.06 dv 0.03 dv 

SO2 

0.3%-S Residual Fuel Oil 

(85% sulfur reduction**) 0.08 dv 0.07 dv 0.04 dv 

NOx 50% with SCR 0.01 dv < 0.01 dv* < 0.01 dv* 

PM 99% with upgraded controls *** *** *** 

 * below sensitivity limit of model 

 ** from maximum permitted level 

*** Modeling for PM was not performed because existing controls may already be achieving greater than 90% reduction, 

and any visibility benefit would be below the model’s sensitivity limit. 

Further description of the assessment of visibility impacts from these two BART sources may 

be found in the detailed BART analyses presented in Attachment X. 

9.3.3 BART-Eligible EGUs and the Role of CAIR 

The BART-eligible EGUs in MANE-VU represent the largest opportunity for potential 

emission reductions among the various BART-eligible source categories. Under the Clean 

Air Interstate Rule (CAIR), the population of BART-eligible EGUs within the MANE-VU 

domain fall into three geographical groups. 

• CAIR states (year-round): EGUs in states eligible to participate in the (CAIR) 

program on a year-round basis (Delaware, District of Columbia, Maryland, New 

Jersey, New York, and Pennsylvania, for SO2 and NOX); 

• CAIR states (seasonal): EGUs in states eligible to participate in the seasonal CAIR 

program only (Connecticut and Massachusetts, for summertime NOX); and 

• Non-CAIR states: EGUs in states not eligible to participate in the CAIR program 

(Maine, New Hampshire, Rhode Island, and Vermont). 

In 40 CFR 51.308(e)(4), EPA established that a state’s participation in the CAIR program 

would satisfy BART requirements for BART-eligible EGUs that were also subject to CAIR. 
New Hampshire Regional Haze SIP Revision Page 89 

This provision affected all BART-eligible EGUs in Pennsylvania, Delaware, Maryland, New 

Jersey, New York, the District of Columbia, and those EGUs located in Connecticut and 

Massachusetts that were also included in the CAIR program, but only with respect to their 

emissions of ozone-season NOX. Following the federal court’s remand of CAIR, the BARTequivalency provision may be revised or rescinded. 

The original purpose of BART was to require source-specific controls on BART-eligible units. 

NHDES has always maintained that emissions from BART-eligible EGUs and their impacts 

on visibility in Class I areas should be addressed as the BART rule intended. MANE-VU 

assessments have determined that allowing EGUs with the largest impacts on Class I areas to 

purchase allowances under the CAIR emissions trading program would produce less visibility 

benefit than intended by the BART rule. Accordingly, MANE-VU developed a targeted EGU 

strategy in order to recapture some of the lost benefit. (The targeted EGU strategy is discussed 

at length in Sections 10 and 11). 

9.4 Alternatives to BART for Any Source 

40 CFR 51.308(e)(1)(v)(2) of the Regional Haze Rule provides that a state may opt to 

implement an emissions trading program or other alternative measure rather than require 

sources subject to BART to install, operate, and maintain BART. In such case, the state must 

demonstrate that the emissions trading program or other alternative measure will achieve 

greater reasonable progress than would be achieved through the installation and operation of 

BART. To make this demonstration, the state must submit an implementation plan containing 

the elements listed in the above-referenced part of the rule.

New Hampshire does not support the provisions of the BART rule that allow emissions trading 

programs or other alternative measures because they are not likely to yield visibility 

improvements equivalent to those that would accrue from source-specific BART controls. 

Consequently, NHDES does not propose to use alternative measures for BART-eligible 

sources in New Hampshire.

9.5 BART Enforceable Provisions and Implementation Schedule 

The enforceable provisions and compliance schedule for BART are summarized in Tables 9-6 

and 9-7 for New Hampshire’s two BART-eligible sources. The BART control measures will 

be enforceable through a combination of existing permit conditions, existing administrative 

rules, and a proposed administrative rule to be adopted as Chapter Env-A 2300 Mitigation of 

Regional Haze (see draft rule, Attachment GG). 

40 CFR 51.308(e)(1)(iv) requires that BART must be in operation for each applicable source 

no later than five years after SIP approval. NHDES is requiring all BART-eligible sources to 

install and operate BART controls as expeditiously as practicable but in no case later than 

July 1, 2013. 

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 will meet this requirement by including in the Title V operating 

permit for each BART-eligible 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 will 
New Hampshire Regional Haze SIP Revision Page 90 

first need to be placed into a state temporary permit (i.e., construction permit) before they can 

be incorporated subsequently into a federal Title V operating permit. 

Table 9-6: BART Enforceable Provisions and Compliance Schedule 

for PSNH Merrimack Station Unit MK2 

Pollutant BART Controls / 

Emission Limitations Regulatory Citations* Compliance

Date

NOX SCR (existing); 

NOx emission limit of 0.37 lb/MMBtu, 

calendar monthly average (proposed) 

Draft Title V operating permit (TV-0055); 

Administrative Rule Env-A 2300 

Mitigation of Regional Haze (proposed); 

Rule: 

July 1, 2013 

PM Two ESPs in series (existing) 

TSP emission limit of 0.08 lb/MMBtu 

(proposed) 

Draft Title V operating permit (TV-0055); 

Administrative Rule Env-A 2300 

Mitigation of Regional Haze (proposed) 

Rule: 

July 1, 2013 

SO2 Fuel sulfur limits (existing); 

Flue gas desulfurization (FGD), with 

required SO2 percent reduction set at 

maximum sustainable rate, but not less 

than 90% as a calendar monthly average 

(proposed) 

Administrative Rule Env-A 1606.01 

Maximum Sulfur Content Allowable in 

Coal (existing); 

Temporary permit for FGD system (TP-0008); 

Draft Title V operating permit (TV-0055) 

FGD: 

July 1, 2013 

Table 9-7: BART Enforceable Provisions and Compliance Schedule 

for PSNH Newington Station Unit NT1 

Pollutant BART Controls / 

Emission Limitations Regulatory Citations* Compliance

Date 

NOX Overfire air and water injection 

(existing); 

NOx emission limits of 0.35 lb/MMBtu 

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

24-hour calendar day average (existing) 

Title V operating permit (TV-OP-054) N.A 

(Existing 

controls are 

BART) 

PM Electrostatic precipitator (existing); 

TSP emission limit of 0.22 lb/MMBtu 

(existing) 

Title V operating permit (TV-OP-054) N.A 

(Existing 

controls are 

BART) 

SO2 SO2 emission limit of 0.50 lb/MMBtu, 

calendar monthly average, applicable to 

any fuel type or mix (proposed) 

Administrative Rule Env-A 2300 

Mitigation of Regional Haze (proposed) 

Rule: 

July 1, 2013 

*Applicable permits and draft rules are available in Attachments FF through II. 

The tentative schedule for development and adoption of Env-A 2300 Mitigation of Regional 

Haze is as follows: 

Circulate rough draft of rule................................ January 2012 

Confer with affected stakeholders.........................February - June 2012 

Issue draft rule; initiate formal public process........... September 2012 

Adopt final rule.............................................. May 2013 

Final rule becomes effective by............................ July 1, 2013 
New Hampshire Regional Haze SIP Revision Page 91 

10. REASONABLE PROGRESS GOALS 

40 CFR 51.308 (d)(1) of the Regional Haze Rule requires New Hampshire to establish, for 

each Class I area within the state, reasonable progress goals (RPG) toward achieving natural 

visibility conditions. On June 1, 2007, the U.S. Environmental Protection Agency (EPA) 

released final guidance to be used by states in setting reasonable progress goals. The goals 

must provide for visibility improvement on the days of greatest visibility impairment and 

ensure no visibility degradation on the days of least visibility impairment for the duration of 

the State Implementation Plan (SIP) period. 

As provided in 40 CFR 51.308 (d)(1)(iv), the state must consult with other states in the setting 

of reasonable progress goals. The rule states: 

“In developing each reasonable progress goal, the State must consult with those States which may 

reasonably be anticipated to cause or contribute to visibility impairment in the mandatory Class I 

Federal area. In any situation in which the State cannot agree with another such State or group of 

States that a goal provides for reasonable progress, the State must describe in its submittal the 

actions taken to resolve the disagreement. In reviewing the State’s implementation plan submittal, 

the Administrator will take this information into account in determining whether the State’s goal for 

visibility improvement provides for reasonable progress towards natural visibility condition.” 

New Hampshire consulted with states found to contribute to visibility impairment at New 

Hampshire’s Class I areas and with states that requested consultation with New Hampshire 

regarding visibility conditions at their Class I areas. In particular, New Hampshire worked 

closely with the other MANE-VU states to ensure consistency of approach in setting 

reasonable progress goals. Accordingly, New Hampshire agrees with the reasonable 

progress goals established by Maine, Vermont, and New Jersey. A description of the 

consultation process is found under Section 3, Regional Planning and Consultation. 

The Regional Haze Rule also requires each Class I state to consider four factors in setting 

reasonable progress goals: cost, time needed for compliance, energy and non-air quality 

environmental impacts, and remaining useful life. In addition, the state must show that it 

considered the uniform rate of improvement and the emission reduction measures needed to 

achieve it for the period covered by the implementation plan. If the state proposes a rate of 

progress slower than the uniform rate of progress, the state must assess the number of years it 

would take to attain natural conditions if visibility improvement continues at the rate 

proposed. 

10.1 Calculation of Uniform Rate of Progress 

As a benchmark to aid in developing reasonable progress goals, MANE-VU compared 

baseline visibility conditions to natural visibility conditions at each MANE-VU Class I area. 

The difference between baseline and natural visibility conditions for the 20 percent worst days 

was used to determine the uniform rate of progress that would be needed during each 

implementation period in order to attain natural visibility conditions by 2064. Table 10.1 

presents baseline visibility, natural visibility, and required uniform rate of progress for each 

MANE-VU Class I area. Visibility values are expressed in deciviews (dv), where each 

single-unit deciview decrease would represent a barely perceptible improvement in visibility. 
New Hampshire Regional Haze SIP Revision Page 92 

Table 10.1: Uniform Rate of Progress Calculation (all values in deciviews) 

Class I Area 

2000-2004 

Baseline 

Visibility 

(20% Worst 

Days) 

Natural 

Visibility 

(20% Worst 

Days) 

Total 

Improvement 

Needed by 

2018 

Total 

Improvement 

Needed by 

2064 

Uniform 

Annual Rate of 

Improvement 

Acadia National Park 22.9 12.4 2.4 10.5 0.174 

Moosehorn Wilderness and 

Roosevelt Campobello 

International Park 

21.7 12.0 2.3 9.7 0.162 

Great Gulf Wilderness and 

Presidential Range - Dry River 

Wilderness 

22.8 12.0 2.5 10.8 0.180 

Lye Brook Wilderness 24.5 11.7 3.0 12.8 0.212 

Brigantine Wilderness 29.0 12.2 3.9 16.8 0.280 

Note: Both natural conditions and baseline visibility for the 5-year period from 2000 through 2004 were calculated in conformance with 

an alternative method recommended by the IMPROVE Steering Committee.24

 

The reasonable progress goals established for MANE-VU’s Class I Areas, described later in 

Subsection 10.3, are expected to provide visibility improvements in excess of the uniform 

rates of progress shown above. 

10.2 Identification of (Additional) Reasonable Control Measures 

New Hampshire and the other MANE-VU states have identified specific emission control 

measures – beyond those which individual states or RPOs had already made commitments to 

implement – that would be reasonable to undertake as part of a concerted strategy to mitigate 

regional haze. The proposed additional control measures were incorporated into the regional 

strategy adopted by MANE-VU on June 20, 2007, to meet the reasonable progress goals 

established in this SIP. The basic elements of this strategy are described in the New 

Hampshire/MANE-VU “Ask” (see Part 3.2.2 under Section 3, Regional Planning and 

Consultation). States targeted for coordinated actions toward achieving these goals include all 

of the MANE-VU states plus Georgia, Illinois, Indiana, Kentucky, Michigan, North Carolina, 

Ohio, South Carolina, Tennessee, Virginia, and West Virginia.25

 

In addition to including proposed emission controls in the eastern United States, MANE-VU 

determined that it was reasonable to include anticipated emission reductions in Canada in the 

modeling used to set reasonable progress goals. This determination was based on evaluations 

conducted before and during the consultation process (see description of relevant consultations 

in Part 3.2.1). Specifically, the modeling accounts for six coal-burning electric generating 

units (EGUs) in Canada having a combined output of 6,500 MW that are scheduled to be shut 

 

24 “Baseline and Natural Visibility Conditions, Considerations and Proposed Approach to the Calculation of Baseline and 

Natural Visibility Conditions at MANE-VU Class I Areas,” NESCAUM, December 2006. 

25 In addition, Vermont identified at least one source in Wisconsin as a significant contributor to visibility impairment at the 

Lye Brook Wilderness Class I Area. 
New Hampshire Regional Haze SIP Revision Page 93 

down and replaced by nine natural gas turbine units equipped with selective catalytic 

reduction (SCR) by 2018. 

The process of identifying reasonable measures and setting reasonable progress goals is 

described in the subsections which follow. Further elaboration on the reasonable measures 

which make up the New Hampshire/MANE-VU long-term strategy is provided in Section 11 

of this SIP. Under this plan, the affected states will have a maximum of 10 years to 

implement reasonable and cost-effective control measures to reduce primarily SO2 and NOX

emissions. For a description of how proposed emission control measures were modeled to 

estimate resulting visibility improvements, see Subsection 10.4, Visibility Affects of 

(Additional) Reasonable Control Measures. 

10.2.1 Rationale for Determining Reasonable Controls 

40 CFR 51.308(d)(1)(i)(A) of EPA’s Regional Haze Rule requires that, in establishing 

reasonable progress goals for each Class I area, the state must consider the costs of 

compliance, the time necessary for compliance, the energy and non-air quality environmental 

impacts of compliance, and the remaining useful life of any potentially affected sources. The 

SIP must include a demonstration showing how these factors were taken into consideration in 

setting the RPGs. These factors are sometimes termed the “four statutory factors,” since their 

consideration is required by the Clean Air Act. 

Early Focus on SO2: MANE-VU conducted a Contribution Assessment (Attachment B) and 

developed a conceptual model that showed the dominant contributor to visibility impairment 

at all MANE-VU Class I areas during all seasons in the base year was particulate sulfate 

formed from emissions of SO2. While other pollutants, including organic carbon, will need to 

be addressed in order to achieve the national visibility goals, MANE-VU’s contribution 

assessment suggested that an early emphasis on SO2 would yield the greatest near-term 

benefit. Therefore, it is reasonable to conclude that the additional measures considered in 

setting reasonable progress goals require reductions in SO2 emissions. 

Contributing Sources: The MANE-VU Contribution Assessment indicates that emissions 

from within MANE-VU in 2002 were responsible for approximately 25 percent of the sulfate 

at MANE-VU Class I Areas. Sources in the Midwest and Southeast regions were responsible 

for about 15 to 25 percent each. Point sources dominated the inventory of SO2 emissions. 

Therefore, MANE-VU’s long-term strategy includes additional measures to control sources of 

SO2 both within the MANE-VU region and in other states that were determined to contribute 

to regional haze at MANE-VU Class I Areas. 

The Contribution Assessment documented the source categories most responsible for 

visibility degradation at MANE-VU Class I Areas. As described in Section 11, Long-Term 

Strategy, there was a collaborative effort between the Ozone Transport Commission and 

MANE-VU to evaluate a large number of potential control measures. Several measures that 

would reduce SO2 emissions were identified for further study. 

Four-Factor Analysis: These efforts led to production of the MANE-VU report by 

MACTEC Federal Programs, Inc., “Assessment of Reasonable Progress for Regional Haze in 

MANE-VU Class I Areas,” Final, July 9, 2007, otherwise known as the Reasonable Progress 

Report (Attachment Y). This report provides an analysis of the four statutory factors for five 

major source categories: electrical generating units (EGUs); industrial, commercial, and 
New Hampshire Regional Haze SIP Revision Page 94 

institutional (ICI) boilers; cement and lime kilns; heating oil combustion; and residential 

wood combustion. Table 10.2 summarizes the results of MANE-VU’s four-factor analysis for 

the source categories considered. 

Table 10.2: Summary of Results from Four-Factor Analysis of Different Source Categories 

Source 

Category 

Primary 

Regional 

Haze 

Pollutant

Control Measure(s) 

Average Cost in 

2006 dollars 

(per ton of 

pollutant 

reduction) 

Compliance 

Timeframe 

Energy and NonAir Quality 

Environmental 

Impacts 

Remaining 

Useful Life

Electric 

Generating 

Units 

SO2 Switch to a low-sulfur coal (generally 

<1% sulfur); switch to natural gas 

(virtually 0% sulfur); coal cleaning; 

flue gas desulfurization (FGD), 

including wet, spray-dry, or dry. 

$775-$1,690 

based on IPM® 

v.2.1.9 * 

$170-$5,700 based 

on available 

literature 

2-3 years following 

SIP submittal 

Fuel supply issues, 

possible permitting 

issues, reduced 

electricity production 

capacity, wastewater 

issues 

50 years or 

more 

Industrial, 

Commercial, 

Institutional 

Boilers 

SO2 Switch to a low-sulfur coal (generally 

<1% sulfur); switch to natural gas 

(virtually 0% sulfur); switch to a 

lower-sulfur oil; coal cleaning; 

combustion controls; flue gas 

desulfurization (FGD), including wet, 

spray-dry, or dry. 

$130-$11,000 

based on available 

literature; 

dependent on size. 

2-3 years following 

SIP submittal 

Fuel supply issues, 

potential permitting 

issues, control device 

energy requirements, 

wastewater issues 

10-30 years 

Cement and 

Lime Kilns 

SO2 Fuel switching; flue gas 

desulfurization (FGD), including wet, 

spray-dry, or dry; advanced flue gas 

desulfurization (FGD). 

$1,900-$73,000 

based on available 

literature; 

dependent on size. 

2-3 years following 

SIP submittal 

Control device 

energy requirements, 

wastewater issues 

10-30 years 

Heating Oil SO2 Switch to lower-sulfur fuel 

(varies by state) 

$550-$750 based on 

available literature; 

high degree of 

uncertainty with this 

cost estimate 

Currently feasible; 

capacity issues may 

influence timeframe 

for implementation 

of new fuel standards

Increased 

furnace/boiler 

efficiency, reduced 

furnace/boiler 

maintenance 

requirements 

18-25 years 

Residential 

Wood 

Combustion 

PM State implementation of NSPS, 

ban on resale of uncertified devices, 

installer training certification or 

inspection program, pellet stoves, 

EPA Phase II certified RWC devices, 

retrofit requirement, accelerated 

changeover requirement or 

inducement 

$0-$10,000 based on 

available literature 

Several years, 

depending on 

mechanism for 

emission reductions 

Increased efficiency 

of combustion 

device, reduced 

greenhouse gas 

emissions 

10-15 years 

* Integrated Planning Model® CAIR versus CAIR plus analysis conducted for MARAMA/MANE-VU by ICF Consulting, L.L.C.

