District of Columbia 

Regional Haze 

State Implementation Plan 

Submitted to: 

U.S. Environmental Protection Agency, Region 3 

Prepared by: 

GOVERNMENT OF THE DISTRICT OF COLUMBIA 

District Department of the Environment 

Air Quality Division 

1200 First Street, NE 

Washington, DC 20002 

green.dc.gov 

FINAL October 2011
The District Department of the Environmental acknowledges 

the Mid-Atlantic Visibility Union (MANE-VU), 

Mid-Atlantic Regional Air Management 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 Agriculture’s Forest Service 

for their assistance and guidance during the assembly 

of this State Implementation Plan. 
TABLE OF CONTENTS 

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

1.1. GENERAL DESCRIPTION OF REGIONAL HAZE ..........................................................................2

1.2. THE CLEAN AIR ACT GOAL AND THE FEDERAL REGIONAL HAZE RULE ........................2

2. GENERAL STATE IMPLEMENTATION PLAN REQUIREMENTS .......................................................7

3. REGIONAL PLANNING AND CONSULTATION.......................................................................................9

3.1. PARTICIPATION IN REGIONAL PLANNING ORGANIZATION.................................................9

3.2. CONSULTATION FRAMEWORK .....................................................................................................11

3.3. CONSULTATION WITH OTHER STATES......................................................................................12

3.3.1. States Notifying the District of Contribution to Haze ..........................................................................12

3.3.2. MANE-VU Consultation Area..............................................................................................................13

3.3.3. Summary of MANE-VU Consultation ..................................................................................................15

4. FEDERAL LAND MANAGER COORDINATION .....................................................................................17

4.1. PRELIMINARY CONSULTATION WITH FLMS ...........................................................................17

4.2. CONSULTATION WITH FLMS CONCERNING THIS SIP ...........................................................17

4.3. COMMITMENT TO CONTINUING CONSULTATION WITH FLMS IN THE FUTURE.........17

4.4. REASONABLY ATTRIBUTABLE VISIBILITY IMPAIRMENT...................................................18

5. MONITORING STRATEGY .........................................................................................................................19

5.1. USE OF IMPROVE MONITORING ...................................................................................................19

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

6. ASSESSMENT OF BASELINE, NATURAL AND CURRENT CONDITIONS .......................................21

7. CAUSES OF VISIBILITY IMPAIRMENT AT NEARBY CLASS I AREAS ...........................................22

7.1. MONITORING RESULTS ...................................................................................................................23

7.2. HAZE POLLUTANT EMISSIONS – SOURCES AND TRENDS ....................................................24

7.2.1. Sulfur Dioxide (SO2) ............................................................................................................................25

7.2.2. Volatile Organic Compounds (VOC)...................................................................................................27

7.2.3. Oxides of Nitrogen (NOx).....................................................................................................................29

7.2.4. Primary Particulate Matter (PM10 and PM2.5) ....................................................................................30

7.2.5. Ammonia Emissions.............................................................................................................................34

7.3. DATA ANALYSIS AND MODELING ................................................................................................35

7.3.1. Grid-Based Source Modeling (REMSAD tagged runs)........................................................................37

7.3.2. Emissions Divided by Distance (Q/d) ..................................................................................................37

7.3.3. Air Parcel-Based Source Dispersion Modeling (CALPUFF)..............................................................38

7.3.4. Emissions Times Upwind Probability..................................................................................................39

7.4. COMPARISON OF TECHNIQUES ....................................................................................................40

8. CLASS 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-VU Class I Areas .....................................................................................................................42

8.1.2. VISTAS Class I Areas ..........................................................................................................................43

9. EMISSIONS INVENTORIES FOR MODELING........................................................................................44

9.1. BASELINE AND FUTURE YEAR INVENTORIES FOR MODELING.........................................44

9.2. DEVELOPMENT OF MANE-VU’S 2002 BASELINE INVENTORY .............................................45

9.3. DEVELOPMENT OF FUTURE YEAR EMISSION INVENTORIES FOR MANE-VU................46

9.3.1. Emissions Control Scenarios ...............................................................................................................47

9.4. BRIEF SUMMARY OF CALCULATION METHODS.....................................................................48

9.4.1. Stationary Point Sources .....................................................................................................................49

9.4.2. Stationary Area Sources ......................................................................................................................50
9.4.3. Onroad Mobile Sources.......................................................................................................................50

9.4.4. Nonroad Mobile Sources .....................................................................................................................50

9.4.5. Biogenic Emission Sources..................................................................................................................51

9.5. SUMMARY OF EMISSIONS ...............................................................................................................51

9.5.1. Emissions from Sources in the District of Columbia ...........................................................................51

9.5.2. Emissions from the District Compared to MANE-VU Emissions ........................................................52

