# District of Columbia Regional Haze State Implementation Plan

Submitted to:

U.S. Environmental Protection Agency, Region 3

Prepared by:

GOVERNMENT OF THE DIST RICT OF COLUMBIA District Department of the Environment Air Quality Division 1200 First Street, NE Washington, DC 20002 green.dc.gov

FINAL October 2011The District Department of the Environmental acknowledges the Mid-Atlantic Visibility Union (MANE-VU), Mid-Atlantic Regional Air Manage ment Association (MARAMA), Northeast States for Coordinated Air Use Management (NESCAUM), all of the other MANE-VU states, as well as Federal counterparts at the U.S. Environmental Protection Agency Region 3, U.S. Department of Interior’s National Park Service and Fish and Wildlife Service, and the U.S. Department of Ag riculture’s Forest Service

for their assistance and guid ance during the assembly of this State Implementation Plan.

### TABLE OF CONTENTS

1. BACKGROUND ................................................................................................................................................ 2

1.1. GENER AL DESCRIPTION OF REGIONAL HAZE .......................................................................... 2 1.2. THE CLEAN AIR ACT GOAL AND THE FEDERAL REGIONAL HAZE RULE ........................ 2

2. GENER AL STATE IMPLEMENTATI ON PLAN REQUIREMENTS ....................................................... 7

3. REGIO NAL PLANNING AND CONSULTATION....................................................................................... 9

3.1. PA RTICIPATION IN REGIONAL PLANNING ORGANIZATION................................................. 9 3.2. CO NSULTATION FRAMEWORK ..................................................................................................... 11 3.3. CO NSULTATION WITH OTHER STATES...................................................................................... 12 3.3.1. States N otifying the District of Contribu tion to Haze .......................................................................... 12
3.3.2. MANE-V U Consul tation Area.............................................................................................................. 13 3.3.3. Sum mary of MANE-VU Consultation ................................................................................................

.. 15

4. FEDER AL LAND MANAGER COORDINATION ..................................................................................... 17

4.1. PRELIM INARY CONSULTA TION WITH FLMS ........................................................................... 17 4.2. CO NSULTATION WITH FLMS CONCERNING THIS SIP ........................................................... 17 4.3. CO MMITMENT TO CONTINUING CONSULTATION WITH FLMS IN THE FUTURE......... 17 4.4. REASONAB LY ATTRIBUTABLE VISIBILITY IMPAIRMENT................................................... 18

5. MO NITORING STRATEGY ............................................................................................................

............. 19

5.1. USE OF IMPROVE MONITORING ................................................................................................... 19 5.2. USE OF IMPROVE MONITORING TO TRACK PROGRESS....................................................... 19

6. ASSES SMENT OF BASELINE, NAT URAL AND CURRENT CONDITIONS ....................................... 21

7. CA USES OF VISIBILITY IMPAIRMENT AT NEARBY CLASS I AREAS ........................................... 22

7.1. MO NITORING RESULTS .............................................................................................................

...... 23 7.2. HAZ E POLLUTANT EMISSION S – SOURCES AND TRENDS .................................................... 24
7.2.1. S ulfur Dioxide (SO 2 ) ............................................................................................................................ 25 7.2.2. Volatile Or ganic Co mpounds (VOC)...............................................................................................

.... 27
7.2.3. Oxi des of Nitrogen (NO
x )..................................................................................................................... 29
7.2.4. Prima ry Particulate Matter (PM 10 and PM 2.5 ) .................................................................................... 30 7.2.5. Amm onia Em issions..............................................................................................................

............... 34 7.3. DAT A ANALYSIS AND MODELING ................................................................................................ 35
7.3.1. Grid-B ased Source Modeling (REMSAD tagged runs)........................................................................ 37 7.3.2. Emissions Divided by Distance (Q/d) ............................................................................................

...... 37
7.3.3. Air Parcel -Based Source Di spersion Modeling (CALPUFF).............................................................. 38 7.3.4. Emissions Times Up wind Pr obability.............................................................................................

..... 39 7.4. CO MPARISON OF TECHNIQUES .................................................................................................... 40

8. CLAS S I AREAS WHICH MAY BE AFFECTED BY DISTRICT EMISSIONS ..................................... 42

8.1. DC ’S CONTRIBUTION TO VISIBILITY IMPAIRMENT IN CLASS I AREAS .......................... 42
8.1.1. MANE-V U Cla ss I Areas ..........................................................................................................

........... 42 8.1.2. VISTA S Class I Areas ...........................................................................................................

............... 43

9. EMISSI ONS INVENTORIES FOR MODELING........................................................................................ 44

9.1. BASELINE AND FUTURE YEAR INVENTORIES FOR MODELING......................................... 44 9.2. DEVELOP MENT OF MANE-VU’S 2002 BASELINE INVENT ORY ............................................. 45 9.3. DEVELOP MENT OF FUTURE YEAR EMISSION INVENTORIES FOR MANE-VU................ 46 9.3.1. Emissions C ontro l Scenarios ....................................................................................................

........... 47 9.4. BRIEF S UMMARY OF CA LCULATION METHODS..................................................................... 48 9.4.1. Stationary P o int Sou rces .......................................................................................................

.............. 49 9.4.2. Stationary Ar e a Sources ........................................................................................................

.............. 509.4.3. Onroad Mobile Sources..........................................................................................................

............. 50 9.4.4. Nonr oad Mobi le Sources .........................................................................................................

............ 50 9.4.5. Bioge nic Emissi on Sou rces......................................................................................................

............ 51 9.5. SU MMARY OF EMISSIONS ...........................................................................................................

.... 51 9.5.1. Emissions fr om Sources in the District of Columbia ........................................................................... 51 9.5.2. Emissions fr om the District Co mpared to MANE-VU Emissions ........................................................ 52

10. REAS ONABLE PROGRESS GOALS ...................................................................................................... 55

10.1. REQ UIREMENT ....................................................................................................................

............... 55 10.2. RELATIO NSHIP TO THE LONG-TERM STRATEGY................................................................... 56 10.3. EFFECT OF REMAND OF C LEAN AIR INTER STATE RULE..................................................... 57

11. BEST AVAIL ABLE RETROF IT TECHN OLOGY ................................................................................ 58

11.1. BART ELI GI BILI TY ...............................................................................................................

............. 58 11.2. SOU RCES SUBJEC T TO BART ........................................................................................................

. 59
11.2.1. Cap-O uts and Shutdowns.........................................................................................................

....... 59 11.2.2. Sm all Source Exemption .........................................................................................................

........ 59
11.2.3. CAIR...........................................................................................................................

..................... 60 11.3. BART FOR THE DISTRICT..........................................................................................................

...... 61 11.3.1. Description of BART-Eligible Sources in th e Dist rict..................................................................... 61
11.3.2. Is BR GS Subj ect to BART?.......................................................................................................

....... 61
11.3.3. BART f or BRGS..................................................................................................................

............. 62 11.4. AD DITIONAL EMISSIONS REDUCTIONS...................................................................................... 62

12. THE DIST RICT’S LO NG-TERM STRATEGY...................................................................................... 64

12.1. REQ UIREMENT FOR LO NG-TERM STRATEGY ......................................................................... 64 12.2. DO CUMENTATION OF TECHNICAL BASIS FOR THE DISTRICT’S EMISSION REDUCTION O BLIGATIONS..........................................................................................................

................. 64 12.3. OVE RVIEW OF THE LONG-TERM ST RATEGY DEVELOPMENT PROCESS ....................... 65 12.4. KEY A NTHROPOGENIC SOURCES OF VISIBILITY IMPAIRMENT ....................................... 66
12.4.1. So urces of SO 2 Emissions................................................................................................................ 66
12.4.2. Sources of Othe r Pollutants ....................................................................................................

........ 67 12.5. EMISS ION REDUCTIONS DUE TO ONGOING AIR POLLUTION PROGRAMS..................... 68 12.5.1. EGU Emissions Controls Expected by 2018 Due to Ongo ing Air Po llution................................... 68 Control Pr ograms

............................................................................................................... ........... 68
12.5.2. No n-EGU Point Source Controls Expected by 2018 Due to Ongoing Air Pollution Control Programs........................................................................................................................................ 70
12.5.3. Area Sources Controls Expected by 2018 Du e to Ongoing Air Pollu tion Control Programs ........ 71
12.5.4. C ontrols on Nonroad Sources Expected by 2018 due to Ongoing Air Pollution Contro l Programs........................................................................................................................................ 72
12.5.5. Mobile Source Controls Expected by 2018 du e to Ongoing Air Pollu tion Control Programs ....... 72 12.6. ADDITIONAL REASONABLE STRAT EGIES CONSIDERED FOR MANE-VU’S LONGTERM STRATEGY ..................................................................................................................

........................... 73 12.6.1. Ide ntification of Key Source Ca tegories ........................................................................................

. 73 12.6.2. Analysis of t he Four Statutory Factors .........................................................................................

.. 74 12.7. AD DITIONAL CONTROL MEASURES CONSIDERED ................................................................ 76 12.7.1. Source Retirement and Re placement Schedules.............................................................................. 76
12.7.2. Meas ures to Mitigate the Impact s of Construc tion Activ ities ......................................................... 76
12.7.3. Agricultural and Forest ry Smoke Management .............................................................................. 77 12.8. ESTIMATED IMPACTS OF THE DISTRICT’S LONG-TERM STRATEGY ON VISIBILITY 77 12.9. SHA RE OF EMISSION REDUCTIONS ............................................................................................. 77 12.10. CH ANGES TO EMISSIONS BY 2018................................................................................................. 78 12.11. ENFO RCEABILITY OF EMISSION LIMITATIONS AND CONTROL MEASURES ................ 79

13. NE XT STEPS.....................................................................................................................

.......................... 81

### L IST OF 

### T ABLES

T ABLE 3.1. MANE-VU M EMBERS

............................................................................................................................... .9
T ABLE 3.2. S TATES I NCLUDED IN THE MANE-VU C ONSULTATION A REA

.................................................................. 14
T ABLE 7.1. S UMMARY OF T ECHNICAL A PPROACHES FOR A TTRIBUTING S TATE

.......................................................... 22
T ABLE 8.1. P ERCENT A NNUAL A VERAGE S ULFATE C ONTRIBUTION FROM D ISTRICT S OURCES IN 2002...................... 42
T ABLE 9.1. DC 2002 E MISSIONS I NVENTORY S UMMARY

............................................................................................ 51
T ABLE 9.2. DC 2018 OTB/W E MISSIONS I NVENTORY S UMMARY

............................................................................... 52
T ABLE 9.3. R EGIONAL S UMMARY OF THE 2002 MANE-VU E MISSIONS I NVENTORY

.................................................. 52
T ABLE 9.4. P ERCENT OF 2002 MANE-VU E MISSIONS FROM S OURCES IN THE D ISTRICT

............................................ 53
T ABLE 9.5. R EGIONAL S UMMARY OF THE MANE-VU 2018 OTB/W E MISSIONS I NVENTORY

.................................... 53
T ABLE 9.6. P ERCENT OF MANE-VU 2018 OTB/W E MISSIONS FROM S OURCES IN THE D ISTRICT

............................... 53
T ABLE 10.1. D ECIVIEW E STIMATES

............................................................................................................................. 56
T ABLE 10.2 C OMPARISON OF 2018 RPG AND OTB/W D ECIVIEW I MPACTS ................................................56
T ABLE 11.1 BART-E LIGIBLE S OURCES IN THE D ISTRICT OF C OLUMBIA

................................................... .61
T ABLE 11.2 E STIMATED EGU E MISSIONS R EDUCTIONS .......................................................................63
T ABLE 12.1. C ORRECTED E MISSIONS FROM THE D ISTRICT OF C OLUMBIA

................................................................... 72
T ABLE 12.2. E MISSIONS FROM P OINT
, A REA
, AND M OBILE S OURCES IN MANE-VU (SO 2 TPY ) ................................. 79
T ABLE 12.3. E MISSIONS FROM P OINT
, A REA
, AND M OBILE S OURCES IN THE D ISTRICT (SO 2 TPY ) .............................. 79

### L IST OF 

### F IGURES

F IGURE 1.1. C LASS I A REAS W ITHIN 300 KM OF THE D ISTRICT OF C OLUMBIA

.............................................................. 3
F IGURE 1.2. C LASS I A REAS IN THE MANE-VU AND VISTAS R EGIONS
, ..................................................................... 6
F IGURE 7.1. B ASELINE C ONTRIBUTIONS TO PM 2.5 E XTINCTION AT S EVEN C LASS 1 A REAS

........................................ 24
F IGURE 7.2. S TATE L EVEL S ULFUR D IOXIDE E MISSIONS

............................................................................................. 26
F IGURE 7.3. 2002 A NNUAL A NTHROPOGENIC SO 2 E MISSIONS BY S TATE AND P ERCENT BY S OURCE T YPE

................ 27
F IGURE 7.4. 2002 A NNUAL A NTHROPOGENIC VOC E MISSIONS BY S TATE AND P ERCENT BY S OURCE T YPE

.............. 28
F IGURE 7.5. S TATE L EVEL N ITROGEN O XIDES E MISSIONS

.......................................................................................... 29
F IGURE 7.6. 2002 A NNUAL A NTHROPOGENIC NO X E MISSIONS BY S TATE AND P ERCENT BY S OURCE T YPE

............... 30
F IGURE 7.7. S TATE L EVEL P RIMARY PM 10 E MISSIONS

................................................................................................ 31
F IGURE 7.8. S TATE L EVEL P RIMARY PM 2.5 E MISSIONS

................................................................................................ 32
F IGURE 7.9. 2002 A NNUAL A NTHROPOGENIC P RIMARY PM 10 E MISSIONS

................................................................... 33
F IGURE 7.10. 2002 A NNUAL A NTHROPOGENIC P RIMARY PM 2.5 E MISSIONS

................................................................ 33
F IGURE 7.11. S TATE L EVEL A MMONIA E MISSIONS

...................................................................................................... 34
F IGURE 7.12. 2002 A NNUAL A NTHROPOGENIC NH 3 E MISSIONS

.................................................................................. 35
F IGURE 7.13. R ANKED STATE PERCENT SULFATE CONTRIBUTIONS TO M ID -A TLANTIC C LASS I RECEPTORS BASED ON

EMISSIONS DIVIDED BY DISTANCE (Q/ D ) RESULTS

............................................................................................... 38
F IGURE 7.14. R ANKED STATE PERCENT SULFATE CONTRIBUTIONS TO M ID -A TLANTIC C LASS I RECEPTORS BASED ON

OBSERVATION

- BASED (VT) CALPUFF RESULTS

................................................................................................ 39
F IGURE 7.15 ( A AND B ). C OMPARISON OF NORMALIZED ( PERCENT CONTRIBUTION ) RESULTS USING DIFFERENT TECHNIQUES FOR RANKING STATE CONTRIBUTIONS TO SULFATE LEVELS AT THE S HENANDOAH AND B RIGANTINE C LASS I A REAS

............................................................................................................................... .................... 40
F IGURE 12.1. 167 EGU S TACKS A FFECTING MANE-VU C LASS I A REA ( S ) ................................................................ 67

### L IST OF 

### A PPENDICES

APPENDIX A MANE-VU’s Final Interim Principles for Regional Planning

APPENDIX B Inter-RPO State/Tribal and FLM Consultation Framework

APPENDIX C Summary of Federal Land Manager Comments and District Responses

APPENDIX D Technical Support Document for 2002 MANE-VU SIP Modeling Inventories, Version 3

APPENDIX E Development of Emissions Projections for 2009, 2012, and 2018 for Non-EGU Point, Area, and Nonroad Sources in the MANE-VU Region

APPENDIX F Documentation of 2018 Emissions from Electric Generating Units in the Eastern United States for MANE-VU’s Regional Haze Modeling

APPENDIX G Development of MANE-VU Mobile Source Projection Inventories for SMOKE/MOBILE6 Application

APPENDIX H MANE-VU Modeling for Reasonable Progress Goals: Model Performance Evaluation, Pollution Apportionment, and Control Measure Benefits (NESCAUM, February 2008)

APPENDIX I 2018 Visibility Projections (NESCAUM, March 2008)

APPENDIX J Baseline and Natural Visibility Conditions

APPENDIX K Contributions to Regional Haze in the Northeast and Mid-Atlantic United States (NESCAUM, August 2006)

APPENDIX L NYSDEC Technical Support Document TSD-1a

APPENDIX M NYSDEC Technical Support Document TSD-1e

APPENDIX N NYSDEC Technical Support Document TSD-1d

APPENDIX O The Nature of the Fine Particle and Regional Haze Air Quality Problems in the MANEVU Region: A Conceptual Description (NESCAUM, November 2006)

APPENDIX P Assessment of Reasonable Progress for Regional Haze in MANE-VU Class I Areas (called the Reasonable Progress Report )

APPENDIX Q Five-Factor Analysis of BART-Elig ible Sources: Survey of Options for Conducting BART Determinations

APPENDIX R Assessment of Contro l Technology Options for BART-Eligible Sources: Steam Electric Boilers, Industrial Boilers, Cement Plants and Paper and Pulp Facilities.

APPENDIX S Technical Support Document on Agricultural and Forestry Smoke Management in the MANE-VU Region

APPENDIX T Technical Support Document on M easures to Mitigate the Visibility Impacts of Construction Activities in the MANE-VU Region

APPENDIX U DC Municipal RegulationsAPPENDIX V Regional Long-Term Strategy Letter to Improve the Visibility at Brigantine Wilderness (letter from New Jersey; letter from New Hamp shire; Resolution of the Commissioners of States with Mandatory Class I Federal Areas Within the MANE-VU))

### A CRONYMS AND 

### A BBREVIATIONS

BART Best Available Retrofit Technology BEIS Biogenic Emission Inventory System BOTW Beyond On the Way CAA Clean Air Act CAIR Clean Air Interstate Rule CALMET CALPUFF meteorological wind field pre-processor CALPUFF California Puff Model CAMR Clean Air Mercury Rule CAP Cooperative Agency Profilers CASTNET Clean Air Status Trends Network
CEED Center for Energy and Ec onomic Development v. EPA CEM Continuous Emissions Monitoring CERR Consolidated Emissions Reporting Rule CFR Code of Federal Regulations CMAQ Community Multiscale Air Quality CMAS Community Modeling and Analysis System DC District of Columbia DV Deciview EGU Electric Generating Unit EKPC East Kentucky Power Cooperative EPA Environmental Protection Agency FGD Flue Gas Desulfurization FLM Federal Land Manager GCVTC Grand Canyon Visibility Transport Commission GEOS Goddard Earth Observing System HAP Hazardous Air Pollutant ICI Industrial, Commercial, and Institutional IMPROVE Interagency Monitoring of Protected Visual Environments IPM Integrated Planning Model kW Kilowatts LSD Low Sulfur Diesel MACT Maximum Achievable Control Technology MANE-VU Mid-Atlantic and Northeast Visibility Union MARAMA Mid-Atlantic Regional Air Management Association MDE Maryland Department of the Environment
MM5 NCAR 5 th Generation Mesoscale Model MRPO Midwest RPO NCAR National Center for Atmospheric Research NESCAUM Northeast States for Coordinated Air Use Management NEI National Emissions Inventory NET National Emissions Trends
NH 3 Ammonia (NH 3 ) NIF NEI Input Format NJDEP New Jersey Department of Environmental Protection NMHC Non-Methane Hydrocarbons NP National Park NSPS New Source Performance Standards NTI National Toxics Inventory NWS National Weather Service NYSDEC New York State Department of Conservation OTB On the books OTB/W On the books/On the way OTC Ozone Transport Commission OTR Ozone Transport RegionOTW On the way PAG Policy Advisory Group PES Pepco Energy Services, Inc. PJM PJM Interconnection, LLC
PM 10 Particles with an aerodynamic diameter less than or equal to 10 μm
PM 2.5 Particles with an aerodynamic diameter less than or equal to 2.5 μm PPR Potomac Power Resources, LLC QA Quality Assurance QAPP Quality Assurance Project Plan RACT Reasonably Available Control Technology REMSAD Regional Model for Aerosols and Deposition ROP Rate of Progress RPG Reasonable Progress Goals RPO Regional Planning Organization RWC Residential Wood Combustion SCC Source Category Code SCR Selective Catalytic Reduction SIP State Implementation Plan SMOKE Sparse Matrix Operator Kernel Emissions
SO 2 Sulfur Dioxide (SO 2 ) SOA Secondary Organic Aerosols
TPY Tons Per Year TSC Technical S upport Committee UMD University of Maryland U.S. United States USC United States Code VADEQ Virginia Department of Environmental Quality VEPCO Virginia Electric and Power Company VISTAS Visibility Improvement State and Tribal Association of the Southeast VOC Volatile Organic Compounds (VOC) VTDEC Vermont Department of Environmental Conservation WRAP Western Regional Air PartnershipOctober 2011

2 District of Columbia Regional Haze SIP 

### 1. Background

1.1. General Description of Regional Haze

Good Visibility – v iewing the scenery through clean, fr esh air – is a valued attribute of lands that are Federally protected and managed for the enjo yment of future generations and to preserve natural conditions. This plan addresses visibility impairme nt at key national parks and wilderness areas caused by the emission of air pollutants from numerous sources located over a wide geographic area, otherwise known as regional haze.

Regional haze in the Eastern United States is caused primarily by anthropogenic (manmade) pollutants but can also be influenced by a number of natural phenomena, in cluding forest fires, dust, storms, and sea spray. The optical effects of these pollutants and na tural substances result from the scattering and absorption of light by particles and gasses. The scattering of light by fine particles (those less than 2.5 micr ons in diameter) is the predomin ant contributor at most times and places.