The MANE-VU states reviewed the four-factor analyses presented in the Reasonable Progress 

Report, consulted with one another about possible control measures, and concluded by 

adopting the statements known as the MANE-VU Ask. These statements identify the control 

measures that would be pursued toward improving visibility in the region. The following 

discussions focus on the four basic control strategies chosen by MANE-VU and included in 

the modeling to establish the reasonable progress goals: 

1. Best Available Retrofit Technology (BART), 

2. Low-sulfur fuel oil requirements, 

3. Emission reductions from specific EGUs, and 

4. Additional measures determined to be reasonable. 
New Hampshire Regional Haze SIP Revision Page 95 

10.2.2 Best Available Retrofit Technology Controls 

The MANE-VU states have identified approximately 100 BART-eligible sources in the 

region. Most of these facilities are already controlling emissions in response to other federal 

or state air programs or are likely to install emission controls under new programs. 

(Previously, EPA determined that CAIR fulfilled the BART requirement for all EGUs in 

participating CAIR states. New Hampshire anticipates that those same units will be covered 

under BART, by CAIR successor legislation, or by new rulemaking following the redesign of 

CAIR.) A complete compilation of BART-eligible sources in the MANE-VU region is 

available in Appendix A of MANE-VU’s “Assessment of Control Technology Options for 

BART-Eligible Sources,” March 2005, also known as the BART Report (Attachment Z). 

To assess the benefits of implementing BART in the MANE-VU region, NESCAUM 

estimated emission reductions for twelve BART-eligible sources in MANE-VU states that 

would probably be controlled as a result of BART requirements alone. These sources include 

one EGU and eleven non-EGUs. The affected sources were identified by a survey of states’ 

staff members, who furnished data on the potential control technologies and expected control 

levels for these sources under BART implementation. The twelve sources are listed in Table 

10.3 along with their 2002 baseline and 2018 estimated emissions. Information on these 

sources was incorporated into the 2018 emissions inventory projections that were used in the 

modeling to set reasonable progress goals. 

Table 10.3: Estimated Emissions from BART-Eligible Facilities in MANE-VU States 

(Facilities Likely to be Controlled as a Result of BART Alone) 

State Facility Name Unit 

Name SCC Code

Plant ID 

(MANE-VU 

Inventory)

Point ID 

(MANE-VU 

Inventory)

Facility 

Type 

2002 

SO2

Emissions 

(tons) 

2018 

SO2

Emissions 

(tons) 

MD EastAlco Aluminum 28 30300101 021-0005 28 Metal 

Production 1,506 1,356 

MD Eastalco Aluminum 29 30300101 021-0005 29 Metal 

Production 1,506 1,356 

MD Lehigh Portland 

Cement 39 30500606 013-0012 39 Portland Cement 9 8 

MD Lehigh Portland 

Cement 16 30500915 021-0003 16 Portland Cement 1,321 1,189 

MD Lehigh Portland 

Cement 17 30500915 021-0003 17 Portland Cement 9,76 8,78 

MD Westvaco Fine Papers 2 10200212 001-0011 2 Paper and 

Pulp 8,923 1,338 

ME Wyman Station Boiler 3 10100401 2300500135 004 EGU 616 308 

ME SAPPI Somerset Power 

Boiler 1 10200799 2302500027 001 Paper and Pulp 2,884 1,442 

ME Verso Androscoggin 

LLC 

Power 

Boiler 1 10200401 2300700021 001 Paper and Pulp 2,964* 1,482 

ME Verso Androscoggin 

LLC 

Power 

Boiler 2 10200401 2300700021 002 Paper and Pulp 3,086* 1,543 

NY Kodak Park Division U00015 10200203 8261400205 U00015 Chemical 

Manufacturer 2,3798 1,4216 

NY Lafarge Building 

Materials, Inc 41000 30500706 4012400001 041000 Portland Cement 14,800 4,440 

Note: Many additional sources in MANE-VU are BART-eligible but are expected to be controlled as a result of other 

emission reduction programs (e.g., state-specific multi-pollutant programs, a redesigned CAIR, etc.). 

*Data for 1999 baseline year. 
New Hampshire Regional Haze SIP Revision Page 96 

Best Available Retrofit Technology is Reasonable: BART controls are part of the strategy 

for improving visibility at MANE-VU Class I Areas. MANE-VU prepared reports to provide 

states with information about available control technologies (e.g., MANE-VU’s BART Report 

referenced above), estimated cost ranges, and other factors associated with those controls. 

The reasonable progress goals established in this regional haze SIP assume that states whose 

emissions affect Class I areas in New Hampshire and elsewhere in MANE-VU will make 

determinations demonstrating the reasonableness of BART controls for sources in their states. 

10.2.3 Low-Sulfur Fuel Strategy 

The MANE-VU region, especially the Northeast, is heavily reliant on distillate oil for home 

space heating, with more than 4 million gallons used, according to 2006 estimates from the 

Energy Information Administration26. Likewise, the heavier residual oils are widely used by 

non-EGU sources and, to a lesser extent, the EGU sector. The sulfur content of distillate fuels 

currently averages above 2,000 ppm (0.2 percent). Although the sulfur content of residual 

oils varies by source and region, it can exceed 2.0 percent. Combustion of distillate and 

residual fuel in the MANE-VU states resulted in SO2 emissions totaling approximately 

380,000 tons in 2002.

As the second component of MANE-VU’s long-term strategy, the member states agreed to 

pursue measures that would require the sale and use of fuel oils having reduced sulfur content. 

This strategy would be implemented in two phases: 

• Phase 1 would require reducing the sulfur content in distillate (#1 and # 2) fuel oils 

from current levels of 2,000 to 2,300 ppm (0.20 to 0.23 percent) to a maximum of 500 

ppm (0.05 percent) by weight. It would also restrict the sale of heavier blends of 

residual (# 4, #5, and # 6) fuel oils that have sulfur content greater than 2,500 ppm 

(0.25 percent) and 5,000 ppm (0.5 percent) by weight, respectively. 

• Phase 2 would require further reducing the sulfur content of the distillate fraction from 

500 ppm (0.05 percent) to 15 ppm (0.015 percent) while keeping the sulfur limits on 

residual oils at first-phase levels. 

The two phases are to be introduced in sequence with slightly different timing for an inner zone 

of MANE-VU states27 and the remainder of MANE-VU states. While all MANE-VU states 

have agreed to pursue implementation of both phases to full effect by the end of 2018, it is 

possible that not every state can make a firm commitment to these measures today. States are 

expected to review the situation by the time of the first regional haze SIP progress report in 

2013 and to seek alternate, equivalent reductions if necessary. 

Reductions in sulfur dioxide emissions will occur as a direct consequence of the low-sulfur 

fuel strategy. For both phases combined, it is estimated that SO2 emissions in the MANE-VU 

region will decline from 2002 levels by 168,222 tons per year for combustion of light 

distillates and by 42,875 tons per year for combustion of the heavier fuels. Together, these 

reductions represent a 35 percent decrease in the projected 2018 SO2 emissions inventory for 

non-EGU sources in the region. 

 

26 U.S. Department of Energy, EIA, Table F3a, at http://www.eia.doe.gov/emeu/states/sep_fuel/html/fuel_use_df.html. 

27 The inner zone includes New Jersey, Delaware, New York City, and possibly portions of eastern Pennsylvania. 
New Hampshire Regional Haze SIP Revision Page 97 

NESCAUM analyzed the two program phases separately for MANE-VU, but it is the 

combined benefit of implementing both phases that is relevant to the question of visibility 

improvement by 2018. To estimate the effects of the low-sulfur fuel strategy, MANE-VU 

applied the expected sulfur dioxide emission reductions to all non-EGU sources burning #1, 

#2, #4, #5, or #6 fuel oil. These emission reductions would result directly from the lowering 

of fuel sulfur content from original levels to 0.015 percent for #1 and #2 oil, to 0.25 percent 

for #4 oil, and to 0.5 percent for #5 and #6 oil. 

The reduction in SO2 emissions by 2018 will yield corresponding reductions in sulfate 

aerosol, the main culprit in fine-particle pollution and regional haze. The full benefit of 

MANE-VU-s low-sulfur fuel strategy is represented in Figure 10.1, which displays the 

estimated average reductions in 24-hr PM2.5 concentration as calculated by the CMAQ model 

for the combined first and second phases of the program. 

Figure 10.1: Average Change in 24-hr PM2.5 Due to Low-Sulfur Fuel Strategy 

(Phases 1 and 2 Combined) Relative to OTB/OTW (values in μg/m3) 

Low-Sulfur Fuel Oil Requirements are Reasonable: The MANE-VU Contribution Assessment 

documented source apportionment analyses that linked visibility impairment in MANE-VU 

Class I Areas with SO2 emissions from sources burning fuel oil. The reasonable assumption 

underlying the low-sulfur fuel oil strategy is that refiners can, by 2018, produce home heating 

and fuel oils that contain 50 percent less sulfur for the heavier grades (#4 and #6 residual oil), 

and 75 to 99.25 percent less sulfur in #2 fuel oil (also known as home heating oil, distillate, or 

diesel fuel) at an acceptably small increase in price to the consumer. 
New Hampshire Regional Haze SIP Revision Page 98 

Four-Factor Analysis – Low-Sulfur Fuel Oil Strategy: The MANE-VU Reasonable Progress 

Report discussed the four factors as they apply to low-sulfur fuel use for ICI boilers and 

residential heating systems. MANE-VU’s Reasonable Progress Report identified switching to 

a lower-sulfur fuel oil as an available SO2 control option that would achieve 50 to 90 percent

reductions in SO2 emissions from ICI Boilers. The report also noted that home heating oil use 

generates an estimated 100,000 tons of SO2 emissions in the Northeast each year and that SO2

emissions would decline in proportion to reductions in fuel sulfur content. The following 

discussion summarizes information concerning the four factors for the low-sulfur fuel 

strategy.

1) Low-Sulfur Fuel Oil Strategy – Costs of Compliance: The MANE-VU Reasonable 

Progress report noted that because of requirements for motor vehicle fuels, refineries have 

already performed the capital investments required for the production of low-sulfur diesel 

(LSD) and ultra-low sulfur diesel (ULSD). The report estimated a cost per ton of SO2

removed by switching to lower-sulfur fuel would range from $554 to $734 per ton (converted 

from 2001 to 2006 dollars using a conversion factor of 1.1383). In some seasons and some 

locations, low-sulfur diesel is actually cheaper than regular diesel fuel. (See Chapter 8 of the 

Reasonable Progress Report.) 

The sulfur content of #4 and #6 fuels can also be cost-effectively reduced. Residual oil is 

essentially a byproduct of the refining process and is produced in several grades that can be 

blended to meet a specified fuel sulfur content limit. New York Harbor residual fuel prices 

for the week ending March 21, 2008, ranged from a low of $71.38 a barrel for 2.0 and 2.2 

percent sulfur fuel to a high of $91.38 per barrel for 0.3 percent sulfur fuel28

. 

While the costs of achieving the projected emissions reductions with the low-sulfur fuel 

strategy are somewhat uncertain, they are believed to be reasonable in comparison with the 

costs of controlling other sectors. Some MANE-VU states are proceeding with low-sulfur oil 

requirements much sooner than 2018; however, all of the MANE-VU states concur that a lowsulfur oil strategy is both reasonable and achievable within the MANE-VU region by no later 

than 2018. MANE-VU has concluded that the cost of requiring the use of lower-sulfur fuels 

is reasonable. 

2) Low-Sulfur Fuel Oil Strategy – Time Necessary for Compliance: MANE-VU’s Reasonable 

Progress Report indicated that furnaces and boilers would not have to be retrofit and would 

not require expensive control technologies to burn ULSD distillate fuel oil. Therefore, the 

time necessary for compliance would be determined by the availability of the fuel. 

The MANE-VU Reasonable Progress Report notes that, on a national scale, more ULSD is 

produced than both LSD and high-sulfur fuel, and concludes that the United States has the 

infrastructure to produce adequate stocks of these fuels. NESCAUM’s report, “Low Sulfur 

Heating Oil in the Northeast States: An Overview of Benefits, Costs, and Implementation 

Issues,” December 2005 (Attachment AA) observes that the federal rules for heavy duty 

highway diesel fuel are flexible, so that if there is a shortage of 15 ppm fuel, the 15 to 500 

ppm fuel could be used to relieve the shortage. With this flexibility, the report concludes that 

 

28 During this same period, low-pour (low-temperature, reduced viscosity) residual fuel oil with a 0.5 percent sulfur content 

sold for $80.83 per barrel. Residual oil with a fuel sulfur content limit of 0.7 percent and 1.0 percent traded at $75.13 and 

$72.63, respectively. 
New Hampshire Regional Haze SIP Revision Page 99 

the likelihood of a fuel shortage in the short term due to use of ULSD for heating oil is 

diminished. The volatile nature of heating supply and demand presents unique challenges to 

the fuel oil industry. The success of a low-sulfur fuel oil program is predicated on meeting 

these challenges. The Northeast states are consulting with fuel suppliers and assessing a 

variety of business strategies and regulatory approaches that could be used to minimize any 

potential adverse supply and price impacts that could result from a regional 500 ppm sulfur 

standard for heating oil. Suppliers can increase pre-season reserves of low-sulfur product. 

Blending domestically produced biodiesel into heating oil offers opportunity to reduce 

imports, stabilize supplies and minimize supply-related price spikes. 

Potential supply disruptions and price spikes for residual fuels are a particular concern for 

several northern MANE-VU states. Maine, New Hampshire, and Massachusetts receive a 

significant percentage of their residual fuel supplies from offshore sources during the winter 

months, when barge traffic from New York Harbor is interrupted because of severe weather. 

At these times, residual oil is often imported directly from foreign sources (e.g., Venezuela 

and Russia), and stakeholders have expressed concerns that the supply of low-sulfur residual 

fuels may be insufficient to satisfy demand during these periods. While the potential for 

disruptions in the supply of residual fuels is greater than that for distillate oil, these 

disruptions would affect only a limited number of states during extreme weather events. 

MANE-VU has identified several mechanisms that could be implemented to address 

disruptions, including seasonal averaging and emergency waivers. A seasonal averaging 

approach would reduce potential supply constraints by allowing the use of higher-sulfur fuel 

during periods of peak demand (and limited supply), and then requiring the increased sulfur 

content of these fuels to be offset through the use of a lower-sulfur fuel at other times. This 

approach would provide regulatory certainty and greater flexibility during the winter months 

when fuel supplies may be subject to weather-related disruptions, but at a cost of increased 

recordkeeping and compliance monitoring. Since many states already have statutory 

authority to waive fuel sulfur limits in an emergency, states could also utilize their 

discretionary powers to address short-term supply disruptions. 

Although New Hampshire does not intend to use seasonal averaging, the state would reserve the 

option of pursuing an emergency waiver in a fuel supply disruption and would follow EPA’s 

established procedures for fuel waivers. As described on the agency’s’s fuel waivers website at 

http://www.epa.gov/compliance/resources/faqs/civil/fuelwaiver.html, EPA, with the concurrence 

of the Department of Energy, may temporarily waive a fuel or fuel additive requirement if 

doing so will alleviate the fuel supply emergency. Clean Air Act Section 211(c)(4)(C), which 

authorizes fuels waivers, specifies the criteria for granting a fuel waiver and the conditions 

that must be included in a fuel waiver. In the case of an emergency disruption of low-sulfur 

fuel supplies, NHDES would seek a short-term emergency waiver on fuel sulfur content. To 

the extent feasible, it would be the intent of any such waiver to moderate the degree of 

visibility degradation resulting from temporary use of higher-sulfur fuels in a supply 

disruption. The details would be worked out in response to the particulars of the emergency 

situation at the time of any waiver request. 

To implement the low-sulfur fuel oil strategy, New Hampshire and the other MANE-VU 

states propose a phase-in of the required use of lower-sulfur fuels by 2018, allowing adequate 

time to achieve the strategy’s full effect. 
New Hampshire Regional Haze SIP Revision Page 100 

3) Low-Sulfur Fuel Oil Strategy – Energy and Non-Air Quality Environmental Impacts of 

Compliance: According to MANE-VU’s Reasonable Progress Report, reducing the sulfur 

content of fuel oil would have a variety of beneficial consequences for boilers and furnaces 

using this fuel. Low-sulfur distillate fuel is cleaner burning and emits less particulate matter, 

thereby reducing the rate of fouling of heating units and allowing longer time intervals 

between cleanings. The MANE-VU report cites a study by the New York State Energy 

Research and Development Authority (NYSERDA) that showed that boiler deposits are 

reduced by a factor of two by lowering the fuel sulfur content from 1,400 ppm to 500 ppm. 

The use of low-sulfur oil could extend the useful life of a source by reducing the maintenance 

required because low-sulfur oil is less damaging to the combustion equipment. 

The report also notes that decreasing sulfur levels in fuel would enable manufacturers to 

develop more efficient furnaces and boilers by using more advanced condensing equipment 

that recovers energy normally lost to the heating of water vapor in the exhaust gases. In 

addition, SO2 controls would have beneficial environmental impacts by reducing acid 

deposition and helping to decrease ambient concentrations of PM2.5. Reductions in PM2.5

resulting from use of low-sulfur fuels could help nonattainment areas meet health-based 

National Ambient Air Quality Standards. 

4) Low-Sulfur Fuel Oil Strategy – Remaining Useful Life of Any Potentially Affected Sources: 

Residential furnaces and boilers have finite life spans, but they do not need to be replaced to 

burn low- or ultra-low-sulfur fuel oil. The Energy Research Center estimates that the average 

life expectancy of a residential heating oil boiler is 20-25 years. As noted above, use of lowsulfur fuel is less damaging to equipment and could therefore extend the useful life of an oilfired residential furnace or boiler. 

Available information on the remaining useful life of ICI boilers indicates a wide range of life 

expectancies, depending on unit size, capacity factor, and level of maintenance performed. 

(Capacity factor is defined as the actual amount of energy a boiler generates in one year 

divided by the total amount it could generate if it ran full time at full capacity.) The typical 

life expectancy of an ICI boiler ranges from 10 years to more than 30 years. As in the case of 

residential units, use of lower-sulfur fuels could extend the life span of an ICI boiler. 

10.2.4 Targeted EGU Strategy for SO2 Reduction 

Electrical generating units (EGUs) are the single largest sector contributing to visibility 

impairment at MANE-VU’s Class I Areas. SO2 emissions from power plants continue to 

dominate the emissions inventory. Sulfate formed through atmospheric processes from SO2

emissions are responsible for over half the mass and approximately 70-80 percent of visibility 

extinction on the days of worst visibility (see NESCAUM’s Contribution Assessment, 

Attachment B). 

To ensure that EGU control measures are targeted at those units having the greatest impact on 

visibility at MANE-VU Class I Areas, a CALPUFF modeling analysis was conducted to 

identify the individual sources responsible for the highest contributions to visibility degradation. 

Accordingly, MANE-VU developed lists of the 100 EGU emission points (stacks) having the 

largest impacts at each MANE-VU Class I Area during 2002. The combined list for all seven 

MANE-VU Class I Areas identified a total of 167 distinct emission points. These 167 stacks 

are spread across the Northeast, Southeast, and Midwest (Figure 10.2). 
New Hampshire Regional Haze SIP Revision Page 101 

Figure 10.2: 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. 