10. REASONABLE PROGRESS GOALS ......................................................................................................55

10.1. REQUIREMENT ...................................................................................................................................55

10.2. RELATIONSHIP TO THE LONG-TERM STRATEGY...................................................................56

10.3. EFFECT OF REMAND OF CLEAN AIR INTERSTATE RULE.....................................................57

11. BEST AVAILABLE RETROFIT TECHNOLOGY ................................................................................58

11.1. BART ELIGIBILITY ............................................................................................................................58

11.2. SOURCES SUBJECT TO BART .........................................................................................................59

11.2.1. Cap-Outs and Shutdowns................................................................................................................59

11.2.2. Small Source Exemption .................................................................................................................59

11.2.3. CAIR................................................................................................................................................60

11.3. BART FOR THE DISTRICT................................................................................................................61

11.3.1. Description of BART-Eligible Sources in the District.....................................................................61

11.3.2. Is BRGS Subject to BART?..............................................................................................................61

11.3.3. BART for BRGS...............................................................................................................................62

11.4. ADDITIONAL EMISSIONS REDUCTIONS......................................................................................62

12. THE DISTRICT’S LONG-TERM STRATEGY......................................................................................64

12.1. REQUIREMENT FOR LONG-TERM STRATEGY .........................................................................64

12.2. DOCUMENTATION OF TECHNICAL BASIS FOR THE DISTRICT’S EMISSION 

REDUCTION OBLIGATIONS...........................................................................................................................64

12.3. OVERVIEW OF THE LONG-TERM STRATEGY DEVELOPMENT PROCESS .......................65

12.4. KEY ANTHROPOGENIC SOURCES OF VISIBILITY IMPAIRMENT .......................................66

12.4.1. Sources of SO2 Emissions................................................................................................................66

12.4.2. Sources of Other Pollutants ............................................................................................................67

12.5. EMISSION REDUCTIONS DUE TO ONGOING AIR POLLUTION PROGRAMS.....................68

12.5.1. EGU Emissions Controls Expected by 2018 Due to Ongoing Air Pollution...................................68

 Control Programs ..........................................................................................................................68

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

 Programs........................................................................................................................................70

12.5.3. Area Sources Controls Expected by 2018 Due to Ongoing Air Pollution Control Programs ........71

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

 Programs........................................................................................................................................72

12.5.5. Mobile Source Controls Expected by 2018 due to Ongoing Air Pollution Control Programs .......72

12.6. ADDITIONAL REASONABLE STRATEGIES CONSIDERED FOR MANE-VU’S LONGTERM STRATEGY .............................................................................................................................................73

12.6.1. Identification of Key Source Categories .........................................................................................73

12.6.2. Analysis of the Four Statutory Factors ...........................................................................................74

12.7. ADDITIONAL CONTROL MEASURES CONSIDERED ................................................................76

12.7.1. Source Retirement and Replacement Schedules..............................................................................76

12.7.2. Measures to Mitigate the Impacts of Construction Activities .........................................................76

12.7.3. Agricultural and Forestry Smoke Management ..............................................................................77

12.8. ESTIMATED IMPACTS OF THE DISTRICT’S LONG-TERM STRATEGY ON VISIBILITY 77

12.9. SHARE OF EMISSION REDUCTIONS .............................................................................................77

12.10. CHANGES TO EMISSIONS BY 2018.................................................................................................78

12.11. ENFORCEABILITY OF EMISSION LIMITATIONS AND CONTROL MEASURES ................79

13. NEXT STEPS...............................................................................................................................................81
LIST OF TABLES

TABLE 3.1. MANE-VU MEMBERS ................................................................................................................................9

TABLE 3.2. STATES INCLUDED IN THE MANE-VU CONSULTATION AREA ..................................................................14

TABLE 7.1. SUMMARY OF TECHNICAL APPROACHES FOR ATTRIBUTING STATE ..........................................................22

TABLE 8.1. PERCENT ANNUAL AVERAGE SULFATE CONTRIBUTION FROM DISTRICT SOURCES IN 2002......................42

TABLE 9.1. DC 2002 EMISSIONS INVENTORY SUMMARY ............................................................................................51

TABLE 9.2. DC 2018 OTB/W EMISSIONS INVENTORY SUMMARY...............................................................................52

TABLE 9.3. REGIONAL SUMMARY OF THE 2002 MANE-VU EMISSIONS INVENTORY..................................................52

TABLE 9.4. PERCENT OF 2002 MANE-VU EMISSIONS FROM SOURCES IN THE DISTRICT ............................................53

TABLE 9.5. REGIONAL SUMMARY OF THE MANE-VU 2018 OTB/W EMISSIONS INVENTORY ....................................53

TABLE 9.6. PERCENT OF MANE-VU 2018 OTB/W EMISSIONS FROM SOURCES IN THE DISTRICT...............................53

TABLE 10.1. DECIVIEW ESTIMATES.............................................................................................................................56