Some haze-causing particles are emitted directly to the atmosphere by primary sources of particle emission such as electr ic power plants, factories, auto mobiles, construction activities, and agricultural burning. Others occur when gases emitted into the air (particle precursors) interact to form secondary particles. Some secondary particles including sulfate and nitrate compounds are hygroscopic, and will grow in size and scatter more light as relative humidity increases.

Fine particles formed from multip le primary and secondary sources can mix together over broad geographic areas and can be tran sported hundreds or thousands of miles. Consequently, regional haze occurs throughout the nation.

1.2. The Clean Air Act Goal and the Federal Regional Haze Rule

In am ending the Clean Air Act 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 man-made air pollution.

Class I Federal Areas are:

• International parks;

• National wilderness areas which exceed 5,000 acres in size;

• National memorial parks which exceed 5,000 acres in size; and

• National parks which exceed 6,000 acres in size.

Class I areas near the District of Columbia are shown in Figure 1.1.October 2011

3 District of Columbia Regional Haze SIP Figure 1.1. Class I Areas Within 300 km of the District of Columbia

Source: Draft BART analysis prepared by ENSR/ AECOM for PEPCO Energy Systems (October 2008)

The five Class I areas within 300 kilome ters (km) of the District include:

• Shenandoah National Park

• Dolly Sods Wilderness

• Otter Creek Wilderness

• Brigantine Wilderness

• James River Face Wilderness

Note that Shenandoah National Park in Virginia is the closest Class I area to the District. The next closest areas are the Brigantine Wilderne ss area in New Jersey, the Dolly Sods and Otter Creek Wilderness Areas in West Virginia, and th e James River Face Wilderness in Virginia. The Federal Land Management (FLM) agencies re sponsible for protecting these areas are the National Park Service and the U.S. Fish and Wild life Service (both of th e U.S. Department of Interior), and the U.S. Forest Service (U.S. Department of Agriculture).October 2011

4 District of Columbia Regional Haze SIP When Congress amended the Clean Air Act in 1990, they added Section 169B (42 USC 7492), authorizing further visibility re search and periodic assessments of the progress made toward improving visibility in Class I areas. Based on the results of research conducted in the 1990s, and to implement the Clean Air Act visibility goal, EPA adopted the Regional Haze Rule (64 FR 35714) on July 1, 1999, and the rule went into effect on August 30, 1999. This rule seeks to address the combined visibility effects of various pollution sources over a wide geographic region. This wide-reaching rule requires many stat es – even those without Class I Areas – to participate in haze reduction efforts.

The following points summarize key requi rements of the Regional Haze Rule:

• States with Class I areas must establish “reasonable progress goa ls” for visibility improvement and monitor air quality at Class I areas to determine whether visibility is meeting these goals.

• States with emissions sources impacting visibi lity in Class I areas must collaborate with the Class I state to formulate a long-term st rategy for meeting the reasonable progress goals.

• States must adopt measures to ensure that certain large sources placed into operation between 1962 and 1977 use the Best Av ailable Retrofit Technology (BART).

• States must adopt a State Implementation Plan (SIP) to formalize measures they have taken to meet the requirements of the Regional Haze Rule, and this plan must be provided Brigantine Wilderness in New Jersey contains undeveloped barrier beaches, tidal wetlands, and dunes. The nutrient-rich estuarine environment is significant for migrating and wintering birds, including the Federally endangered peregrine falcon and Federally threatened pipi ng plover, and fisheries. Brigantine is part of the Edwin B. Forsythe Wildlife Refuge.

Shenandoah National Park is within the Blue Ridge mountain range in the southern Appalachians, approximately 75 miles west of the District of Columbia in Virginia. The park contains a mix of diverse habitats, forests and wildlife. The Appalachian Trail, a popular East Coast footpath from Georgia to Maine, meanders through the park. Skyline Drive was built al ong the mountain crests in the 1930s by the Civilian Conservation Corps. It allows visitors to enjoy views of the peaks and valleys that surround the area.

Dolly Sods Wilderness , part of the Monongahela National Forest in West Virginia, contains wide-open views among high-elevation plateaus. In previous times, these open fields, or “sods”, were used for grazing. The wind and boggy soils ultimately made the area uninhabitable. Restoration efforts have since created a diverse wilderness, heavily influenced by being located downstream of a creek through the Allegheny Mountains, considered the eastern continental divide.

Otter Creek Wilderness , very close and similar to Dolly Sods and also within the Monongahela NationalForest, lies within a bowl formed by mountains, the confluence of mountain streams, and floods. It is a secondgeneration forest and recovering habitat, currently managed for wild turkey, black bears, and similar species.

James River Face Wilderness contains a river gorge and typical Appa lachian hardwood forest. The longest Virginia river traverses from the Blue Ridge mountains in the west and through the Wilderness towards the Chesapeake Bay. The area can be enjoyed for hi king and for its exceptionally diverse vegetation.October 2011

5 District of Columbia Regional Haze SIP to Federal Land Managers and the public for review and then submitted to the U.S. Environmental Protection Agency (EPA) for approval.

• States must review their plan s every five years to determin e whether the goa ls previously set are still reasonabl e, whether reasonable measures have been implemented to meet those goals, and what measures will be impl emented in the next five to ten years.

On May 24, 2002, the U.S. Court of Appeals, DC District Court ruled on the challenge brought by the American Corn Growers Association ag ainst EPA’s Regional Haze Rule of 1999. The Court remanded to EPA the BART provisions of the rule, and denied industry’s challenge to the rule’s goals of natural visibility and no degradation requirements.

On February 18, 2005, the U.S. Court of Appeals, DC District Court issued another ruling vacating the Regional Haze Rule in part and sust aining 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 provi sions that governed the optional emissions trading program for certain Western States and Tribes (the WRAP Annex Rule).

On July 6, 2005, EPA addressed the court’s rema nd and published amendments to the rule and BART guidelines. The final rulemaking provided the following changes to the Regional Haze Rule:

1. Revised the regulatory text in Sec tion 51.308(e)(2)(i) in response to the CEED court’s remand, to remove the requirement that the determination of a BART “benchmark” be based on cumulative visibility analyses, a nd to clarify the process for making such determinations, including the application of BART presumptions for EGUs as contained in Appendix Y to 40 CFR 51;
2. Added new regulatory text in Section 51.308(e )(2)(vi), to provide minimum elements for cap and trade programs in lieu of BART; and
3. Revised regulatory text in Section 51.309, to reconcile the optional framework for certain Western States and Tribes to implement the recommendations of the Grand Canyon Visibility Transport Commission (GCVTC) with the CEED decision.

The regional strategies implemented to improve visibility in Class I areas will also benefit visibility outside these areas and may help address other air qualit y problems as well, particularly high concentrations of fine particles.

Subsequent to the above described revisions to the Regional Haze Rule, EPA issued a memorandum from William T. Harnett, Director , Air Quality Policy Division, Office of Air Quality Planning and Standards, U.S. EPA, en titled “Guidance for State Implementation Plan (SIP) Submissions to Under 110(a)(1) and (2) for the 2006 24- Hour fine Particle (PM 2.5 ) National Ambient Air Quality Standards (NAAQS ),’’ dated September 25, 2009. Through this guidance, EPA clarified that the District of Columbia's obliga tion pursuant to Clean Air Act §110(a)(2)(D)(i)(II) can be satisf ied by an approved SIP addressi ng regional haze. The District of Columbia believes that this plan is sufficient for purposes of the District of Columbia meeting its obligations related to visibili ty pursuant to §110(a )(2) of the federal Clean Air Act, includingOctober 2011

6 District of Columbia Regional Haze SIP but not limited to §§ 110(a)(2)(D)(i)(II) and 110(a)(2)( J), and the District of Columbia intends to rely on this submittal to satisfy all applicab le CAA §110(a)(2) obligations, including, but not limited to, §§110(a)(2)(D )(i)(II) and 110(a)(2)(J), for the Di strict of Columbia's 1997 ozone,
1997 PM 2.5 , and 2006 PM 2.5 National Ambient Air Quality Standards (NAAQS).

Figure 1.2. Class I Areas in the MANE-VU and VIST AS Regions, In Relation to the District

Source: Based on National Park Service map of “Mandatory Class I Areas” (updated 3/16/2006, accessed in 2010 at http://www.nature.nps.gov/air /map s/images/ClassIAreas.jpg )October 2011

7 District of Columbia Regional Haze SIP 

### 2. General State Implementation Plan Requirements

Pursuant to the requirements of 40 CFR 51.308(a) and (b), the District of Co lumbia prepared this SIP to meet the requirements of EPA’s Regional Haze Rule. Elements of this Plan address the Core Requirements pursuant to 40 CFR 51.308(d) and the Best Available Retrofit Technology (BART) components of 40 CFR 51.308(e). This Pl an also addresses requirements for Regional Planning and State/Tribe and Federal Land Manager coordination and co nsultation, according to 40 CFR 51.308(i). In addition:

Title 40 CFR 51.308(d)(4)(v) requires the District to make periodic updates to its emissions inventory. The Distri ct proposes to complete these upda tes to coincide with the EPA requirements for periodic emission inventories.

Title 40 CFR 51.308(f) requires the District to subm it periodic revisions to its Regional Haze SIP by July 31, 2018, and every ten years thereafter. The District acknowledg es and will comply with this schedule.

Title 40 CFR 51.308(g) requires the District to su bmit a report to EPA every five years that evaluates progress toward the reas onable progress goals for each mandatory Class I area located outside the State that may be aff ected by emissions from within th e State. The District will use the five-year review to look at wh ere the District is in terms of emissions projections within five years of submittal of this initial plan.

Pursuant to 40 CFR 51.308(h), th e District will submit a determ ination of adequacy of its Regional Haze SIP whenever a progress report is submitted. Depending on the findings of its five-year review, the District will take one or more of the following actions at that time, whichever actions are ap propriate or necessary:

• If the District determines that the existing SIP requires no further substantive revision in order to achieve established goals for visibility improveme nt and emissions reductions, the District will provide to the EPA a negative declaration that further revision of the plan is not needed.

• If the District determines that the SIP is or may be inadequate to ensure reasonable progress due to emissions from sources within th e District, the District will revise its SIP to address the deficiencies within one y ear from the determination, allowing the FLMs and the public to review how the District plans to meet emissions projections.

There are several sections of th e Regional Haze Rule that establish requirements applicable only to states containing Class I areas. The following is a list of requirements of the Regional Haze Rule that do not pertain to the Di strict, since the Distri ct has no Class I areas, as well as a brief discussion of some of those requirements:

• Monitoring : The District of Columbia does not contain any Class I Areas; therefore no monitoring strategy for measuring, characterizi ng, and reporting regional haze visibility impairment within the District into th e future is required under 40 CFR Section 51.308(d)(4) of EPA’s Regional Haze Rule.October 2011

8 District of Columbia Regional Haze SIP There are monitors in Class I areas to track visibility tre nds. Section 5 of this SIP explains how the District will use available monitoring data to help assess progress in visibility improvement.

• Determining baseline and natural visibility conditions : The District contains no Class I areas and therefore is not required to dete rmine baseline and natural conditions for any Class I areas. However, as described in S ection 6, the District reviewed information developed by states with Class I areas.

• Establishing reasonable progress goals: Since there are no Class I areas within the District of Columbia, the District is not requ ired to establish reas onable progress goals for any Class I areas. Under 40 CFR Section 51.308 (d)(1)(iv), as they establish reasonable progress goals, states with Class I areas must consult with other states reasonably anticipated to cause or contribute to regional ha ze in those Class I areas. Section 3 of this SIP describes the District’s consultation with Class I stat es potentially affected by emissions from within the District.

• Notification if SIP is inadequate due to transport: If a Class I state determines that its SIP is or may be inadequate to ensure reas onable progress as a resu lt of emissions from sources in other states which participated in the regional pl anning process, the state is required to provide notification to EPA and to those other states.

If a Class I state determines that its impleme ntation plan is or may be inadequate to ensure reasonable progress as a result of emi ssions from sources in another country, such as Canada, the state is require d to provide notification and av ailable information to EPA.

The District will collaborate with the othe r states through the regional planning process for the purpose of developing additional strategi es to address any such deficiencies in the District’s SIP.October 2011

9 District of Columbia Regional Haze SIP 

### 3. Regional Planning and Consultation

3.1. Participation in Regional Planning Organization

Sections 51. 308(d)(1) and (3) of EPA’s Regi onal Haze Rule, on development of reasonable progress goals and development of a long-term stra tegy, require interstate consultation. In the preamble to the Regional Haze Rule, published in the Federal Register on July 1, 1999, EPA strongly encourages states to pa rticipate in a regional planning process as they prepare their Regional Haze SIPs.

In 1999, EPA and affected states and tribes agreed to create five Regional Planning Organizations (RPOs) to facilitate interstate co ordination on Regional Haze SI Ps. The District of Columbia is a member of the Mid-Atlantic a nd Northeast Visibility Union (MANE-VU) RPO. Members of MANE-VU are listed in Table 3.1. A copy of MANE-VU’s Final Interim Principles for Regional Planning can be found in Appendix A.

Table 3.1

. MANE-VU Members

*Non-voting members

This SIP relies on data analysis, modeling re sults and other techni cal support documents prepared for MANE-VU members. By coordi nating with MANE-VU and other RPOs, the District of Columbia has worked to ensure that its long-term strategy (s ee Section 12) and BART (see Section 11) provide sufficient reductions to m itigate impacts of sources from the District of Columbia on nearby Class I areas.

Information and a description of consultation with other states are availabl e later in this section, and information and a description of consultatio n with Federal Land Managers are available in Section 4 of this SIP.

Since its inception on July 24, 2001, MANE-VU maintained an active committee structure to address both technical and non-technical issues related to regional haze.

The Technical Support Committee (TSC) is charged with assessing the nature and magnitude of the regional haze problem within MANE-VU, inte rpreting the results of technical work, and reporting on such work to the MANE-VU Board. The TSC evolved to function as a valuable sounding board for all the technical projects and processes of MANE-VU. The TSC established Connecticut Pennsylvania

Delaware Penobscot Nation
District of Columbia Rhode Island
Maine St. Regis Mohawk Tribe Maryland Vermont Massachusetts U.S. Environmental Protection Agency* New Hampshire U.S. National Park Service* New Jersey U.S. Fish and Wildlife Service*
New York U.S. Forest Service*October 2011

10 District of Columbia Regional Haze SIP a process to ensure that importa nt regional haze-related projec ts were completed in a timely fashion, and members were kept informed of a ll MANE-VU tasks and duties. There were three standing working groups of the TSC: the Emissions Inventory, Modeli ng, and Monitoring/Data Analysis Workgroups.

The Communications Committee oversaw the de velopment of MANE-VU’s newsletter and outreach tools both for stakeholders and the public regarding regional issues among MANEVU’s membership. The Communica tions Committee is charged with developing approaches to inform the public about the regional haze problem in the region and making any recommendations to the MANE-VU Board to facil itate that goal. Ulti mately, policy decisions are made by the MANE-VU Board.

MANE-VU also established a Policy Advisory Group (PAG) to provide advice to decisionmakers on policy questions. FLMs, EPA, states, a nd tribes were represented on the PAG. It met on an as needed basis.

MANE-VU’s work is managed by the Ozone Tran sport Commission (OTC) a nd also carried out by OTC, the Mid-Atlantic Regional Air Ma nagement Association (MARAMA), and the Northeast States for Coordinated Air Use Mana gement (NESCAUM). The states, along with Federal agencies and professional staff from OTC, MARAMA, and NESCAUM are members of the various committees and workgroups.

The following points highlight many of the ways the District and other MANE-VU member states and tribes have coopera tively addressed regional haze:

• Issue Coordination: MANE-VU established a conference call and meeting schedule for each of its committees and workgroups. In addition, MANE-VU Directors regularly discuss pertinent issues.

• SIP Policy and Planning: MANE-VU states/tribes collaborated on the development of a SIP Template. MANE-VU members also agre ed on an approach to setting reasonable progress goals and considering measures to ensure long-term progress in improving visibility.

• Capacity Building: To educate its sta ff and members, MANE-VU offered technical presentations on conference calls and organi zed workshops with nationally recognized experts. Presentations on data analysis, BA RT work, inventory t opics, modeling, control measures, and the like were an eff ective education and coordination tool.

• Routine Operations: MANE-VU staff at OTC, MARAMA, and NESCAUM established a coordinated approach to budget, grant deli verables and due-dates, workgroup meetings, inter-RPO feedback, and the like.

The District of Columbia pa rticipated in reviewing work conducted by MANE-VU, and has utilized MANE-VU work products to prepare this SIP.October 2011

11 District of Columbia Regional Haze SIP 3.2. Consultation Framework

The Regional Haze Rule at 40 CFR Section 51.3 08(d )(3)(i) requires the Distri ct to consult with other States/Tribes to develop coordinated emission management strategies. This requirement applies both where emissions from the 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 contri bute to visibility impairment in Class I areas within the State/Tribe.

The District consulted with ot her states/tribes by participa tion in the MANE-VU and through MANE-VU’s consultation with other RPOs.

On May 10, 2006, MANE-VU adopted the Inter-RPO State/Tribal and FLM Consultation Framework (Appendix B). That document set forth the following principles:

1. All State, Tribal, RPO, and Federal particip ants are committed to continuing dialogue and information sharing in order to create unders tanding of the respective concerns and needs of the parties.
2. Continuous documentation of a ll 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 interRPO framework is designed solely to facili tate needed communicat ion, coordination and cooperation among jurisdictions but does not es tablish binding obligation on the part of participating agencies.
4. There are two areas which require State-to-S tate 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 com ponents 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 consulta tions 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 f acilitate the consultati on process through their respective RPOs, when feasible.
6. Technical analyses will be transparent, when possible, and will re flect the most up-todate information and best scientific methods for the decision needed within the resources available.
7. The State with the Class I area retains the re sponsibility to establ ish reasonable progress goals. The RPOs will make reasonable efforts to facilitate the development of a consensus between the State with a Class I area and other States aff ecting that area. In instances where the State with the Class I area cannot agree w ith such other States that the goal provides for reasonable progress, actio ns taken to resolve the disagreement must be included in the State’s regional haze impl ementation plan (or plan revisions) submitted to the EPA Administrator as requir ed under 40 CFR Section 51.308(d)(1)(iv).
8. All States whose em issions are reasonably an ticipated to contribu te to visibility impairment in a Class I area, must provide the Federal Land Mana ger (“FLM”) agency for that Class I area with an opportunity for consultation, in person, on their regional hazeOctober 2011

12 District of Columbia Regional Haze SIP implementation plans. The States/Tribes w ill pursue the development of a memorandum of understanding to expedite the submission and consideration of the FLMs’ comments on the reasonable progress goa ls and related implementation plans. As required under 40 CFR Section 51.308(i)(3), the plan or plan revi sion 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 accordan ce with the FLM coordination requirements specified in 40 CFR Section 51.308(i) and other consultation procedures developed by

consensus. 10. The consultation process is designed to shar e information, define and document issues, develop a range of options, solicit feedback on options, de velop 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.

The document also describes a process primarily app licable to formal consultation with states in other RPOs concerning Regional Haze SIP elem ents. Although other RPOs, such as the Visibility Improvement State and Tribal Asso ciation of the South east (VISTAS), did not formally adopt the same process, in general, the process was followe d and provided significant opportunities for consultation.

3.3. Consultation with Other States

Because of long-range transport of fine particulate m atter, emissi ons from within the District have the potential to affect visibility in Cla ss I areas hundreds of kilometers away. However, because the emissions from sources in the Dist rict are a relatively small part of regional emissions, the impacts of these emissions are also relatively small. Secti on 8 of this SIP reviews the District’s contribution to visibili ty impairment in Class I areas.

3.3.1. States Notifying the District of Contribution to Haze

On January 18, 2007, New Jersey reque sted the District’s particip ation as a member of MANEVU in the development of a regional long-term stra tegy to improve visibility at one Class I area, the Brigantine Wilder ness (Appendix V).

In a letter dated April 4, 2007, New Hampshire aske d the District to join in the consultative process to develop a collective solution to regi onal haze in New Hampshire (Appendix V). New Hampshire has two Class I areas: Great Gulf Wilderness and the Presid ential Range-Dry River Wilderness.

No other states formally contacted th e District concerni ng regional haze.

As Figure 1.1 indicates, the Dist rict is within 300 km of Class I areas in Virginia and West Virginia. Both Virginia and West Virginia are members of the VISTAS RPO, and the District participated in MANE-VU’s consultation with VI STAS states. No states from the VISTAS region contacted the District to ask for emissi ons reductions to reduce haze in Class I areas.October 2011

13 District of Columbia Regional Haze SIP 3.3.2. MANE-VU Consultation Area

For the maximum protection of visibility at Class I areas, MANE-VU concluded that it was appropriate to consult with all of its participati ng states, as well as with states outside of MANEVU that contributed at least two percent of the sulfate ion to its Class I areas in 2002. Table 3.2 lists states included in the MANE-VU consultation area.

This selection of states was made for purposes of consultation and does not necessarily indicate a substantial impact on all MANE-VU Class I areas. Note that several of the MANE-VU states, including the District of Colu mbia, have impacts on these Class I areas that are below the 0.1 μg/m 3 or two percent threshold – that is, their im pacts on any Class I areas in the consultation area are insignificant according to this measure. These states and the Dist rict were included in the consultation area because they are M ANE-VU members, not because of potential contributions to visibility impairment in Class I areas.