After consultations with its member states and with other RPOs, MANE-VU requested a 90-

percent reduction in SO2 emissions from the top 167 stacks by no later than 2018 (see the 

MANE-VU “Ask”). NESCAUM’s preliminary modeling for MANE-VU showed that SO2

emission reductions of this magnitude from the targeted facilities would produce substantial 

improvements in ambient 24-hour PM2.5 concentrations. Assuming a control level equal to 10 

percent of the 2002 baseline emissions (i.e., 90-percent emission reduction), NESCAUM used 

CMAQ to model sulfate concentrations in 2018 after implementation of controls. The modeled 

sulfate values were then converted to estimates of PM2.5 concentration. Figure 10.3 displays the 

predicted average change in 24-hr PM2.5. 

The map illustrates the reductions in fine-particle pollution in the Eastern U.S. that would result 

from implementation of the targeted EGU strategy for SO2. Improvements in PM2.5 levels 

would occur throughout the MANE-VU region and portions of the VISTAS and MRPO 

regions, especially along the Ohio River Valley. 
New Hampshire Regional Haze SIP Revision Page 102 

Figure 10.3: Preliminary Estimate of Average Change in 24-hr PM2.5 Resulting from a 

90-Percent Reduction in SO2 Emissions from the Top 167 EGU Stacks 

Affecting MANE-VU Class I Areas 

Although the reductions would be both advantageous and potentially large, MANE-VU 

determined, after further consultation with affected states, that it was unreasonable to expect 

that the full 90-percent reduction in SO2 emissions would be achieved by 2018. Therefore, 

additional modeling was conducted to assess the more realistic scenario in which emissions 

would be controlled by the individual facilities and/or states to levels already projected to take 

place by that date. At some facilities, the actual emission reductions are anticipated to be 

greater or less than the 90 percent benchmark. For details, see Alpine Geophysics’ report for 

MARAMA entitled, “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 (Attachment H).

Targeted EGU SO2 Reduction Strategy Controls are Reasonable: MANE-VU identified 

specific EGU stacks that were significant contributors to visibility degradation at MANE-VU 

Class I Areas in 2002. The CALPUFF modeling analyses identifying potentially significant 

contributing sources are documented in the Contribution Assessment. MANE-VU obtained 

information about existing and planned controls on emissions from those stacks. These 

analyses and information on proposed EGU controls are presented in MANE-VU’s 

Reasonable Progress Report and the Contribution Assessment as well as in Section 6, 

Emissions Inventory, and Section 11, Long-Term Strategy section of this SIP. 
New Hampshire Regional Haze SIP Revision Page 103 

Based on information gathered from the states and regional planning organizations, MANEVU anticipated that emissions from many of the targeted EGU stacks would be subject to 

EPA’s Clean Air Interstate Rule (CAIR). However, because CAIR was a cap-and-trade 

program, it was not possible to predict with certainty which of the 167 stacks would actually be 

controlled under CAIR in 2018. 

Four-Factor Analysis – Targeted EGU SO2 Reduction Strategy: The following discussion 

addresses each of the four factors with respect to the strategy of controlling specific EGUs. 

Information is taken primarily from the MANE-VU Reasonable Progress Report (Attachment 

Y) and MANE-VU BART Report (Attachment Z). 

1) Targeted EGU SO2 Reduction Strategy – Costs of Compliance: Technologies to control the 

precursors of regional haze are commercially available today. Because EGUs are the most 

significant stationary source of SO2, NOX, and PM, they have been subject to extensive 

federal and state regulations to control all three pollutants. The technical feasibility of control 

technologies has been successfully proven for a substantial number of small (e.g., 100 MW) 

to very large (over 1,000 MW) boilers burning different types of coal. Over the last few 

years, the cost data clearly indicate that many technologies provide substantial and costeffective emission reductions.

Both wet and dry scrubbers are in wide commercial use in the U.S. for controlling SO2

emissions from coal-fired power plants. The capital costs for new or retrofit wet or dry 

scrubbers are higher than the capital costs for NOX and PM controls. The MANE-VU BART 

report found that the capital costs of scrubbers ranged from $180/kW for large units (greater 

than 600 MW) to as high as $350/kW for small units (200 to 300 MW). Typical costs were in 

the range of 200 to 500 dollars per ton of SO2 removed, but rose steeply for small units 

burning lower-sulfur coal and operating at low capacity factors. (See pages 2-22 through 2-25 

of the BART Report, Attachment Z). 

The MANE-VU Reasonable Progress Report (Attachment Y) reviewed options for controlling 

coal-fired EGU boilers, including switching to lower-sulfur coal, switching to natural gas, 

coal cleaning, and flue gas desulfurization (FGD). The most effective control option (but not 

necessarily appropriate for all installations) is FGD, which can achieve up to 95 percent 

reduction in SO2 emissions. The costs of different technologies vary considerably among 

units and were estimated to range from as low as $170/ton to as high as $5,700/ton. 

Table 10.4 summarizes the estimated costs of controlling SO2 emissions, expressed in dollars 

per ton of SO2 removed. 
New Hampshire Regional Haze SIP Revision Page 104 

Table 10.4: Estimated Cost Ranges for SO2 Control Options for Coal-Fired EGU Boilers 

(2006 dollars per ton of SO2 removed) 

To predict future emissions and further evaluate the costs of emission controls for electric 

generating units, MANE-VU and other RPOs have followed the example of the US 

Environmental Protection Agency (EPA) in using the Integrated Planning Model (IPM®), an 

integrated economic and emissions model for EGUs. This model projects electricity supplies 

based on various assumptions while at the same time developing least-cost solutions to 

electrical generating needs within specified emissions targets. IPM also provides estimates of 

the costs of complying with various policy requirements. 

EPA developed IPM version 2.1.9 and used this model to evaluate the impacts of CAIR and 

the Clean Air Mercury Rule (CAMR). (Note that CAMR was vacated by the federal courts 

and is no longer in effect.) Recently, EPA updated their input data and developed IPM v.3.0. 

However, because of time constraints, all MANE-VU runs were based on EPA IPM v.2.1.9 

with changes made to the input assumptions. 

The RPOs collaborated with one another to update the inputs to IPM v.2.1.9 using more 

current data on the EGUs and more realistic fuel prices. The resulting IPM run is called 

VISTAS PC_1f. This IPM run serves as the basis for regional air quality modeling for ozone 

and haze SIPs in MANE-VU and the OTC. 
New Hampshire Regional Haze SIP Revision Page 105 

MANE-VU, through MARAMA, contracted with the consulting firm ICF Resources, L.L.C. 

to prepare two new IPM runs, as documented in “Comparison of CAIR and CAIR Plus 

Proposal using the Integrated Planning Model (IPM®),” Final Draft Report, May 30, 2007 

(Attachment BB). The first run, known as the MARAMA CAIR Base Case run (also known 

as MARAMA_5c), was based on the VISTAS PC_1f run and underlying EPA IPM v.2.1.9 

with some updated information on fuel prices, control constraints, etc. The second run, called 

the MARAMA CAIR Plus run (also known as MARAMA_4c), was similarly based on 

VISTAS PC_1f run and the underlying EPA IPM v.2.1.9. The MARAMA CAIR Plus run 

included updated information used in the VISTAS run but assumed lower NOX emission caps 

and higher SO2 retirement ratios. 

Based on the modeling results, MANE-VU estimates that the marginal cost of SO2 emission 

reductions (the cost of reducing one additional ton of emissions) ranges from $640/ton in 

2008 to $1,392/ton in 2018 (see Table 6, “Allowance Prices (Marginal Costs) of Emissions 

Reductions...,” in Attachment BB). 

Costs will vary for individual plants to reduce emissions by 90 percent, as recommended in 

the New Hampshire/MANE-VU Ask. However, this strategy provides states with flexibility 

to pursue controls on specific sources as appropriate and to control emissions from alternative 

sources, if necessary, to meet the 90 percent target established in the Ask. 

Given the importance of SO2 emissions from specific EGUs to visibility impairment in 

MANE-VU Class I Areas, the MANE-VU Commissioners, after weighing all factors – the 

availability of technology to reduce emissions, the estimated costs of controls, the costs of 

alternative measures, the flexibility to achieve alternative reductions if necessary, etc. – 

concluded that the costs of the targeted EGU strategy are reasonable. New Hampshire agrees 

with this conclusion. 

2) Targeted EGU SO2 Reduction Strategy – Time Necessary for Compliance: MANE-VU’s 

Reasonable Progress Report indicates that, generally, sources are given a 2- to 4-year phase-in 

period to comply with new rules. Under Phase I of the NOX SIP call, EPA provided a 

compliance date of about 31⁄2 years from the SIP submittal date. Most MACT standards allow 

a 3-year compliance period. Under Phase II of the NOX SIP Call, EPA provided for 2-year 

compliance period from the SIP submittal date. New Hampshire concludes that there is more 

than sufficient time between 2008 and 2018 for affected states to adopt requirements and for 

affected sources to install necessary controls.

3) Targeted EGU SO2 Reduction Strategy – Energy and Non-Air Quality Environmental 

Impacts of Compliance: The MANE-VU Reasonable Progress Report identified several 

energy and non-air quality impacts from additional EGU controls. Large-scale fuel switching 

could potentially impact fuel supplies. Flue gas desulfurization systems may generate 

wastewater and sludge (which is sometimes recycled as a useful byproduct). On the other 

hand, SO2, NOX, and ammonia controls would have beneficial environmental impacts by 

reducing acid deposition and nitrogen deposition to water bodies and natural land areas. 

Emission reductions for these pollutants would also produce decreases in ambient levels of 

PM2.5 and result in corresponding health benefits. Similarly, mercury emissions may be 

reduced by the addition of controls for other pollutants. New Hampshire concludes that the 

energy and non-air quality impacts of additional EGU controls are reasonable. 
New Hampshire Regional Haze SIP Revision Page 106 

4) Targeted EGU SO2 Reduction Strategy – Remaining Useful Life of Any Potentially Affected 

Sources: As noted in the MANE-VU Reasonable Progress Report, remaining useful life 

estimates of EGU boilers indicate a wide range of operating lifetimes, depending on unit size, 

capacity factor, and level of maintenance performed. Typical life expectancies range to 50 

years or more. Additionally, implementation of air pollution regulations over the years has 

necessitated emission control retrofits that have increased the expected life spans of many 

EGUs. The lifetime of an EGU may be extended through repair, re-powering, or other 

strategies if the unit is more economical to run than to replace with power from other sources. 

Extending facility lifetime may be particularly likely for a unit serving an area with limited 

transmission capacity to bring in other power. 

10.2.5 Non-EGU SO2 Emissions Reduction Strategy for Non-MANE-VU States 

In addition to the measures described above (i.e., BART, low-sulfur fuel, and targeted EGU 

controls), New Hampshire asked states in neighboring regional planning organizations to 

consider further non-EGU emission reductions comparable to those achieved by MANE-VU 

states through application of MANE-VU’s low-sulfur fuel strategy. Previous modeling 

indicated that the MANE-VU low-sulfur fuel strategy would achieve a greater than 28- 

percent reduction in non-EGU SO2 emissions by 2018. After consultation with other states 

and consideration of comments received, MANE-VU decided to include, in the latest 

modeling for the VISTAS and MRPO regions, implementation of control measures capable of 

achieving SO2 emission reductions equivalent to MANE-VU’s 28-percent reduction in nonEGU SO2 emissions in 2018. 

To model the effects of this strategy on visibility at MANE-VU Class I Areas, MANE-VU 

had to make reasonable assumptions about where the requested emission reductions would 

occur in the VISTAS and MRPO states without knowing precisely how those reductions 

would be realized. As a way to represent approximately a 28-percent reduction in non-EGU 

SO2 emissions, the following reductions were modeled: 

• For control measures in VISTAS and MRPO states: 

− Coal-fired ICI boilers: SO2 emissions were reduced by 60 percent. 

− Oil-fired ICI boilers: SO2 emissions were reduced by 75 percent. 

− ICI boilers lacking fuel specification: SO2 emissions were reduced by 50 percent. 

• For additional controls only in the VISTAS states: SO2 emissions from other oil-fired 

area sources were reduced by 75 percent (based on the same SCCs identified in 

MANE-VU’s oil strategies list). 

This modeling scenario represents just one example of realistic strategies that states outside of 

MANE-VU could employ to meet the non-EGU SO2 emissions reductions requested by 

MANE-VU. 

New Hampshire acknowledges that a number of non-MANE-VU states have not included, or 

may not include, the requested 28-percent reduction in non-EGU SO2 emissions in their State 

Implementation Plans at the present time. New Hampshire expects these states to revisit the 

MANE-VU Ask in the course of future regional haze SIP revisions and to make commitments 

to this request where feasible. NHDES will continue to monitor other states’ actions with 

respect to regional haze planning. In time, actual reductions could turn out to be greater or 

less than the MANE-VU Ask. If necessary, New Hampshire will adjust its reasonable 
New Hampshire Regional Haze SIP Revision Page 107 

progress goals and long-term strategy at a later date to be consistent with programs 

implemented by the non-MANE-VU states. Any such adjustments would be incorporated 

into New Hampshire’s first regional haze SIP revision in 2013. 

Non-EGU SO2 Emission Reduction Measures Outside MANE-VU are Reasonable: After 

EGUs, ICI boilers are the next largest class of SO2 emitters. ICI boilers are thus a logical 

choice among non-EGU sources for consideration of additional SO2 control measures. 

ICI Boiler Control Options: Air pollution reduction and control technologies for ICI boilers 

have advanced substantially over the past 25 years. However, according to a 1998 survey of 

industrial boilers by EPA (2004), only 2 percent of gas-fired boilers and 3 percent of oil-fired 

boilers had installed any kind of air pollution control device. A larger percentage of coalfired boilers had installed air pollution controls: specifically, 47 percent had installed some 

type of control device, mainly to control particulate matter (PM). Post-combustion SO2

controls were used by less than one percent of industrial boilers in 1998, with the exception of 

boilers firing petroleum coke (2 percent of boilers using this fuel had acid scrubbers). A small 

percentage of industrial boilers had combustion controls in place in 1998, although additional 

low-NOX firing systems may have been installed since that date. 

Almost all SO2 emission control technologies fall into the category of reducing SO2 after its 

formation as opposed to minimizing its formation during combustion. The method of SO2

control appropriate for any individual ICI boiler is dependent upon the type of boiler, type of 

fuel, capacity utilization, and the types and staging of other air pollution control devices. 

However, cost-effective emission reduction technologies for SO2 are available and are 

effective in reducing emissions from the exhaust gas stream of ICI boilers. Post-combustion 

SO2 control is accomplished by reacting the SO2 in the gas with a reagent (usually calcium- or 

sodium-based) and removing the resulting product (a sulfate/sulfite) for disposal or 

commercial use, depending on the particular technology. SO2 reduction technologies are 

commonly referred to as flue gas desulfurization (FGD) and are usually described in terms of 

the process conditions (wet versus dry), byproduct utilization (throwaway versus saleable) 

and reagent utilization (once-through versus regenerable). 

The exceptions to the nearly universal use of post-combustion controls are found in fuel 

switching, coal cleaning, and fluidized bed boilers, in which limestone is added to the fuel in 

the combustion chamber. Both pre- and post-combustion SO2 emission control alternatives 

for ICI boilers are outlined in Table 10.5. Further description of these technology options is 

available in Chapter 4 of the MANE-VU Reasonable Progress Report (Attachment Y). 

The SO2 removal efficiency of these controls varies from 20 to 99+ percent depending on the 

fuel type and control technology. For coal-fired boilers, options include switching to lowsulfur coal, coal cleaning, wet FGD, dry FGD, and spray dryers. The overall SO2 reductions 

vary from a low of 20 to 25 percent for fuel switching to a high of 60 to 95 percent for wet 

FGD and spray dry FGD. The majority of control strategies, however, are capable of 

achieving a 60 percent or greater reduction. Thus, assuming that coal-fired ICI boilers adopt 

varying levels of controls, with most choosing a 50- to 70- percent reduction strategy and 

fewer choosing either the 20-percent or the 90-percent reduction strategy, the region-wide 

average would be likely to fall in the vicinity of a 60- percent reduction in SO2 emissions. 

This assumption is validated by data showing that wet FGD systems represent 85 percent of 

the FGD systems in use in the United States and that these systems have an average SO2

removal efficiency of 78 percent. MANE-VU’s modeling of a 60-percent reduction in SO2

emission from coal-fired ICI boilers is therefore reasonable. 
New Hampshire Regional Haze SIP Revision Page 108 

Table 10.5: Available SO2 Control Options for ICI Boilers 

For oil-fired boilers, options include switching to a lower-sulfur fuel (e.g., oil or natural gas), 

dry FGD, and spray dryers. The overall SO2 reductions vary from a low of 40 to 60 percent 

for dry FGD to a high of 60 to 95 percent for spray dry FGD. For comparison, the MANEVU low-sulfur fuel strategy assumes a 50- to 90- percent reduction in SO2 emissions from oilfired ICI boilers. Assuming a normal distribution of control strategies chosen by the sources, 

MANE-VU’s modeling of an average 75-percent reduction in SO2 emission from oil-fired ICI 

boilers is reasonable. 

For ICI boilers in which a fuel was not specified, a 50-percent reduction in SO2 emissions was 

assumed. ICI boilers in this category include those outside the MANE-VU region for which 

the current inventory did not specify the type of fuel burned. Because a response from the 

MRPO was not received, this assumption also encompasses some of the uncertainty regarding 

the implementation of MANE-VU’s non-EGU Ask. Given the paucity of data, a lower 

reduction in SO2 emissions (50 percent) was assumed for this category than for coal- or oilfired ICI boilers. Implementation of one or more of the suggested SO2 control options to 

achieve, on average, a 50-percent reduction in SO2 emissions at these sources is a reasonable 

assumption. 

For emissions from other area oil-combustion sources in the VISTAS region, an SO2 

reduction of 75 percent was assumed. This reduction is equal to the reduction that would 

Technology Description Applicability Performance 

Flue Gas Desulfurization 

(FGD) - Dry

Powdered lime or other 

suitable sorbent is injected 

directly into flue gas

Applicable primarily for 

boilers currently firing low 

to medium sulfur fuels

40-60% reduction in SO2 

emissions

Flue Gas Desulfurization 

(FGD) - Spray Dry

A fine mist containing lime or 

other suitable sorbent is 

injected directly into flue gas

Applicable primarily for 

boilers currently firing low 

to medium sulfur fuels

60-95%+ reduction in SO2 

emissions 

Flue Gas Desulfurization 

(FGD) - W et

SO2 is removed from flue 

gas by dissolving it in a lime 

or limestone slurry. (Other 

alkaline chemical are 

sometimes used) 

Applicable to all coal-fired 

ICI boilers

30-95%+ reduction in SO2 

emissions 

Combustion Control A reactive material, such as 

limestone or bi-carbonate, is 

introduced into the 

combustion chamber along 

with the fuel

Applicable to pulverized 

coal-fired boilers and 

circulating fluidized bed 

boilers 

40%-85% reductions in SO2 

emissions

Coal Cleaning Coal is washed to remove 

some of the sulfur and ash 

prior to combustion 

Potential control measure 

for all coal-fired ICI boilers 

20-25% reduction in SO2 

emissions

Switch to a Lower Sulfur Oil Replace higher-sulfur 

residual oil with lower-sulfur 

distillate oil. Alternatively, 

replace medium sulfur 

distillate oil with ultra-low 

sulfur distillate oil

Potential control measure 

for all oil-fired ICIs 

currently using higher 

sulfur content residual or 

distillate oils 

50-80% reduction in SO2 

emissions by switching to a 

lower-sulfur oil 

Switch to Natural Gas 

(virtually 0% sulfur)

Replace coal combustion 

with natural gas

Potential control measure 

for all coal-fired ICIs 

Virtually eliminate SO2 

emissions by switching to 

natural gas 

Switch to a Low Sulfur Coal 

(generally <1% sulfur)

Replace high-sulfur 

bituminous coal combustion 

with lower-sulfur coal

Potential control measure 

for all coal-fired ICIs 

currently using coal with 

high sulfur content 

50-80% reduction in SO2 

emissions by switching to a 

lower-sulfur coal
New Hampshire Regional Haze SIP Revision Page 109 

result from implementing the MANE-VU low-sulfur fuel strategy for this sector. The fourfactor analysis for the low-sulfur fuel strategy was described in Part 10.2.3 of this section. 