TABLE 10.2 COMPARISON OF 2018 RPG AND OTB/W DECIVIEW IMPACTS................................................56 

TABLE 11.1 BART-ELIGIBLE SOURCES IN THE DISTRICT OF COLUMBIA................................................... .61 

TABLE 11.2 ESTIMATED EGU EMISSIONS REDUCTIONS.......................................................................63 

TABLE 12.1. CORRECTED EMISSIONS FROM THE DISTRICT OF COLUMBIA ...................................................................72

TABLE 12.2. EMISSIONS FROM POINT, AREA, AND MOBILE SOURCES IN MANE-VU (SO2 TPY) .................................79

TABLE 12.3. EMISSIONS FROM POINT, AREA, AND MOBILE SOURCES IN THE DISTRICT (SO2 TPY) ..............................79
LIST OF FIGURES

FIGURE 1.1. CLASS I AREAS WITHIN 300 KM OF THE DISTRICT OF COLUMBIA ..............................................................3

FIGURE 1.2. CLASS I AREAS IN THE MANE-VU AND VISTAS REGIONS, .....................................................................6

FIGURE 7.1. BASELINE CONTRIBUTIONS TO PM2.5 EXTINCTION AT SEVEN CLASS 1 AREAS ........................................24

FIGURE 7.2. STATE LEVEL SULFUR DIOXIDE EMISSIONS .............................................................................................26

FIGURE 7.3. 2002 ANNUAL ANTHROPOGENIC SO2 EMISSIONS BY STATE AND PERCENT BY SOURCE TYPE ................27

FIGURE 7.4. 2002 ANNUAL ANTHROPOGENIC VOC EMISSIONS BY STATE AND PERCENT BY SOURCE TYPE ..............28

FIGURE 7.5. STATE LEVEL NITROGEN OXIDES EMISSIONS ..........................................................................................29

FIGURE 7.6. 2002 ANNUAL ANTHROPOGENIC NOX EMISSIONS BY STATE AND PERCENT BY SOURCE TYPE ...............30

FIGURE 7.7. STATE LEVEL PRIMARY PM10 EMISSIONS ................................................................................................31

FIGURE 7.8. STATE LEVEL PRIMARY PM2.5 EMISSIONS................................................................................................32

FIGURE 7.9. 2002 ANNUAL ANTHROPOGENIC PRIMARY PM10 EMISSIONS...................................................................33

FIGURE 7.10. 2002 ANNUAL ANTHROPOGENIC PRIMARY PM2.5 EMISSIONS ................................................................33

FIGURE 7.11. STATE LEVEL AMMONIA EMISSIONS......................................................................................................34

FIGURE 7.12. 2002 ANNUAL ANTHROPOGENIC NH3 EMISSIONS..................................................................................35

FIGURE 7.13. RANKED STATE PERCENT SULFATE CONTRIBUTIONS TO MID-ATLANTIC CLASS I RECEPTORS BASED ON 

EMISSIONS DIVIDED BY DISTANCE (Q/D) RESULTS...............................................................................................38

FIGURE 7.14. RANKED STATE PERCENT SULFATE CONTRIBUTIONS TO MID-ATLANTIC CLASS I RECEPTORS BASED ON 

OBSERVATION-BASED (VT) CALPUFF RESULTS................................................................................................39

FIGURE 7.15 (A AND B). COMPARISON OF NORMALIZED (PERCENT CONTRIBUTION) RESULTS USING DIFFERENT 

TECHNIQUES FOR RANKING STATE CONTRIBUTIONS TO SULFATE LEVELS AT THE SHENANDOAH AND BRIGANTINE 

CLASS I AREAS ...................................................................................................................................................40

FIGURE 12.1. 167 EGU STACKS AFFECTING MANE-VU CLASS I AREA(S) ................................................................67
LIST OF APPENDICES

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-Eligible Sources: Survey of Options for Conducting 

BART Determinations 

APPENDIX R Assessment of Control 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 Measures to Mitigate the Visibility Impacts of 

Construction Activities in the MANE-VU Region 

APPENDIX U DC Municipal Regulations 
APPENDIX V Regional Long-Term Strategy Letter to Improve the Visibility at Brigantine Wilderness 

(letter from New Jersey; letter from New Hampshire; Resolution of the Commissioners of 

States with Mandatory Class I Federal Areas Within the MANE-VU)) 
ACRONYMS AND ABBREVIATIONS

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 Economic 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 5th 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 

NH3 Ammonia (NH3) 

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 Region 
OTW On the way 

PAG Policy Advisory Group 

PES Pepco Energy Services, Inc. 