Shenandoah National Park (Virginia) and Dolly Sods Wilderness Area (West Virginia), both within the VISTAS region, were included in MANE-VU’s technical analysis of emissions contributing to regional haze.October 2011

14 District of Columbia Regional Haze SIP Table 3.2. States Included in th e MANE-VU Consultation Area

State RPO Class I Areas receiving Impacts of 2% or More from Listed State

Connecticut MANE-VU None

Delaware MANE-VU Brigantine

District of Columbia MANE-VU None

Maine MANE-VU Acadia, Great Gulf, Moosehorn

Maryland MANE-VU Acadia, Brigantine, Dolly Sods, Lye Brook, Shenandoah

Massachusetts MANE-VU Acadia, Brigantine, Great Gulf, Lye Brook, Moosehorn New Hampshire MANE-VU Acadia, Great Gulf
New Jersey MANE-VU Brigantine

New York MANE-VU Acadia, Brigantine, Great Gulf, Lye Brook, Moosehorn, Shenandoah

Pennsylvania MANE-VU Acadia, Brigantine, Dolly Sods, Great Gulf, Lye Brook, Moosehorn, Shenandoah

Rhode Island MANE-VU None

Vermont MANE-VU None
Georgia VISTAS Brigantine, Dolly Sods, Shenandoah

Kentucky VISTAS Brigantine, Dolly Sods, Lye Brook, Shenandoah

North Carolina VISTAS Brigantine, Dolly Sods, Shenandoah

Tennessee VISTAS Dolly Sods, Shenandoah
Virginia VISTAS Brigantine, Dolly Sods, Shenandoah

West Virginia VISTAS Acadia, Brigantine, Dolly Sods, Great Gulf, Lye Brook, Shenandoah

Illinois MRPO Dolly Sods, Great Gulf, Lye Brook, Shenandoah

Indiana MRPO Acadia, Brigantine, Dolly Sods, Great Gulf, Lye Brook, Moosehorn, Shenandoah

Michigan MRPO Acadia, Brigantine, Dolly sods, Great Gulf, Lye Brook, Shenandoah

Ohio MRPO Acadia, Brigantine, Dolly Sods, Great Gulf, Lye Brook, Moosehorn, Shenandoah

Source: Table 8-1 from the MANE-VU Contribution Assessment.(Appendix K)October 2011

15 District of Columbia Regional Haze SIP 3.3.3. Summary of MANE-VU Consultation

MANE-VU held numerous conference calls and m eetings which provided opportunities for the District to consult with other states concerning reasonable progre ss goals, a coordinated regional emissions management strategy, and other elem ents of the SIP. MANE-VU consultation meetings and conference calls included those held on the following dates:

• MANE-VU Intra-Regional Consultation, March 1, 2007

o At this meeting, MANE-VU members revi ewed the requirements for regional haze plans, preliminary modeling results (incl uding estimates of the uniform rate of progress and potential reasona ble progress goals), the work being done to prepare the MANE-VU report on reasonable progress fact ors, and control strategy options under review.

• MANE-VU Class I States Consultation, June 7, 2007

o At this meeting, the MANE-VU Class I stat es adopted a statem ent of principles (included in Appendix V), and all MANE- VU members discussed draft statements concerning reasonable controls within a nd outside of MANE-VU. Federal Land Managers also attended the meeting, which was open to stakeholders.

• MANE-VU Conference Call, June 20, 2007

o On this call, the MANE-VU states concl uded discussions of statements concerning reasonable controls within and outside MANE-VU and agreed on the statements called the MANE-VU “Ask,” including a statement concerning controls within MANE-VU, a statement concerning contro ls 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, al l statements as well as the statement of principles adopted on June 7 were posted and publicly avai lable on the MANE-VU web site.

• MANE-VU Class I States’ Consultation Open Technical Call, July 19, 2007

o On this call, the MANE-VU “Ask” was presen ted to states in other RPOs, RPO staff and Federal Land Managers. An opportuni ty was provided to request further information. This call was intended to provi de information to facilitate informed discussion at follow-up meetings.

• MANE-VU Consultation Meeti ng with MRPO, August 6, 2007

o This meeting was held at LADCO offices in Chicago, Illinois, and was attended by representatives of both MANE- VU and Midwest RPO (MRPO) st ates as well as staff. Modeling results were reviewed as well as draft reasonable progress goals. The meeting provided an opportunity to forma lly present the MANE-VU “Ask” to MRPO states and to consult with them regard ing the reasonablene ss of the requested controls. Federal Land Manager ag encies also attended the meeting.

• MANE-VU Consultation Meeti ng with VISTAS, August 20, 2007

o This meeting was held at State of Georgia offices in Atlanta and was attended by representatives of both MANE-VU and VISTAS states as well as staff. Modeling results were reviewed as well as draft reasonable progress goals. The meeting provided an opportunity to formally presen t the MANE-VU “Ask” to VISTAS states and to consult with them regarding the r easonableness of the re quested controls. Federal Land Manager agencies also attended the meeting.October 2011

16 District of Columbia Regional Haze SIP • MANE-VU – Midwest RPO Consultati on Conference Call, September 13, 2007

o This call was a follow-up to the meeting held on August 6 in Chicago and provided an opportunity to further clarify what wa s being asked of the MRPO states. The flexibility in the “Ask” was explained. Both MRPO and MANE-VU staff agreed to work together to facilitate discussion of further controls on ICI boilers and EGUs.

• MANE-VU Air Directors’ Consultati on Conference Call, September 26, 2007

o This call allowed MANE-VU members to clarify their understanding of the “Ask” and to provide direction to modeling sta ff as to how to interpret the “Ask” for purposes of estimating visibility im pacts of the requested controls.

• MANE-VU Air Directors’ C onference Call, March 31, 2008

o On this call, NESCAUM presented the results of the final 2018 modeling and described the methods used to represent the impacts of the measures agreed to by the Class I States. The reasonable progress goals were also discussed. Federal Land Manager agencies also attended this call.October 2011

17 District of Columbia Regional Haze SIP 

### 4. Federal Land Manager Coordination

Coordination between States/T ribes and the Federal Land Mana gers (FLMs) is required by 40 CFR Section 51.308(i).

4.1. Preliminary Consultation with FLMs

On July 31, 2008, the District wrote to representativ es of the U.S. Fish and Wildlife Service, the National Park Service, and the U.S. Forest Service to inform them that the District was preparing a Regional Haze SIP and to identify Ms. Cecily Beall as the primary contact for further information.

4.2. Consultation with FLMs Concerning this SIP

In addition to the consultation calls and mee tings described in Sec tion 3, MANE-VU provided opportunities for FLMs to review and comment on each of the technical documents developed by MANE-VU and included in this SIP.

In the development of the Plan, submitted to U.S. EPA on September 21, 2010, the FLMs were consulted in accordance with the provisions of 40 CFR 51.308(i)(2). The District of Columbia provided the FLMs an opportunity for consultation, in person and at least 60 days prior to holding any public hearing on the SIP. (A draft of this SIP, except for the BART chapter, was provided to FLMs on November 19, 2009, for revi ew and comment. A draft of the BART chapter was provided to the FLMs on Ma y 12, 2010, for review and comment.)

In accordance with 40 CFR 51.308(i)(3), the District of Columbia received comments regarding the SIP from FLMs. Comments received from the FLMs on the Plan were addressed and are included in Appendix C.

On September 1, 2011, the FLMs were notified of proposed changes to the September 21, 2010, SIP submittal. These changes include the use of the OTB/W modeling scenario for the District’s long-term strategy and the closure of the Dist rict’s only BART sources by December 17, 2012, which will result in additional SO 2 emission reductions beyo nd the OTB/W scenario.

4.3. Commitment to Continuing Consultation with FLMs in the Future

In accordance with 40 CFR Section 51.308(i)(4), the District will continue to coordinate and consult with FLMs on the implementation of th e visibility protection program, including development of future plan revisions. In part icular, the District will consult with the FLMs on the following implementation items:

1. Implementation of emissions strategies identif ied in the SIP as contributing to achieving improvement in the worst-day visibility;
2. Summary of major new source permits issue d, since projected emissions growth under permitting programs such as New Source Review (NSR) and Prevention of Significant Deterioration (PSD) may impact regiona l haze and reasonable progress goals;October 2011

18 District of Columbia Regional Haze SIP 3. Status of District actions to meet commitmen ts for completing any future assessments or rulemakings on sources identified as likely cont ributors to visibility impairment, but not directly addressed in the most recent SIP revision;
4. Any changes to the monitoring strategy or m onitoring stations status that may affect tracking of reasonable progress;
5. Work underway for preparing the 5-y ear review or 10-year revision;
6. Items for FLMs to consider or provide suppor t for in preparation for any visibility protection SIP revisions (based on a 5-year review or 10-year revision schedule under EPA’s Regional Haze Rule);
7. Summary of topics (discussi on, meetings, emails, other records) covered in ongoing communications between the District and the FLMs regarding implementation of the visibility program.

The District is committed to the goal of improving visibility, so will consid er the link of regional haze to other air programs having the potential to contribute to the impairment of visibility in Class I areas. Consultation will be coordinated w ith the designated visibility protection program coordinators for the National Park Service, U. S. Fish and Wildlife Service and the U.S. Forest Service.

4.4. Reasonably Attributable Visibility Impairment

Section 51.302(c) provides for ge neral plan requirem ent in cases where the affected FLM has notified the State that Reasonably Attributable Visibility Impairme nt (RAVI) exists in a Class I Area in the state. There are no RAVI sources in MANE-VU.October 2011

19 District of Columbia Regional Haze SIP 

### 5. Monitoring Strategy

A nationwide visibility monitori ng network was established under the Interagency Monitoring of Protected Visual Environments (IMPROVE) pr ogram in 1985 to track current visibility conditions, changes in visibility, and help determine the causes of visibility impairment in Class I Areas. A national IMPROVE Steering Comm ittee provides oversight for the IMPROVE network and establishes protocols for monito ring techniques and data analysis.

5.1. Use of IMPROVE Monitoring

As mentioned in Section 2, the District of Columbia does no t contain any Class I Areas; therefore, no monitoring strategy for measur ing, characterizing, and reporting regional haze visibility impairment within the District is required under 40 CFR Section 51.308(d)(4) of EPA’s Regional Haze Rule.

However, 40 CFR 51.308(d)(4)(iii) re quires that for a State with no mandatory Class I areas, the implementation plan must provide for pro cedures by which monitoring data and other information are used in determining the contri bution of emissions from within the State to regional haze impairment at mandatory Class I Federal areas in other States.

The preamble to the final Regional Haze Rule pu blished in the Federal Register on July 1, 1999, explained that EPA believed it was important for States with no Cl ass I areas to “understand and describe the implications of monitoring da ta.” On page 35744 (FR Vol. 64, No. 126), EPA stated:

First, it is important for those states to review monitoring inform ation, including data on the chemical composition of individual species concentrations, to help understand the relative contribution of emissions from their state to Class I areas in other States. Second, it is important for those States to understand and describe how they will use the monitoring data to review progress and trends.

As a participant in MANE-VU, the District reviewed information about the chemical composition of individual species co ncentrations at Class I areas in and near MANE-VU in order to understand the sources of haze causing pollutants.

5.2. Use of IMPROVE Monitoring to Track Progress

Title 40 CFR 51.308(d) and (g) provide for tracking improvements in both visibility and emissions in order to demons trate reasonable progress toward achieving natural visibility conditions. States with Cla ss I areas have established ba seline conditions in their implementation plans and set goals for reasonable progress in im proving visibility by 2018. (See Appendix J for more information.) States wi th Class I areas must establish a monitoring program and report data to EPA th at is representative of visibi lity at the Class I areas. The IMPROVE network meets this requirement.

The District commits to continuing support of ongoing visibility monitoring in Class I areas. The IMPROVE network currently meets this mon itoring goal, and the District agrees thatOctober 2011

20 District of Columbia Regional Haze SIP IMPROVE is an appropriate monitoring network to track regional haze progress and will work with neighboring states and the FLMs to meet the goals of the IMPROVE program. In the future, as required by 40 CFR 51.308 (f) and (g), th e District will use monitoring data to review progress and trends in visibility at Class I areas that may be affected by emissions from the District both for comprehensive periodic revisions of this implementation plan and for periodic reports describing progress towards the reas onable progress goals for those areas.

In September 2003, EPA issued Guidance for Tracking Progress Under the Regional Haze Rule (EPA-454/B-03-004). This report describes th e procedures for using IMPROVE data and emissions data to track progress. The District will use procedures consistent with this EPA guidance to comply with 40 CFR 51.308(f) and (g).October 2011

21 District of Columbia Regional Haze SIP 

### 6. Assessment of Baseline, Natural and Current Conditions

Under 40 CFR 51.308(d)(2), each state containing a Class I area must determine baseline and natural visibility conditions for its Class I area(s). The requirement for this Section applies only to states containing Class I areas. The District is not required to addr ess baseline, natural and current conditions in this SIP, although the basic principles ar e key to understanding the SIP.

Baseline visibility is the average visibility during the five-year period from 2000 to 2004. For the purposes of this document, baseline visibil ity is the same as current conditions. Natural conditions represent an estimate of the visibility that would be present in Class I areas in the absence of human-caused pollution in 2064, the target date for returning to natural visibility. Comparing baseline conditions to natural visibility conditions determines a linear benchmark of improvement called the uniform rate of progress, which must be considered as states set reasonable progress goals for each Class I area. Th e uniform rate of progress is also called a “glide path.” Reasonable progress goals are estab lished along the glide path at 10-year intervals, beginning in 2018.

In general, to comply with the Regional Haze Rule, visibility conditions are evaluated for the days with most-impaired visibility (i.e., the aver age of the 20 percent most impaired days over a calendar year) and the cleanest or least impaired days (i.e., the average of the 20 percent least impaired days).

Visibility is expressed in deci views (dv). A deciview is a m easure of visibility impairment derived from calculated light extin ction. Light extinction is calcu lated using the mass of various components of airborne particles (nitrates, sulf ates, elemental carbon, orga nic carbon, and crustal material).

The reasonable progress goals for 2018 for Class I ar eas near the District ar e further discussed in Chapter 10.October 2011

22 District of Columbia Regional Haze SIP 

### 7. Causes of Visibility Impairme nt at Nearby Class I Areas

The District collaborated with other MANE-VU members to identi fy emissions source categories and states that contribute to fi ne particulate pollution, and thus vi sibility impairment, at Class I areas in the eastern United States. MANE-VU’ s work is documented in the report entitled Contributions to Regional Haze in the Northeast and Mid-Atlantic States , called the Contribution
Assessment (Appendix K).

As explained in the Contribution Assessment , several procedures were used to analyze visibility at MANE-VU Class I areas including the use of Eu lerian (grid-based) source models, Lagrangian (air parcel-based) source dispersi on models, as well as a variety of data analysis techniques that include source apportionment models, back trajecto ry calculations, and the use of monitoring and inventory data. A range of met hodological approaches characterize these tools, listed in Table
7.1.

Table 7.1. Summary of Technical A pproaches for Attributing State Contributions to Observed Sulfa te in MANE-VU Class I Areas

Analytical Technique Approach
Emissions/distance Empirical Incremental probability Lagrangian trajectory technique Cluster-weighted probability Lagrangian trajectory technique Emissions × upwind probability Empirical/trajectory hybrid Source apportionment approaches Receptor model/trajectory hybrid REMSAD tagged species Eulerian source model CALPUFF with MM5-based meteorology Lagrangian source dispersion model CALPUFF with observation-based meteorology Lagrangian source dispersion model Source: Appendix K

There was substantial consiste ncy across these analytical methods using techniques based on disparate chemical, meteorological and physical principles. Taken t ogether, these findings create a strong weight-of-evidence case for the prelimin ary identification of the most significant contributors to visibility impairmen t in the MANE-VU Class I areas.

The Contribution Assessment concludes that the overall coheren ce and consistency of results that emerge from application of these tools and techniques suggest that what is known about the causes of sulfate pollution in the MANE-VU re gion is sufficient to provide a useful and appropriate basis for design of fu ture control programs and for consultations between different regional organizations charged with planning for compliance with the Regional Haze Rule.

It is important to emphasize th at these methods have been reviewed, updated, and refined to ensure that high quality results are ava ilable for the SIP development process.October 2011

23 District of Columbia Regional Haze SIP 7.1. Monitoring Results

Monitoring data served as the primary basis for several of the receptor techniques used in the Contribution Assessment to understand the causes of fine particle pollution and visibility impairment.

As documented in the Contribution Assessment , IMPROVE monitoring and analysis has indicated that while substantia l visibility impairment is co mmon across the MANE-VU region, it is most severe in the southern and western port ions of MANE-VU that ar e closest to large power plant sources of sulfur dioxide (SO 2 ) emissions located in the Oh io River and Tennessee Valleys. Summertime visibility is driven almost excl usively by the presence or absence of regional sulfate, whereas wintertime visibility depends on a combination of regional and local influences coupled with local meteorological conditions (inver sions) that can lead to the concentrated buildup of emissions from local sources. These findings suggest that an effective emissions management approach would rely heavily on broad-based regional SO 2 control efforts in the eastern United States aimed at reducing summertime fine particulate matter (PM 2.5 ) concentrations.

Available monitoring data provide strong evidence that regional SO 2 reductions have yielded, and will continue to yield, reductions in ambien t secondary sulfate levels with subsequent reductions in regional haze and associated light extinction. They indicate that reductions in anthropogenic (i.e., manmade) primary particle emissions will also result in visibility improvements, but that these will not have a zone of influence as large as those of the secondary aerosols.

Given the dominant role of sulfate in the form ation of regional haze in the Northeast and MidAtlantic region, MANE-VU conclude d that it is likely that SO 2 reductions need to play a central role in achieving near-term visibility improvements.

Figure 7.1 shows the dominance of sulfate in visibility extinction calculated from 2000 to 2004 baseline data for seven Northeast Class I Areas.October 2011

24 District of Columbia Regional Haze SIP Figure 7.1. Baseline Contributions to PM 2.5 Extinction at Seven Class 1 Areas on the 20 Percent Worst Visibility Days

7.2. Haze Pollutant Emissio ns – Sources and Trends

In conjunction with other efforts to assess th e contribution of various source categories and source regions to regional haze in Class I ar eas, MANE-VU reviewed trends in emissions inventories. This section descri bes origins and characteristics of pollutant emissions contributing to regional haze. It presents information about trends in emissions of the major pollutants responsible for regional haze (SO 2 , VOC, NO
x , PM and NH 3 ) throughout the MANE-VU region. The emissions data and graphics presented in th is section rely on severa l data sources. These include EPA’s 1996 National Emissions Tre nds database (NET), EPA’s 1999 National Emissions Inventory (NEI), and Vers ion 3.0 of the 2002 MANE-VU inventory. 1 Because the

1 EPA's Emission Factor and Inventory Group (EFIG) EPA/OAR (Office of Air and Radiation)/OAQPS (Office of Air Quality Planning and Standards)/EMAD (Emissions, M onitoring and Analysis Division) prepares a national database of air emissions information with input from air agencies, tribes, and industry. This database contains information on stationary and mobile sources that emit criteria air pollutants and their precursors, as well as hazardous air pollutants (HAPs). The database includes estimates of an nual air pollutant emissions, by source and area of the country. The NEI includes emission estimates for all 50 states, the District of Columbia, Puerto Rico, and the Virgin Islands. Emission estimates are available for individual point or major sources (facilities), as well asOctober 2011

25 District of Columbia Regional Haze SIP NET was the predecessor of the NEI, references to the 1996 NET in the discussion below use the shorthand reference 1996 NEI.

7.2.1. Sulfur Dioxide (SO 2 )

SO 2 is the primary precursor pollutant for sulf ate particles which commonly account for more than 50 percent of particle-related light extincti on at northeastern Class I areas on the clearest days, and for as much as or more than 80 percent on the haziest days. Hence, SO 2 emissions are an obvious target of opportunity for reducing regional haze in the eastern United States. Combustion of coal and, to a le sser extent, use of certain petr oleum products accounts for most anthropogenic SO 2 emissions. In fact, in 1998, a singl e source category, coal-burning power plants, was responsible for two-thirds of total SO 2 emissions nationwide (NESCAUM, 2001a).

Figure 7.2 shows SO 2 emissions trends in the MANE-VU states extracted from the NEI for the years 1996 and 1999, and the 2002 MANE-VU invent ory (EPA 2005 and Pechan, 2006). Except Maryland, the states show declines in 2002 annual SO 2 emissions when compared with 1996 emissions. Some states show an increase in 1999 followed by a decline in 2002, and others show consistent declines th roughout the entire period. The upward tr end in emissions in 1999 probably reflects electricity demand growth during the la te 1990s combined with the availability of banked emissions allowances from initial over-com pliance with control requirements in Phase 1 of the EPA Acid Rain Program. This led to relati vely low market prices for allowances later in the decade, which encouraged utilities to pur chase allowances rather than implement new controls as electricity output expa nded. The observed decline in the 2002 SO 2 emissions inventory reflects implementation of the second pha se of the EPA Acid Rain Program, which in 2000 further reduced allowable emissions and exte nded emissions limits to more power plants.

county level estimates for area, mobile and other sources. Prior to 1999, the National Emission Trends (NET) database maintained criteria pollutant emission estimates and the National Toxics Inventory (NTI) database maintained HAP emission estimates. Beginning with 1999, the NEI integrated criteria and HAP emissions into a single database that replaces the NET and the NTI.October 2011

26 District of Columbia Regional Haze SIP Figure 7.2. State Level Sul fur Dioxide Emissions

0.0 0.2 0.4 0.6 0.8 1.0 1.2 1.4

Co

n n ect

ic

u t

D elawar e

D i str

i ct of C

o l u mbi a Maine Mar yl

an

d

M

ass

ach u s etts

New H ampsh i r e New Jers ey New York Penns yl

vania Rhode Isl an

d Vermontmillion t/y NEI 1996

NEI 1999 V3

MANE-VU 2002 V3

Source: Figure 4-1 from the Contribution Assessment (Appendix K)

Figure 7.2 shows that emissions from the District of Columbia are much smaller than emissions from other MANE-VU states ex cept Rhode Island and Vermont.