Four-Factor Analysis – Non-EGU SO2 Emission Reduction Measures Outside MANE-VU: 

Based on the survey of available technologies outlined above and the four-factor analyses 

summarized below, MANE-VU concludes that each of the strategies assumed for modeling 

purposes to meet the New Hampshire/MANE-VU Ask of a 28-percent reduction in non-EGU 

SO2 emissions is reasonable. States should have no difficulty in meeting this benchmark in 

light of the control efficiencies that are attainable at reasonable costs with retrofit technologies 

that are available for ICI boilers today. 

1) Non-EGU SO2 Emission Reduction Measures outside MANE-VU – Costs of Compliance: 

Industrial boilers have a wider range of sizes than EGUs and often operate over a wider range 

of capacities. Thus, cost estimates for the same technologies will generally span a relatively 

larger range, and costs for an individual boiler will depend on the capacity of the boiler and 

typical operating conditions. In general, cost-effectiveness increases as boiler size and 

capacity factor (a measure of boiler utilization) increases. 

MANE-VU’s Reasonable Progress Report (Attachment Y) provides emission control cost 

estimates for ICI boilers in the range of $130 to $11,000 per ton of SO2 removed, a very wide 

spread due to the variability of sources and control options in this category. All costs 

presented below for emission controls on ICI boilers are borrowed from this report. Dollar 

amounts originated from EPA publications cited in the report and are restated in 2006 dollars 

using appropriate adjustment factors found at www.inflationdata.com. 

◊ Cost of Fuel Switching: Although fuel switching can be a very effective means of 

controlling SO2 emissions (reductions of 50 to 99.9 percent are possible), burning low-sulfur 

fuel may not be technically feasible or economically practical as an SO2 control option for 

every coal-fired boiler. Factors impacting applicability include the characteristics of the plant 

and the particular type of fuel change being considered. Additionally, switching to a lowersulfur coal can affect fuel handling systems, boiler performance, PM control effectiveness, 

and ash handling systems. Oil-fired boilers switching to a lower-sulfur fuel of the same grade 

(e.g., switching from #6 fuel oil at 2.0% S to #6 fuel oil at 0.5% S) do not typically encounter 

these issues. (See Part 10.2.3 for a discussion of the costs and issues associated with switching 

to low-sulfur fuel oil.) 

The costs of coal fuel switching, including substitution or blending with a low-sulfur coal, can 

be attributed to two main factors: the cost of low-sulfur coal compared to higher-sulfur coal 

(including consideration of the coal’s heating value), and the cost of necessary boiler or coalhandling equipment modifications. Many plants will be able to switch from high-sulfur to 

low-sulfur bituminous coal without serious difficulty, but switching from bituminous to 

subbituminous coal may require potentially significant investments and modifications to an 

existing plant. Even if a lower-sulfur fuel is available, it may not be cost competitive if it 

must be supplied in small quantities or transported long distances from the supplier. It also 

may be more cost-effective to burn a higher-sulfur fuel supplied by nearby suppliers and to 

use a post-combustion control device. 

Switching from coal combustion to natural gas combustion virtually eliminates SO2

emissions. It is technically feasible to switch from coal to natural gas; but it is currently 

uneconomical to consider this option for large ICI boilers because of the required equipment 
New Hampshire Regional Haze SIP Revision Page 110 

modifications, the fuel quantities necessary, and the generally higher price of natural gas 

compared to coal. 

◊ Cost of Coal Cleaning: The World Bank, an organization which assists with economic and 

technological needs in developing countries, reports that the cost of physically cleaning coal 

varies from $1 to $10 per ton of coal cleaned, depending on the coal quality, the cleaning 

process used, and the degree of cleaning desired. In most cases, the costs were found to be 

between $1 and $5 per ton of coal cleaned. Coal cleaning typically results in a 20- to 25-

percent reduction in SO2 emissions and increases the heating value of the fuel by a small 

amount. 

◊ Cost of Combustion Controls: Dry sorbent injection (DSI) systems have lower capital and 

operation costs than post-combustion FGD systems because of the simplicity of the DSI 

design, lower water use needs, and smaller land area requirements. Table 10.6 presents the 

estimated costs of adding DSI-based SO2 emission controls to ICI boilers for different boiler 

sizes, fuel types, and capacity factors. 

Table 10.6: Estimated Costs of Dry Sorbent Injection (DSI) for ICI Boilers (2006 dollars) 

Cost-Effectiveness ($/ton of SO2 removed) 

Fuel 

SO2

Reduction 

(%) 

Capacity 

Factor 

(%) 

100 

MMBtu/hr 

250 

MMBTU/hr 

1,000 

MMBTU/hr 

14 4,686 3,793 2,979 

2%-Sulfur Coal 40 50 1,312 1,062 834 

83 772 624 490 

14 2,732 2,212 1,737 

3.43%-Sulfur Coal 40 50 765 619 486 

83 450 364 286 

14 2,205 1,786 1,402 

2%-Sulfur Coal 85 50 617 500 392 

83 363 294 231 

14 1,286 1,040 818 

3.43%-Sulfur Coal 85 50 360 291 229 

83 212 171 134 

Note: Data as compiled and presented in Table 4.3 of MACTEC Federal Programs, Inc., “Assessment 

of Reasonable Progress for Regional Haze in MANE-VU Class I Areas,” Final, July 9, 2007. 

◊ Cost of FGD: Installation of post-combustion SO2 controls in the form of FGD has several 

impacts on facility operations, maintenance, and waste handling procedures. FGD systems 

generally require substantial land area for construction of the absorber towers, sorbent tanks, 

and waste handling equipment. The facility costs therefore depend on the cost and 

availability of space for construction of the FGD system. In addition, significant quantities of 

waste material may be generated that require disposal. The costs may be mitigated, however, 

by utilization of a forced oxidation FGD process that produces commercial-grade gypsum, 

which may be sold as a raw material for other commercial processes. 

Table 10.7 presents the total estimated cost-per-ton of adding FGD-based SO2 emission 

controls to ICI boilers for different boiler sizes, fuel types, and capacity factors. There is no 
New Hampshire Regional Haze SIP Revision Page 111 

indication that these cost data include possible revenues from gypsum sales, which would 

partially offset the costs of FGD controls. 

Carbon dioxide is also emitted as a byproduct of FGD; therefore, the impacts of increased 

carbon emissions associated with this technology would need to be considered. CO2 emissions 

will become more of an issue in the future if they are limited under climate change mitigation 

strategies. Given the uncertainty of such future strategies, costs related to increased carbon 

emissions from FGD cannot yet be assessed. 

MANE-VU’s request for a 28-percent reduction in non-EGU SO2 emissions allows states 

flexibility in determining which sources to control, so that the most cost-effective control 

measures can be adopted and implemented over the next 10 years. Given the wide range of 

control options and costs available for this purpose, MANE-VU has concluded that the 

request for a 28-percent reduction in non-EGU SO2 emissions is reasonable. New Hampshire 

concurs with this conclusion. 

Table 10.7: Estimated Costs of Flue Gas Desulfurization for ICI Boilers (2006 dollars) 

Cost-Effectiveness ($/ton of SO2 removed) 

Fuel Technology 

SO2

Reduction 

(%) 

Capacity 

Factor 

(%) 

100 

MMBtu/hr 

250 

MMBTU/hr 

1,000 

MMBTU/hr 

14 3,781 2,637 1,817 

50 1,379 1,059 828 High-Sulfur 

Coal a FGD (dry) 40 

83 1,006 814 676 

14 4,571 3,150 2,119 

50 1,605 1,207 928 Lower-Sulfur 

Coal b FGD (dry) 40 

83 1,147 906 744 

14 4,183 2,786 1,601 

Coal 50 1,290 899 567 FGD 

(spray dry) 90 

83 843 607 407 

14 3,642 2,890 1,909 

50 1,116 875 601 High-Sulfur 

Coal 

FGD 

(spray dry) 90 

83 709 563 398 

14 4,797 3,693 2,426 

50 1,415 1,106 751 Lower-Sulfur 

Coal FGD (wet) 90 

83 892 705 492 

14 10,843 8,325 5,424 

Oil 50 2,269 1,765 1,184 c FGD (wet) 90 

83 1,371 1,079 740 

Note: Data as compiled and presented in Table 4.4 of MACTEC Federal Programs, Inc., “Assessment of 

Reasonable Progress for Regional Haze in MANE-VU Class I Areas,” Final, July 9, 2007. 

a

 Assumes sulfur content = 3.43% and ash content = 12.71%. 

b

 Assumes sulfur content = 2.0% and ash content = 13.2%. 

c

 Sulfur content of oil is not specified.
New Hampshire Regional Haze SIP Revision Page 112 

2) Non-EGU SO2 Emission Reduction Measures outside MANE-VU – Time Necessary for 

Compliance: For pre- and post-combustion SO2 emission controls, engineering and 

construction lead times will vary between 2 and 5 years, depending on the size of the facility 

and specific control technology selected. Generally, sources are given a 2- to 4- year phase-in 

period to comply with new rules, as previously described, and states generally have a 2-year 

period for compliance with RACT rules. 

For the purposes of this review, it is assumed that a 2-year period after SIP submittal is 

adequate for pre-combustion controls (fuel switching or cleaning), and a 3-year period is 

adequate for the installation of post-combustion controls. MANE-VU has therefore 

concluded that there is sufficient time between 2008 and 2018 for affected states to adopt 

emission control requirements and for affected sources to install the necessary controls to 

meet MANE-VU’s requested SO2 emission reductions from non-EGU sources. New 

Hampshire concurs with this conclusion. 

3) Non-EGU SO2 Emission Reduction Measures Outside MANE-VU – Energy and Non-Air 

Quality Environmental Impacts of Compliance: The primary energy impact of pre- or postcombustion control alternatives is a potential increase in electricity usage. Fuel switching and 

cleaning do not significantly affect the efficiency of the boiler itself, but require additional 

energy to clean or blend coal. FGD systems typically operate with high-pressure drops across 

the control equipment and therefore consume significant amounts of electricity to operate 

blowers and circulation pumps. In addition, some combinations of FGD technology and plant 

configuration may require flue gas reheating to prevent physical damage to equipment, 

resulting in higher fuel usage. 

The primary non-air environmental impacts of fuel switching derive from transportation of 

the fuel. Secondary environmental impacts derive from waste disposal and material handling 

operations (e.g. fugitive dust). For FGD systems, the generation of wastewater and sludge 

from the SO2 removal process is a consideration. Wastewater from the FGD systems will 

increase sulfate, metals, and solids loading at the receiving wastewater treatment facility, 

resulting in potential impacts to operating cost, energy requirements, and effluent water 

quality. Processing of the wastewater sludge can require energy for stabilization and/or 

dewatering, and transporting the dewatered sludge to a landfill has additional environmental 

implications. 

Fuel switching to a low-sulfur distillate fuel oil has a variety of beneficial consequences for 

ICI boilers. Low-sulfur distillate fuel is cleaner burning and emits less particulate matter, 

which reduces the rate of fouling of heating units substantially and permits longer time 

intervals between cleanings. According to a study conducted by NYSERDA (reference 10 in 

Attachment AA), boiler deposits are reduced by a factor of two by lowering the fuel sulfur 

content from 1,400 ppm to 500 ppm. These reductions in buildup of deposits result in longer 

service intervals between cleanings. 

Reducing SO2 emissions from ICI boilers would have positive environmental and health 

impacts. SO2 controls would reduce acid deposition, helping to preserve aquatic life, forests, 

and crops as well as buildings and sculptures made of acid-sensitive materials. These 

emission reductions would also help to decrease ambient levels of PM2.5, a significant 

contributor to premature morbidity and illness in individuals with heart or lung conditions. 
New Hampshire Regional Haze SIP Revision Page 113 

MANE-VU has concluded that the energy and non-air environmental impacts of controlling 

SO2 emissions from ICI boilers are justified in light of the beneficial impacts on regional haze, 

fine particulate air pollution, acid rain, and equipment operation, as described above. New 

Hampshire concurs with this conclusion. 

4) Non-EGU SO2 Emission Reduction Measures Outside MANE-VU – Remaining Useful Life 

of Any Potentially Affected Sources: Available information for remaining useful life estimates 

of ICI boilers indicates a wide range of life expectancies, depending on unit size, capacity 

factor, and level of maintenance performed. Typical life spans range from about 10 years to 

over 30 years. However, the remaining useful life of a specific source is highly variable; and 

older units are not likely to be retrofitted with expensive emission controls. Given the typical 

range of life expectancies of ICI boilers, the technical options available, and the flexibility 

that non-MANE-VU states would have to meet the Ask, MANE-VU has concluded that a 28-

percent reduction in non-EGU SO2 emissions is reasonable. New Hampshire concurs with 

this conclusion. 

10.3 Reasonable Progress Goals for Class I Areas in the State 

As required under 40 CFR 51.308(d)(1), this regional haze SIP establishes reasonable 

progress goals for Class I areas in New Hampshire for the 10-year period of the 

implementation plan ending in 2018. These RPGs are determined from modeling based on 

implementation of the proposed reasonable measures included in MANE-VU’s long-term 

strategy. Table 10.8 provides a summary of the reasonable progress goals, in deciviews, for 

New Hampshire’s two Class I areas: Great Gulf Wilderness and Presidential Range - Dry 

River Wilderness. 

Table 10.8: Reasonable Progress Goals for Great Gulf Wilderness and 

Presidential Range - Dry River Wilderness (all values in deciviews) 

Visibility Condition 

Natural 

Visibility 

2000-2004 

Baseline 

Visibility 

RPG 

(Visibility 

Expected by 

2018) 

Visibility 

Improvement 

Expected by 

2018 

20 Percent Worst Days 

(Average) 12.0 22.8 19.1 3.7 

20 Percent Best Days 

(Average) 3.7 7.7 7.2 0.5 

Both natural conditions and baseline visibility for the 5-year period from 2000 through 2004 

were calculated in conformance with an alternative method recommended by the IMPROVE 

Steering Committee. (See Attachment L, “Baseline and Natural Visibility Conditions: 

Considerations and Proposed Approach to the Calculation of Baseline and Natural Visibility 

Conditions at MANE-VU Class I Areas,” December 2006.) Future progress toward the 2018 

visibility target will be calculated in a nationally consistent manner based on 5-year averages 

in accordance with EPA’s “Guidance for Tracking Progress Under the Regional Haze Rule” 

(EPA-454/B-03-004, September 2003) with adjustments for the alternative method as 

recommended by the IMPROVE Steering Committee.
New Hampshire Regional Haze SIP Revision Page 114 

40 CFR 51.308(d)(1)(vi) requires that reasonable progress goals represent at least the 

visibility improvement expected from implementation of other Clean Air Act programs during 

the applicable planning period. The modeling that formed the basis for reasonable progress 

goals for MANE-VU Class I Areas included estimation of the effects of all other programs 

required by the Clean Air Act. MANE-VU’s modeling also included the specific control 

measure assumptions described previously in Subsection 10.2. Additional information may 

be found in Section 6, Emissions Inventory, and Section 11, Long-Term Strategy, as well as 

in the documentation for the MANE-VU modeling. 

In setting the reasonable progress goals to improve visibility at MANE-VU Class I Areas, 

New Hampshire recognizes that contributing states will have flexibility to submit SIP 

revisions and implement various control measures to meet these goals between now and 2018. 

The overall approach to reducing and preventing emissions that contribute to regional haze 

allows each state up to 10 years to implement reasonable SO2 and NOX control measures as 

appropriate and necessary. 

10.4 Visibility Effects of (Additional) Reasonable Control Measures 

MANE-VU’s evaluations included modeling to estimate the effects on visibility of the New 

Hampshire/MANE-VU Ask. The results of this work are summarized below. 

NESCAUM performed preliminary modeling as described in the report entitled “MANE-VU 

Modeling for Reasonable Progress Goals, Model Performance Evaluation, Pollution 

Apportionment, and Control Measure Benefits,” February 7, 2008 (Attachment G). 

NESCAUM also conducted more recent, revised modeling to assess the effects of all haze 

reduction strategies combined. The latter modeling is described in NESCAUM’s “2018 

Visibility Projections,” May 13, 2008 (Attachment Q). 

The NESCAUM modeling demonstrates that significant visibility benefits will accrue from 

implementation of the additional reasonable control measures described in Subsection 10.2, 

above. Figures 10.4 and 10.5 describe the results of this modeling. In the first of the two 

figures, the light yellow bars represent expected visibility at MANE-VU Class I Areas in 

2018. Comparison of these values with the 2018 “glide slope” values (the plum-colored bars) 

shows that all areas are expected to experience visibility improvements that meet or exceed 

the uniform rate of progress calculated for each area. The second figure shows that, for the 20 

percent of days having best visibility, expected visibility in 2018 will be better than it is today 

at all locations. 

In conclusion, the reasonable control measures proposed by New Hampshire and the other 

MANE-VU states are found to be consistent with the stated national goals of preventing 

further visibility degradation while making measurable progress toward achieving natural 

visibility conditions in wilderness areas by 2064. 
New Hampshire Regional Haze SIP Revision Page 115 

Figure 10.4: Demonstration of Required and Reasonable Visibility Progress 

for 20 Percent Worst Visibility Days 

Visibility Progress for 20% Worst Days 

0

5

10

15

20

25

30

35

Acadia Brigantine Great Gulf Lye Brook Moosehorn

Visibility (deciviews)

2002 Baseline 2018 Glideslope 2018 Projected Progress Natural

(Visibility Improvements Must be Made at Reasonable Rate)

Figure 10.5: Demonstration of Required Maintenance or Improvement of Visibility for 

20 Percent Best Visibility Days 

Visibility Progress For 20% Best Days

0

2

4

6

8

10

12

14

16

Acadia Brigantine Great Gulf Lye Brook Moosehorn

Visibility (deciviews)

2002 Baseline 2018 Projected Progress

(Baseline Visibility Must be Maintained or Improved)

References 

U.S. Environmental Protection Agency, National Emission Standards for Hazardous Air 

Pollutants for Industrial/ Commercial/Institutional Boilers and Process Heaters, 

http://cascade.epa.gov/RightSite/dk_public_collection_detail.htm?ObjectType=dk_docket_collection

&cid=OAR-2002-0058&ShowList=items&Action=view (accessed Feb. 25, 2004). 
New Hampshire Regional Haze SIP Revision Page 116 

11. LONG-TERM STRATEGY 

40 CFR 51.308(d)(3) of the Regional Haze Rule requires the State of New Hampshire to 

submit a long-term strategy that addresses regional haze visibility impairment for all 

mandatory Class I federal areas within and outside the state that may be affected by emissions 

from within the state. Affected areas include the seven designated Class 1 areas within the 

MANE-VU region: Great Gulf Wilderness, Presidential Range - Dry River Wilderness, Acadia 

National Park, Moosehorn Wilderness, Roosevelt Campobello International Park, Lye Brook 

Wilderness, and Brigantine Wilderness. As presented in Section 3, Regional Planning and 

Consultation, New Hampshire consulted with other states to develop the coordinated emission 

management strategies contained in this SIP. The following describes how New Hampshire 

meets the long-term strategy requirements of the Regional Haze Rule. 