PJM PJM Interconnection, LLC 

PM10 Particles with an aerodynamic diameter less than or equal to 10 μm 

PM2.5 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 

SO2 Sulfur Dioxide (SO2) 

SOA Secondary Organic Aerosols 

TPY Tons Per Year 

TSC Technical Support 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 Partnership 
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District of Columbia Regional Haze SIP 

1. Background 

1.1. General Description of Regional Haze 

Good Visibility – viewing the scenery through clean, fresh air – is a valued attribute of lands that 

are Federally protected and managed for the enjoyment of future generations and to preserve 

natural conditions. This plan addresses visibility impairment 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, including forest fires, 

dust, storms, and sea spray. The optical effects of these pollutants and natural 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 microns in diameter) is the predominant contributor at most times 

and places. 

Some haze-causing particles are emitted directly to the atmosphere by primary sources of 

particle emission such as electric power plants, factories, automobiles, 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 multiple primary and secondary sources can mix together over broad 

geographic areas and can be transported 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 amending 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. 
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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 kilometers (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 Wilderness area in New Jersey, the Dolly Sods and Otter 

Creek Wilderness Areas in West Virginia, and the James River Face Wilderness in Virginia. 

The Federal Land Management (FLM) agencies responsible for protecting these areas are the 

National Park Service and the U.S. Fish and Wildlife Service (both of the U.S. Department of 

Interior), and the U.S. Forest Service (U.S. Department of Agriculture). 
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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 research 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 states – even those without Class I Areas – to 

participate in haze reduction efforts. 

The following points summarize key requirements of the Regional Haze Rule: 

• States with Class I areas must establish “reasonable progress goals” for visibility 

improvement and monitor air quality at Class I areas to determine whether visibility is 

meeting these goals. 

• States with emissions sources impacting visibility in Class I areas must collaborate with 

the Class I state to formulate a long-term strategy 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 Available 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 piping 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 along 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 National 

Forest, 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 Appalachian 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 hiking and for its exceptionally diverse vegetation. 
October 2011 

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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 plans every five years to determine whether the goals previously 

set are still reasonable, whether reasonable measures have been implemented to meet 

those goals, and what measures will be implemented 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 against 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 sustaining it in part. For more information, see 

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

(“CEED v. EPA”). In this case, the court granted a petition challenging provisions 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 remand 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 Section 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, and 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 quality 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, entitled “Guidance for State Implementation Plan 

(SIP) Submissions to Under 110(a)(1) and (2) for the 2006 24-Hour fine Particle (PM2.5) 

National Ambient Air Quality Standards (NAAQS),’’ dated September 25, 2009. Through this 

guidance, EPA clarified that the District of Columbia's obligation pursuant to Clean Air Act 

§110(a)(2)(D)(i)(II) can be satisfied by an approved SIP addressing regional haze. The District 

of Columbia believes that this plan is sufficient for purposes of the District of Columbia meeting 

its obligations related to visibility pursuant to §110(a)(2) of the federal Clean Air Act, including 
October 2011 

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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 applicable CAA §110(a)(2) obligations, including, but not 

limited to, §§110(a)(2)(D)(i)(II) and 110(a)(2)(J), for the District of Columbia's 1997 ozone, 

1997 PM2.5, and 2006 PM2.5 National Ambient Air Quality Standards (NAAQS).

Figure 1.2. Class I Areas in the MANE-VU and VISTAS 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/maps/images/ClassIAreas.jpg) 
October 2011 

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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 Columbia 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 Plan also addresses requirements for Regional 

Planning and State/Tribe and Federal Land Manager coordination and consultation, 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 District proposes to complete these updates to coincide with the EPA 

requirements for periodic emission inventories. 

Title 40 CFR 51.308(f) requires the District to submit periodic revisions to its Regional Haze SIP 

by July 31, 2018, and every ten years thereafter. The District acknowledges and will comply 

with this schedule. 

Title 40 CFR 51.308(g) requires the District to submit a report to EPA every five years that 

evaluates progress toward the reasonable progress goals for each mandatory Class I area located 

outside the State that may be affected by emissions from within the State. The District will use 

the five-year review to look at where the District is in terms of emissions projections within five 

years of submittal of this initial plan. 

Pursuant to 40 CFR 51.308(h), the District will submit a determination 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 appropriate or necessary: 

• If the District determines that the existing SIP requires no further substantive revision in 

order to achieve established goals for visibility improvement 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 the District, the District will revise its SIP 

to address the deficiencies within one year from the determination, allowing the FLMs 

and the public to review how the District plans to meet emissions projections. 

