DEVAL L f'ATriICK 

GOVCrnor 

F21CHAnD K SULLIVAN in . 

S Iuurol,~Iry 

TIMOTHY P MUiiRM KENNETH L . KIMMELL 

Lujuur3nant Governor CommioLiuner 

August 19, 2011 

David Conroy, Chief, Air Programs Branch 

US EPA - New England 

5 Post Office Square- Suite 100 (Mail Code OEP05-2) 

Boston, MA 02109-3912 

Re: SIP Submittal Addressing Massachusetts' Obligations Under §§110(a)(1) and (2) of the 

Clean Air Act - Addendum to § 110(a)(2)(D)(i)(I) portion of the Infrastructure SIP 

certification for 2006 PM2,5 NAAQS 

Dear M\ onroy: 

On September 21, 2009, the Massachusetts Department of Environmental Protection (MassDEP) 

submitted Massachusetts' Infrastructure State Implementation Plan (SIP) certification for 

adoption into the Massachusetts' SIP. The Infrastructure SIP certified that Massachusetts meets 

the required elements of §§110(a)(1) and (2) of the Clean Air Act and demonstrated that 

Massachusetts' resources and authorities are adequate to implement, maintain, and enforce the 

2006 24-hour National Ambient Air Quality Standards (NAAQS) for PMZ.5 . 

The § 110(a)(2)(D)(i)(I) portion of the submittal addresses the requirement that Massachusetts 

prohibit any source or other type of emissions activity in the state from contributing significantly 

to nonattainment, or interfering with maintenance, of the NAAQS in another state. This portion 

of Massachusetts' submittal referenced EPA's 2005 Clean Air Interstate Rule (CAIR) and the 

associated State program. However, a December 2008 court decision vacated CAIR, but kept 

CAIR requirements in place temporarily while directing EPA to issue a replacement rule . On 

August 2, 2010, EPA proposed the Transport Rule,' The analysis conducted for the proposed 

Transport Rule supported the conclusion at the time that Massachusetts significantly contributed 

to nonattainment or interfered with maintenance of the 2006 PM2.5 NAAQS. After discussions 

with EPA Region 1 staff regarding the impact of the 2008 court decision on the approvability of 

our September, 2009 Infrastructure SIP and the conclusions in the proposed Transport Rule, in 

Commonwealth of Massachusetts 

Executive Office of Energy & Environmental Affairs 

Department of Environmental Protection 

One Winter Street Boston, MA 02108 " 617-292-5500 

1 See, Federal Implementation Plans To Reduce Interstate Transport of Fine particulate Matter and Ozone (75 FR 

45210. 

This information Is available In alternate format . Call Michelle Waters-Ekanem, Diversity Director, at 617-282-5751 . TDD# 1-866-639-7622 or 1-617-674-6868 

MassDEP Website: www.mass.govldep 

Printed on Recycled Paper 
our January 13, 2011 letter to you, Massachusetts withdrew the § 110(a)(2)(D)(i)(I) portion of the 

Infrastructure SIP submittal. 

On July 6, 2011, EPA finalized the Cross-State Air Pollution Rule (CSAPR or Transport Rule), 

which replaces CAIR. The results of the analysis conducted for the final CSAPR differ from the 

results of the proposed Transport Rule . 2 The CSAPR provisions do not include Massachusetts 

because updated EPA air-quality modeling supports EPA's conclusion that Massachusetts does 

not contribute significantly to nonattainment, or interfere with maintenance, of the 2006 PMZ,5 

NAAQS (or of the 1997 ozone or PM2.5 NAAQS) in another state .3 Therefore, we are 

resubmitting that section of our September, 2009 Infrastructure SIP that addresses interstate 

transport and § 110(a)(2)(D)(i)(I), and certifying that Massachusetts does not contribute 

significantly to nonattainment, or interfere with maintenance, of the 2006 PM2,5 NAAQS (or of 

the 1997 ozone or PM2,5 NAAQS) in any other state based on air-quality modeling performed for 

CSAPR. 

Thank you for your consideration of this clarification of the Massachusetts Infrastructure SIP 

certification for the 2006 PM2,5 NAAQS. If you have any questions or comments concerning this 

matter, please contact Eileen Hiney (617-292-5520; Eileen .Hineycnt.state .ma.us .) 

Sincerely, 

,----. 

( 

Nancy L. Seidman 

Deputy Assistant Commissioner for Climate Strategies 

Bureau of Waste Prevention 

2 EPA updated its modeling platforms and modeling inputs in response to public comments received on the proposed 

Transport Rule and subsequent NODAs and performed other standard updates. 

3 Information about EPA's modeling for CSAPR is available on their CSAPR website on the technical information 

and support documents page : http ://www epa yov/crossstaterule/techinfo html .