New Hampshire’s long-term strategy includes enforceable emission limitations, compliance 

schedules, and other measures necessary to achieve the reasonable progress goals described in 

Section 10. Additional measures may be reasonable to adopt at a later date after further 

consideration and review. In developing this long-term strategy, New Hampshire also 

considered the requirements of the Clean Air Act, Section 110 (a)(2)(D)(i)(II), pertaining to 

interstate and international transport of pollutants. NHDES has previously addressed this 

issue in New Hampshire’s “Transport SIP Revision,” submitted to EPA on March, 11, 2008. 

As that document observed, states must include provisions in their implementation plans to 

prohibit any source or activity from emitting air pollutants in amounts that would interfere 

with another state’s ability to prevent significant deterioration of air quality and visibility. 

The long-term strategy presented herein is designed to protect visibility in New Hampshire as 

well as areas downwind from New Hampshire. 

11.1 Overview of Strategy Development Process 

The regional strategy development process identified reasonable measures that would reduce 

emissions contributing to visibility impairment at Class I areas by 2018 or earlier. The 

process of identifying potential emission reduction measures and the technical basis for the 

long-term strategy are discussed in this section. As a MANE-VU member and participant, 

New Hampshire supported several technical analyses undertaken to assist the MANE-VU 

states in deciding which regional haze control measures to pursue. These analyses are 

documented in the following reports: 

• NESCAUM, “Contributions to Regional Haze in the Northeast and Mid-Atlantic 

United States,” August 2006, otherwise known as the Contribution Assessment 

(Attachment B). 

• ICF Resources, L.L.C., “Comparison of CAIR and CAIR Plus Proposal Using the 

Integrated Planning Model®,” Final Draft Report, May 30, 2007, otherwise known as 

the CAIR Plus Report (Attachment BB); 

• MACTEC Federal Programs, Inc., “Assessment of Reasonable Progress for Regional 

Haze in MANE-VU Class I Areas,” Final, July 9, 2007, otherwise known as the 

Reasonable Progress Report (Attachment Y); 

• NESCAUM, “Five-Factor Analysis of BART-Eligible Sources: Survey of Options for 

Conducting BART Determinations,” June 1, 2007 (Attachment W); and 
New Hampshire Regional Haze SIP Revision Page 117 

• NESCAUM, “Assessment of Control Technology Options for BART-Eligible 

Sources: Steam Electric Boilers, Industrial Boilers, Cement Plants and Paper and Pulp 

Facilities,” March 2005, otherwise known as the BART Report (Attachment Z). 

MANE-VU reviewed a wide range of potential control measures aimed at reducing regional 

haze by the 2018 milestone. The process of choosing a set of control measures started in late 

2005. OTC selected a contracting firm to assist with the analysis of ozone and regional haze 

control measure options and provided the contractor with a master list of some 900 potential 

control measures based on experience and previous state implementation plan work. With the 

help of an internal OTC Control Measures Workgroup, the contractor narrowed the list of 

regional haze control measures for further consideration by MANE-VU. 

MANE-VU then developed an interim short list of possible control measures for regional 

haze. The identified control measures can be divided into three general categories: 

• Beyond-CAIR sulfate reductions and related control measures targeted at specific 

electrical generating units (EGUs) in the eastern United States, 

• Low-sulfur heating oil for industrial, commercial, institutional (ICI) boilers and 

residential sources (i.e., boilers and furnaces), and 

• Emission controls on ICI boilers (both coal- and oil-fired); lime and cement kilns; 

residential woodstoves; and outdoor wood burning (including outdoor wood boilers). 

The next step was to further refine this list, with the aid of several of the reports named above. 

The ICF CAIR Plus Report (Attachment BB) documents MANE-VU’s assessment of the 

costs of CAIR and provides a cost analysis for additional SO2 and NOX controls in the eastern 

United States. The Reasonable Progress Report documents the assessment of control 

measures for EGUs and the other source categories selected for analysis. Further analysis is 

provided in the second of the two NESCAUM documents referenced above pertaining to Best 

Available Retrofit Technology (BART) controls.

The beyond-CAIR strategy for EGUs rose to the top of the list because the Contribution 

Assessment showed that EGU sulfate emissions have, by far, the largest impact on visibility 

in the MANE-VU Class I Areas. Similarly, a low-sulfur oil strategy gained traction after a 

NESCAUM-initiated conference with refiners and fuel-oil suppliers concluded that such a 

strategy could realistically be implemented within the next 10 years. Thus, the low-sulfur 

heating oil option for the residential and commercial sectors and the control measures option 

for the oil-fired ICI boiler sector merged into an overall strategy requiring the use of lowsulfur oil. Under this strategy, low-sulfur oil would be required for all residential and 

commercial heating units and all ICI boilers burning #2, #4, or #6 fuel oils. 

During MANE-VU’s internal consultation meeting in March 2007, member states reviewed 

the interim list of control measures to make additional refinements. States determined, for 

example, that there may be too few coal-fired ICI boilers in MANE-VU for these sources to 

be included in a regional strategy, but that they could be covered in programs adopted by 

individual states. The member states also decided that lime and cement kilns, of which there 

are few in the MANE-VU region, are most likely to be handled via the BART determination 

process. Residential wood burning and outdoor wood boilers remained on the list for those 

states where localized visibility impacts are a consideration even though emissions from these 

sources are primarily organic carbon and direct particulate matter. Finally, it was decided that 

the issue of outdoor wood burning should be examined further on a state-by-state basis 
New Hampshire Regional Haze SIP Revision Page 118 

because of concerns related to enforcement and penetration of existing state regulations. New 

Hampshire is currently considering additional regulation of this sector. 

11.2 Technical Basis for Strategy Development 

40 CFR 51.308(d)(3)(iii) requires New Hampshire to document the technical basis for the 

state’s apportionment of emission reductions necessary to meet reasonable progress goals in 

each Class I area affected by New Hampshire’s emissions. New Hampshire relied on 

technical analyses developed by MANE-VU to demonstrate that New Hampshire’s emission 

reductions, when coordinated with those of other states and tribes, are sufficient to achieve 

reasonable progress goals in Class I areas located in New Hampshire and in other Class I 

areas affected by emissions originating in New Hampshire. 

The emission reductions necessary to meet reasonable progress goals in Class I areas affected 

by New Hampshire are described in the following documents: 

• NESCAUM, “Baseline and Natural Background Visibility Conditions: Considerations 

and Proposed Approach to the Calculation of Baseline and Natural Background 

Visibility Conditions at MANE-VU Class I Areas,” December 2006 (Attachment L); 

• NESCAUM, “The Nature of the Fine Particle and Regional Haze Air Quality 

Problems in the MANE-VU Region: A Conceptual Description,” Final, November 2, 

2006 (Attachment CC); 

• NESCAUM, “Contributions to Regional Haze in the Northeast and Mid-Atlantic 

United States,” August 2006, otherwise known as the Contribution Assessment 

(Attachment B). 

• ICF Resources, L.L.C., “Comparison of CAIR and CAIR Plus Proposal Using the 

Integrated Planning Model®,” Final Draft Report, May 30, 2007, otherwise known as 

the CAIR Plus Report (Attachment BB); 

• MACTEC Federal Programs, Inc., “Assessment of Reasonable Progress for Regional 

Haze in MANE-VU Class I Areas,” Final, July 9, 2007, otherwise known as the 

Reasonable Progress Report (Attachment Y); 

• NESCAUM, “Five-Factor Analysis of BART-Eligible Sources: Survey of Options for 

Conducting BART Determinations,” June 1, 2007 (Attachment W); 

• NESCAUM, “Assessment of Control Technology Options for BART-Eligible 

Sources: Steam Electric Boilers, Industrial Boilers, Cement Plants and Paper and Pulp 

Facilities,” March 2005, otherwise known as the BART Report (Attachment Z); 

• NESCAUM, “MANE-VU Modeling for Reasonable Progress Goals: Model Performance 

Evaluation, Pollution Apportionment, and Control Measure Benefits,” February 7, 2008 

(Attachment G); and 

• NESCAUM, “2018 Visibility Projections,” May 13, 2008 (Attachment Q). 

As described in Subsection 11.1, above, New Hampshire worked with other members of the 

Ozone Transport Commission and MANE-VU to evaluate a large number of potential 

emission reduction strategies covering a wide range of sources of SO2 and other pollutants 

contributing to regional haze. 40 CFR 51.308(d)(3)(v) requires states to consider several 
New Hampshire Regional Haze SIP Revision Page 119 

factors in developing their long-term strategies. Operating within this framework and using 

available information about emissions and potential impacts, the MANE-VU Reasonable 

Progress Workgroup selected the following source categories for detailed analysis: 

• Coal and oil-fired electric generating units (EGUs); 

• Point and area source ICI boilers; 

• Cement kilns and lime kilns; 

• Sources capable of using low-sulfur heating oil; and 

• Residential wood combustion and open burning. 

These efforts led to the selection of the emission reduction strategies presented in this SIP. 

11.3 Existing Commitments / Expected Measures to Reduce Emissions 

40 CFR Section 51.308(d)(3)(v)(A) requires New Hampshire to consider emission reductions 

from ongoing pollution control programs. In developing its long-term strategy, New 

Hampshire considered air pollution programs being implemented between the 2002 baseline 

year and 2018. The emission reduction programs described in Parts 11.3.1, 11.3.2, and 

11.3.3, below, represent commitments already made by New Hampshire and other states to 

implement air pollution control measures for EGU point sources, non-EGU point sources, and 

area sources, respectively. These control measures are the very same measures that were 

included in the 2018 emissions inventory and used in the modeling. While these control 

measures were not designed expressly for the purpose of improving visibility, the pollutants 

they control include those that contribute to visibility impairment in MANE-VU Class I Areas. 

MANE-VU’s 2018 beyond-on-the-way (BOTW) emissions inventory accounts for emission 

controls already in place as well as emission controls that are not yet finalized but are likely to 

achieve additional emission reductions by 2018. The BOTW inventory was developed based 

on the MANE-VU 2002 Version 3.0 inventory and the MANE-VU 2018 on-the-books/on-theway (OTB/OTW) inventory. Inventories used for other RPOs reflect anticipated emissions 

controls that will be in place by 2018. The inventory is termed BOTW because it includes 

control measures that were developed for ozone SIPs that were not yet on the books in some 

states. For some states, BOTW also included controls that were under consideration for 

regional haze SIPs that have not yet been adopted. More information may be found in the 

following documents: 

• MACTEC Federal Programs, Inc., “Development of Emissions Projections for 2009, 

2012, and 2018 for NonEGU Point, Area, and Nonroad Sources in the MANE-VU 

Region,” Final Report, February 28, 2007, otherwise known as the Emission 

Projections Report (Attachment N); 

• Alpine Geophysics, LLC, “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 (Attachment H); 

• NESCAUM, “MANE-VU Modeling for Reasonable Progress Goals: Model 

Performance Evaluation, Pollution Apportionment, and Control Measure Benefits,” 

February 7, 2008 (Attachment G); and 

• NESCAUM, “2018 Visibility Projections,” May 13, 2008 (Attachment Q). 
New Hampshire Regional Haze SIP Revision Page 120 

11.3.1 Controls on EGUs Expected by 2018 

The following EGU emission reduction programs were included in the modeling used to 

develop the reasonable progress goals. These programs represent the greatest opportunities 

for reducing SO2 emissions at Class I areas in the MANE-VU region and serve as the starting 

point for MANE-VU’s long-term strategy to mitigate regional haze. 

Clean Air Interstate Rule (CAIR): This major federal rule has been remanded to EPA to 

correct deficiencies. The original CAIR imposed permanent emissions caps on sulfur dioxide 

(SO2) and nitrogen oxides (NOX) in the eastern United States by 2015. When fully effective, 

this program was expected to reduce SO2 emissions in the CAIR region by up to 70 percent. 

To predict future emissions from EGUs after implementation of CAIR, MANE-VU used the 

Integrated Planning Model (IPM®)29. Adjustments to the IPM output were made to provide a 

more accurate representation of anticipated controls at specific EGU sources as documented 

in the Alpine Geophysics report listed above. In making these adjustments, emission controls 

originating from the following state and regional programs were considered: 

Connecticut EGU Regulations: Connecticut adopted the following regulations governing 

EGU emissions: 

• Regulations of Connecticut State Agencies (RCSA), section 22a-174-19a, limiting the 

SO2 emission rate to 0.33 lb/MMBtu for fossil-fuel-fired EGUs greater than 15 MW 

that are also Title IV sources (effective, 2007). 

• RCSA, section 22a-174-22, limiting the non-ozone seasonal NOX emission rate to 0.15 

lb/MMBtu for fossil-fuel-fired EGUs greater than 15 MW (effective, 2007). 

• RCSA, section 22a-199, limiting the mercury (Hg) emission rate to 0.0000006 

lb/MMBtu for all coal-fired EGUs, or alternatively coal-fired EGUs can meet a 90-

percent Hg emission reduction (effective, 2008). 

Delaware EGU Regulations: Delaware adopted the following regulations governing EGU 

emissions: 

• Reg. 1144, Control of Stationary Generator Emissions, requiring emission controls for 

SO2, PM, VOC, and NOX state-wide, effective January 2006. 

• Reg. 1146, Electric Generating Unit (EGU) Multi-Pollutant Regulation, requiring SO2

and NOX emission controls state-wide, effective December 2007. SO2 reductions will 

be more than regulation specifies 

• Reg. 1148, Control of Stationary Combustion Turbine Electric Generating Unit 

Emissions, requiring SO2, NOX, and PM2.5 emission controls state-wide, effective 

January 2007. 

 

29 The IPM model runs also anticipated the implementation of EPA’s Clean Air Mercury Rule (CAMR), which was recently 

vacated by the courts. However, MANE-VU believes that the adjustments made to the predicted SO2

 emissions from 

electric generating units (EGUs) will have a larger effect on the air quality modeling analysis conducted for this SIP than 

will the vacatur of the CAMR rule. The emission adjustments were based on states’ comments on the actual levels of SO2 

controls expected to be installed in response to state-specific regulations and EPA’s CAIR rule. MANE-VU believes these 

adjustments improve the reliability of both the emissions inventory and modeling results. 
New Hampshire Regional Haze SIP Revision Page 121 

Delaware estimates that these regulations will result in the following emission reductions for 

affected units: SO2 emissions of 32,630 tons in 2002 will decline to 8,137 tons in 2018 (a 75-

percent reduction); NOX emissions of 8,735tons in 2002 will decline to 3,740 tons in 2018 (a 

57-percent reduction). 

Also, Delaware anticipates the following reductions resulting from the consent decree with 

Valero Refinery Delaware City, DE (formerly Motiva, Valero Enterprises): SO2 emissions of 

29,747 tons in 2002 will decline to 608 tons in 2018 (a 98-percent reduction); NOX emissions 

in 1,022 in 2002 will decline to 102 tons in 2018 (a 90-percent reduction). 

Maine EGU Regulations: Chapter 145, NOX Control Program, limits the NOX emission rate 

to 0.22 lb/MMBtu for fossil-fuel-fired units greater than 25 MW built before 1995 with a heat 

input capacity between 250 and 750 MMBtu/hr, and also limits the NOX emission rate to 0.15 

lb/MMBtu for fossil-fuel-fired units greater than 25 MW built before 1995 with a heat input 

capacity greater than 750 MMBtu/hr (effective, 2007). 

Massachusetts EGU Regulations: Based on the Massachusetts Department of Environmental 

Protection’s 310 CMR 7.29, Emissions Standards for Power Plants, adopted in 2001, six of 

the largest fossil-fuel-fired power plants in Massachusetts must comply with emissions 

limitations for NOX, SO2, Hg, and CO2. These regulations will achieve an approximately 50-

percent reduction in NOX emissions and a 50- to 75-percent reduction in SO2 emissions. 

Depending on the compliance paths selected, the affected facilities will meet the output-based 

NOX and SO2 standards between 2004 and 2008. This regulation also limits the six 

grandfathered EGUs to a CO2 emission rate of 1,800 lb/MWh. 

New Hampshire EGU Regulations: New Hampshire adopted the following regulations 

governing EGU emissions (inclusive of the New Hampshire Clean Power Act): 

• 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-fuelfired steam units by December 31, 2006. 

• 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. 

• RSA 125-O, Multiple Pollutant Reduction Program, requiring the installation and 

operation of a flue gas desulfurization system (scrubber) on PSNH Merrimack Station 

Units MK1 and MK2 to reduce mercury emissions by at least 80 percent, with the cobenefit of SO2 emission reductions (90 percent expected minimum).

New Jersey New Source Review Settlement Agreements: The New Jersey settlement 

agreement with PSEG required the following actions for specific EGUs: 

• Bergen Unit #2: Repower to combined cycle by December 31, 2002. 

• Hudson Unit #2: Install dry FGD or approved alternative technology by Dec. 31, 

2006, to control SO2 emissions and operate the control technology at all times the unit 

operates to limit SO2 emissions to 0.15 lb/MMBtu; install SCR or approved alternative 

technology by May 1, 2007, to control NOX emissions and operate the control 

technology year-round to limit NOX emissions to 0.1 lb/MMBtu; and install a 
New Hampshire Regional Haze SIP Revision Page 122 

baghouse or approved alternative technology by May 1, 2007, to control and limit PM 

emissions to 0.015 lb PM/MMBtu. 

• Mercer Unit #1: Install dry FGD or approved alternative technology by Dec. 31, 

2010, to control SO2 emissions and operate the control technology at all times the unit 

operates to limit SO2 emissions to 0.15 lb/MMBtu; and install SCR or approved 

alternative technology by 2005 to control NOX emissions and operate the control 

technology during ozone season only in 2005 and year-round by May 1, 2006, to limit 

NOX emissions to 0.13 lb/MMBtu. 

• Mercer Unit #2: Install dry FGD or approved alternative technology by Dec. 31, 

2012, to control SO2 emissions and operate the control technology at all times the unit 

operates to limit SO2 emissions to 0.15 lb/MMBtu; and install SCR or approved 

alternative technology by 2004 to control NOX emissions and operate the control 

technology during ozone season only in 2004 and year-round by May 1, 2006, to limit 

NOX emissions to 0.13 lb/MMBtu. 