There are several sections of the 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 District, since the District 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, characterizing, and reporting regional haze visibility 

impairment within the District into the future is required under 40 CFR Section 

51.308(d)(4) of EPA’s Regional Haze Rule. 
October 2011 

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District of Columbia Regional Haze SIP 

There are monitors in Class I areas to track visibility trends. 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 determine baseline and natural conditions for any 

Class I areas. However, as described in Section 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 required to establish reasonable 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 haze in those Class I areas. Section 3 of this 

SIP describes the District’s consultation with Class I states 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 reasonable progress as a result of emissions from 

sources in other states which participated in the regional planning process, the state is 

required to provide notification to EPA and to those other states. 

If a Class I state determines that its implementation plan is or may be inadequate to 

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

as Canada, the state is required to provide notification and available information to EPA. 

The District will collaborate with the other states through the regional planning process 

for the purpose of developing additional strategies to address any such deficiencies in the 

District’s SIP. 
October 2011 

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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 Regional Haze Rule, on development of reasonable 

progress goals and development of a long-term strategy, 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 participate 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 coordination on Regional Haze SIPs. The District of 

Columbia is a member of the Mid-Atlantic and 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 results and other technical support documents 

prepared for MANE-VU members. By coordinating with MANE-VU and other RPOs, the 

District of Columbia has worked to ensure that its long-term strategy (see Section 12) and BART 

(see Section 11) provide sufficient reductions to mitigate impacts of sources from the District of 

Columbia on nearby Class I areas. 

Information and a description of consultation with other states are available later in this section, 

and information and a description of consultation 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, interpreting 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* 
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District of Columbia Regional Haze SIP 

a process to ensure that important regional haze-related projects were completed in a timely 

fashion, and members were kept informed of all MANE-VU tasks and duties. There were three 

standing working groups of the TSC: the Emissions Inventory, Modeling, and Monitoring/Data 

Analysis Workgroups. 

The Communications Committee oversaw the development of MANE-VU’s newsletter and 

outreach tools both for stakeholders and the public regarding regional issues among MANEVU’s membership. The Communications 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 facilitate that goal. Ultimately, 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, and tribes were represented on the PAG. It met 

on an as needed basis. 

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

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

Northeast States for Coordinated Air Use Management (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 cooperatively 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 agreed on an approach to setting reasonable 

progress goals and considering measures to ensure long-term progress in improving 

visibility. 

• Capacity Building: To educate its staff and members, MANE-VU offered technical 

presentations on conference calls and organized workshops with nationally recognized 

experts. Presentations on data analysis, BART work, inventory topics, modeling, control 

measures, and the like were an effective education and coordination tool. 

• Routine Operations: MANE-VU staff at OTC, MARAMA, and NESCAUM established 

a coordinated approach to budget, grant deliverables and due-dates, workgroup meetings, 

inter-RPO feedback, and the like. 

The District of Columbia participated in reviewing work conducted by MANE-VU, and has 

utilized MANE-VU work products to prepare this SIP. 
October 2011 

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District of Columbia Regional Haze SIP 

3.2. Consultation Framework 

The Regional Haze Rule at 40 CFR Section 51.308(d)(3)(i) requires the District 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 contribute to visibility impairment in Class I areas 

within the State/Tribe. 

The District consulted with other states/tribes by participation 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 participants are committed to continuing dialogue and 

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

of the parties. 

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

inclusion in the SIP submittal to EPA. 

3. States alone have the authority to undertake specific measures under their SIP. This interRPO framework is designed solely to facilitate needed communication, coordination and 

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

participating agencies. 

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

(“formal” consultations): (i) development of the reasonable progress goal for a Class I 

area, and (ii) development of long-term strategies. While it is anticipated that the formal 

consultation will cover the technical components that make up each of these policy 

decision areas, there may be a need for the RPOs, in coordination with their State and 

Tribal members, to have informal consultations on these technical considerations. 

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

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

respective RPOs, when feasible. 

6. Technical analyses will be transparent, when possible, and will reflect the most up-todate information and best scientific methods for the decision needed within the resources 

available. 

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

goals. The RPOs will make reasonable efforts to facilitate the development of a 

consensus between the State with a Class I area and other States affecting that area. In 

instances where the State with the Class I area cannot agree with such other States that 

the goal provides for reasonable progress, actions taken to resolve the disagreement must 

be included in the State’s regional haze implementation plan (or plan revisions) submitted 

to the EPA Administrator as required under 40 CFR Section 51.308(d)(1)(iv). 

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

impairment in a Class I area, must provide the Federal Land Manager (“FLM”) agency 

for that Class I area with an opportunity for consultation, in person, on their regional haze 
October 2011 

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District of Columbia Regional Haze SIP 

implementation plans. The States/Tribes will pursue the development of a memorandum 

of understanding to expedite the submission and consideration of the FLMs’ comments 

on the reasonable progress goals and related implementation plans. As required under 40 

CFR Section 51.308(i)(3), the plan or plan revision must include a description of how the 

State addressed any FLM comments. 