Figure 7.3 shows the percent contribution from four source categories to overall annual 2002
SO 2 emissions in the MANE-VU states. The chart shows that in most states point sources dominate SO 2 emissions; however, in the District, the la rgest category is area sources. Point sources primarily consist of stationary combustion sources for generating electricity, industrial energy, and heat. Smaller stationary combustion sources, called area sources, such as commercial and residential heating and smaller industrial facilities, are particul arly important in small states such as the District of Columbia. By contra st, onroad and nonroad mobile sources make a relatively small contribution to overall SO 2 emissions in the region (NESCAUM, 2001a).October 2011

27 District of Columbia Regional Haze SIP Figure 7.3. 2002 Annual Anthropogenic SO 2 Emissions by State and Percent by Source Type

0% 25% 50% 75% 100%

Conn e ct

i cut

D ela

w ar

e

Di

s tric

t of Columbia M ai

n e Maryland

M

a ss

achu setts

N ew Hampshire New Jer s e y New Y o rk Pennsylvania Rhode Isl

an

d

V e rmont 0.0 0.2 0.4 0.6 0.8 1.0 1.2million t/y

AREA NONROAD ONROAD POINT Emission

Source: Figure 4-2 from the Contribution Assessment (Appendix K)

In sum, total SO 2 emissions from sources located in the District are a very small part of the regional total and declined from 1996 to 2002.

7.2.2. Volatile Organic Compounds (VOC)

From a regional haze perspective, condensation and oxidation processes act on VOCs to form secondary organic aerosols (SOA). Thus, the VOC inventory category can contribute to the organic carbon portion of PM 2.5

.
After sulfate, organic carbon genera lly accounts for the second largest share of fine particle mass and particle-related light extinc tion at northeastern Class I site s. The term “organic carbon” encompasses a large number and variety of chem ical compounds that may come directly from emission sources as a part of primary PM or may form in the atmosphere as secondary pollutants. The organic carbon present at Class I sites comprises a mix of species, including pollutants originating from anthropogenic sour ces as well as biogenic hydrocarbons emitted by vegetation. Recent efforts to reduce manmade orga nic carbon emissions have been undertaken primarily to address summertime ozone formation in urban centers. Future efforts to further reduce organic carbon emissions may be driven by programs that address fine particles and visibility. This is explained in more detail on pages 4-2 through 4-5 of the Contribution
Assessment (Appendix K), which also st ates that, “we need furthe r work to characterize the organic carbon contribution to re gional haze in the Northeast a nd Mid-Atlantic states and to develop emissions inventories that will be of greater value for visibility planning purposes.”October 2011

28 District of Columbia Regional Haze SIP Understanding the transport dynamics and source regions for organic carbon in northeastern Class I areas is more complex than for sulfate. This is due to the larg e number and variety of organic carbon species. Each of th ese species has its individual and widely variable transport characteristics and complex atmospheric ch emical reaction. Thus, the organic carbon contribution to visibility impairme nt at most Class I sites in th e East is likely to include both biogenic and manmade pollution. The manmade co mponent may be transported from a distance or originate from nearby sources.

Based on available information as shown in Figure 7.4, VOC emissions from sources in the District are a small portion of the regional tota l and are dominated by onroad mobile and area

sources.

Figure 7.4. 2002 Annual Anthropoge nic VOC Emissions by State and Percent by Source Type

0% 25% 50% 75% 100%

Connecticut

D

elaw ar

e

Dist r ict

of Colum b ia Maine Maryland

Ma

s sac

h

u s etts

New Ham p shir e New Je

r sey Ne

w Y or

k

Pe

n n sy

lvania

R

ho

de Island

V er

montmillion t/y

0.0 0.2 0.4 0.6 0.8 1.0 1.2 1.4 1.6

AREA NONROAD ONROAD POINT Emission

Source: MANE-VU Contribution Assessment, Figure 4-3 (Appendix K)

The same sources predominate in the entire MANE-VU region. Onroad mobile sources of VOCs include both evaporative and exhaust emissions from gasoline passenger vehicles and dieselpowered heavy-duty vehicles as we ll as evaporative emissions from the transportation of fuels. Nonroad sources include vehicles such as boats, planes, and locomotives as well as vehicles and equipment used in agriculture, construction, and other off-road operations. Area sources contributing to VOC emissions include solvents, ar chitectural coatings, and dry cleaners. Point sources that emit VOCs incl ude industrial facilities a nd petroleum refineries.October 2011

29 District of Columbia Regional Haze SIP 7.2.3. Oxides of Nitrogen (NO
x )

NO
x emissions contribute to visibility impairment in the eastern U.S. by forming light-scattering nitrate particles. Nitrat e generally accounts for a substantially smaller frac tion of fine particle mass and related light extinction than sulfate and orga nic carbon at northeastern Class I sites. Notably, nitrate may play a more important role at urban sites and in the wintertime. In addition,
NO
x may have an indirect effect on summertime visibili ty by virtue of its ro le in the formation of ozone, which in turn promotes the formati on of secondary organic aerosols (NESCAUM, 2001a).

Figure 7.5 shows NO
x emissions in the MANE-VU region at the state level. Since 1980, nationwide emissions of NO
x from all sources have shown little change. Emissions increased by only 2 percent between 1989 and 1998 (EPA, 2000a). This increase is most likely due to industrial sources and th e transportation sector, as power pl ant combustion sources implemented modest emissions reductions during that time period. Most states in the MANE-VU region experienced declining NO
x emissions from 1996 through 2002, except Massachusetts, Maryland, New York, and Rhode Island, which show an increase in NO
x emissions in 1999 before declining to levels below 1996 emissions in 2002.

Figure 7.5. State Level Ni trogen Oxides Emissions

0.0 0.5 1.0 1.5

Co

n n ecti cu

t

D el

awar e

D i str

i ct

o f C olumb i a Main e Maryland

M

assac husetts

N

ew

H

amp shire

N ew Jersey New Yo r k

Pen

nsylvania

R h

o d e Island Vermontmillion t/y NEI 1996

NEI 1999 V3

MANE-VU 2002 V3

Source: MANE-VU Contribution Assessment, Figure 4-4 (Appendix K)

NO
x emissions from the District are the smallest portion of total regiona l emissions. The chart above illustrates that rela tionship and shows that NO
x emissions from the District decreased steadily from 1996 to 2002.October 2011

30 District of Columbia Regional Haze SIP Figure 7.6, below, shows that in the District, mob ile sources are the most important source of
NO
x emissions. In general, power plants and mobile sources dominate state and national NO
x emissions inventories. Nationally, power plants account for more than one quarter of all NO
x emissions, amounting for over six million tons.

Figure 7.6. 2002 Annual Anthropogenic NO x Emissions by State and Percent by Source Type

0% 25% 50% 75% 100%

Connecticut De

l aware

Di

stri

ct

o f Col u mb

i a M ai

n e Ma ryl

a n d Massa c husetts

New H a mpshir e New Jer s ey New Y o rk Pennsy l va

n ia Rhode Island Vermontmillion t/y

0.0 0.3 0.6 0.9

AREA NONROAD ONROAD POINT Emission

Source: MANE-VU Contribution Assessment, Figure 4-5 (Appendix K)

By contrast, onroad mobile sour ces – a category that mainly includes highway vehicles – dominate the NO
x inventories for more urbanized Mid- Atlantic and New England states. Emissions from nonroad mobile sources, primaril y diesel-fired engines, also represent a substantial fraction of the MANE-VU 2002 NO
x inventory. Area s ources are less important with respect to NO
x .

7.2.4. Primary Particulate Matter (PM 10 and PM 2.5 )

Directly emitted or “primary” particles (as distin ct from secondary particles that form in the atmosphere through chemical reactions i nvolving precursor pollutants such as SO 2 and NO
x ) can also contribute to regional haze. For regulatory purposes, a distinction is made between particles with an aerodynamic diameter less than or equal to 10 micrometers and smaller par ticles with an aerodynamic diameter less than or equal to 2.5 micrometers (i.e., primary PM 10 and PM 2.5 , respectively).

Figure 7.7 and Figure 7.8 show PM 10 and PM 2.5 emissions for the MANE-VU states for the years 1996, 1999, and 2002. Except Maine, states show a steady decline in annual PM 10 emissionsOctober 2011

31 District of Columbia Regional Haze SIP over this time period. By contrast , emission trends for primary PM 2.5 are more variable. Emissions of PM 10 and PM 2.5 from sources in the District repr esent a very small portion of total regional emissions. Emission of these pollutants in the District increased slightly between 1996 and 1999 and then decreased in 2002.

Figure 7.7. State Level Primary PM 10 Emissions

0.0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8

Connec t icut Delawa re

D is t ric

t of

C

olum bia M aine

M a ry land

Massac hus

etts New H am

pshire

N ew

J ersey

N ew

Yor

k

P

enns y lv ani

a Rho

de

Island Verm ontmillion t/y NEI 1996

NEI 1999 V3

MANE-VU 2002 V3

Source: MANE-VU Contribution Assessment, Figure 4-6 (Appendix K)October 2011

32 District of Columbia Regional Haze SIP Figure 7.8. State Level Primary PM 2.5 Emissions

0.0 0.1 0.2 0.3

C

o n n ecticu t

D el

a war

e District of Columbia Maine

M aryl an

d Massachusetts New Hampshire

N

ew

J

er

sey New Yo

rk

Pennsylvan i a

R hode Isl an

d Verm o ntmillion t/y NEI 1996

NEI 1999 V3

MANE-VU 2002 V3

Source: MANE-VU Contribution Assessment, Figure 4-7 (Appendix K)

Crustal sources are significant contributors of primary PM em issions. This category includes fugitive dust emissions from construction activit ies, paved and unpaved roads, and agricultural tilling. Comparisons between estimated emissi on rates for fine particles and observed concentrations of crustal matter in the ambient air at downwind recepto r sites suggest that physical or chemical processes remove a signif icant fraction of crusta l material relatively quickly. As a result, it rarely entrains into layers of the atmo sphere where it can transport to downwind receptors. Because of this discrepa ncy between estimated emissions and observed ambient concentrations, modelers typically reduce estimates of total PM 2.5 emissions from all crustal sources by applying a fact or of 0.15 to 0.25 to the total PM 2.5 emissions before including it in modeling analyses.

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 (200 0 to 2004), it accounted for six to eleven percent of particle-related light extinction at MANE-VU Class 1 sites. On the 20 percent worst-visibility days, however, crustal material generally plays a much smaller role relative to other haze-forming pollutants, ranging from two to three percent. Moreover, the crustal fraction includes material of natural origin (such as soil or sea salt) th at is not targeted under the Haze Rule.

Figure 7.9 and Figure 7.10 show that area so urces dominate primary PM emissions.October 2011

33 District of Columbia Regional Haze SIP Figure 7.9. 2002 Annual An thropogenic Primary PM 10 Emissions by State and Percent by Source Type

0% 20% 40% 60% 80% 100%

Con nec

tic

u t Del aware
Distric t of

Co

lum

b ia Main e

M

a r yland Massa chu se

tt

s New Hamps h ire New Je

r se

y

N

e w York

Penns y lv

a nia Rhode I s l an

d

V e r montmillion t/y

0.0 0.1 0.2 0.3 0.4 0.5

AREA NONROAD ONROAD POINT Emission

Figure 7.10. 2002 Annual Anthropogenic Primary PM 2.5 Emissions by State and Percent by Source Type

0% 25% 50% 75% 100%

Con n ect

i c u t Dela w

are

Di

s t rict

o f Co lum

b ia M a i n e

M

a r yl

a n d

M

a s sachuset ts

N

ew

Hampsh ir

e New J e rsey

N

ew York Pennsylvania
Rho d

e

Is

lan

d Ve r m

on

tmillion t/y

0.00 0.05 0.10 0.15 0.20

AREA NONROAD ONROAD POINT Emission

Source: MANE-VU Contribution Assessment, Figures 4-8 and 4-9 (Appendix K)October 2011

34 District of Columbia Regional Haze SIP The relative contribution of point s ources is larger in the primary PM 2.5 inventory than in the primary PM 10 inventory since the crustal component (which consists ma inly of larger or “coarsemode” particles) contributes mostly to overall PM 10 levels. At the same time, pollution control equipment commonly installed at large point so urces is usually more efficient at capturing coarse-mode particles.

7.2.5. Ammonia Emissions

Ammonia emissions play an important role in the formation of particles in the atmosphere. Ammonium ion (formed from ammo nia emissions to the atmosphere ) is an important constituent of airborne particulate matter, including ammoni um sulfate and ammonium nitrate. Ammonium typically accounts for 10 to 20 percen t of total fine particle mass.

Figure 7.11 shows that estimated ammonia emissi ons were fairly stable in the 1996 NEI, 1999 NEI, and 2002 Version 3 MANE-VU inventories for MANE-VU states, with some slight increases observed for most states in MANE-VU.

Figure 7.11. State Level Ammonia Emissions

0.00 0.05 0.10 0.15 0.20

Co

n n ect

ic

u t

D el

a war

e

D i strict of C o lumbia Main e

M aryl an

d Massachuset t s

N

ew

H

a mp

sh

i r e

New Jersey

N ew

Yo

r k

Pen n sylvan i a Rhode Island Verm o ntmillion t/y NEI 1996

NEI 1999 V3

MANE-VU 2002 V3

Source: MANE-VU Contribution Assessment, Figure 4-10 (Appendix K)October 2011

35 District of Columbia Regional Haze SIP Area and onroad mobile sources dominate, as found in Figure 7.12.

Figure 7.12. 2002 Annual Anthropogenic NH 3 Emissions by State and Percent by Source Type

0% 25% 50% 75% 100%

C

onnect icut Delaware

D

ist

r i ct

of

C

olu

mb

ia Maine Maryl and

M

ass

achuset t s

N

e w

H ampshi r e New Je

rs

ey

N

ew Yor k

P

enn

syl

vania

Rh

ode

I

s l and

V

er

m

on

tmillion t/y

0.00 0.06 0.12

AREA NONROAD ONROAD POINT Emission
Source: MANE-VU Contribution Assessment, Figure 4-11 (Appendix K)

Exhaust from highway vehicles are the major s ource of ammonia emissions in the District, and as with other pollutants, the emissions from the Di strict are a small portion of the regional total. Except in the District, area sour ce emissions from agricultural sources and livestock production account for the largest share of estimated ammonia emissions in the MANE-VU region. The remaining area sources with a significant emi ssions contribution is wastewater treatment systems.

7.3. Data Analysis and Modeling

Further quantitative data and modeling analys es reinforced the notions presented by the assessments of monitoring and inventory data.

With respect to sulfate, based on estimates from four different techniques, emissions from within MANE-VU in 2002 were responsible for about 25 to 30 percent of the sulf ate at nearby Class I areas. (See Section 8 of the Contribution Assessment .) Emissions from other regions, Canada, and outside the modeling domain were also important.October 2011

36 District of Columbia Regional Haze SIP Regional Haze Modeling

Air quality modeling to assess regional haze was perform ed cooperatively by several modeling centers within MANE-VU. These modeling efforts included emissions data processing, meteorological input analyses, and chemical transport modeling to perfo rm regional air quality simulations for calendar year 2002 and several future periods, including the primary target date for this SIP, 2018.

Modeling was conducted for two purposes: 1) To assess contributions from upwind areas to Class I areas in downwind states, and 2) To evaluate visibility benefits of specific control measures being considered to achieve reasonable progress goals and establish a long-te rm emissions management strategy for MANE-VU Class I Areas.

Several modeling tools were utilized for these analyses:

• The Fifth-Generation Pennsylvania State Un iversity/National Center for Atmospheric Research (NCAR) Mesoscale Model (MM5), vers ion 3.6, was used to derive the required meteorological inputs for the air quality simulations (Penn State, 2005).

• The Sparse Matrix Operator Kernel Emissions (SMOKE) emissions modeling system, version 2.1, was used to process and format the emissi ons inventories for input into the air quality models (SMOKE, 2007).

• The Community Mesoscale Air Quality model (C MAQ), version 4.5.1, was used for the primary SIP modeling (Byun and Ching, 1999).

• The Regional Model for Aerosols and Depositi on (REMSAD), version 8, was used during contribution apportionment (SAI, 2005).

• The California Puff Model (CALPUFF), version 5, and its associated meteorological wind field pre-processor (CALMET) were used to assess the contribution of individual states’ emissions to sulfate levels at selec ted Class I receptor sites (USEPA, 2006).

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 a demonstration that the models have appropriate skill for the intended application, model performance evaluations were performed and documentation can be found in the following references:

• MM5 – See Appendix H (Sections 1.2 and 2.1) and Appendix L;

• SMOKE – See Appendix H (Section 1.3);

• CMAQ – See Appendix H (Sections 1.4.1 and 2. 2) and Appendix M; also, see Appendix C of Appendix K;

• REMSAD – See Appendix H (Sections 1.4.2); also see Appendix C of Appendix K; and

• CALPUFF and CALMET – See Appendix D of Appendix K.

The District is aware of concerns about the modeling techniques used by MANE-VU. MANE-VU modeling results used to evaluate progress ar e based on emissions assumptions for MRPO and VISTAS states that differ from the emissions assumptions made by those states. As a result, regional model projections for MRPO and VISTAS differ fro m projections made by MANE-VU. However, because the District’s emissions are a very small fr action of total emissions in the MANE-VU region, these models are adequate to demonstrate the Distri ct’s relative contribution to visibility impairment.October 2011

37 District of Columbia Regional Haze SIP 7.3.1. Grid-Based Source Modeling (REMSAD tagged runs)

Table 7.2 shows the results of one of the four methods of assessing state-by-state contributions to sulfate impacts (the REMSAD model). This tabl e highlights the importance of emissions from outside the MANE-VU region.

Table 7.2. Percent Contributions (Mass Basis) of Individual States and Regions to total Annual Sulfate Impacts at Northeast Class I Areas (REMSAD)

Contributing States or Areas Acadia, Maine

(%) Brigantine, New Jersey (%) Dolly Sods,
West Virginia

(%) Great Gulf
and Presidential Range Dry River, New Hampshire (%) Lye Brook, Vermont (%) Moosehorn and Roosevelt Campobello, Maine

(%) Shenandoah, Virginia

(%)

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

Midwest RPO 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

Canada & Other 43.36 25.02 18.18 40.03 33.09 52.83 18.71

TOTAL (μg/m 3 ) 2.026 3.444 3.867 1.780 2.137 1.767 3.919 Source: Table 8-1 from the Contribution Assessment (Appendix K)

Note that Table 7.2 indicates that the District’s contribu tion to regional haze in the listed Class I areas is no more than 0.04 percent, which is well below the two percent threshold.

7.3.2. Emissions Divided by Distance (Q/d)

The following figure shows the results of anot her method used to identify and rank states’ contributions to sulfate at MANE-VU and near by Class I areas using 2002 data. A simple technique for deducing the relative impact of emissi ons from specific point sources on a specific receptor site involves calculating the ratio of annual emissions (Q ) to source-receptor distanceOctober 2011

38 District of Columbia Regional Haze SIP (d). This ratio is then multiplied by a factor designed to account for the effects of prevailing winds and to convert units. The use of this technique is explained in the Contribution
Assessment (page 4-13).

Figure 6.2 shows the resulting rankings across a set ofsouthern Class I areas in or near MANEVU. Details may be found in Table 4-1 (page 4-15) of the Contribution Assessment, which summarizes impacts using the CALPUFF-scal ed Q/d technique. Emissions of SO 2 from the District were 1,715 tons in 2002, with estimated impacts on Acadia, Lye Brook, Brigantine, and Shenandoah each less than 0.01 μg/m 3

.

Figure 7.13. Ranked state percent sulfate co ntributions to Mid-Atlantic Class I receptors based on emissions divided by distance (Q/d) results

Source: Figure 4-13 from the Contribution Assessment (Appendix K)

7.3.3. Air Parcel-Based Source Dispersion Modeling (CALPUFF)

Modeling results using CALPUFF provided similar results, as shown in Figure 6.3, below. CALPUFF modeling was conducted by two modeling centers for MANE-VU. One center used meteorology inputs calculated using the MM5 mo del, while the other center used National Weather Service rawinsonde-based meteorology. The models predicted annual average SO 4 ion concentration at Acadia, Lye Brook, Brigantine, and Shenandoah, which are reported in Tables 7-2a, b, c, and d on pages 7-5 through 7-8 of the Contribution Assessment

.
The MM5-based CALPUFF modeling predicted impact s from emissions in the District would be 0.0005 μg/m 3 at Acadia, 0.0030 μg/m 3 at Brigantine, 0.0006 μg/m 3 at Lye Brook, and 0.0013 μg/m 3 at Shenandoah. The NWS-based CALPUFF m odeling predicted impacts from emissions in the District would be 0.0004 μg/m 3 at Acadia, 0.0021 μg/m 3 at Brigantine, 0.0005 μg/m 3 at Lye Brook, and 0.0016 μg/m 3 at Shenandoah.October 2011

39 District of Columbia Regional Haze SIP Table 8-3 in the Contribution Assessment reports the contributions using the NWS-based model as percentages, and the percent contribution to any of these areas from sources in the District ranges from 0.02 percent at Acadia, Dolly Sods , Lye Brook, and Moosehorn to a maximum of 0.07 percent at Brigantine. The percentage cont ribution at Shenandoah, the Class I area closest to the District, was 0.05 percent. Table 8-4 in the Contribution Assessment reports percentage contributions calculated using the MM5 model, with the maximum also being 0.07 percent at Brigantine.