The New Jersey settlement also requires that units operating an FGD use coal having a 

monthly average sulfur content no greater than 2 percent.

New York EGU Regulations: New York adopted the following regulations governing EGU 

emissions: 

• Title 6 NYCRR Parts 237, Acid Deposition Reduction NOX Budget Trading Program, 

limits NOX emissions on all fossil-fuel-fired EGUs greater than 25 MW to a nonozone season cap of 39,908 tons in 2007. 

• Title 6 NYCRR Parts 238, Acid Deposition Reduction SO2 Budget Trading Program, 

limits SO2 emissions from all fossil-fuel-fired EGUs greater than 25 MW to an annual 

cap of 197,046 tons per year starting in 2007 and an annual cap of 131,364 tons per 

year starting in 2008. 

North Carolina Clean Smokestacks Act: Enacted in 2002, this legislation requires that coalfired EGUs achieve a 77-percent cut in NOX emissions by 2009 and a 73-percent cut in sulfur 

dioxide SO2 emissions by 2013. This act also established annual caps on both SO2 and NOX

emissions for the two primary utility companies in North Carolina, Duke Energy and Progress 

Energy. These reductions must be made in North Carolina, and allowances are not saleable. 

Consent Agreements in the VISTAS region: The effects of the following consent agreements 

in the VISTAS states were reflected in the emissions inventories used for those states: 

• Santee Cooper: A 2004 consent agreement calls for Santee Cooper in South Carolina to 

install and commence operation of continuous emission control equipment for 

PM/SO2/NOX emissions; comply with system-wide annual PM/SO2/NOX emissions 

limits; agree not to buy, sell, or trade SO2/NOX allowances allocated to Santee Cooper 

System as a result of this agreement; and to comply with emission unit limits of this 

agreement. 

• TECO: Under a settlement agreement, by 2008, Tampa Electric in the state of Florida 

will install permanent emission control equipment to meet stringent pollution limits; 

implement a series of interim pollution reduction measures to reduce emissions while 

the permanent controls are designed and installed; and retire pollution emission 
New Hampshire Regional Haze SIP Revision Page 123 

allowances that Tampa Electric or others could use, or sell to others, to emit additional 

NOX, SO2, and PM.

• VEPCO: Virginia Electric and Power Co. agreed to spend $1.2 billion by 2013 to 

eliminate 237,000 tons of SO2 and NOX emissions each year from eight coal-fired 

electricity generating plants in Virginia and West Virginia. 

• Gulf Power 7: A 2002 agreement calls for Gulf Power to upgrade its operation to cut 

NOX emission rates by 61 percent at its Crist 7 generating plant by 2007 with major 

reductions beginning in early 2005. The Crist plant is a significant source of NOX

emissions in the Pensacola, Florida, area. 

11.3.2 Controls on Non-EGU Point Sources Expected by 2018 

For non-EGU sources within MANE-VU, New Hampshire relied on MANE-VU’s Version 

3.0 Emission Inventory for 2002. MACTEC conducted an analysis of various control 

measures as documented in the Emission Projections Report (Attachment N). Control factors 

were applied to the 2018 MANE-VU inventory for non-EGUs to represent the following 

national, regional, or state control measures: 

• NOX SIP Call Phase I (NOX Budget Trading Program) (except ME, NH, VT); 

• NOX SIP Call Phase II (except ME, NH, VT); 

• NOX RACT in 1-hour Ozone SIPs (already included in the 2002 inventory); 

• NOX OTC 2001 Model Rule for ICI Boilers; 

• 2-, 4-, 7-, and 10-year MACT Standards; 

• Combustion Turbine and RICE MACT (NOX co-benefits were not included and 

assumed to be small); 

• Industrial Boiler/Process Heater MACT30; and 

• Refinery Enforcement Initiative (Fluid catalytic cracking units and fluid coking units, 

process heaters and boilers, flare gas recovery, leak detection and repair, and benzene 

(wastewater)). 

In addition, states provided control measure information about specific non-EGU sources or 

regulatory programs in their states. MANE-VU used the state-specific data to the extent it 

was available. For example, several states developed additional control measures in the 

course of their planning efforts to reduce ozone within the Ozone Transport Region (OTR). 

These control measures were included by MANE-VU in the inventories used for regional 

haze modeling. (The affected states may or may not have committed to adopting these 

measures in their ozone SIPs.) For specific states, the ozone-reduction strategies included in 

the modeling would reduce NOX emissions from the following non-EGU point sources: 

• Asphalt production plants in Connecticut, New Jersey, New York, and the District of 

Columbia; 

• Cement kilns in Maine, Maryland, New York, and Pennsylvania; and 

 

30 The inventory was prepared before the MACT for Industrial Boilers and Process Heaters was vacated. Control efficiency 

was assumed to be 4 percent for SO2

 and 40 percent for PM. The overall effects of including these reductions in the 

inventory are estimated to be minimal. 
New Hampshire Regional Haze SIP Revision Page 124 

• Glass and fiberglass furnaces in Maryland, Massachusetts, New Jersey, New York, 

and Pennsylvania. 

For other regions, MANE-VU used emission inventory data developed by the RPOs for those 

regions, including VISTAS’s Base G2, MRPO’s Base K, and CenRAP’s emissions inventory. 

Non-EGU source controls incorporated into the modeling include those required under the 

following consent agreements as reflected in the VISTAS inventory: 

• Dupont: A 2007 agreement calls for E. I. Dupont Nemours & Co.’s James River plant 

to install dual absorption pollution control equipment by September 1, 2009, resulting 

in SO2 emission reductions of approximately 1,000 tons annually. The James River 

plant is a non-EGU located in the state of Virginia. 

• Stone Container: A 2004 agreement calls for the West Point Paper Mill in Virginia 

owned by Smurfit/Stone Container to control SO2 emissions from its #8 Power Boiler 

by using a wet scrubber. This control device should result in reductions of over 3,500 

tons of SO2 in 2018. 

11.3.3 Controls on Area Sources Expected by 2018 

For area sources within MANE-VU, New Hampshire relied on MANE-VU’s Version 3.0 

Emissions Inventory for 2002. In general, MANE-VU developed the 2018 inventory for area 

sources by applying growth and control factors to the 2002 Version 3.0 inventory. Area 

source control factors were developed for the following national or regional control measures: 

• Phase 1 of MANE-VU’s low-sulfur fuel oil strategy for the inner-zone states (New 

Jersey, New York, Delaware, and Pennsylvania, or portions thereof) to reduce the 

sulfur content of: 

− #2 distillate oil to 0.05 percent (500 ppm) sulfur, by weight, by no later than 2012; 

− #4 residual oil to 0.25 percent sulfur, by weight, by no later than 2012; 

− #6 residual oil to 0.3-0.5 percent sulfur, by weight, by no later than 2012; 

• Phase 1 of MANE-VU’s low-sulfur fuel oil strategy for the outer-zone states (the rest 

of the MANE-VU region) to reduce the sulfur content of: 

− #2 distillate oil to 0.05 percent (500 ppm) sulfur, by weight, by no later than 2014; 

− #4 residual oil to 0.25-0.50 percent sulfur, by weight, by no later than 2018; 

− #6 residual oil to 0.5 percent sulfur or less, by weight, by no later than 2018; 

• The Ozone Transport Commission’s VOC Model Rules (for consumer products, 

architectural and industrial maintenance coatings, portable fuel containers, mobile 

equipment repair and refinishing, and solvent cleaning); 

• Stage I vapor recovery systems at vehicle refueling stations in all New Hampshire 

counties and Stage II vapor recovery systems at vehicle refueling stations in the four 

southern counties classified as ozone nonattainment areas (Rockingham, Strafford, 

Hillsborough, and Merrimack); 

• New Jersey post-2002 area source controls; and 

• Residential woodstove NSPS. 
New Hampshire Regional Haze SIP Revision Page 125 

The following additional control measures were included in the 2018 analysis to reduce NOX

and VOC emissions for the following area source categories for some (identified) states: 

• NOX control measures for combustion of coal; natural gas; and #2, #4, and #6 fuel oils 

(CT, NJ, and NY only); 

• VOC control measures for adhesives and sealants (all MANE-VU states except New 

Jersey31 and VT); 

• VOC control measures for emulsified and cutback asphalt paving (all MANE-VU states 

except ME and VT); 

• VOC control measures for consumer products (all MANE-VU states except VT); and 

• VOC control measures for portable fuel containers (all MANE-VU states except VT). 

Some of the area-source control measures listed above may have been developed by states for 

the primary purpose of reducing ozone within the Ozone Transport Region (OTR) – see Part 

11.3.2 for information on other measures included in states’ ozone SIPs. 

11.3.4 Controls on Mobile Sources Expected by 2018 

For the on-road mobile source emission inventory, New Hampshire relied on MANE-VU’s 

Version 3.0 emission inventory, which included the following emission control measures for 

New Hampshire: 

• Use of reformulated gasoline in the four southern counties classified as ozone 

nonattainment areas: Rockingham, Strafford, Hillsborough, and Merrimack; 

• An enhanced safety inspection program, including an anti-tampering inspection for 

motor vehicles less than 20 years old; 

• On-board diagnostics testing for 1996 and newer vehicles in lieu of the anti-tampering 

inspection; 

• Federal On-Board Refueling Vapor Recovery (ORVR) Rule; 

• Federal Tier 2 Motor Vehicle Emissions Standards and Gasoline Sulfur Requirements; 

• Federal Heavy-Duty Diesel Engine Emission Standards for Trucks and Buses; and 

• Federal Emission Standards for Large Industrial Spark-Ignition Engines and 

Recreational Vehicles

Similar programs in other MANE-VU states were included in the on-road mobile source 

emission inventory, where applicable. The last four items listed above are federal programs, 

briefly described here: 

On-Board Refueling Vapor Recovery (ORVR) Rule: The 1990 Clean Air Act (CAA) 

Amendments contain provisions that require passenger cars to capture refueling emissions. In 

1994, EPA published the ORVR Rule establishing standards for refueling emissions controls 

for passenger cars and light trucks. The onboard controls were required to be phased in for all 

 

31 New Jersey’s emission reductions from control measures for adhesives and sealants apply only to area sources. No reductions 

for point sources (SCC 4-02-0007-xx) were included to avoid inventory double-counting. 
New Hampshire Regional Haze SIP Revision Page 126 

new car production by 2000 and for all light trucks by 2006. The rule established a refueling 

emission standard of 0.20 grams per gallon of dispensed fuel, which was expected to yield a 

95 percent reduction of VOC emissions over uncontrolled levels. The CAA authorizes EPA 

to allow state and local agencies to phase out Stage II programs, even in the worst 

nonattainment areas, once EPA has determined that onboard systems are in widespread use. 

Tier 2 Motor Vehicle Emissions Standards: Tier 2 is a fleet-averaging program modeled 

after the California LEV II standards. Manufacturers can produce vehicles with emissions 

ranging from relatively dirty to zero, but the mix of vehicles a manufacturer sells each year 

must have average NOX emissions below a specified value. The Tier 2 regulations also 

require reduced gasoline sulfur levels. The reduction in sulfur levels contributes directly to 

cleaner air and has additional beneficial effects on vehicle emission control systems. The Tier 

2 standards became effective in the 2005 model year and are included in the assumptions used 

for calculating mobile source emissions inventories used for 2018. 

Heavy-Duty Diesel Engine Emission Standards for Trucks and Buses: EPA set a PM 

emissions standard of 0.01 grams per brake-horsepower-hour (g/bhp-hr) for new heavy-duty 

diesel engines in trucks and buses, to take full effect in the 2007 model year. This rule also 

includes standards for NOX and non-methane hydrocarbons (NMHC) of 0.20 g/bhp-hr and 

0.14 g/bhp-hr, respectively. These NOX and NMHC standards will be phased in together 

between 2007 and 2010. Sulfur in diesel fuel must be lowered to enable modern pollutioncontrol technology to be effective on the trucks and buses that use this fuel. EPA will require a 

97-percent reduction in the sulfur content of highway diesel fuel from its current level of 500 

parts per million (low-sulfur diesel) to 15 parts per million (ultra-low sulfur diesel).

Emission Standards for Large Industrial Spark-Ignition Engines and Recreational 

Vehicles: EPA has adopted new standards for emissions of NOX, hydrocarbons (HC), and 

carbon monoxide (CO) from several groups of previously unregulated non-road engines. 

Included are large industrial spark-ignition engines and recreational vehicles. The affected 

spark-ignition engines are those powered by gasoline, liquid propane, or compressed natural 

gas rated over 19 kilowatts (kW) (25 horsepower). These engines are used in commercial and 

industrial applications, including forklifts, electric generators, airport baggage transport 

vehicles, and a variety of farm and construction applications. Non-road recreational vehicles 

include snowmobiles, off-highway motorcycles, and all-terrain vehicles. These rules were 

initially effective in 2004 and will be fully phased-in by 2012. 

11.3.5 Controls on Non-Road Sources Expected by 2018 

For non-road emission sources, New Hampshire used Version 3.0 of the MANE-VU 2002 

Emissions Inventory. Because the NONROAD Model used to develop the non-road source 

emissions did not include aircraft, commercial marine vessels, and locomotives, MANE-VU’s 

contractor, MACTEC, developed the inventory for these sources. Non-road mobile source 

emissions for the 2018 emission inventory were calculated with EPA’s NONROAD2005 

emissions model as incorporated into the NMIM2005 (National Mobile Inventory Model) 

database. The NONROAD model accounts for emissions benefits associated with federal 

non-road emission control requirements such as the following: 

• “Control of Air Pollution: Determination of Significance for Nonroad Sources and 

Emissions Standards for New Nonroad Compression Ignition Engines at or above 37 

Kilowatts,” 59 FR 31306, June 17, 1994. 
New Hampshire Regional Haze SIP Revision Page 127 

• “Control of Emissions of Air Pollution from Nonroad Diesel Engines,” 63 FR 56967, 

October 23, 1998. 

• “Control of Emissions from Nonroad Large Spark-Ignition Engines and Recreational 

Engines (Marine and Land-Based),” Final Rule, 67 FR 68241, November 8, 2002. 

• “Control of Emissions of Air Pollution from Nonroad Diesel Engines and Fuel,” Final 

Rule, April, 2004. 

As noted above, inventory data for other regions were obtained from those regions’ RPOs. 

11.4 Additional Reasonable Measures 

As required under 40 CFR 51.308(d)(1)(i)(A), New Hampshire and the other MANE-VU 

states applied four-factor analysis to potential control measures for the purpose of establishing 

reasonable progress goals (see Subsection 10.2 for detailed description). Reasonable 

measures include those that the affected states have already committed themselves to 

implementing, as described in Subsection 11.3, above. In addition, the MANE-VU states 

have identified other control measures that were found to be reasonable and were included in 

the modeling that was used to set reasonable progress goals. (These additional measures 

surpass the “beyond-on-the-way” emission controls and inventories.) All of the control 

measures – those embodied in the states’ commitments to existing or planned programs and 

the additional reasonable control measures described below – comprise the long-term strategy 

for improving visibility at MANE-VU Class I Areas. 

Specifically, the New Hampshire/MANE-VU long-term strategy includes the following 

additional measures to reduce pollutants that cause regional haze. 

• Timely implementation of BART requirements. 

• Phase 2 of MANE-VU’s low-sulfur fuel oil strategy to further reduce the sulfur 

content of distillate oil to 15 ppm by no later than: 

− 2016 for the inner-zone states (New Jersey, New York, Delaware, and 

Pennsylvania, or portions thereof); and 

− 2018 for the outer-zone states (the rest of the MANE-VU region). 

(Schedule would be contingent on fuel supply and availability.) 

• A 90-percent or greater reduction in sulfur dioxide (SO2) emissions from each of the 

EGUs identified by MANE-VU as reasonably anticipated to cause or contribute to 

impairment of visibility in each mandatory Class I area in the MANE-VU region. 

(This requirement affects 167 point sources, or stacks, at EGU facilities in the eastern 

United States.) If it is infeasible to achieve this level of SO2 reductions from specific 

EGUs, equivalent alternative measures will be pursued in the affected states. 

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

alternative clean fuels, other measures to reduce SO2 and nitrogen oxide (NOX) 

emissions from all coal-burning facilities by 2018, and new source performance 

standards for wood combustion. 
New Hampshire Regional Haze SIP Revision Page 128 

This suite of additional control measures are those that the MANE-VU states have agreed to 

pursue for the purpose of mitigating regional haze. The corollary is that the MANE-VU Class 

I states (Maine, New Hampshire, Vermont, and New Jersey) are asking states outside the 

MANE-VU region that contribute to visibility impairment inside the region to pursue similar 

measures. The control measures that non-MANE-VU states choose to pursue may be directed 

toward the same emission source sectors identified by MANE-VU for its own emission 

reductions, or they may be equivalent measures targeting other source sectors. Under MANEVU’s long-term strategy, states will be allowed up to ten years to pursue adoption and 

implementation of proposed control measures. While some measures that states pursue may 

not represent enforceable commitments immediately, they may become enforceable in the 

future as new laws are passed, rules are written, and facility permits are issued. 

11.4.1 BART 

Implementation of the BART provisions of the Regional Haze Rule (40 CFR 51.308(e)) is 

one of the reasonable strategies included in this SIP. For electrical generating units, EPA 

determined that CAIR (before its remand) would fulfill BART requirements for this sector. 

However, New Hampshire’s approach is consistent with the MANE-VU long-term strategy; 

i.e., it goes beyond the original CAIR standards by requiring BART controls on all BARTeligible sources in the state. Proposed control measures for New Hampshire’s two BARTeligible sources, both of which are EGUs, are described in Section 9 of this SIP. These two 

sources are also addressed in MANE-VU’s targeted EGU strategy (see Part 11.4.3, below). 

To assess the benefits of implementing BART controls for MANE-VU’s non-EGU sectors, 

NESCAUM included in the final 2018 CMAQ modeling analysis anticipated emission 

reductions for the region’s BART-eligible facilities, as described previously in Part 10.2.2 of 

this SIP. It is anticipated that twelve units at eight BART-eligible sources in MANE-VU 

would be controlled as a result of BART requirements alone (see Table 10.3). 

Note that additional emission reductions will occur at many other BART-eligible facilities 

within MANE-VU as a result of controls achieved by other programs that serve as BART but 

are not specifically identified as such (e.g., RACT control measures). While not specifically 

identified as being attributable to BART, these additional emission reductions were fully 

accounted for in the 2018 CMAQ modeling. 

Further visibility benefits are likely to result from installation of new emission controls at 

BART-eligible facilities located in neighboring RPOs. However, the MANE-VU modeling 

did not account for BART controls in other RPOs and, consequently, did not include visibility 

improvements at MANE-VU Class I Areas that would be likely to accrue from such measures. 