9. States/Tribes will consult with the affected FLMs to protect the air resources of the 

State/Tribe and Class I areas in accordance with the FLM coordination requirements 

specified in 40 CFR Section 51.308(i) and other consultation procedures developed by 

consensus. 

10. The consultation process is designed to share information, define and document issues, 

develop a range of options, solicit feedback on options, develop consensus advice if 

possible, and facilitate informed decisions by the Class I States. 

11. The collaborators, including States, Tribes and affected FLMs, will promptly respond to 

other RPOs’/States’/Tribes’ requests for comments. 

The document also describes a process primarily applicable to formal consultation with states in 

other RPOs concerning Regional Haze SIP elements. Although other RPOs, such as the 

Visibility Improvement State and Tribal Association of the Southeast (VISTAS), did not 

formally adopt the same process, in general, the process was followed and provided significant 

opportunities for consultation. 

3.3. Consultation with Other States 

Because of long-range transport of fine particulate matter, emissions from within the District 

have the potential to affect visibility in Class I areas hundreds of kilometers away. However, 

because the emissions from sources in the District are a relatively small part of regional 

emissions, the impacts of these emissions are also relatively small. Section 8 of this SIP reviews 

the District’s contribution to visibility impairment in Class I areas. 

3.3.1. States Notifying the District of Contribution to Haze 

On January 18, 2007, New Jersey requested the District’s participation as a member of MANEVU in the development of a regional long-term strategy to improve visibility at one Class I area, 

the Brigantine Wilderness (Appendix V). 

In a letter dated April 4, 2007, New Hampshire asked the District to join in the consultative 

process to develop a collective solution to regional haze in New Hampshire (Appendix V). New 

Hampshire has two Class I areas: Great Gulf Wilderness and the Presidential Range-Dry River 

Wilderness. 

No other states formally contacted the District concerning regional haze. 

As Figure 1.1 indicates, the District 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 VISTAS states. No states from the VISTAS 

region contacted the District to ask for emissions reductions to reduce haze in Class I areas. 
October 2011 

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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 participating 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 Columbia, have impacts on these Class I areas that are below the 0.1 

μg/m3 or two percent threshold – that is, their impacts on any Class I areas in the consultation 

area are insignificant according to this measure. These states and the District were included in 

the consultation area because they are MANE-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 

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District of Columbia Regional Haze SIP 

Table 3.2. States Included in the 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 

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District of Columbia Regional Haze SIP 

3.3.3. Summary of MANE-VU Consultation 

MANE-VU held numerous conference calls and meetings which provided opportunities for the 

District to consult with other states concerning reasonable progress goals, a coordinated regional 

emissions management strategy, and other elements 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 reviewed the requirements for regional haze 

plans, preliminary modeling results (including estimates of the uniform rate of 

progress and potential reasonable progress goals), the work being done to prepare the 

MANE-VU report on reasonable progress factors, and control strategy options under 

review. 

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

o At this meeting, the MANE-VU Class I states adopted a statement of principles 

(included in Appendix V), and all MANE-VU members discussed draft statements 

concerning reasonable controls within and outside of MANE-VU. Federal Land 

Managers also attended the meeting, which was open to stakeholders. 

• MANE-VU Conference Call, June 20, 2007 

o On this call, the MANE-VU states concluded discussions of statements concerning 

reasonable controls within and outside MANE-VU and agreed on the statements 

called the MANE-VU “Ask,” including a statement concerning controls within 

MANE-VU, a statement concerning controls outside MANE-VU, and a statement 

requesting a course of action by the U.S. EPA. Federal Land Managers also 

participated in the call. Upon approval, all statements as well as the statement of 

principles adopted on June 7 were posted and publicly available on the MANE-VU 

web site. 

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

o On this call, the MANE-VU “Ask” was presented to states in other RPOs, RPO staff 

and Federal Land Managers. An opportunity was provided to request further 

information. This call was intended to provide information to facilitate informed 

discussion at follow-up meetings. 

• MANE-VU Consultation Meeting with MRPO, August 6, 2007 

o This meeting was held at LADCO offices in Chicago, Illinois, and was attended by 

representatives of both MANE-VU and Midwest RPO (MRPO) states as well as staff. 

Modeling results were reviewed as well as draft reasonable progress goals. The 

meeting provided an opportunity to formally present the MANE-VU “Ask” to MRPO 

states and to consult with them regarding the reasonableness of the requested 

controls. Federal Land Manager agencies also attended the meeting. 

• MANE-VU Consultation Meeting 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 present the MANE-VU “Ask” to VISTAS states 

and to consult with them regarding the reasonableness of the requested controls. 

Federal Land Manager agencies also attended the meeting. 
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District of Columbia Regional Haze SIP 

• MANE-VU – Midwest RPO Consultation 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 was 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’ Consultation 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 staff as to how to interpret the “Ask” for 

purposes of estimating visibility impacts of the requested controls. 