Figure 7.14. Ranked state percent sulfate co ntributions to Mid-Atlantic Class I receptors based on observation-based (VT) CALPUFF results

Source: Figure 7-3b from the Contribution Assessment (Appendix K)

7.3.4. Emissions Times Upwind Probability

Table 4.2 (p. 4-18) in the Contribution Assessment documents impacts using the upwind probability method of assessing contribution. This method involves calculating residence time probabilities using back-trajectory techniques. The back-trajectory calculated residence time probability for a grid cell is multiplied by the total emissions over the same time period from that grid cell. The product is an emissions-weighted probability field that can be integrated within state boundaries to calculate re lative probabilities of each st ate contributing to pollution transport. Based on this technique, 2002 SO 2 emissions from within th e District contributed less than 0.01 percent to the transpor t of sulfur to Acadia, Lye Brook, Brigantine, or Shenandoah.October 2011

40 District of Columbia Regional Haze SIP 7.4. Comparison of Techniques

Finally, results from the multiple analys is tools and techniques used for the Contribution
Assessment were compared, showing the similarity of the predicted contributions to haze. See Figure 6.4, which shows the comparison for Sh enandoah National Park and Brigantine Wilderness, the two Class I areas receiving the la rgest impacts from sources in the District.

Figure 7.15 (a and b). Comparison of no rmalized (percent contribution) results using different techniques for ranking st ate contributions to sulfate levels at the Shenandoah and Brigantine Class I Areas

Source: Figure 8-1 from the Contribution Assessment (Appendix K)October 2011

41 District of Columbia Regional Haze SIP Based on these results, MANE-VU concluded that the most effective near-term strategy for reducing fine particulate pollution and visibility impairment in the East is to continue reducing anthropogenic emissions of SO 2

.
When results of using various analysis tools and techniques are normalized and compared, there is broad general agreement concerning the top contri buting states at each Class I site, as well as some differences. The use of different approaches results in more agreement than difference. The general patterns of c ontribution are unlikely to change du e to further refinements of data inputs. Given that as much as 30 to 50 percent of the ambient su lfate found at northeastern Class I sites on hazy days appears to originate with in neighboring RPOs, coor dination and consultation is likely to be critic al if MANE-VU is to achieve its visibility goals for 2018 and beyond.October 2011

42 District of Columbia Regional Haze SIP 

### 8. Class I Areas which May be Affected by District Emissions

Section 51.308(d) of EPA’s Regional Haze Rule re quires the State to address regional haze in each mandatory Class I Federal area located wi thin the State and in each mandatory Class I Federal area located outside the State which may be affected by emissions from its facilities.

8.1. DC’s Contribution to Visibility Impairment in Class I Areas

The District did not cont ribute greater than 0.1 μg/m 3 or two percent sulfat e contribution to any nearby Class I areas, which is the threshold es tablished by MANE-VU states with Class I areas for contributing to meet the reasonable progres s goals for 2018. The highest impacts, at the Brigantine Wilderness Area and Shenandoah Nationa l Park, are well below these thresholds. Table 7.1 summarizes the District-s pecific results of the various data analyses described in Section 7.

Table 8.1. Percent Annual Average Sulfate Co ntribution from District Sources in 2002

Contribution from DC Sources Class I Area REMSAD Q/D CALPUFF (NWS) CALPUFF (MM5)

Acadia 0.01% 0.01% 0.02% 0.01%

Brigantine 0.04% 0.05% 0.07% 0.07%

Dolly Sods 0.01% 0.02% 0.02% N.A.

Great Gulf 0.01% 0.01% 0.03% N.A.

Lye Brook 0.02% 0.02% 0.02% 0.02%

Moosehorn 0.01% 0.01% 0.02% N.A.

Shenandoah 0.04% 0.09% 0.05% 0.03%
Source: Appendix K (REMSAD: Table 8-1, p. 8-2; Q/D: Table 8-2, p. 8-3; CALPUFF (NWS): Table 8-3, p. 8-4; CALPUFF (MM5): Table 8-4, p. 8-5)

8.1.1. MANE-VU Class I Areas

The Regional Haze Rule requires states that may reasonably cause or contribute to visibility impairment in Class I areas to work with states with Class I areas to develop regional progress goals.

As discussed in Section 3.3.1, no MANE-VU states with Class I areas asked the District to participate in meeting reasonable progress goa ls by 2018. According to Section 7.7 of New Jersey’s July 28, 2009, final Regional Haze SIP:

New Jersey does not expect that states that were identified because they were MANE-VU members, and did not meet the criteria for contribution of greater than 0.1 μg/m 3 or greater than two percent sulfate contributi on to the Brigantine Wilderness Area, will need to document in their Regional Haze Pl an that they have obtained their share of emission reductions necessary to reach the first progress goal for the BrigantineOctober 2011

43 District of Columbia Regional Haze SIP Wilderness Area, unless any of the top 167 EGU st acks is located in the states. Rather, New Jersey would like to see these MANE-VU me mbers, not identified as contributing to meet the 2018 reasonable progress goal, propose and adopt through their administrative processes the agreed upon Reasonable Measures.

Since the District did not contribute more than 0.1 μg/m 3 or two percent sulfate to any nearby Class I area, and does not contain any of the t op 167 EGU stacks (see Figur e 12.1), the District is not expected to contribute to meeting the 2018 reasonable progress goals established by MANEVU.

8.1.2. VISTAS Class I Areas

Shenandoah National Park and James River Face Wilderness Area are in Virginia. Dolly Sods and Otter Creek Wilderness Areas are in West Virginia. Both Virginia and West Virginia are members of the VISTAS RPO, and the District participated in MANE-V U’s consultation with VISTAS states, including Virg inia and West Virginia.

VISTAS conducted its own contribution assessme nt and did not request additional emission reductions from the District.October 2011

44 District of Columbia Regional Haze SIP 

### 9. Emissions Inventories for Modeling

Section 51.308(d)(4)(v) of EPA’s Regional Haze Rule requires states to inventory emissions of pollutants that are reasonably anticipated to cause or contribute to visibility impairment in any Class I area. The inventory must include emissi ons for a baseline year, future (projected) year, and the most recent year for which data are available. Section 51.308(d)(3)(iii) of EPA’s Regional Haze Rule requires states to identify the baseline emissions level on which strategies are established.

Consistent with the MANE-VU and VISTAS states, the District’s baseline year is 2002. Future year emissions inventories for 2009, 2012, and 2018 were projected from the 2002 base year by MARAMA and its contractors. Only the 2002 and 2018 inventories are summarized below.

The District inventoried the follo wing pollutants whose emissions a ffect fine particle formation, and thus contribute to regiona l haze: sulfur dioxide (SO 2 ), oxides of nitrogen (NO
x ), volatile organic compounds (VOC), ammonia (NH 3 ), and particles with an aerodynamic diameter less than or equal to 10 and 2.5 μm (i.e., primary PM 10 and PM 2.5 ).

The following source categories were included in th e District’s emissions inventory: stationary point sources, stationary area sources, onroad mobile sources, a nd nonroad mobile sources. An inventory of biogenic emi ssions was also prepared for the region as part of the modeling process. These emissions categories are disc ussed further later in Section 9.4.

Section 9.1 begins the overview of the develo pment of baseline and future year emission inventories for modeling.

9.1. Baseline and Future Year Inventories for Modeling

The baseline inventory is intende d to be used to assess progre ss in m aking emission reductions. In accordance with EPA guidance entitled 2002 Base Year Emission Inventory SIP Planning: 8- Hour Ozone, PM 2.5 , and Regional Haze Programs, all MANE-VU states used 2002 as the anticipated baseline emission inve ntory year for regional haze.

To meet the requirements of EPA’s Consolid ated Emissions Reporting Rule (CERR; 40 CFR Part 51), a consolidated 2002 inventory of poi nt, area, onroad, and nonroad emissions was submitted by MANE-VU state and local agencies to EPA between May and July of 2004. The District of Columbia submitted its final 2002 periodic inventory to EPA on May 25, 2004.

The emissions data submitted to EPA by MANE-VU states and the District were the starting point for development of the MANE-VU base year emissions inventory fo r regional modeling. As described below, MARAMA and its contractors worked with the state and local agencies in the MANE-VU region to quality assure and impr ove this initial invent ory, so the final 2002 baseline inventory summarized in this document may differ slightly from the District’s original 2002 baseline inventory submittal.October 2011

45 District of Columbia Regional Haze SIP Future year emissions inventories for 2009, 2012, and 2018 include emissions growth due to projected increases in economic activity, as we ll as emissions reductions expected from the implementation of control measures.

Both baseline and future year inventories were processed for us e in regional modeling. This required MARAMA and its contract ors to revise the format of the emissions inventory and provide it to NESCAUM and othe r modeling centers. The m odeling centers then further processed the emissions data us ing the Sparse Matrix Operator Kernel Emissions (SMOKE) emissions pre-processor to prepare input data for the CMAQ and REMSAD air quality models, as described in Section 7.

Emissions inventories for other parts of th e modeling domain (outside MANE-VU) were obtained from other RPOs, such as VISTAS. EP A provided data for Canadian sources within the modeling domain.

9.2. Development of MANE-VU’s 2002 Baseline Inventory

MANE-VU’s baseline inventory of emissions in the region includes annual average emissions for the year 2002. Preparation of the MANE-V U inventory involved three major development steps, known as Versions 1.0, 2.0 and the final Version 3.0.

Work on Version 1.0 of the 2002 MANE-VU invent ory began in April 2004. To meet the requirements of the CERR, a consolidated inve ntory of point, area, onroad, and nonroad sources was submitted by MANE-VU state and local agenci es to EPA between May and July of 2004. Electronic quality assurance (QA) programs, including the EPA QA software, were run to identify format and data content issues. 2 Pechan worked with MANE-VU member states and MARAMA staff to resolve quality assurance issues and augment the inventories to fill data gaps in accordance with the MANE-VU Quality Assurance Project Plan. 3 The final Version 1.0 inventory was finalized in January 2005.

Work on Version 2.0 (conducted from April th rough September 2005) in volved incorporating revisions requested by some MANE -VU state and local agencies on the point, area, and onroad inventories.

The Version 3.0 inventory for point, area, and onroad sources was built upon Versions 1.0 and 2.0. Work on Version 3.0 (conducted from December 2005 through April 2007) included additional revisions to the point, area, and onroad inventories as requested by some states. For Version 3.0, the nonroad inventory was rebuilt as a result of cha nges to the NONROAD2005

2 EPA. Basic Format & Content Checker 3.0 (Formerly know n as the Quality Assurance/Quality Control Software 3.0) – March 2004. Extended Quality Control Tool – Updated May 18, 2004. United States Environmental Protection Agency. 2004.

3 MANE-VU. Quality Assu rance Project Plan (QAPP) for Area and Point Source Emissions Modeling Inventory Project, Final. Prepared for the Mid- Atlantic/Northeast Visibility Union by E.H. Pechan & Associates, Inc. and Carolina Environmental Program, August 3, 2004.October 2011

46 District of Columbia Regional Haze SIP model by EPA. During the same time period, th e New York Department of Environmental Conservation also developed the biogenics i nventory for the entire MANE-VU region.

Version 3.0 of the 2002 base year emission inve ntory was used in the regional modeling. A technical support document explaining the datasources, methods, and results for the MANEVU 2002 base inventory is presented in:

APPENDIX D Technical Support Document for 2002 MANE-VU SIP Modeling Inventories, Version 3

The District provided poin t source data for CO, NH 3 , NO
x , SO 2 , VOC, and at least one form of PM. PM emissions were augmented by MANE-VU to calculate emissions for the other forms of PM. The District provided annual emissions for the majority of area s ource categories, except for categories for which the District elected to use data from MANE- VU-sponsored inventories (i.e., outdoor wood burning, paved roads, compos ting, and open burning). For the nonroad inventory, there was no Dist rict or NEI data available for airc raft. Commercial marine vessels data was taken from a 2002 preliminary NEI, and locomotives data came from the District’s CERR submittal. For nonroad and onroad modeli ng, the District provided some data sets and requested use of model defaults for others. The OTC-LEV program implementation schedule was included in the modeling, starting implemen tation in the 1999 model year followed by a full implementation of the National LEV program in the 2001 model year. (Appendix D)

9.3. Development of Future Year Em ission Inventories for MANE-VU

MARAMA and its contractors developed future year emission inventories for the MANE-VU region for the years 2009, 2012 and 2018 based on projections from the 2002 base year, using EPA-approved methods. Only the 2018 projection year was considered for this SIP, since 2018 is the target year of interest for reasonable progress goals. Projection years 2009 and 2012 were developed for concurrent PM and Ozone SIPs purposes.

These future year emission inventories include em issions growth due to projected increases in economic activity, as well as the emissions reduc tions due to the implementation of control measures. Detailed documentation of these inventories is included in:

APPENDIX E Development of Emissions Projections For 2009, 2012, and 2018 for NonEGU Point, Area, and Nonroad Sources in the MANE-VU Region

APPENDIX F Documentation of 2018 Emissions from Electric Generating Units in the Eastern United States for MA NE-VU’s Regional Haze Modeling

APPENDIX G Development of MANE-VU Mobile Source Projection Inventories for SMOKE/MOBILE6 Application

Version 3.0 of the MANE-VU 2002 inventory was the basis for projections of future emissions for stationary sources (point and area) other than electricity generating units (EGUs) and for mobile sources (onroad and nonroad). No change was projected in biogenic emissions. MANEVU used emissions projections for EGUs devel oped by a contractor hire d by VISTAS on behalfOctober 2011

47 District of Columbia Regional Haze SIP of the eastern RPOs. The contractor used the Integrated Planning Model (IPM ® ). Projections for onroad mobile sources were developed for 2018 by NESCAUM using the SMOKE model.

9.3.1. Emissions Control Scenarios

Two emission control scenarios were developed:

• OTB/W Scenario

The first future base case scenario included emi ssions growth and control measures that were either already “on the books” (promulgated as of June 15, 2005) or were considered well “on the way” to being implemented because they we re proposed but not yet final (OTB/W).

The following are the control measures that are part of the OTB/W scenario:

• Non-EGU point source controls included NO
x SIP Call Phase I (NO
x Budget Trading Program); NO
x SIP Call Phase II; NO
x RACT in 1-Hour Ozone SIPs; NO
x OTC 2001 Model Rule for ICI Boilers; 2-, 4-, 7-, and 10-year MACT Standards; Combustion Turbine and RICE MACT; Industrial Boile r/ Process Heater MACT; Refinery Enforcement Initiative; and Source Shutdowns; and

• Area source control factors included 2001 OT C VOC Model Rules; Federal On-Board Vapor Recovery; New Jersey Post-2002 Area Source Controls; and Residential Woodstove NSPS.

Non-EGU point source control factors were not in cluded in the inventory for the District.

Area source control factors that applied for th e District included the 2001 OTC model rules (consumer products, AIM coatings, portable fuel containers, and mobile equipment repair and refinishing; solvent cleaning was already accounted for in the 2002 inventory); on-board vapor recovery (OBVR); and residen tial wood combustion. A control factor in the EPA methodology for residential wood combustion accounts for the replacement of retired fireplaces and woodstoves that emit at pre-new source performance standard (NSPS) levels.

Of the controls accounted for in the Di strict, the following are enforceable:

• 2001 OTC model rules (20 DCMR Chapter 7, adopted in April 2004 and amended in December 2004):

○ Consumer products, 20 DCMR §§ 719 to 734;

○ AIM coatings, 20 DCMR §§ 749 to 754;

○ Portable fuel containers, 20 DCMR §§ 735 to 741;

○ Mobile equipment repair and refinishing, 20 DCMR §718; and

○ Solvent cleaning, 20 DCMR §§ 742 to 748.

• On-Board Vapor Recovery (20 DCMR §705)

In addition, Federally-enforceable controls were incorporated in the EGU and mobile source models. These include CAIR; the Nonroad Dies el Rule, the 2007 Highway Diesel Standards, Tier 2 Motor Vehicle Standards, and the Large Spark Ignition and Recreational Vehicle Rule.October 2011

48 District of Columbia Regional Haze SIP • BOTW Scenario

Next, MANE-VU considered a “beyond on the way” (BOTW) scenario that included potential additional control measures to attain the ozone and fine particulate NAAQS and to meet regional haze goals (see Appendix E).

• Non-EGU point source controls included NO
x measures (asphalt production plants; cement kilns; glass and fiberglass furnaces; low sulfur heating oil for commercial and institutional units; and ICI boilers using natural gas, #2 or #4 or #6 fuel oil, and coal); one primary PM 10 and PM 2.5 measure (commercial heating oil); SO 2 measures (commercial heating oil and ICI boilers us ing #2 or #4 or #6 fuel oil a nd coal); and a VOC measure (adhesives and sealants application); and

• Area source control factors included NO
x measures (ICI boilers us ing natural gas, #2 and #4 and #6 fuel oil, and coal; and residential and commercial home heating oil); primary
PM 10 and PM 2.5 measures (residential and commercial home heating oil); SO 2 measures (residential and commercial home heating oil and ICI boilers using distillate oil); and VOC measures (adhesives and sealants; emulsi fied and cutback asphalt paving; consumer products; and portable fuel containers).

Additional potential and reasonable measures were analyzed using a four factor analysis (see Appendix P). The list of measures was further re fined and incorporated into a second BOTW, or “best and final” inventory, and include:

• Top 167 EGU stacks strategy;

• Low sulfur fuel strategy (includi ng second phase, to 15 ppm limit);

• BART implementation strategy; and

• Continued evaluation of additional control measures.

For the District, the difference between th e two BOTW inventories is neglible.

The District does not cont ribute more than 0.1 μg/m 3 to visibility impairment at any Class I area, so chose not to adopt measures in the BOTW or “best and final” scenario s, as further discussed in Section 10.2.

9.4. Brief Summary of Calculation Methods

This section provides a general description of the em ission sour ce classifications in the MANEVU emissions inventories and summarizes info rmation about methods used to calculate emissions.

There are five emission source classifications in the emissions inventory as follows:

• Stationary point

• Stationary area

• Onroad mobile

• Nonroad mobile

• BiogenicOctober 2011

49 District of Columbia Regional Haze SIP Stationary point sources are large sources such as electric generating units (EGUs). Stationary area sources are those sources whose individual emissions are relatively small but due to the large number of these sources, th e collective emissions could be significant (e.g., dry cleaners, service stations, agricultural sources, fire emissions, etc). Onroad mobile sources are automobiles, trucks, and motorcycles that use th e roadway system. Nonroad mobile sources are equipment that can move but do not use the ro adways, such as lawn mowers, construction equipment, railroad locomotives, and aircraft. The emissions from these onroad and nonroad sources are estimated by vehicle type and road type. Biogenic sources are natural sources such as trees, crops, grasses and natural decay of plants.

Stationary point source emissions data is tracked at the facility/unit level. Emissions for all other source types are summed District-wide (or for states, on the county level).

9.4.1. Stationary Point Sources

Point source emissions are emissions from larg e individual sources. Ge nerally, point sources have permits to operate and their emissions ar e individually calculated based on source-specific factors on a regular schedule. The largest point sources are in ventoried annually. These are considered to be major sources having emissions of 100 tons per year (tpy) of a criteria pollutant, 10 tpy of a single hazardous air pollutant (HAP), or 25 tpy tota l HAP. Emissions from smaller sources are also calculated indivi dually but less frequently (every three years). Point sources are grouped into EGU sources and othe r industrial point sour ces, termed as non-EGU point sources. (Appendix E)

• Electricity Generating Units (EGU)

The base year inventory for large EGU s ources was based on 2002 continuous emissions monitoring (CEM) data reported to the EPA in compliance with the Acid Rain program or 2002 hourly emission data provided by stakeholders. These data provide hourly emissions profiles that can be used in the modeling of emissions of SO 2 and NO
x from these large sources. Emission profiles are used to es timate emissions of other polluta nts (volatile organic compounds, carbon monoxide, ammonia, fine particles, soil) based on measured emissions of SO 2 and NO
x . (Appendix F)

Future year inventories of EGU emissions for 2009 and 2018 were developed using the IPM ® model to forecast growth in electric demand and the replacement of older, less efficient and more polluting power plants with newer, more efficient and cleaner units. The IPM ® estimates were reviewed and revised if necessa ry to reflect newer information on planned controls and shut downs. Adjustments were made by MANE- VU modelers to maintain the CAIR cap.

The output of the IPM ® model predicts that certain older plants will be replaced by newer units to meet future electric growth and state-by-state NO
x and SO 2 caps. However, the IPM ® model results are not the best basis upon which to reliab ly predict plant closures . Plant closures are addressed in Section 12.7.