11.4.2 Low-Sulfur Oil Strategy 

The important assumption underlying MANE-VU’s low-sulfur fuel oil strategy is that refiners 

can, by 2018, produce sufficient quantities of home heating and other fuel oils with lower 

sulfur content than current fuel supplies at only a small increase in price to the end user. The 

expected reductions in sulfur content range from 50 percent for the heavier grades (#4 and #6 

residual) to a minimum of 75 percent and maximum of 99.25 percent for #2 fuel oil (also 

known as home heating oil, distillate, or diesel fuel). As much as three-fourths of the total 

sulfur reductions achieved by this strategy will come from using low-sulfur #2 distillate for 

space heating in the residential and commercial sectors. The costs of these emissions 

reductions are estimated at $550 to $750 per ton, as documented in the MANE-VU 
New Hampshire Regional Haze SIP Revision Page 129 

Reasonable Progress Report. While the costs of the low-sulfur fuel oil strategy remain 

somewhat uncertain, they appear to be reasonable when measured against the costs of 

controlling other sectors. 

Currently there are logistical issues in supplying large quantities of low-sulfur oils to the 

PADD1B (northern New England region). This oil is supplied by PADD1A and barged into 

the region in quantities that allow for blending with high-sulfur fuels to produce 1-percent 

sulfur fuels. Current capacities are limited by Federal restrictions that prevent large ships 

from transferring fuels between two U.S. ports. The states of this region intend to build full 

capacity for 0.5-percent-sulfur #6 fuel oil by 2018. 

The MANE-VU states agree that a low-sulfur oil strategy is reasonable to pursue in the next 

ten years. NHDES will review the details of this strategy within five years, coincident with 

New Hampshire’s first regional haze SIP progress report, to ascertain that requiring the use of 

low-sulfur fuel remains viable for implementation by 2018. 

11.4.3 Targeted EGU Strategy 

MANE-VU has identified emissions from the top 167 EGU emission points, including three 

in New Hampshire, that contribute the most to visibility impairment at MANE-VU Class I 

Areas (see Figure 10.2). Controlling emissions from these contributing facilities is crucial to 

mitigating haze pollution in wilderness areas and national parks of the Northeast states. 

MANE-VU’s agreed regional strategy for the EGU source sector is to pursue a 90-percent 

control level on SO2 emissions from the 167 identified stacks by 2018. MANE-VU has 

concluded that pursuing this level of sulfur reduction is both reasonable and cost-effective. 

For some units, actual SO2 removal efficiencies would be expected to approach or exceed 95 

percent. The costs of SO2 emission reductions will vary by unit. MANE-VU’s Reasonable 

Progress Report (Attachment Y) summarizes the available control methods and costs, which 

range from $170 to $5,700 per ton (2006 dollars), depending on site-specific factors such as 

size of unit, combustion technology used, and type of fuel burned. 

As shown in Table 11.1, the three targeted EGUs in New Hampshire are projected to reduce 

their SO2 emissions, in the aggregate, by 87 percent between 2002 and 2018. 

Table 11.1: Projected SO2 Emission Reductions from Targeted EGUs in New Hampshire 

2002 SO2

Emissions 

SO2 Emission 

Reductions 

2018 SO2

Facility Name/Unit Emissions Targeted 

EGU 

BARTEligible Fuel 

Type 

(tons)

Proposed 

Control 

Method (%) (tons) (tons)

Merrimack Station MK1 yes no coal 9,754 scrubber 90 8,779 975 

Merrimack Station MK2 yes yes coal 20,902 scrubber 90 18,812 2,090 

Newington Station NT1 yes yes fuel oil/ 

natural gas 5,226 0.50 lb/MMBtu S emission limit 67 3,484 1,742 

TOTALS 35,882 87 31,075 4,807 

Notes: All 2002 values are based on continuous emissions monitoring (CEM) data. For Newington Station, additional SO2 emission 

reductions beyond the stated value may occur with a switch to 0.5-percent low-sulfur oil under MANE-VU’s low-sulfur oil strategy. 
New Hampshire Regional Haze SIP Revision Page 130 

These projections are conservative estimates for at least two reasons: 

• The actual performance of scrubbers to be installed on PSNH’s Merrimack Station Units 

MK1 and MK2 is expected to match or exceed MANE-VU’s Ask level of 90-percent 

SO2 from targeted EGUs. (Note that MANE-VU’s Assessment of Control Options for 

BART-Eligible Sources, Attachment Z references 95-percent control reductions. 

However, this rate applies to EGUs at power plants having capacities above 750-MW, 

i.e., facilities larger than PSNH’s. Also, note that the overall SO2 control level for the 

three PSNH units would be greater than stated if the baseline reduction resulting from 

use of lower-sulfur coal were included in the efficiency calculation.) 

• PSNH’s Newington Station Unit NT1, being primarily an oil-fired EGU, is expected 

to have low utilization rates well into the future because of the economics associated 

with the cost of fuel. In 2007, high fuel costs caused this unit to operate only 5 

percent of the time. In fact, the most recent IPM modeling predicts that this unit will 

be shut down permanently by 2018. (Note that MANE-VU, from the outset, never 

envisioned that this oil-fired unit would be capable of achieving a control level equal 

to the presumptive norm for large EGUs.) 

Given these considerations, there is a high probability that New Hampshire will actually 

surpass MANE-VU’s goal of a 90-percent overall reduction in SO2 emissions from targeted 

EGUs by 2018. However, in the event that New Hampshire is unable to attain this level of 

emission reductions, equivalency could be demonstrated by alternative methods. For example: 

• Credit could be taken for SO2 emission reductions resulting from the recently 

completed fuel conversion of Schiller Station Unit 5 from coal to wood and from any 

similar fuel conversions that might occur for other New Hampshire EGUs in the future. 

• Additional SO2 emission reductions could be achieved before 2018 by requiring all 

sources that burn residual fuel oil to switch to residual fuel oil with a sulfur content of 

0.5-percent (or lower), if economics and supplies allow. New Hampshire intends to 

investigate this possibility further. 

The anticipated benefits to regional visibility that will result from using FGD technology on 

New Hampshire’s largest EGUs are an intended consequence of New Hampshire’s Multiple 

Pollutant Reduction Program, which was established by law in RSA Chapter 125-O. This 

program requires aggressive reductions in SO2, NOX, mercury, and carbon dioxide (CO2) 

while simultaneously allowing state-level SO2 credits for over- or early- compliance. Under 

this program, emission controls for SO2 and mercury are scheduled to be installed and 

operational at New Hampshire’s PSNH Merrimack Station Units MK1 and MK2 by July 1, 

2013. In the meantime, NHDES will continue to evaluate other control measures for EGUs to 

determine whether it is reasonable to implement additional controls on those sources by that 

date. NHDES will provide an update on its determinations in New Hampshire’s first regional 

haze SIP progress report. 

Several other states within and outside the MANE-VU region have implemented state-specific 

EGU emission reduction programs that will help MANE-VU meet visibility improvement 

goals. Many of the state programs that will contribute to meeting the targeted EGU strategy 

are identified in Part 11.3.1 of this section. Listed below are other state programs not 

previously identified that will also contribute to meeting this strategy. These other programs 

may yield additional benefits by controlling emissions at certain EGUs not listed among the 
New Hampshire Regional Haze SIP Revision Page 131 

top 167 EGU stacks. The listed programs represent existing commitments by the states and, 

as such, were included in MANE-VU’s most recent modeling. 

Maryland Healthy Air Act: Maryland adopted the following requirements governing EGU 

emissions: 

• For NOX: Phase I (2009) sets unit-specific annual caps totaling 20,216 tons 

and ozone-season caps totaling 8,900 tons. 

Phase II (2012) sets unit-specific annual caps totaling 16,667 tons 

and ozone-season caps totaling 7,337 tons. 

• For SO2: Phase I (2010) sets unit-specific annual caps totaling 48,818 tons. 

Phase II (2013) sets unit-specific annual caps totaling 37,235 tons. 

• For mercury: Phase I (2010) requires a 12-month-rolling-average minimum 

removal efficiency of 80 percent. 

Phase II (2013) requires a 12-month-rolling-average minimum 

removal efficiency of 90 percent. 

The specific EGUs included are: Brandon Shores (Units 1 and 2), C.P.Crane (Units 1 and 2), 

Chalk Point (Units 1, and 2), Dickerson (Units 1, 2, and 3), H.A. Wagner (Units 2 and 3) 

Morgantown (Units 1 and 2), and R. Paul Smith (Units 3 and 4). No out-of-state trading of 

emission allowances, no inter-company trading of allowances, and no banking of allowances 

from year to year were included in the analyses. 

New Jersey Mercury MACT Rule: Under this rule all coal-fired EGUs in New Jersey will 

have a mercury removal efficiency of 90 percent. (Some SO2 reductions may occur as a cobenefit of mercury emission controls.) 

Consent Agreements in the VISTAS region: The following consent agreements in the 

VISTAS states were reflected in the emissions inventories used for those states: 

• East Kentucky Power Cooperative: A July 2, 2007, consent agreement between EPA 

and East Kentucky Power Cooperative (EKPC) requires the utility to reduce its SO2

emissions by 54,000 tons per year and its NOX emissions by 8,000 tons per year, by 

installing and operating selective catalytic reduction (SCR) technology; low-NOX

burners, and PM and mercury continuous emissions monitors at the utility’s Spurlock, 

Dale, and Cooper Plants. According to the EPA, total emissions from the plants will 

decrease between 50 and 75 percent from 2005 levels. As with all federal consent 

decrees, EKPC is precluded from using reductions required under other programs such 

as CAIR to meet the reduction requirements of the consent decree. EKPC is expected 

to spend $654 million to install pollution controls. 

• American Electric Power: Under this agreement, American Electric Power (AEP) will 

spend $4.6 billion dollars for emission controls at sixteen plants located in Indiana, 

Kentucky, Ohio, Virginia, and West Virginia. These control measures will eliminate 

72,000 tons of NOX emissions each year by 2016 and 174,000 tons of SO2 emissions 

each year by 2018 from the affected facilities.
New Hampshire Regional Haze SIP Revision Page 132 

11.5 Source Retirement and Replacement Schedules 

40 CFR Section 51.308(d)(3)(v)(D) of the Regional Haze Rule requires New Hampshire to 

consider source retirement and replacement schedules in developing reasonable progress 

goals. Source retirement and replacement were considered in developing the 2018 emissions 

inventory described previously in Subsection 10.3, Reasonable Progress Goals for Class I 

Areas in the State. See also Table B-5 in the Emission Projections Report (Attachment N). 

The following sources in New Hampshire were shut down (or replaced) after the 2002 base 

year and therefore were not included in the 2018 inventory: 

• Batesville Manufacturing, Inc. (Nashua, NH) 

• PSNH Schiller Station, Unit No. 5 boiler replacement (Portsmouth, NH) 

• Groveton Paperboard, Inc. (Groveton, NH) 

• Wausau Paper Printing & Writing, LLC (Groveton, NH)

Since the 2002 and 2018 inventories were developed and the modeling analyses performed, 

the following major source has also shut down: 

• Fraser N.H. LLC (Berlin, NH) 

11.6 Measures to Mitigate the Impacts of Construction Activities 

40 CFR 51.308(d)(3)(v)(B) of the Regional Haze Rule requires New Hampshire to consider 

measures to mitigate the impacts of construction activities on regional haze. MANE-VU’s 

consideration of control measures for construction activities is documented in “Technical 

Support Document on Measures to Mitigate the Visibility Impacts of Construction Activities 

in the MANE-VU Region,” Draft, October 20, 2006,” (Attachment DD). 

The construction industry is already subject to requirements for controlling pollutants that 

contribute to visibility impairment. For example, federal regulations require the reduction of 

SO2 emissions from construction vehicles. At the state level, New Hampshire’s Code of 

Administrative Rules Env-A 1002, Fugitive Dust, requires the control of direct emissions of 

particulate matter (primarily crustal material) from mining, transportation, storage, use, and 

removal activities. These requirements apply to such sources as quarries, unpaved roads, 

cement plants, construction sites, rock-crushing operations, and general earth-moving activities. 

Controls may include wet suppression, covering, vacuuming, and other approved means. 

MANE-VU’s Contribution Assessment (Attachment B) found that, from a regional haze 

perspective, crustal material generally does not play a major role. On the 20 percent bestvisibility 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 MANE-VU Class I Areas could 

have a noticeable effect on visibility. 
New Hampshire Regional Haze SIP Revision Page 133 

For this regional haze SIP, New Hampshire considered additional measures to mitigate the 

impacts of construction activities but decided to defer evaluation of further controls. Future 

deliberations on potential control measures for construction activities and their possible 

implementation will be documented in the first regional haze SIP progress report in 2013. 

11.7 Agricultural and Forestry Smoke Management 

40 CFR 51.308(d)(3)(v)(E) requires New Hampshire to consider smoke management 

techniques related to agricultural and forestry management in developing the long-term 

strategy. 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 the MANE-VU Region, September 1, 2006,” (Attachment V). 

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. 

The largest wood smoke source categories, with respect to PM2.5 emissions, are residential 

wood combustion (73 percent); open burning (15 percent); and industrial, commercial, and 

institutional wood combustion (9 percent). Unwanted fires involving buildings and wild 

lands make up only a minor fraction of wood burning emissions and cannot be reasonably 

addressed in a SIP. 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 MANE-VU. 

Moreover, smoke emissions from all sources represent only a minor fraction of fine-particle 

mass that is the cause of regional haze. MANE-VU’s Contribution Assessment (Attachment 

B) found that elemental carbon, the main ingredient of smoke, contributed only 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. It is therefore reasonable to conclude that 

smoke emissions from controlled agricultural and forestry burning contribute, on average, 

only a small fraction of one percent of total light extinction on days of both good and poor 

visibility. NHDES has no information to indicate that this situation would change significantly 

over the next decade. 

Nevertheless, New Hampshire intends to consult with the Forest Protection Bureau of the 

New Hampshire Department of Agriculture and with the New Hampshire Department of 

Resources and Economic Development (DRED) to consider smoke management in 

agricultural and forestry practices to address visibility effects at MANE-VU Class I Areas. In 

addition, New Hampshire will consider ways to improve the inventory of smoke emissions 

and to achieve a better understanding of the relative importance of agricultural and forestry 

sources (versus residential wood stoves, in particular) as contributors to regional haze. The 

results of these efforts will be documented in the first regional haze SIP progress report in 

2013. 

11.8 Estimated Effects of Long-Term Strategy on Visibility 

40 CFR 51.308(d)(3)(v)(G) requires New Hampshire to consider, in developing its long-term 

strategy, the anticipated net effect on visibility due to projected changes in point, area, and 

mobile source emissions over the period addressed by the long-term strategy. NESCAUM 

conducted modeling to evaluate the expected improvements to visibility at affected Class I 

areas by 2018 as a consequence of implementing MANE-VU’s long-term strategy. Those 
New Hampshire Regional Haze SIP Revision Page 134 

visibility improvements will result, in part, from the efforts identified in this SIP to reduce 

emissions that originate in New Hampshire. 

All Class I states affected by emissions originating in New Hampshire have (or will have) 

established reasonable progress goals for 2018 for each of their Class I areas. The control 

measures included in this SIP represent the reasonable efforts of New Hampshire, in 

conjunction with the efforts of other MANE-VU states, toward achieving the reasonable 

progress goals established by the affected states. 

Based on the most recent MANE-VU modeling, the proposed control measures will reduce 

sulfate levels at affected Class I areas by about one-third on the worst visibility days and by 

6 to 31 percent on the best visibility days by 2018. Nitrate and elemental carbon levels will 

also show substantial reductions across all areas for both best and worst days, while smaller 

reductions in organic carbon levels will occur. Small increases are predicted for the fine soil 

component of regional haze. There is a possibility that the predicted increases in this 

component are not real but, rather, related to structural differences in the data sets used in the 

modeling for the baseline and future years. (Specifically, the fire emissions inventory used in 

VISTAS for the base year relied on an earlier version of fire emissions data than the one used 

for the 2018 inventory.) No changes are predicted for sea salt because the model does not 

track this component. 

The 2000-2004 visibility readings at affected Class I areas provide the baseline against which 

future visibility readings will be measured to assess progress deriving from implementation of 

New Hampshire’s regional haze SIP and those of the other MANE-VU states. To determine 

baseline visibility for affected Class I areas, NHDES used the 2000-2004 IMPROVE 

monitoring data to calculate the average deciview values for the 20 percent best visibility days 

and the 20 percent worst visibility days over that period. (Note that both natural conditions 

and baseline visibility for the 5-year period were calculated in conformance with an 

alternative method recommended by the IMPROVE Steering Committee – see Subsection 

4.1) Thus, the 20 percent best day and 20 percent worst day values represent average visibility 

conditions for the top and bottom quintiles. 

To create the series of visibility graphs which follow, 2018 visibility estimates were made in 

accordance with EPA modeling guidance. First, 2002 daily average baseline concentrations 

were multiplied by their corresponding relative reduction factors to obtain 2018 projected 

concentrations for each day. The 2018 projected concentrations were then used to derive 

daily visibility in deciviews. As a final step, the deciview values for the 20 percent of days 

having best visibility were averaged, and the process repeated for the 20 percent of days having 

worst visibility. The resulting averages represent the projected upper and lower quintiles of 

visibility in 2018.

The following is provided to assist with interpretation of the line graphs in Figures 11.1 and 

Figures 11.3 through 11.6. Note that lower deciview values indicate better visibility. 

• The irregular blue line (~) represents the 20 percent best visibility average value as 

determined from monitoring data for each year of the period 2001-2005. 

• The irregular red line (~) represents the 20 percent worst visibility average value as 

determined from monitoring data for each year of the period 2001-2005. 
New Hampshire Regional Haze SIP Revision Page 135 

• The straight orange line (▬) represents the 20 percent best visibility average value as 

determined from monitoring data for the 5-year period of 2000-2004. (This line 

represents the 20 percent best visibility baseline condition.) 

• The straight blue line (▬) represents the 20 percent worst visibility average value as 

determined from monitoring data for the 5-year period of 2000-2004. (This line 

represents the 20 percent worst visibility baseline condition.) 

• The straight broken line (▪ ▪ ▪) is a continuation of the 20 percent best visibility baseline, 

representing the 20 percent best visibility condition as it would be with no further 

degradation or improvement. 

• The straight green line (▬) represents the 20 percent worst visibility values that 

establish the uniform rate of progress for the period 2004-2064. (This line is 

sometimes referred to as the uniform progress line, or “glide slope.” It was created by 

linear interpolation between the average 20 percent worst visibility baseline value 

from 2000-2004 and the 20 percent worst visibility value under natural conditions in 

2064. If visibility improvements match this rate of progress, actual visibility will 

return to natural conditions in 2064. Visibility values used for the calculation of 

uniform rate of progress may be found in Table 10.1.) 

• The light-green dash (▬) shown at 2064 represents the theoretical 20 percent best 

visibility value under natural conditions (i.e., no anthropogenic emissions). 

• The purple star () represents the 20 percent best visibility value in 2018 after 

implementation of MANE-VU’s long-term strategy, as predicted by the CMAQ model. 

(This value is a reasonable progress goal.) 

• The blue star () represents the 20 percent worst visibility value in 2018 after 

implementation of MANE-VU’s long-term strategy, as predicted by the CMAQ model. 

(This value is a reasonable progress goal.) 