• MANE-VU Air Directors’ Conference 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 

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District of Columbia Regional Haze SIP 

4. Federal Land Manager Coordination 

Coordination between States/Tribes and the Federal Land Managers (FLMs) is required by 40 

CFR Section 51.308(i). 

4.1. Preliminary Consultation with FLMs 

On July 31, 2008, the District wrote to representatives 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 meetings described in Section 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 review and comment. A draft of the BART 

chapter was provided to the FLMs on May 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 District’s only BART sources by December 17, 2012, 

which will result in additional SO2 emission reductions beyond 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 the visibility protection program, including 

development of future plan revisions. In particular, the District will consult with the FLMs on 

the following implementation items: 

1. Implementation of emissions strategies identified in the SIP as contributing to achieving 

improvement in the worst-day visibility; 

2. Summary of major new source permits issued, since projected emissions growth under 

permitting programs such as New Source Review (NSR) and Prevention of Significant 

Deterioration (PSD) may impact regional haze and reasonable progress goals; 
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District of Columbia Regional Haze SIP 

3. Status of District actions to meet commitments for completing any future assessments or 

rulemakings on sources identified as likely contributors to visibility impairment, but not 

directly addressed in the most recent SIP revision; 

4. Any changes to the monitoring strategy or monitoring stations status that may affect 

tracking of reasonable progress; 

5. Work underway for preparing the 5-year review or 10-year revision; 

6. Items for FLMs to consider or provide support 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 (discussion, 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 consider 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 with 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 general plan requirement in cases where the affected FLM has 

notified the State that Reasonably Attributable Visibility Impairment (RAVI) exists in a Class I 

Area in the state. There are no RAVI sources in MANE-VU. 
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District of Columbia Regional Haze SIP 

5. Monitoring Strategy 

A nationwide visibility monitoring network was established under the Interagency Monitoring of 

Protected Visual Environments (IMPROVE) program 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 Committee provides oversight for the IMPROVE 

network and establishes protocols for monitoring techniques and data analysis. 

5.1. Use of IMPROVE Monitoring 

As mentioned in Section 2, the District of Columbia does not contain any Class I Areas; 

therefore, no monitoring strategy for measuring, 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) requires that for a State with no mandatory Class I areas, the 

implementation plan must provide for procedures by which monitoring data and other 

information are used in determining the contribution 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 published in the Federal Register on July 1, 1999, 

explained that EPA believed it was important for States with no Class I areas to “understand and 

describe the implications of monitoring data.” On page 35744 (FR Vol. 64, No. 126), EPA 

stated: 

First, it is important for those states to review monitoring information, 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 concentrations 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 demonstrate reasonable progress toward achieving natural visibility 

conditions. States with Class I areas have established baseline conditions in their 

implementation plans and set goals for reasonable progress in improving visibility by 2018. (See 

Appendix J for more information.) States with Class I areas must establish a monitoring 

program and report data to EPA that is representative of visibility 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 monitoring goal, and the District agrees that 
October 2011 

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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), the 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 reasonable 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 the 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). 
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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 address baseline, natural and 

current conditions in this SIP, although the basic principles are 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 visibility 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. The uniform rate of progress is also called a 

“glide path.” Reasonable progress goals are established 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 average 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 deciviews (dv). A deciview is a measure of visibility impairment 

derived from calculated light extinction. Light extinction is calculated using the mass of various 

components of airborne particles (nitrates, sulfates, elemental carbon, organic carbon, and crustal 

material). 

The reasonable progress goals for 2018 for Class I areas near the District are further discussed in 

Chapter 10. 
October 2011 

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District of Columbia Regional Haze SIP 

7. Causes of Visibility Impairment at Nearby Class I Areas 

The District collaborated with other MANE-VU members to identify emissions source categories 

and states that contribute to fine particulate pollution, and thus visibility 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 Eulerian (grid-based) source models, Lagrangian 

(air parcel-based) source dispersion models, as well as a variety of data analysis techniques that 

include source apportionment models, back trajectory calculations, and the use of monitoring and 

inventory data. A range of methodological approaches characterize these tools, listed in Table 

7.1. 

Table 7.1. Summary of Technical Approaches for Attributing State 

Contributions to Observed Sulfate 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 consistency across these analytical methods using techniques based on 

disparate chemical, meteorological and physical principles. Taken together, these findings create 

a strong weight-of-evidence case for the preliminary identification of the most significant 

contributors to visibility impairment in the MANE-VU Class I areas. 

The Contribution Assessment concludes that the overall coherence 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 region is sufficient to provide a useful and 

appropriate basis for design of future control programs and for consultations between different 

regional organizations charged with planning for compliance with the Regional Haze Rule. 