• Point Sources other than EGUsOctober 2011

50 District of Columbia Regional Haze SIP The non-EGU point source category used annual emi ssions as reported by stat es and the District for the CERR for the base year 2002. These emissi ons were temporally allocated to month, day, and source category code (SCC) base d allocation factors. (Appendix D)

The general approach for estimating future year emissions was to use growth and control data consistent with EPA’s CAIR modeling analysis. This data was supplemented with site-specific growth factors as appropriate. (Appendix E)

9.4.2. Stationary Area Sources

Stationary area source base year emissions were estimated by multiplying an emission factor by some known indicator of collec tive activity such as fuel us age, number of households, or population. (Appendix D)

The general approach for estimating future year emissions was to use growth factors to account for changes in economic activity and control f actors for future emission reductions from the OTB/W control regulations. This data was supplem ented with state-specific growth factors as appropriate. (Appendix E)

9.4.3. Onroad Mobile Sources

For onroad vehicles, MOBILE6.2 was used to estimat e emissions. For future year emissions, the model considers that a certain number of the vehi cle fleet in each state will be replaced every year by newer, less polluting vehicles that meet the EPA Tier II motor vehicle standards. These lower emissions have been built into the 2018 in ventory as well as the benefits received from lower sulfur gasoline in onroad diesel and gasoline vehicles and the 2007 heavy-duty diesel standards (see Section 12.5). A ll new mobile source measures and standards, as well as any benefits from implementation of individual st ate Inspection and Mainte nance programs, were used in developing the inventory. (Appendix G)

9.4.4. Nonroad Mobile Sources

For the majority of the nonroad mobile sources, the emissions for base year 2002 were estimated using the EPA’s NONROAD model.

For the future year inventories, the NONROA D model considered that a certain number of nonroad sources would be replaced every year by newer, less polluting vehicles that meet the new EPA standards for nonroad sources (Appendix D). These lower emissions due to vehicle replacement have been built into the 2018 inventory as well as th e benefits received from lower sulfur gasoline in nonroad ve hicles (see Section 12.5.4).

Aircraft engine, railroad locomotives and co mmercial marine are not estimated using the NONROAD model. For these sources, growth a nd control data consistent with EPA’s CAIR analyses were used. This projection method was used with three exceptions. These exceptions were: 1) Maryland sources, 2) DC locomotive growth and controls, and 3) Logan (Boston) airport. Each of these sources used alternative growth and/or controls provided by the states or developed from current Federal rules for th ese sources (applies to controls only).October 2011

51 District of Columbia Regional Haze SIP The District of Columbia used alternative grow th factors for locomotive emissions in order to represent the effect of future Federal emission control programs. The control factors developed for locomotives for Maryland (based on Federal cont rol programs) were used to apply controls to the DC locomotive emissions. The control fact ors were “additive” and were used on the base year emission without back-calculating uncontroll ed emissions, since th e control levels were relative to controls in place for 2002. (Appendix E)

9.4.5. Biogenic Emission Sources

Biogenic emissions were estimated using SMOKE-BEIS3 (Biogenic Emission Inventory System 3, Version 0.9) pre-processor. Biogenic emissions were calculated for VOC and NO
x . Biogenic emissions used for modeling remained constant from 2002 to 2018. Emissions from the District were about 0.1 percent of the regi onal total biogenic emissions. (See Appendices H and I, which describe preliminary and final modeling.)

9.5. Summary of Emissions

This section summarizes emissions from sources in the District and MANE-VU. More detail is provided in Appendices D (base line), E (future years for non-EGU point, area, and nonroad sources), F (future years for EGUs), and G (f uture years for onroad mobile sources).

9.5.1. Emissions from Sources in the District of Columbia

The District’s baseline and future year emissions inventories ar e summarized in Tables 9.1 and 9.2. All values are reported in tons per year. All MANE-VU members used 2002 as the baseline year. As discussed in Section 9.3, the future base case scenario was developed to include growth and control measures that were already either “on the books” or considered well “on the way” to being implemented.

Table 9.1. DC 2002 Emissions Inventory Summary (Tons/Year)

Type of Source VOC NO x PM 2.5 PM 10 NH 3 SO 2 EGU Point 0 300 4 4 0 345
Non-EGU Point 69 480 128 157 4 618
Area 6,432 1,644 805 3,269 14 1,337
Onroad Mobile 4,895 8,902 153 222 398 271
Nonroad Mobile 2,073 3,571 299 310 2 375 Biogenics 1,726 30 - - - -

TOTAL 14,033 15,689 1,389 3,962 422 3,403 Source: Appendix DOctober 2011

52 District of Columbia Regional Haze SIP Table 9.2. DC 2018 OTB/W Emissions Inventory Summary (Tons/Year)

Type of Source VOC NO x PM 2.5 PM 10 NH 3 SO 2 EGU Point 5 103 99 104 12 83
Non-EGU Point 85 627 164 198 5 780
Area 5,255 2,259 917 3,825 17 1,632
Onroad Mobile 1,797 1,717 58 65 438 41
Nonroad Mobile 1,369 1,815 124 135 3 5 Biogenics 1,726 30 - - - -

TOTAL 10,237 6,551 1,362 4,326 474 2,541 Source: Appendices E, F and G

The reductions in EGU emissions of SO 2 and NO
x between the 2002 inventory and 2018 OTB/W inventories are primarily due to CAIR. The d eclines in area source PM and VOC estimates are presumably due to residential wood burning contro ls. Between the same two inventories, the large differences in onroad and nonroad emissions are due to the implemen tation of Federal rules to reduce emissions from nonroad diesel and he avy duty diesel engines and motor vehicles, including low sulfur diesel rule s, Tier 2 vehicle standards, fleet turnover as reflected in modeling, and similar efforts.

9.5.2. Emissions from the District Co mpared to MANE-VU Emissions

As reported in the previous section, Tables 9.3 and 9.4 show emissions from the MANE-VU region and the percentage of emissions from the District of Columbia for the 2002 base year and the 2018 OTB/W inventory. All MANE-VU members us ed 2002 as the baseline year. Note that EGU and non-EGU point sources are combined.

Table 9.3. Regional Summary of th e 2002 MANE-VU Emissions Inventory (Tons/Year)

Type of Source VOC NO x PM 2.5 PM 10 NH 3 SO 2 Point 97,300 673,660 55,447 89,150 6,194 1,907,634
Area 1,528,141 262,477 332,729 1,455,311 249,795 316,357
Onroad Mobile 788,560 1,308,233 22,107 31,561 52,984 40,091
Nonroad Mobile 572,751 431,631 30,084 40,114 287 57,257 Biogenics 2,575,232 28,363 - - - -

TOTAL 5,561,985 2,704,397 440,367 1,616,136 309,260 2,321,338 Source: Appendix DOctober 2011

53 District of Columbia Regional Haze SIP Table 9.4. Percent of 2002 MANE-VU Emissions from Sources in the District (Percent)

Type of Source VOC NO x PM 2.5 PM 10 NH 3 SO 2 Point 0.1 0.1 0.2 0.2 0.1 0.1
Area 0.4 0.6 0.2 0.2 0.0 0.4
Onroad Mobile 0.6 0.7 0.7 0.7 0.8 0.7
Nonroad Mobile 0.4 0.8 1.0 0.8 0.7 0.7 Biogenics 0.1 0.1 - - - -

TOTAL 0.3 0.6 0.3 0.2 0.1 0.1

Point sources are the leading contributor of SO 2 emissions in the MANE-VU region, and area source emissions make up the second largest category of SO 2 emissions. Emissions from sources in the District are a very small part of the emission totals in the MANE-VU region as a whole. Mobile source emissions from the Dist rict represent the largest percentage of the regional emissions, along with area source NO
x emissions due to fuel combustion.

Tables 9.5 and 9.6 display the 2018 MANE-VU em issions inventory summary for the OTB/W modeling inventory, and the percent of these emissions due to sources located in the District of Columbia.

Table 9.5. Regional Summary of the M ANE-VU 2018 OTB/W Emissions Inventory (Tons/Year)

Type of Source VOC NO x PM 2.5 PM 10 NH 3 SO 2 EGU Point 4,528 175,219 65,558 52,360 6,148 320,651
Non-EGU Point 110,524 237,802 41,220 63,757 4,986 270,433
Area 1,387,882 284,535 345,419 1,614,476 341,746 305,437
Onroad Mobile 269,981 303,955 9,189 9,852 66,476 8,757
Nonroad Mobile 380,080 271,185 23,938 27,059 369 8,643 Biogenics 2,575,232 28,396 - - - -

TOTAL 4,728,227 1,301,092 485,324 1,767,504 419,725 913,921 Source: Appendices E, F and G

Table 9.6. Percent of MANE-VU 2018 OTB/W Emi ssions from Sources in the District (Percent)

Type of Source VOC NO x PM 2.5 PM 10 NH 3 SO 2 EGU Point 0.1 0.1 0.2 0.2 0.2 0.0
Non-EGU Point 0.1 0.3 0.4 0.3 0.1 0.3
Area 0.4 0.8 0.3 0.2 0.0 0.5
Onroad Mobile 0.7 0.6 0.6 0.7 0.7 0.5
Nonroad Mobile 0.4 0.7 0.5 0.5 0.8 0.1 Biogenics 0.1 0.1 - - - -

TOTAL 0.2 0.5 0.3 0.2 0.1 0.3October 2011

54 District of Columbia Regional Haze SIP The reduction measures represented above are enforceable. The largest percentage of OTB/W emissions in the District are from mobile sources and from area source NO
x . Table 9.6 indicates that the District would cont ribute 0.3 percent of the SO 2 emissions in the MANE-VU region under the 2018 OTB/W scenario. This represents a larger percentage than in the 2002 base year, presumably because the District has fewer pot ential non-EGU controls than other states, although total SO 2 emissions in the region would drop.October 2011

55 District of Columbia Regional Haze SIP 

### 10. Reasonable Progress Goals

10.1. Requirement

Since there are no Class I areas within the District of Columbia, the Distri ct is not required to establish reasonable progress goals for any Class I areas. Under 40 CFR Section 51.308 (d)(1)(iv), States with Class I areas must consult w ith other States as they develop goals for their Class I areas. The rule reads as follows:

In developing each reasonable progress goal, the State must consu lt with those States which may reasonably be anticipated to cause or contribute to visibility impairment in the mandatory Class I Federal area. In any situ ation 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 implemen tation plan submittal, the Ad ministrator will take this information into account in determining whether the State's goal for visibility improvement provides for reasonable progre ss towards natural visibility conditions.

As a member of MANE-VU, the District worked in cooperation with MANE-VU Class I states as those states established r easonable progress goals for their Class I areas. MANE-VU also sponsored meetings and conference calls to facili tate consultation with states in the VISTAS RPO, including Virginia and West Virginia.

Section 6 introduced the process undertaken to establish natural and baseline conditions and the uniform rate of progress (ROP), or glide pat h, on which goals for each implementation period leading up to 2064, the target date for returning to natural visibi lity, are established. MANE-VU states with Class I areas establis hed the following deciview conditions 4 , rate of progress targets, and natural visibility goals for the Class I areas near the Distri ct. The current implementation period ends in 2018, so the reasonable progress goals for 2018 are equivalent to baseline visibility minus worst day ROP for each Class I area.

4 Appendix J notes that final EPA guidance recommends a default method for calculating natural background and baseline visibility conditions, but allows States to pursue certain refinements in order to make estimates more representative of a specific Class I area if it is poorly represented by the default method. MANE-VU adopted the results of an alternative method. The alternative method values are listed in this report.October 2011

56 District of Columbia Regional Haze SIP Table 10.1. Deciview Estimates

Class I Area Baseline Visibility (2000 to

2004) Worst Day ROP (target dv reductions by 2018) Reasonable Progress Goals (target by 2018 Natural Background

Visibility (target by 2064) Brigantine Wilderness 29.01 3.91 25.1 12.24 Shenandoah National Park 29.31 4.19 25.12 11.35

Dolly Sods Wilderness 29.04 4.35 24.69 10.39 Otter Creek Wilderness 29.04 4.35 24.69 10.39 James River Face Wilderness 29.12 4.20 24.92 11.13 Source: Tables 3-2 and 3-3 of Appendix J and VISTAS presentation found at: http://www.vistas-sesarm.org/docum en ts/VISTAS_Summary_May232007.pdf

The District supports the reasona ble progress goals set by the Cla ss I states, including those set by Virginia and West Virginia th rough the VISTAS process.

10.2. Relationship to the Long-Term Strategy

According to the Region al Haze Rule [40 CFR Part 51 (July 1, 1999)], if reasonable measures can be identified to meet the reasonable pr ogress goals by 2018, while ensuring no degradation of visibility on the best days, then they should be adopted as the state’s long-term strategy.

MANE-VU’s analysis of emissions included two control measure scenarios: the OTB/W and BOTW (with updates in a Best and Final modelin g run). Appendix I expl ains that the BOTW measures were developed as additional reasonable measures, in part due to presumptions about the effectiveness of CAIR. MANE-VU also ac knowledges that states will document in their Regional Haze SIPs any difference of opinion as to whether additional measures are reasonable.

As shown in Table 10.2, the OTB/W scenario will meet the 2018 visibility goal for the Brigantine Wilderness:

Table 10.2. Comparison of 2018 RPGs and OTB/W Deciview Impacts (Deciviews)

Class I Area Reasonable Progress Goal (target visibility by 2018 OTB/W Controls Scenario

(2018)

Brigantine Wilderness 25.10 24.28
Shenandoah National Park 25.12 * Source: Tables 5-1 and 5-2 of Appendix HOctober 2011

57 District of Columbia Regional Haze SIP The control measures in the OTB/ W scenario are reasonable for th e District’s long-term strategy because the District’s contribution to regional haze is less than 0.1 μg/m 3 and two percent sulfate thresholds established by MANE-VU.

The District’s long-term strategy is not the same as the MANE-VU long-term strategy, but emission reductions will provide sufficient emissi ons reductions to meet the reasonable progress goal for the Brigantine Wilderness.

VISTAS did not request emissions reductions for Shenandoah National Park or the other Class I areas within 300 km of the District.

10.3. Effect of Remand of Clean Air Interstate Rule

The District’s long-term strategy is based on regional modeling that predicts emissions in 2018, as required by EPA guidance. The emissions pr ojections that include the OTB/W scenario assume the implementation of EPA’s Clean Air Inte rstate Rule (CAIR). CAIR established a cap and trade program in the eastern United States intended to reduce emissions of SO 2 and NO
x from electricity generating units (EGUs) . The rule was issued on March 10, 2005.

On July 11, 2008, the U.S. Court of Appeals for the District of Columbia Circuit vacated CAIR. On December 23, 2008, the Court decided to remand rather than vacate the rule, allowing CAIR to remain in effect while EPA formulated a replacement rule.

The states with Class I areas pot entially affected by emissions fr om sources in the District did not revise their reasonable progress goals modeling as a result of the remand of CAIR. This does not impact the District’s ability to meet the unifo rm rate of progress because the District’s BART measures account for the CAIR replacemen t rule, as discussed in Section 11.October 2011

58 District of Columbia Regional Haze SIP 

### 11. Best Available Retrofit Technology

The Best Available Retrofit Technology (BART) re quirement of Section 169A of the Clean Air Act (42 U.S.C.§7491(b)(2)(A)) and implementi ng rules (40 CFR §51.30 8(e) and 40 CFR §51 Appendix Y) are intended to re duce emissions specifically from large sources that, due to age, were exempted from other requirements of the Clean Air Act. The District of Columbia is required to submit an implementation plan c ontaining emission limitations representing Best Available Retrofit Technology (BART) and sche dules for compliance with BART for each BART-eligible source that may reasonably be anticipated to cause or contribute to any impairment of visibility in a ny mandatory Class I Federal area, unless it can demonstrate that an emissions trading program or othe r alternative will achieve greater reasonable progress toward natural visibility conditions. Vi sibility impairing pollutants ar e defined by the EPA as sulfur dioxide (SO 2 ), oxides of nitrogen (NO
x ), and particles with an aer odynamic diameter less than or equal to 10 and 2.5 μ m (i.e., PM 10 and PM 2.5 , respectively). (40 CF R Part 51, Appendix Y; 70 Fed. Reg. 39160)

States are required to undertake three key steps to comply with the BART requirements of the Regional Haze Rule:

1. Determine if a source is BART-eligible;
2. Determine if a source reasonably causes or cont ributes to visibility impairment in any Class I area (is “subject to BART”);
3. Determine if additional controls or emissi on limits are necessary (BART determination).

11.1. BART Eligibility

BART eligibility is b ased on three conditions. First, it is limited to sources in one of 26 stationary source categories unde r the Federal Clean Air Act:

1. Fossil-fuel fired steam electric plants of mo re than 250 million BTUs per hour heat input;
2. Coal cleaning plants (thermal dryers);
3. Kraft pulp mills;
4. Portland cement plants;
5. Primary zinc smelters;
6. Iron and steel mill plants;
7. Primary aluminum ore reduction plants;
8. Primary copper smelters;
9. Municipal incinerators capable of million BTUs per hour heat input, charging more than 250 tons of refuse per day;
10. Hydrofluoric, sulfuric, a nd nitric acid plants;
11. Petroleum refineries;
12. Lime plants;
13. Phosphate rock processing plants;
14. Coke oven batteries;
15. Sulfur recovery plants;
16. Carbon black plants (furnace process);
17. Primary lead smelters;October 2011

59 District of Columbia Regional Haze SIP 18. Fuel conversion plants;
19. Sintering plants;
20. Secondary metal production facilities;
21. Chemical process plants;
22. Fossil-fuel boilers of more than 250 million BTUs per hour heat input;
23. Petroleum storage and transfer faciliti es with a capacity exceeding 300,000 barrels;
24. Taconite ore processing facilities;
25. Glass fiber processing plants; and
26. Charcoal production facilities.

Second, eligible sources have units instal led and operating between 1962 and 1977. Such sources pre-date passage of the Clean Air Act Amendments of 1990, which “grandfathered” some sources from new source review permitting re quirements in parts C and D of title I of the Clean Air Act.

Third, eligible sources have a potential to emit of more than 250 tons per year of a visibility impairing pollutant.

11.2. Sources Subject to BART

According to Section III of the 2005 Regional Ha ze Rule preamble, once the State has com piled its list of BART-eligible sources, it needs to dete rmine whether the source is “subject to BART”, and thus requires a BART determination. A sour ce that may not reasonably be anticipated to cause or contribute to any visi bility impairment in a Class I area may be exempted, such as under the following conditions.

11.2.1. Cap-Outs and Shutdowns

Many potentially BART-eligible sources are relatively small emissions sources with potential emissions that exceed the statut ory threshold of 250 tons per y ear or more, but with actual emissions of visibility impairing pollutants of well under 250 tons in any year. A facility may accept a Federally enforceable permit limitation rest ricting their potential emissions by law to less than 250 tons per year. In other words, an otherwise BART-eligible facility may “cap-out” or close operations to avoid being considered BART-eligible.

11.2.2. Small Source Exemption

According to §51.308(e)(1)(ii)(C) of the Regional H aze Rule, “a State is not required to make a determination of BART for SO 2 or NO
x if a BART-eligible source emits less than 40 tons per year of such pollutant(s), or for PM 10 if a BART-eligible source emits less than 15 tons per year of such pollutant.” A BART-eligible facility ma y restrict actual emissions to less than these de
minimis levels using a Federally enforceable permit emission limit, thus making the facility no longer “subject to BART”.October 2011

60 District of Columbia Regional Haze SIP 11.2.3. CAIR

Section 51.308(e)(2) of the Regional Haze Rule provi des that, “a State may opt to implement an emissions trading program or other alternative meas ure rather than to require sources subject to BART to install, operate, and maintain BART.” To do so, the State must demonstrate that the emissions trading program or ot her alternative measure will achi eve greater reasonable progress than would be achieved through the installation and operation of BART .” To make this demonstration, the State must submit an implemen tation plan containing the elements listed in Section (e)(2).

According to Section IV of EPA’s Regional Haze Regulations and Guidelines for Best Available Retrofit Technology (BART) Determinations Pream ble, CAIR would achieve greater reasonable progress that BART for SO 2 and NO
x , and may be used in lieu of BART for BART-eligible facilities:

In June 2004, in the Supplemental Notice of Proposed Rulemaking (SNPR) for the Clean Air Interstate Rule (CAIR), we proposed to conclude that the CAIR will achieve greater reasonable progress than would BART for SO 2 and NO
x at BART-eligible EGUs in CAIR affected States and therefore may be treate d as a program in lieu of BART for those sources. In doing so, we discussed the Re gional Haze Rule S ection 308(e)(2) as precedent for the policy of allowing trading pr ograms to substitute for BART. However, noting that the CAIR trading program aff ected only one category of BART-eligible sources (EGUs), rather than all BART-eligib le categories as en visions for Statedeveloped BART-alternative programs under Section 308(e)(2), we proposed adding a 308(e)(3) applicable only to CAIR. This sect ion would provide that States that comply with the CAIR by subjecting EGUs to th e EPA administered cap and trade program may consider BART satisfied for NO
x and SO
x from BART-eligible EGUs. In the CAIR SNPR and supporting documentation, we provided anal yses demonstrating that CAIR would achieve greater emission reductions t han BART, and would make greater reasonable progress according to the two-pronged visibi lity test previously proposed in the BART guidelines.

On July 11, 2008, the U.S. Court of Appeals for th e District of Columbia Circuit vacated the CAIR rule. EPA requested a rehearing, and, afte r reviewing briefs on the issues, on December 23, 2008, the Court decided to remand rather than v acate the rule, allowing CAIR to remain in effect while EPA formulat ed a replacement rule.

On July 6, 2011, EPA finalized a CAIR replacement rule to respond to the Court’s concerns. The Cross-State Air Pollution Rule (CSAPR) requi res 27 states to reduce power plant emissions through participation in four air qu ality-assured trading programs for SO 2 and NO
x . Emissions reductions will begin in 2012, with CAIR implemented through the 2011 compliance periods. EPA has not released guidance on whether emi ssions reductions under the CSAPR may be used in lieu of BART.October 2011

61 District of Columbia Regional Haze SIP 11.3. BART for the District

According to §51.308(3)(ii)(A), once a source has been identified as BART -eligible and subject to BART, it must conduct an analysis to dete rmine the “best system of continuous emission control technology available and associat ed emission reductions achievable.”