Figure 11.1 illustrates predicted visibility improvements at Great Gulf Wilderness. Observe 

that the blue star lies below the green line, indicating that, by 2018, the long-term strategy of 

this SIP will result in visibility improvements surpassing the uniform rate of progress on days 

of worst visibility. Similarly, the position of the purple star below the dashed line indicates 

that visibility requirements will be met, i.e., there will be no further degradation from baseline 

conditions on days of best visibility. 

Figure 11.2 presents bar graphs depicting expected improvements in haze-causing pollutant 

levels at Great Gulf Wilderness. (The data employed for these graphs also apply to 

Presidential Range - Dry River Wilderness.) The graph on the left shows concentrations of 

visibility-impairing pollutants on days of best visibility for the 2000-2004 baseline period, 

2018 modeled year, and natural background condition. The graph on the right is a similar plot 

for days of worst visibility. The graphs show that almost all of the expected improvements 

will result from reductions in sulfate concentrations. If the states adhere to MANE-VU’s 

reasonable progress goals, sulfate levels (as a fraction of the total pollutant burden) will fall 

from about 60 percent in 2000-2004 to no more than 50 percent in 2018 and to less than 10 

percent (natural conditions) in 2064. 
New Hampshire Regional Haze SIP Revision Page 136 

Figure 11.1: Expected Visibility Improvement at Great Gulf Wilderness 

Based on Most Recent Projections 32

0

5

10

15

20

25

30

19851990199520002005201020152020202520302035204020452050205520602065

Year

Decivews

20% Worst Observed

20% Best Observed

20% Worst Baseline

20% Best Baseline

Uniform Progress

No Degradation

CMAQ 20% Worst

CMAQ 20% Best

20% Best 'Natural'

Figure 11.2: Expected Improvements in Pollutant Concentrations at Great Gulf 

Wilderness on Best and Worst Days

 

32 The visibility improvement estimate for Great Gulf Wilderness also serves as an estimate for Presidential Range - Dry 

River Wilderness. 

20% Best Days 20% Worst Days 

0

1

2

3

4

5

2000-2004

Baseline

2018 CMAQ Natural

Background

Conditions

Mass (ug/m3)

Sulfate Nitrate EC OC Sea Salt Soil

0

5

10

15

20

25

2000-2004

Baseline

2018 CMAQ Natural

Background

Conditions

Mass (ug/m3)

Sulfate Nitrate EC OC Sea Salt Soil
New Hampshire Regional Haze SIP Revision Page 137 

Figures 11.3 through 11.6 are line graphs showing anticipated visibility improvements for the 

other MANE-VU Class I Areas. All locations are projected to meet or exceed their uniformrate-of-progress goals for 2018. In addition, all areas are expected to see improvements in 

best-day visibility relative to baseline values. 

Figure 11.3: Expected Visibility Improvement at Acadia National Park 

Based on Most Recent Projections 

0

5

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19851990199520002005201020152020202520302035204020452050205520602065

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20% Best Baseline

Uniform Progress

No Degradation

CMAQ 20% Worst

CMAQ 20% Best

20% Best 'Natural'

Figure 11.4: Expected Visibility Improvement at Brigantine National Wildlife Refuge 

Based on Most Recent Projections 

0

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20% Worst Baseline

20% Best Baseline

Uniform Progress

No Degradation

CMAQ 20% Worst

CMAQ 20% Best

20% Best 'Natural'
New Hampshire Regional Haze SIP Revision Page 138 

Figure 11.5: Expected Visibility Improvement at Lye Brook Wilderness 

Based on Most Recent Projections 

0

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19851990199520002005201020152020202520302035204020452050205520602065

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20% Best Observed

20% Worst Baseline

20% Best Baseline

Uniform Progress

No Degradation

CMAQ 20% Worst

CMAQ 20% Best

20% Best 'Natural'

Figure 11.6: Expected Visibility Improvement at Moosehorn National Wildlife Refuge 

Based on Most Recent Projections 33

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No Degradation

CMAQ 20% Worst

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20% Best 'Natural'

 

33 The visibility improvement estimate for Moosehorn Wilderness also serves as an estimate for Roosevelt/Campobello 

International Park.
New Hampshire Regional Haze SIP Revision Page 139 

11.9 New Hampshire’s Share of Emission Reductions 

40 CFR 51.308(d)(3)(ii) of the Regional Haze Rule requires New Hampshire to demonstrate 

that its implementation plan includes all measures necessary to obtain its share of emission 

reductions needed to meet the reasonable progress goals. The modeling analyses referenced 

in Subsection 11.8, above, demonstrate that the New Hampshire/MANE-VU long-term 

strategy is sufficient to meet these visibility goals. 

The basis for the long-term strategy is a statement adopted by MANE-VU on June 20, 2007 

(see Part 3.3.3, The MANE-VU “Ask”). This document provides that each state will have up 

to 10 years to pursue adoption and implementation of reasonable control measures for NOX

and SO2 emission reductions. New Hampshire’s regional haze SIP is wholly consistent with 

this long-term strategy. To meet its obligation, New Hampshire agrees to pursue the 

following general and specific emission reduction measures: 

• Timely implementation of BART requirements at the two BART-eligible units in the 

state: PSNH Merrimack Station Unit MK2 and PSNH Newington Station Unit NT1; 

• Participation in a regional low-sulfur fuel oil strategy that will result in SO2 emission 

reductions from one oil-fired electrical generating unit, namely, PSNH Newington 

Station, as well as from ICI boilers and residential heating units across the state; 

• Emission controls on targeted in-state EGUs that contribute to visibility impairment at 

Class I areas in the region – more specifically, compliance with New Hampshire law 

RSA 125-O, Multiple Pollutant Reduction Program, which mandates the installation 

of scrubbers on PSNH Merrimack Station Units MK1 and MK2 by July 1, 2013, to 

control SO2 and mercury emissions. These controls will reduce SO2 emissions at these 

units by at least 90 percent from 2002 levels. It is anticipated that the scrubber will be 

optimized for mercury emission reductions and therefore may not meet the 95 percent 

SO2 reduction rate that is typical for scrubbers. However, the 90-percent minimum 

requirement effectively means that actual SO2 emission reductions must exceed 90 

percent on average. To the extent that these higher rates can be realized, they will be 

applied against the less than 90-percent SO2 reduction expected at Newington station 

in order to fulfill the state’s commitment to MANE-VU’s targeted EGU strategy. 

• Continued evaluation of other possible control measures for haze-causing emissions. 

Implementation of the long-term strategy will produce significant changes in New Hampshire’s 

emissions inventory by the end of the first planning period, 2018. Changes to the emissions 

inventory will also occur as a result of population growth; changes in land use and 

transportation; development of industrial, energy, and natural resources; and other air pollution 

control measures not directly related to regional haze. However, it is the expected reductions 

in SO2 emissions that will have the greatest effect on visibility improvement at MANE-VU 

Class I Areas; and those reductions will be largely due to implementation of the control 

measures developed for this SIP. (As a precursor to sulfate, SO2 emissions are responsible for 

most of the fine-particle mass on the haziest days at MANE-VU Class I Areas. See Section 8, 

Understanding the Sources of Haze-Causing Pollutants.) 

Current and projected SO2 emissions for the various source categories in New Hampshire and, 

for comparison, all of MANE-VU are summarized in Tables 11.2 and 11.3. These emissions 

represent the majority of all haze-causing pollutants originating within the state and region. 
New Hampshire Regional Haze SIP Revision Page 140 

Further information on New Hampshire’s emissions inventory, including other pollutants that 

contribute to visibility impairment, is available in Section 6, Emissions Inventory. 

Table 11.2: SO2 Emissions from Point, Area, and Mobile Sources 

in New Hampshire (tpy) 

Source Category Baseline 

2002 

Projected 

2018 

% Reduction 

2002-2018 

Area 7,072 972 86.3 

Non-EGU Point 2,436 1,084 55.5 

EGU Point 44,124 10,766 75.6 

On-Road Mobile 777 537 30.9 

Non-Road Mobile 891 246 72.4 

TOTAL 55,300 13,605 75.4 

Table 11.3: SO2 Emission from Point, Area, and Mobile Sources 

in all of MANE-VU (tpy) 

Source Category Baseline 

2002 

Projected 

2018 

% Reduction 

2002-2018 

Area 286,921 129,656 54.8 

Non-EGU Point 264,377 91,438 65.4 

EGU Point 1,643,257 368,717 77.6 

On-Road Mobile 40,090 8,757 78.2 

Non-Road Mobile 57,257 8,643 84.9 

TOTAL 2,291,902 607,211 73.5 

The projected overall reduction of 75.4 percent for SO2 emissions originating in New 

Hampshire exceeds by a small amount the projected average reduction of 73.5 for all of 

MANE-VU. This comparison indicates that New Hampshire will meet its share of anticipated 

SO2 emission reductions within the region by 2018. 

11.10 Emission Limitations and Compliance Schedules

40 CFR 51.308(d)(3)(v)(C) requires New Hampshire to establish emission limitations and 

compliance schedules to meet reasonable progress goals. While emission limitations and 

compliance schedules are already in place for some New Hampshire control measures 

outlined in Subsections 11.3 and 11.4, other such provisions will need to be established by 

law (Revised Statutes Annotated, RSA) or codified in New Hampshire Rules Governing the 

Control of Air Pollution (Env-A 100 - 4300); specifically: 

• Best Available Retrofit Technology (BART): The emission limitations and 

compliance schedule for New Hampshire’s two BART-eligible sources are detailed in 

Section 9. The BART emission limitations will be enforceable through a combination 

of existing permit conditions, existing administrative rules, and a proposed 

administrative rule to be adopted as Chapter Env-A 2300 Mitigation of Regional Haze 

(see draft rule, Attachment GG). The tentative schedule for development and adoption
New Hampshire Regional Haze SIP Revision Page 141 

of this new rule begins with initial rulemaking in early 2012 and concludes with an 

effective date of July 1, 2013. All BART provisions will have this compliance date. 

• Low-Sulfur Fuel Oil Requirements: New Hampshire commits to revising Part EnvA 1604, Sulfur Content Limitations for Liquid Fuels, of the New Hampshire Code of 

Administrative Rules to require widespread use of low-sulfur fuel oil in accordance 

with the MANE-VU strategy. A draft copy of the proposed rule change is included in 

Attachment FF. The schedule for this rule revision matches the schedule stated above 

for Env-A 2300 Mitigation of Regional Haze. Phase 1 requirements for suppliers and 

users of low-sulfur fuel oil would take effect on July 1, 2013. Phase 2 requirements 

would be effective on July 1, 2017. (Note: Because New Hampshire’s regulations 

sunset every five years, the state is unable to adopt requirements now with a compliance 

date of 2017.) 

• Emission Reductions from Specific EGUs: PSNH Merrimack Station Units MK1 

and MK2 and PSNH Newington Station Unit NT1 are included in MANE-VU’s 

targeted EGU strategy. The Merrimack plant is required by New Hampshire law to 

install a flue gas desulfurization system (scrubber) to remove SO2 and other major 

pollutants by July 1, 2013 (see temporary permit for Units MK1 and MK2, Attachment 

EE). This control measure will simultaneously satisfy BART requirements for Unit 

MK2. PSNH Newington Station Unit NT1, which is also subject to BART limitations, 

will find it necessary to control fuel sulfur levels in order to achieve a more stringent 

SO2 emission limit than is currently allowed (see BART Analyses for Sources in New 

Hampshire, Attachment X, and Title V operating permit, Attachment II). The BART 

compliance date of July 1, 2013, matches the effective date for Phase 1 of the low-sulfur 

fuel oil strategy. The BART and low-sulfur fuel requirements are intended to 

complement each other. 

NHDES will continue to evaluate all measures included in the long-term strategy to ascertain 

whether they remain reasonable for New Hampshire to implement by the end of the SIP 

planning period (2018) and will formalize that determination with the submission of the first 

regional haze SIP progress report in 2013. New Hampshire intends to adopt all reasonable 

control measures as expeditiously as practicable, in a manner consistent with state law, so 

that they may be in place by the indicated compliance dates. 

11.11 Enforceability of Emission Limitations and Control Measures 

40 CFR 51.308(d)(3)(v)(F) requires New Hampshire to ensure that emission limitations and 

control measures used to meet reasonable progress goals are enforceable. All control 

measures incorporated into law or codified in administrative rules will be enforceable. Any 

facility subject to state or federal permit requirements, including BART-eligible and Title V 

facilities, will be required to comply with the specific permit conditions that reference the 

applicable provisions of those laws and rules. 

In New Hampshire, the authority to create rules, issue permits, and enforce laws related to 

regional haze are established in Revised Statutes Annotated (RSA) 125-C Air Pollution 

Control. Under RSA 125-C:6, Powers and Duties of the Commissioner, the NHDES 

Commissioner is authorized to enforce the state’s air laws, establish a permit program, accept 

and administer grants, and exercise all incidental powers necessary to carry out the statutory 

obligations. 
New Hampshire Regional Haze SIP Revision Page 142 

Sections of New Hampshire law of particular relevance to the regional haze SIP are: 

• RSA 125-C:4, Rulemaking Authority; Subpoena Power, which establishes requirements 

by which the Commissioner shall adopt rules related (but not limited) to: 

− primary and secondary ambient air quality standards; 

− prevention, control, abatement, and limitation of air pollution; 

− procedures to meet air pollution emergencies, 

− establishment and operation of a statewide permit system; 

− notification and public hearings on permit applications; 

− fees and procedures for permit application and review; and 

− procedures for air testing/monitoring and recordkeeping; 

and which authorizes the Commissioner to issue subpoenas requiring the attendance of 

witnesses, production of evidence, and taking of testimony as he may deem necessary. 

• RSA 125-C:11, Permit Required, which authorizes the creation of a permit program 

and the issuance of permits requiring specific emission control measures, including 

enforceable emission limitations; 

• RSA 125-C:12, Administrative Requirements, which authorizes the Commissioner to 

collect fees to recover the costs of reviewing and acting upon permit applications and 

enforcing the terms of permits issued; and 

• RSA 125-C:15, Enforcement, which authorizes NHDES to issue orders to correct 

violations of RSA 125-C and establishes the legal authority for the enforcement of 

New Hampshire Rules Governing the Control of Air Pollution (Env-A 100 - 4300). 

The New Hampshire rules provide for enforceable emission control measures and compliance 

schedules to meet the applicable requirements of the Clean Air Act and rules promulgated by 

EPA. The New Hampshire rules also define the permit program and fee structure for stationary 

sources, to ensure that national ambient air quality standards are achieved; specifically: 

• Chapter Env-A 600, Statewide Permit System (effective 4-26-03, 7-28-04, 6-8-06, 4-3-

08, and 4-22-09), provides for the issuance of temporary permits, state permits to 

operate, and Title V operating permits. Part Env-A 619 of this chapter addresses the 

prevention of significant deterioration of air quality and visibility protection, in 

accordance with the requirements of 40 CFR 51.166, 40 CFR 52.21 and RSA-125-C. 

• Chapter Env-A 700 Permit Fee System (effective 4-26-03 and 6-26-04) provides for 

the payment of fees to cover the reasonable costs of administering the permit program 

and of implementing and enforcing the terms and conditions of any permit. 

With respect to specific control measures for visibility improvement under the Regional Haze 

Rule, the following enforceable provisions will apply: 

• PSNH Merrimack Station Units MK1 and MK2, is required to install an FGD system 

by July 1, 2013, to achieve major emission reductions in SO2 and other pollutants as 

established under New Hampshire law RSA 125-O, Multiple Pollutant Reduction 

Program, and as set forth in Temporary Permit No. TP-0008, issued March 9, 2009 

(Attachment EE). 
New Hampshire Regional Haze SIP Revision Page 143 

• PSNH Newington Station Unit NT1 will be required to meet a new SO2 emission limit 

of 0.50 lb/MMBtu by July 1, 2013, for any fuel or combination of fuels burned, as 

provided in New Hampshire’s proposed rule Env-A 2300 Mitigation of Regional Haze 

(Attachment GG). 

• Statewide use of low-sulfur fuel oil for all emission sources, consistent with MANEVU’s low-sulfur fuel strategy, will be required following adoption of revisions to New 

Hampshire’s existing rule Env-A 1604 Sulfur Content Limitations for Liquid Fuels 

(Attachment FF) by no later than July 1, 2013. 

Ultimately, New Hampshire’s Regional Haze SIP is dependent on the implementation of 

enforceable emission limitations and control measures, both within the state and in other 

states identified as contributing to visibility impairment at New Hampshire’s Class I Areas. 

Because New Hampshire has no jurisdiction over other states, the attainment of regional 

progress goals will, to a large extent, be predicated on the good-faith efforts of contributing 

upwind states to meet their fair share of emission reductions through implementation of their 

own enforceable control measures. While New Hampshire can provide assurances regarding 

the implementation of in-state emission controls, the bulk of regional-haze-causing pollutants 

over New Hampshire will continue to come from out-of-state sources. 

11.12 Prevention of Significant Deterioration 

Part Env-A 619 of Chapter Env-A 600 of New Hampshire’s Rules spells out the Prevention of 

Significant Deterioration (PSD) requirements of the Statewide Permit System. PSD is 

applicable to all major sources (or existing sources making a major modification) located in 

an area that is in attainment with the National Ambient Air Quality Standards. A major 

source is an emissions source that has the potential to emit more than 100 tons per year of any 

pollutant. One of the purposes of the PSD program is to protect air quality in national parks, 

wilderness areas, and other areas of special natural, scenic, or historic value. The PSD 

permitting process requires a technical air quality analysis and additional analyses to assess 

the potential impacts on soils, vegetation, and visibility at Class I areas. 

PSD permit applicants are required to conduct such analyses, and may do so in consultation 

with NHDES and the relevant Federal Land Manager (FLM). Recommended procedures for 

evaluating the impacts of a proposed PSD source on air quality and visibility at Class I areas 

are provided in NHDES’ “Guidance and Procedure for Performing Air Quality Modeling in 

New Hampshire,” July 2006. New major sources and existing sources making major 

modifications will be constructed and operated so as not to degrade air quality or visibility. 

The PSD permitting program, as set for under Env-A 619, is an integral part of New 

Hampshire’s long-term strategy for meeting its regional haze goals. 
New Hampshire Regional Haze SIP Revision Page 144 

12. Administrative Materials 

On May 25, 2009, NHDES published in a statewide newspaper, the Manchester, NH, Union 

Leader, a public notice soliciting comment on New Hampshire’s Regional Haze SIP Revision. 

The notice also announced the opportunity to request a public hearing for the SIP revision. A 

public hearing was held at NHDES headquarters on Wednesday, June 24, 2009. A copy of 

the public notice is presented in Attachment JJ. Documentation certifying the public process 

is provided in Attachment KK. Evidence of legal authority to create and submit this SIP 

revision may be found in Attachment LL. 

NHDES received written comments from EPA and the Federal Land Managers on June 26, 

2009. NHDES also received written comments from the Appalachian Mountain Club on that 

date. NHDES has addressed all comments in the SIP revision. Comments from EPA and the 

FLMs, and NHDES’s formal responses to those comments, are included in Attachment I. 

Comments from AMC and responses to those comments are included in Attachment J. 
New Hampshire Regional Haze SIP Revision 

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