11.3.1. Description of BART-Eligible Sources in the District

Based on a r eview of emissions inventory data, air quality permits, and other data on the air pollution sources, there are two BART-eligible sources in the District located at one facility: the Benning Road Generating Station (BRGS). BRGS is a power plant that meets the electrical demands of the District of Colu mbia, nearby counties in Maryland, and the mid-Atlantic electric grid. The plant typically operates only during hi gh demand periods (mostly during hot spells in the summer or perhaps during very cold conditions of the winter months).

BRGS has two oil-fired steam generators, Units 15 and 16, which operate to produce electricity, and thus fall under the first of the 26 source cate gories eligible for BA RT (“fossil-fuel fired steam electric plants of more than 250 million BT Us per hour heat input”) . Units 15 and 16 were installed in 1968 and 1972, respectivel y, thus meeting the in-service date for BART eligibility, and both have a potential to emit of more than 250 tons per year of a visibility impairing pollutant.

Table 11.1. BART-Eligible Sources in th e District of Columbia

Source and Unit Pollutant Location AFS Facility I.D

Oil-fired steam generating Unit #15 PM, NO
x , SO 2 PPR Benning Road facility 11/001/00001

Oil-fired steam generating Unit #16 PM, NO
x , SO 2 PPR Benning Road facility 11/001/00001

Potomac Power Resources, LLC (“PPR”) owns the BRGS. PPR is a wholly owned but unregulated subsidiary of Pepco Energy Services , Inc. (“PES”), which manages the assets of BRGS on behalf of PPR. PES is a subsidiary of Pe pco Holdings, Inc. (“PHI”), one of the largest energy delivery companies in th e mid-Atlantic region. PHI co mpanies supply energy to PJM Interconnection, LLC (“PJM”), the regional tran smission organization that coordinates the movement of wholesale electricity through the regional electricity grid.

11.3.2. Is BRGS Subject to BART?

Based on the collective importance of BART sources, in June 2004, the MANE-VU Board decided that, “if any source in M ANE-VU is elig ible for BART, it is also subject to BART (i.e., no exceptions will be given).” As a member of MANE-VU, the District agreed to implement the policy decision made by the MANE-VU Board and collaborated with PES, EPA, and the FLMs to explore numerous BART options for BRGS.October 2011

62 District of Columbia Regional Haze SIP 11.3.3. BART for BRGS

Initially, the District planned to use its partic ipation in CAIR to exem pt Units 15 and 16 from BART for SO 2 and NO
x . Units 15 and 16 units are the only el ectric generating units (EGUs) that were are a part of CAIR in the District.

Following extensive analysis and negotiation, DDOE and PES agreed to a permit condition to address BART for PM only. The two EGUs would shut down by December 17, 2012, which is the time by when the Regional Haze Rule states that BART would need to be in place 5 . Based on §51.308(e)(1)(ii)(C) of the Regional Haze Rule, this arrangement would exempt Units 15 and 16 from any triggered BART requirements. It would mean that BRGS would no longer be BART-eligible for PM.

Alternatively, in the same permit condition, PES agr eed that if BRGS con tinued to operate after December 17, 2012, they would accept a de minimis cap on actual emissions of PM 10 of 15 tons per year. The cap would occur on Units 15 and 16. If BRGS remained open, they would be BART-eligible but would be exempted fr om BART based on their acceptance of the de minimis cap. States are not require d to consider less than de minimis emissions when deciding whether a facility is “subject to BART”.

Upon release of the final CAIR replacement rule, CSAPR, the District le arned that no District facilities are included in any CS APR trading program. On Ju ly 18, 2011, the District and EPA met with Pepco representatives to re-evaluate options for SO 2 and NO
x based on CSAPR.

On August 18, 2011, PES formally committed to accept a permit condition to shut down EGU Units 15 and 16 no later than December 17, 2012, w ithout alternative condi tions in lieu of shutting down. This means that the plant is exempt from all BART requirements for SO 2 , NO
x , and PM because the EGUs will no longer be BART-e ligible. The final permit is an enforceable assurance that the District will meet BART requirements.

11.4. Additional Emissions Reductions

The region’s OTB/W scenario incl udes CAIR, and the states with Class I areas did not revise regional modeling as a result of the remand of CAIR and the finalization of CSAPR. Anticipated emissions reductions associated with CAIR must be retained.

The District’s ability to meet the BART requi rement through the closure of BRGS Units 15 and 16 will result in more emissions reductions than CAIR, so is a sufficient replacement for participation in CAIR.

5 According to the Regional Haze Rule (§51.308(b)), regional haze SIPs were due by December 17, 2007. Closure of the BART-eligible units would meet th e intent of the rule: that BART is in place “as expeditiously as practicable but no later than 5 years after EPA appr oves the SIP.” In fact, closure would occur no later than 5 years after the SIP would have been due, which would technically occur prior to EPA approval.October 2011

63 District of Columbia Regional Haze SIP Table 11.2. Estimated EGU Emissions Reductions (Tons/Year)

Pollutant 2002 2018 OTB/OTW EGU Reductions Needed Without CAIR Total EGU Reductions Due to Closure of BRGS 2018 Surplus Reductions

NOx 300 103 197 300 103
SO2 345 83 262 345 83

As Table 11.2 demonstrates, closure of th e units will result in 83 tons of SO 2 reductions and 103 tons of NO
x reductions, in addition to those anticipat ed under the OTB/W scenario. There will also be additional PM reductions. These surplus reductions will further help states with Class I areas meet the reasonable progress goals for 2018.October 2011

64 District of Columbia Regional Haze SIP 

### 12. The District’s Long-Term Strategy

12.1. Requirement for Long-Term Strategy

Under the Clean Air Act, Regional H aze SIPs must contain measures to make reasonable progress toward the goal of ach ieving natural visibility. Ti tle 40 CFR Section 51.308(d)(3) of the Regional Haze Rule requires each State submitting a SIP to also submit a long-term strategy that addresses regional haze visibility impairment for each mandatory Class I Federal area which may be affected by emissions from within the State or, in this case, the District.

The long-term strategy must include enforceab le emissions limitations, compliance schedules, and other measures necessary to achieve the r easonable progress goals es tablished by the states where the Class I areas are located. Each stat e containing a Class I ar ea must consult with other states affecting the Class I area to develop coordinated em ission management strategies. Each state must demonstrate that it has included all measures n ecessary to obtain its share of the emission reductions needed to meet the re asonable progress goals for the Class I areas which are affected by emissions from within the state. A state participating in a regional planning process must include measures needed to achieve its obligati ons agreed upon through that process to the extent that it is reasonable to do so.

12.2. Documentation of Technical Basis for the District’s Emission Reduction Obligations

Title 40 CFR Section 51.308(d)(3)(iii) requires each State submitting a SIP to document the technical basis for the State’ s apportionment of emission re ductions necessary to meet reasonable progress goals in each Class I area affected by the State’s emissions.

The District relied on techni cal analyses developed by MANE -VU to demonstrate that the District is not obligated to reduce emissions to meet the re asonable progress goals because it contributes less than 0.1 μg/m 3 or two percent sulfate at nearby Class I areas. The District is involved in the regional haze planning process as a member of MANE-VU.

When coordinated with control measures adopte d by other states and tr ibes, the anticipated emissions reductions of this long- term strategy will provide additiona l benefits to help meet the reasonable progress goals in nearby Class I areas.

MANE-VU’s technical documentation of the emission reductions necessary to meet reasonable progress goals in each Class I area is summarized in Sections 5, 6 and 7 of this SIP and further supported by the following documents:

• The Nature of the Fine Particle and Regional Haze Air Quality Pr oblems in the MANEVU Region: A Conceptual Description (Appendix O)

• 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 (Appendix J)October 2011

65 District of Columbia Regional Haze SIP • Contributions to Regional Haze in th e Northeast and Mid-Atlantic United States (Appendix K)

• Assessment of Reasonable Progress for Re gional Haze in MANE-VU Class I Areas (called the Reasonable Progress Report ) (Appendix P)

• Five-Factor Analysis of BART-Eligible Sources: Survey of Options for Conducting
BART Determinations (Appendix Q)

• Assessment of Control Technology Options for BART-Eligible Sources: Steam Electric Boilers, Industrial Boilers, Cement Plants and Paper and Pulp Facilities (Appendix R)

• MANE-VU Modeling for Reasonable Progress Goals: Model Performance Evaluation, Pollution Apportionment, and Control Measure Benefits (Appendix H)

• 2018 Visibility Projections (Appendix I)

In addition, the District relied on analysis conducted by neighboring RPOs, including the following documents:

• VISTAS Reasonable Progress Analysis Plan , dated September 18, 2006

• Reasonable Progress for Class I Areas in the Northern Midwest-Factor Analysis , by EC/R, dated July 18, 2007

12.3. Overview of the Long-Term Strategy Development Process

The Distr ict participated in the MANE-VU regional strategy development process, which identified reasonable measures that would reduce emissions contributing to visibility impairment in Class I areas by emissions with in the MANE-VU region by 2018 or earlier. As a participant in MANE-VU, the District supporte d a regional approach towards deciding which control measures to pursue for regional haze. This regional approach was based on technical analyses documented in the following reports:

• Contributions to Regional Haze in th e Northeast and Mid-Atlantic United States (Appendix K)

• Assessment of Reasonable Progress for Re gional Haze in MANE-VU Class I Areas (Appendix P)

• Five-Factor Analysis of BART-Eligible Sources: Survey of Options for Conducting
BART Determinations (Appendix Q)

• Assessment of Control Technology Options for BART-Eligible Sources: Steam Electric Boilers, Industrial Boilers, Cement Plants and Paper and Pulp Facilities (Appendix R)

Sections 12.5 and 12.7 describe the measures reviewed by MANE-VU that were ultimately included in the OTB/W scenario, which the Di strict adopted as its long-term strategy.

Section 12.7 describes additional measures re viewed by MANE-VU as part of two BOTW scenarios.

MANE-VU reviewed a wide range of potential control measures aimed at reducing regional haze by 2018. The process of choosing a set of proposed regional haze control measures started in late 2005 in conjunction with efforts to identify measures to reduce ozone pollution. The OTC selected a contracting firm to assist with the analysis of ozone and regional hazeOctober 2011

66 District of Columbia Regional Haze SIP control measure options. OTC provided the cont ractor with a “master list” of some 900 potential control measures, based on experience a nd previous state implementation plan work. With the help of an OTC control measure wor kgroup, the contractor also identified available regional haze control measures for MANE- VU’s further considerat ion. MANE-VU then developed an interim list of contro l measures for regional haze,

The next step was to further refine th e interim list. The CAIR Plus Report 6 documents the analysis of the cost of additional SO 2 and NO
x controls at EGUs in the Eastern U.S. The Reasonable Progress Report (Appendix P) documents the assessment of control measures for EGUs and the other source categories selected for analysis. Further analys is is provided in the NESCAUM document entitled, “ Assessment of Control Technol ogy Options for BART-Eligible Sources: Steam Electric Boilers, Industrial Boilers, Ceme nt Plants and Paper and Pulp Facilities” (Appendix R). Highlights of these de tailed analyses are provided below.

During MANE-VU’s internal consultation meet ing in March 2007, the District and other member states reviewed the interim list of cont rol measures to make further refinements.

These additional measures beyond the OTB/W scen ario are not in the District’s long-term strategy for 2018.

12.4. Key Anthropogenic Sources of Visibility Impairment

Title 40 CF R Section 51.308(d)(3)(iv) requires the District to iden tify all anthropogenic sources of visibility impairment consid ered in developing its long-term strategy.

12.4.1. Sources of SO 2 Emissions

For the reasons described in Section 7, the emphasis in de veloping this SIP was placed on sources of SO 2 . Emissions inventory analysis summari zed shows that point sources dominated the regional 2002 inventory of SO 2 emissions, except in the District, where area sources (primarily commercial and resi dential heating, and smaller industrial facilities) contributed
most to SO 2 emissions. Additional SO 2 source categories analyzed include oil-fired installations at residen tial, commercial, institutional, or industrial facili ties; industrial, commercial, and institutional (ICI) boilers; and cement and lime kilns.

Roughly 70 percent of the 2.3 million tons of SO 2 emission in the 2002 MANE-VU emissions inventory Version 3.0 were from EGUs, making them the largest SO 2 source category in terms of visibility impairing emi ssions. MANE-VU found through mode ling analysis documented in the Contribution Assessment (Appendix K) that emissions from specific EGUs were important contributors to visibility impairment in M ANE-VU Class I areas in 2002. Figure 12.1 shows the locations of 167 EGU stacks that impair visib ility at one or more MANE-VU Class I area.

6 Prepared by ICF Resources, L.L.C., for MARAMA, Comparison of CAIR and CAIR Plus Proposal using the Integrated Planning Model (IPM ® ), May 30, 2007. Can be accessed at: http://www.marama.org/visibility/CAIR/CAIR_CAIRPlus_FD Report_053007v1.pdf

.October 2011

67 District of Columbia Regional Haze SIP Note that all identified stacks are in the United States, but not all of them are in MANE-VU. Some of the stacks identified as important were ou tside the states identified as contributing at least 2 percent of the sulfate at MANE-VU Class I areas; these were dropped from the list. None of the 167 stacks are located in the District.

Figure 12.1. 167 EGU Stacks Affecting MANE-VU Class I Area(s)

Source: Appendix F

The list of these sources is found in Appendix A of the report Documentation of 2018 Emissions from EGUs (Appendix F).

12.4.2. Sources of Other Pollutants

As discussed in Section 7, VOCs in the M ANE-VU region primarily come from area and onroad mobile sources. Area sources include solv ents, architectural coatings, and dry cleaners.
NO
x emissions are primarily from power plants a nd mobile sources. Mobile sources dominate the NO
x inventories for more urbanized parts of the region, including the District. Primary particulate matter (PM 10 and PM 2.5 ) originates mostly from area sources such as construction activities, paved and unpaved roads, and agri cultural tilling. Amm onia emissions in theOctober 2011

68 District of Columbia Regional Haze SIP District are primarily from hi ghway vehicles, but throughout the region also come from agricultural sources a nd livestock production.

Source apportionment documented in Appendix B of the MANE-VU Contribution Assessment (Appendix K) also identified biomass combustion as a local source contributing to visibility impairment. Wood smoke is di scussed more in Section 12.7.3.

12.5. Emission Reductions Due to Ongoing Air Pollution Programs

Title 40 CF R 51.308(d)(3)(v)(A) requires States to consider emission reductions from ongoing pollution control programs.

MANE-VU developed a future base case scenario that included emissions growth and control measures that were either already “on the books ” (promulgated as of June 15, 2005) or were considered well “on the way” to being implem ented because they were proposed but not yet final (OTB/W). These measures represen t the long-term strategy for the District.

12.5.1. EGU Emissions Controls Expected by 2018 Due to Ongoing Air Pollution Control Programs

The following EGU emissions control strategies fr om MANE-VU states other than the District are to be in place by 2018:

Clean Air Interstate Rule (CAIR) . CAIR was intended to permanently cap emissions of sulfur dioxide (SO 2 ) and nitrogen oxides (NO
x ) in the eastern United States by 2015. When fully implemented, CAIR would have reduced SO 2 emissions in the CAIR region by more than 70 percent and NO
x emissions by more than 60 percent from 2003 levels. As noted previously, EPA developed a new rule to replace CAIR.

The IPM ® model was used to predict future emi ssions from EGUs after implementation of
CAIR. 7 Modifications to the output of IPM ® made to better represent anticipated controls are described in the report, Documentation of 2018 Emissions from Electric Generating Units (Appendix F). Controls considered in making these modifications include the following:

Delaware EGU Regulations : Delaware adopted the follo wing regulations governing EGU emissions:

7 Although the IPM ® model runs also anticipated the implementa tion of EPA’s Clean Air Mercury Rule (CAMR), that rule has since been vacated by the courts. Howeve r, it is anticipated the adjustments to the predicted SO 2 emissions from electric generating units (EGUs) used in the air quality modeling, which were based on statespecific comments on the amount of SO 2 controls that will actually be installed due to state specific regulations and the EPA’s CAIR rule, will have more of an impact on the air quality modeling analysis conducted for this SIP than the vacature of the CAMR rule. MANE-VU believe s the adjustments based on state-specific comments improved the reliability of the inventory and made the modeling results more dependable.October 2011

69 District of Columbia Regional Haze SIP 1. Reg. 1144, Control of Stationary Generator Emissions , SO 2 , PM, VOC and NO
x emission control, State-wide, Effective January 2006.
2. Reg. 1146, EGUs, Electric Generating Unit (EGU) Multi-Pollutant Regulation, SO 2 and NO
x emission control, State-wide, Effective December 2007. SO 2 reductions will be more than regulation specifies
3. Regulation No. 1148, Control of Stationary Combustion Turbine Electric Generating
Unit Emissions , SO 2 , NO
x and PM 2.5 emission control, State-wide, Effective January
2007.

Delaware estimates that these regulations will result in the following emission reductions for affected units:

• SO 2 2002 levels of 32,630 to 8,137 in 2018 (75 percent)

• NO
x 2002 levels of 8,735 to 3,740 in 2018 (57 percent)

Delaware Consent Decree : Valero Refinery Delaware City , DE (formerly Motiva, Valero Enterprises). 2002 SO 2 levels of 29,747 will drop to 608 in 2018 (98 percent). NO
x 2002 levels of 1,022 will fall to 102 in 2018 (90 percent).

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 NO
x , SO 2 , mercury, and CO 2 . These regulations will achieve an approximately 50 percent reduction in NO
x emissions and 50 to 75 percent reduction in SO 2 emissions compared to previous emissions. Depending upon the complian ce path selected by the affected facilities, the facilities will comply with the output-based NO
x and SO 2 standards between 2004 and
2008.

North Carolina Clean Smokestacks Act : Under the act, enacted in 2002, coal-fired power plants (EGUs) in North Carolina must achie ve a 77 percent cut in nitrogen oxide (NO
x ) emissions by 2009 and a 73 percent cut in sulfur dioxide (SO 2 ) emissions by 2013. This legislation establishe s annual caps on both SO 2 and NO
x emissions for the two primary utility companies in North Carolina, Duke Energy a nd Progress Energy. These reductions must be made in North Carolina, and allowances are not saleable.

Consent Agreements in the VISTAS region : The impact of the following consent agreements in the VISTAS states was reflected in the emissions inventory used for those states:

• Santee Cooper: A 2004 consent agreement calls for Santee Cooper in South Carolina to install and commence operation of con tinuous emission control equipment for PM/SO 2 /NO
x emissions; comply with system-wide annual PM/SO 2 /NO
x emissions limits; agree not to buy, sell or trade SO 2 /NO
x allowances allocated to Santee Cooper System as a result of said agreement; and to comply with emission unit limits of said agreement.

• TECO: Under a settlement agreement, by 2008, Tampa Electric in the state of Florida will install permanent emissions-control equipment to meet stringent pollution limits; implement a series of interim pollution-re duction measures to reduce emissions whileOctober 2011

70 District of Columbia Regional Haze SIP the permanent controls are designed and installed; and retire pollution emission allowances that Tampa Electric or others coul d use, or sell to others, to emit additional
NO
x , SO 2 and PM.

• VEPCO: Virginia Electric and Power Co. agreed to spend $1.2 billion between by 2013 to eliminate 237,000 tons of SO 2 and NO
x emissions each year from eight coal-fired electricity generating plants in Virginia and West Virginia.

• Gulf Power 7: A 2002 agreement calls for Gu lf Power to upgrade its operation to cut
NO
x emission rates by 61 percent at its Crest 7 generating plant by 2007 with major reductions beginning in early 2005. The Crest plant is a sign ificant source of nitrogen oxide emissions in the Pensacola Florida area.

• EKPC: A July 2, 2007 consent agreement between the EPA and East Kentucky Power Cooperative requires the utility to reduce its emissions of SO 2 by 54,000 tons per year and its emissions of NO
x by 8,000 tons per year, by instal ling and operating selective catalytic reduction (S CR) technology; low-NO
x burners, and PM and mercury Continuous Emissions Monitors at the utili ty’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 program s, such as CAIR, to meet the reduction requirements of the consent decree. EKPC is expected to spend $654 million to install pollution controls.

• AEP: American Electric Power agreed to spend $4.6 billion dollars to eliminate 72,000 tons of NO
x emissions each year by 2016 and 174,000 tons of SO 2 emissions each year by 2018 from sixteen plants located in Indi ana, Kentucky, Ohio, Virginia and West Virginia.

CAIR was included in visibility modeling runs for the District.

12.5.2. Non-EGU Point Source Controls Exp ected by 2018 Due to Ongoing Air Pollution Control Programs

As discussed in Section 9, c ontrol factors were applied to the 2018 MANE-VU inventory to represent the following OTB/W national, regional, or state control measures:

• NO
x SIP Call Phase I (NO
x Budget Trading Program)

• NO
x SIP Call Phase II

• NO
x RACT in 1-hour Ozone SIPs

• NO
x OTC 2001 Model Rule for ICI Boilers

• 2-, 4-, 7-, and 10-year MACT Standards

• Combustion Turbine and RICE MACT

• Industrial Boiler/Pr ocess Heater MACT 8

• EPA’s Refinery Enforcement Initiative

8 The inventory was prepared before th e MACT for Industrial Boilers and Process Heaters was vacated. Control efficiency was assumed to be at 4 percent for SO 2 and 40 percent for PM.October 2011

71 District of Columbia Regional Haze SIP None of these measures were included in the inventory for the District.

In addition, states prov ided specific control measure info rmation about specific sources or regulatory programs in their state. MANE-VU used the state-specif ic data to the extent it was available.

For other regions, MANE-VU used inventories developed by the RPOs for those regions, including VISTAS Base G2, Moro’s Base K, and Conrad’s emissions inventory. (Emissions for Central states in the MANE-VU modeling do main were taken from the VISTAS Base G2 inventory.)

Non-EGU source controls incorporated into the modeling included the following consent agreements reflected in the VISTAS inventory:

• DuPont: A 2007 agreement calls for E. I. DuPont Nemours & Company’s James River plant to install dual abso rption pollution control equipment by September 1, 2009, resulting in emission reductions of approximately 1,000 tons SO 2 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 with a wet scrubber the SO 2 emissions of the #8 Power Boiler. This control device should result in reducti ons of over 3,500 tons of SO 2 in 2018.

12.5.3. Area Sources Controls Expected by 2018 Due to Ongoing Air Pollution Control Programs

For area sources within MANE-VU, the Distri ct relied on MANE-VU’ s Version 3.0 Emissions Inventory for 2002. In general, the 2018 inve ntory for area sources was developed by MANEVU applying growth and control factors to the 2002 Version 3.0 inventory. OTB/W area source control factors were developed for the following national or regi onal control measures:

• 2001 OTC VOC Model Rules

• Federal On-Board Vapor Recovery (OBVR)

• New Jersey Post-2002 Ar ea Source Controls

• Residential Woodstove NSPS

The VOC, OBVR, and residential wood combustion measures were applied to the inventory for the District.

After release of Version 3.0 of the MANE- VU 2002 inventory, Massachus etts revised their inventory of area source heating o il emissions due to two changes: (1) The sulfur percent used to derive the emissions factors was adjusted from 1.0 to 0.3; and (2) use of the latest DOE-EIA 2002 fuel use data instead of the previous vers ion used 2001. These two changes significantly altered the 2002 SO 2 emissions for area source heati ng oil combustion. Massachusetts provided revised 2002 PE and EM tables, which MACTEC used in preparing the 2009/2012/2018 projection inventoriesOctober 2011

72 District of Columbia Regional Haze SIP The District of Columbia disc overed a gross error in the 2002 re sidential, non-residential and roadway construction. As requested by the Distri ct, the following values were used for the 2002 base year as the basis fo r the 2009/2012/2018 projections:

Table 12.1. Corrected Emissions from the District of Columbia

Source Classification Code Pollutant Code 2002 Annual Emissions (tpy)
2311010000 PM 10 -PRI 8.2933 Residential Construction PM 2.5 -PRI 1.6587
2311020000 PM 10 -PRI 486.1951 Indust/Comm/Inst Const PM 2.5 -PRI 97.239
2311030000 PM 10 -PRI 289.8579 Road Construction PM 2.5 -PRI 57.9716

As noted above, the inventory information used for other regions was obtained from those regions’ RPOs.

12.5.4. Controls on Nonroad Sources Expected by 2018 due to Ongoing Air Pollution Control Programs

The District used Version 3.0 of the M ANE-VU 2002 Emissions Inventory. The nonroad source control incorporated into the modeling was:

Nonroad Diesel Rule . This rule ( http://www/epa/gov/nonroaddiesel/ ) sets standards that will reduce emissions by more than 90 percent from nonroad diesel equipment, and reduce sulfur levels by 99 percent from current levels in nonroad diesel fuel starting in 2007. This step will apply to most nonroad diesel fuel in 2010 and to fuel used in locomotives and marine vessels in 2012.

Since this was a Federal measure and is Federally enforceable, it was included in MANE-VU modeling for the District.

12.5.5. Mobile Source Controls Expected by 2018 due to Ongoing Air Pollution Control Programs

Mobile source controls incorporated in to the modeling include the following:

Heavy Duty Diesel (2007) Engine Standard . EPA set a PM emissions standard for new heavyduty engines of 0.01 grams per brake-horsepower-hour (g/bhp-hr), to take full effect for diesel engines in the 2007 model year. This rule also includes standards for NO
x and non-methane hydrocarbons (NMHC) of 0.20 g/bhp-hr a nd 0.14 g/bhp-hr, respectively. These NO
x and NMHC standards will be phased in together between 2007 and 2010 for diesel engines.

Sulfur in diesel fuel must be lowered to enable modern pollution-control technology to be effective on these trucks and buses. EPA will require a 97 percent reduction in the sulfurOctober 2011

73 District of Columbia Regional Haze SIP content of highway diesel fuel from its current level of 500 parts per million (low sulfur diesel, or LSD) to 15 parts per million (ult ra-low sulfur diesel, or ULSD).

Tier 2 Motor Vehicle Standards . Tier 2 is a fleet averagi ng 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 NO
x emissions below a specified value. 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.

Large Spark Ignition and Recreational Vehicle Rule . EPA has adopted new standards for emissions of NO
x , hydrocarbons (HC), and carbon monoxi de (CO) from several groups of previously unregulated nonroad engines. Included in these are large industrial spark-ignition engines and recreational vehicles. Nonroad sp ark-ignition engines ar e those powered by gasoline, liquid propane, or compressed natu ral gas rated over 19 kilowatts (kW) (25 horsepower). These engines are used in comm ercial and industrial applications, including forklifts, electric generators, airport baggage transport vehicl es, and a variety of farm and construction applications. Nonr oad recreational vehicles incl ude snowmobiles, off-highway motorcycles, and all terrain vehicles. These ru les were initially effective in 2004 and were assumed to be fully phased-in by 2012.

All of these measures are Fe derally enforceable, so were included for the District.

12.6. Additional Reasonable Strategies Considered for MANE-VU’s Long-Term Strategy

Title 40 CFR Section 51.308(d)(3)(v) requires States to consider the following four factors to determine which additional emissi on control measures are needed to make reasonable progress in improving visibility: 1) costs of compliance, 2) time necessary for compliance, 3) energy and non-air quality environmental impacts of compliance, and 4) remaining useful life of any existing source subject to such requirements. The plan must include reasonable measures and identify the visibility improvement th at will result from those measures.

12.6.1. Identification of Key Source Categories

Based on available information about emissi ons and potential impacts, the MANE-VU Reasonable Progress Workgroup sel ected the following source cate gories for detailed analysis of the four factors the Clean Air Act as the basis for determining how much progress in visibility improvement is reasonable:

• Coal and oil-fired Electric Generating Units, (EGUs);

• Point and area source industrial, commercial and institutional boilers;

• Cement kilns;

• Lime kilns;

• The use of heating oil; and

• Residential wood combus tion and open burning.October 2011

74 District of Columbia Regional Haze SIP Prior to making this determination, the District worked with other members of the OTC and MANE-VU to consider a wide variety of pot ential emission reduction strategies covering a wide range of sources of SO 2 and other pollutants contributing to regional haze.

12.6.2. Analysis of the Four Statutory Factors

The District reviewed MANE-VU’s analysis of the four factors that the Clean Air Act requires be considered in determining whether additi onal controls are reasonable. The analysis developed for MANE-VU applied the four factors to a series of emission control measures. This analysis is described in detail in the Reasonable Progress Report (Appendix P). The Reasonable Progress Report summarizes MANE-VU’s asse ssment of pollutants and associated source categories affecting visibility in Class I areas in and near MANE-VU, lists possible control measures for those pollutants an d source categories, and develops the requisite four factor analysis. Table 12.3 presents a summar y of the four factor analysis for the source categories analyzed in the Reasonable Progress Report.October 201175District of Columbia Regional Haze SIPTable 12.3. Summary of Results from the Four Factor AnalysisSourceCategoryPrimaryRegionalHazePollutantControl Measure(s)Average Cost in 2006dollars (per ton ofpollutant reduction)ComplianceTimeframeEnergy and Non-AirQualityEnvironmentalImpactsRemainingUsefulLifeElectricGeneratingUnitsSO2Switch to a low sulfur coal (generally <1%sulfur), switch to natural gas (virtually 0%sulfur), coal cleaning, Flue Gas Desulfurization(FGD)-Wet, -Spray Dry, or -Dry.IPM®* v.2.1.9 predicts$775-$1,690. $170-$5,700based on available literature2-3 years following SIPsubmittalFuel supply issues,potential permittingissues, reduction inelectricity productioncapacity, wastewaterissues50 yearsor moreIndustrial,Commercial,InstitutionalBoilersSO2Switch to a low sulfur coal (generally <1%sulfur), switch to natural gas (virtually 0%sulfur), switch to a lower sulfur oil, coalcleaning, combustion control, Flue GasDesulfurization (FGD)- Wet, -Spray Dry, or -Dry.$130-$11,000 based onavailable literature. Dependson size.2-3 years following SIPsubmittalFuel supply issues,potential permittingissues, control deviceenergy requirements,wastewater issues10-30yearsCement andLime KilnsSO2Fuel switching, Dry Flue Gas DesulfurizationSpray Dryer Absorption (FGD), Wet Flue GasDesulfurization (FGD), Advanced Flue GasDesulfurization (FGD).$1,900-$73,000 based onavailable literature. Dependson size.2-3 years following SIPsubmittalControl deviceenergy requirements,wastewater issues10-30yearsHeating Oil SO2Lower the sulfur content in the fuel. Dependson the state.$550-$750 based onavailable literature. There isa high uncertaintyassociated with this costestimate.Currently feasible.Capacity issues mayinfluence timeframe forimplementation of newfuel standardsIncreases infurnace/boilerefficiency, Decreasedfurnace/boilermaintenancerequirements18-25yearsResidentialWoodCombustionPMState implementation of NSPS, Ban on resale ofuncertified devices, installer trainingcertification or inspection program, pelletstoves, EPA Phase II certified RWC devices,retrofit requirement, accelerated changeoverrequirement, accelerated changeoverinducement.$0-$10,000 based onavailable literatureSeveral years -dependent onmechanism foremission reductionReduce greenhousegas emissions,increase efficiency ofcombustion device10-15yearsSource: Appendix POctober 2011

76 District of Columbia Regional Haze SIP Guided by this analysis, the list of measures wa s further refined. MANE- VU arrived at a suite of suggested control measures that the MANE-VU st ates agreed to pursue as a region by 2018. The corollary was that the MANE-VU Class I stat es (Maine, New Hampshire, Vermont, and New Jersey) also asked states outside of MANE-VU that also contribut e to visibility impairment to pursue similar strategies for reducing sulfate emissi ons from source sectors, or equivalent sulfate reductions if not from the source sectors that MANE-VU has identified for its own sulfate reductions.

The District contributes less than 0.1 μg/m 3 or two percent sulfate at nearby Class I areas, so the District’s long-term strategy does not include additional measures reviewed by MANE-VU using the four-factor analysis. Rather , the District’s long- term strategy adopts measures in the OTB/W scenario.

12.7. Additional Control Measures Considered

In addition, the following control m easures have been consideredby the MANE-VU region.

12.7.1. Source Retirement and Replacement Schedules

Title 40 CF R Section 51.308(d)(3)(v)(D) requires States to consider source retirement and replacement schedules in developing reasonabl e progress goals. Retirement and replacement must comply with existing Federal requirement s, including those pertaining permitting programs such as New Source Review (NSR) and Prevention of Significant Deterioration (PSD), which are not part of this SIP.

Source retirement and replacement were considered in developing the 2018 emissions inventory described in Development of Emissions Projections for 2009, 2012, and 2018 for Non-EGU Point, Area, and Nonroad Sources in the MANE-VU Region (Appendix F). None of the sources considered are in the District.

12.7.2. Measures to Mitigate the Impacts of Construction Activities

Section 40 CFR Section 51.308(d)(3)(v)(B) requires St ates to consider measures to mitigate the impacts of construc tion activities.

MANE-VU’s consideration of measures to mitigat e the impacts of construction can be found in the MANE-VU document entitled, Technical Support Document on Measures to Mitigate the Visibility Impacts of Constructi on Activities in the MANE-VU Region (Appendix T).

MANE-VU’s Contribution Assessment (Appendix K) found that, from a regional haze perspective, crustal material generally does not play a major role. On the 20 percent best visibility days during the 2000 to 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 worstvisibility 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 no t targeted under the Regional Haze Rule. Nevertheless, the crustal fraction at any given location can be heavilyOctober 2011

77 District of Columbia Regional Haze SIP influenced by the proximity of construction activi ties; and construction acti vities occurring in the immediate vicinity of MANE-VU Class I Areas could have a noticeable effect on visibility.

Section 605 of Title 20 District of Columbia Municipal Regulati ons, Control of Fugitive Dust, requires reasonable precautions to minimize emissions of fugitive dust into the atmosphere (Appendix U). Additional measures to mitigate the impact on Class I areas of construction emissions are not needed in the District’s SIP.

12.7.3. Agricultural and Forestry Smoke Management

Title 40 CFR Section 51.308(d)(3)(v)(E) require s States to consider smoke management techniques for the purposes of agricultural and forestry manage ment in developing reasonable progress goals.

The MANE-VU Technical Support Document on Agricult ural and Forestry Smoke Management in the MANE-VU Region (Appendix S) concluded that fire from land management activities was not a major contributor to regional haze in MANE -VU Class I areas, and that the majority of emissions from fires were from residential w ood combustion. According to Appendix B of the document, wood smoke also contributes to visibi lity impairment, with contributions typically higher in rural areas than urba n areas, winter peaks in norther n areas from residential wood burning, and occasional large summer impacts at all sites from wild fires. Wood smoke impacting MANE-VU Class I areas is more local in origin than sources of SO 2 , except for major transport events. 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.

Section 604 of Title 20 District of Columbia Municipal Regulations prohibits open burning within the District (Appendix U). Being an ur ban environment, the District does not have a smoke management plan. Additional measures to mitigate the impact on Class I areas of smoke emissions from agricultural and forest fire s are not needed in the District’s SIP.

12.8. Estimated Impacts of the District’s Long-Term Strategy on Visibility

Title 40 CF R 51.308(d)(3)(v)(G) requires the District to address the net effect of its long-term strategy on visibility resulting from changes projected in point, ar ea and mobile source emissions by 2018.

The District has adopted the c ontrol measures in the OTB/W s cenario, and has met the BART requirement.

12.9. Share of Emission Reductions

Title 40 CF R 51.308(d)(3)(ii) requires the District to demonstrate that its implementation plan includes all measures necessary to obtain its fair share of emission reductions needed to meet reasonable progress goals for nearby Class I areas by 2018.October 2011

78 District of Columbia Regional Haze SIP The District’s contribution to visibility impairme nt at nearby Class I areas is less than 0.1 μg/m 3 or two percent sulfate, so stat es with Class I areas in MANE- VU and VISTAS do not expect the District to document progress towards meeting reasonable progress goals. New Jersey makes an exception for MANE-VU states that are involv ed in the regional haze planning process as members of MANEVU if any of the 167 EGU stacks is located in the state. None of the 167 stacks is located in the District.

Deciview impacts of the OTB/W scenario are e xpected to reduce emissions to meet the 2018 visibility goal for the Brigantine Wilderness:

Table 12.4. Comparison of 2018 RPGs and OTB/W Deciview Impacts (Deciviews)

Class I Area Reasonable Progress Goal (target visibility by 2018 OTB/W Controls Scenario

(2018)

Brigantine Wilderness 25.10 24.28
Shenandoah National Park 25.12 * Source: Tables 5-1 and 5-2 of Appendix H

It would be difficult to determine the decivi ew impacts of the OTB/W scenario on VISTAS states, since OTB/W measures ar e specific to MANE-VU. VIST AS did not request emissions reductions for Shenandoah National Park or the othe r Class I areas within 300 km of the District.

Additional emissions reductions are anticipated as a result of the closure of the District’s two BART-eligible units by December 17, 2012. Since the District is not required to reduce emissions, but is participating as a member of M ANE-VU, the District is meeting more than its share of emissions reductions.

12.10. Changes to Emissions by 2018

The emission inventory for the Di strict projects changes to po int, area, and mobile source inventories by 2018, the end of the first impl ementation period, resulting from population growth; industrial, energy and natural reso urces development; land management; and air pollution control. A summary of SO 2 emissions changes in the MANE-VU region is given in Section 9. More detail is provided in:

• Development of Emissions Projections for 2009, 2012, and 2018 for Non-EGU Point, Area, and Nonroad Sources in the MANE-VU Region (Appendix E), and

• Documentation of 2018 Emissions from Electri c Generating Units in the Eastern U.S. for MANE-VU’s Regional Haze Modeling (Appendix F).October 2011

79 District of Columbia Regional Haze SIP Table 12.2. Emissions from Point, Are a, and Mobile Sources in MANE-VU (SO 2 tpy)

Type of Source Baseline 2002 2018 (with OTB/W measures)

EGU Point 1,643,257 320,651

Non-EGU Point 264,377 270,433

Area 316,357 305,437

Onroad Mobile 40,091 8,757

Nonroad Mobile 57,257 8,643

These estimates are similar to those in Tables 9.3 (2002) and 9.5 (2018).

Table 12.3. Emissions from Point, Area, a nd Mobile Sources in the District (SO 2 tpy)

Type of Source Baseline 2002 2018 (with OTB/W

measures)
EGU Point 345 83

Non-EGU Point 618 780

Area 1,337 1,632

Onroad Mobile 271 41

Nonroad Mobile 375 5

These estimates can be found in Tables 9.1 (2002) and 9.2 (2018).

The differences between the District’s 2002 and 2018 estimates reflect the impact of growth plus control measures in the OTB/W scenario. They include reductions from BART measures, which replace anticipated reductions based on CAIR. All of the OT B/W and BART measures are enforceable.

12.11. Enforceability of Emission Limitations and Control Measures

Title 40 CF R 51.308(d)(3)(v)(F) requires the Distri ct to ensure that emission limitations and control measures used to meet reasonable progress goals are enforceable.

Of the OTB/W controls accounted for in th e District, the following are enforceable:

• 2001 OTC model rules (20 DCMR Chapter 7, adopted in April 2004 and amended in December 2004):

○ Consumer products, 20 DCMR §§ 719 to 734;

○ AIM coatings, 20 DCMR §§ 749 to 754;

○ Portable fuel containers, 20 DCMR §§ 735 to 741;

○ Mobile equipment repair and refinishing, 20 DCMR §718; and

○ Solvent cleaning, 20 DCMR §§ 742 to 748.

• On-Board Vapor Recovery (20 DCMR §705)October 2011

80 District of Columbia Regional Haze SIP The following sections of the DC Municipal Regula tions are also included in the District SIP and are therefore Federally enforceable:

• Section 604 of Title 20 Distri ct of Columbia Municipal Regulations prohibits open burning within the Di strict (Appendix U).

• Section 605 of Title 20 District of Columbia Municipal Regu lations, Control of Fugitive Dust, requires reasonable precautions to mi nimize emissions of fugitive dust into the atmosphere (Appendix U).

• Section 801 of Title 20 District of Columbia Municipal Regulations, Sulfur Content in Fuel Oils, limits sulfur to 1 percent by weight (Appendix U).

Additionally, the BRGS permit, finalized with this SIP, is federally enforceable.October 2011

81 District of Columbia Regional Haze SIP 

### 13. Next Steps

As a result of MANE-VU planning process, on June 20, 2007, the MANE-VU states with Class I areas adopted a statement that became known as the “Ask”. It was shared with other RPOs as part of MANE-VU’s emissions reduction strategy, and includes the following:

1. Timely implementation of BART requirements; and

2. A low sulfur fuel oil strategy in the inner z one States (New Jersey, New York, Delaware, and Pennsylvania, or portions thereof) to reduce the sulfur content of:

• Distillate oil to 0.05 percent sulfur by weight (500 ppm) 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, and

• Further reduce the su lfur content of distillate oil to 15 ppm by 2016; and

3. A low sulfur fuel oil strategy in the outer zone States (the remainder of the MANE-VU region) to reduce the sulfur content of:

• Distillate oil to 0.05 percent sulfur by weight (500 ppm) by no later than 2014,

• #4 residual oil to 0.25 percen t-0.50 percent sulfur by weight by no later than 2018,

• #6 residual oil to no greater than 0.5 per cent sulfur by weight by no later than 2018, and

• Further reduce the su lfur content of distillate oil to 15 ppm by 2018 depending on supply and availability; and

4. A 90 percent or greater reduc tion in sulfur dioxide (SO 2 ) emissions from each of the 167 electric generating unit (EGU) stacks identified by MANE-VU as reasonably anticipated to cause or contribute to impairment of visi bility in each mandatory Class I Federal area in the MANE-VU region. If it is infeasible to achieve that level of reduction from a unit, alternative measures will be pursued in such State; and

5. Continued evaluation of other control measures including energy efficiency, alternative clean fuels, and other measures to reduce SO 2 and nitrogen oxide (NO
x ) emissions from all coal-burning facilities by 2018 and new source performance standards for wood combustion.

The coordinated MANE-VU long-term strategy to reduce and prevent regional haze allows each state up to 10 years to pursue adoption and im plementation of reasonable and cost-effective NO
x and SO 2 control measures as appropriate and necessary.

The District remains committed to the goal of improving visibility, a nd plans to continue pursuing the adoption of the MANE -VU measures in the BOTW and “best and final” scenarios by 2018 as appropriate and necessary.

The District will review emissions projections within five years of submittal of this initial plan to evaluate progress towards meeting the reasonab le progress goals of Cl ass I areas near the District.