It is important to emphasize that these methods have been reviewed, updated, and refined to 

ensure that high quality results are available 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 substantial visibility impairment is common across the MANE-VU region, it 

is most severe in the southern and western portions of MANE-VU that are closest to large power 

plant sources of sulfur dioxide (SO2) emissions located in the Ohio River and Tennessee Valleys. 

Summertime visibility is driven almost exclusively 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 (inversions) 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 SO2 control efforts in the 

eastern United States aimed at reducing summertime fine particulate matter (PM2.5) 

concentrations. 

Available monitoring data provide strong evidence that regional SO2 reductions have yielded, 

and will continue to yield, reductions in ambient 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 formation of regional haze in the Northeast and MidAtlantic region, MANE-VU concluded that it is likely that SO2 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 PM2.5 Extinction at Seven Class 1 Areas 

on the 20 Percent Worst Visibility Days 

7.2. Haze Pollutant Emissions – Sources and Trends 

In conjunction with other efforts to assess the contribution of various source categories and 

source regions to regional haze in Class I areas, MANE-VU reviewed trends in emissions 

inventories. This section describes 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 (SO2, VOC, NOx, PM and NH3) throughout the MANE-VU region. 

The emissions data and graphics presented in this section rely on several data sources. These 

include EPA’s 1996 National Emissions Trends database (NET), EPA’s 1999 National 

Emissions Inventory (NEI), and Version 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, Monitoring 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 annual 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 as 
October 2011 

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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 (SO2) 

SO2 is the primary precursor pollutant for sulfate particles which commonly account for more 

than 50 percent of particle-related light extinction at northeastern Class I areas on the clearest 

days, and for as much as or more than 80 percent on the haziest days. Hence, SO2 emissions are 

an obvious target of opportunity for reducing regional haze in the eastern United States. 

Combustion of coal and, to a lesser extent, use of certain petroleum products accounts for most 

anthropogenic SO2 emissions. In fact, in 1998, a single source category, coal-burning power 

plants, was responsible for two-thirds of total SO2 emissions nationwide (NESCAUM, 2001a). 

Figure 7.2 shows SO2 emissions trends in the MANE-VU states extracted from the NEI for the 

years 1996 and 1999, and the 2002 MANE-VU inventory (EPA 2005 and Pechan, 2006). Except 

Maryland, the states show declines in 2002 annual SO2 emissions when compared with 1996 

emissions. Some states show an increase in 1999 followed by a decline in 2002, and others show 

consistent declines throughout the entire period. The upward trend in emissions in 1999 probably 

reflects electricity demand growth during the late 1990s combined with the availability of 

banked emissions allowances from initial over-compliance with control requirements in Phase 1 

of the EPA Acid Rain Program. This led to relatively low market prices for allowances later in 

the decade, which encouraged utilities to purchase allowances rather than implement new 

controls as electricity output expanded. The observed decline in the 2002 SO2 emissions 

inventory reflects implementation of the second phase of the EPA Acid Rain Program, which in 

2000 further reduced allowable emissions and extended 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 Sulfur Dioxide Emissions 

0.0

0.2

0.4

0.6

0.8

1.0

1.2

1.4

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

million 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 except Rhode Island and Vermont. 

Figure 7.3 shows the percent contribution from four source categories to overall annual 2002 

SO2 emissions in the MANE-VU states. The chart shows that in most states point sources 

dominate SO2 emissions; however, in the District, the largest 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 particularly important in small states 

such as the District of Columbia. By contrast, onroad and nonroad mobile sources make a 

relatively small contribution to overall SO2 emissions in the region (NESCAUM, 2001a). 
October 2011 

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District of Columbia Regional Haze SIP 

Figure 7.3. 2002 Annual Anthropogenic SO2 Emissions by 

State and Percent by Source Type 

0%

25%

50%

75%

100%

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

0.0

0.2

0.4

0.6

0.8

1.0

1.2

million t/y

AREA NONROAD ONROAD POINT Emission

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

In sum, total SO2 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 PM2.5. 

After sulfate, organic carbon generally accounts for the second largest share of fine particle mass 

and particle-related light extinction at northeastern Class I sites. The term “organic carbon” 

encompasses a large number and variety of chemical compounds that may 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 sources as well as biogenic hydrocarbons emitted by 

vegetation. Recent efforts to reduce manmade organic 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 states that, “we need further work to characterize the 

organic carbon contribution to regional haze in the Northeast and Mid-Atlantic states and to 

develop emissions inventories that will be of greater value for visibility planning purposes.” 
October 2011 

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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 large number and variety of 

organic carbon species. Each of these species has its individual and widely variable transport 

characteristics and complex atmospheric chemical reaction. Thus, the organic carbon 

contribution to visibility impairment at most Class I sites in the East is likely to include both 

biogenic and manmade pollution. The manmade component 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 total and are dominated by onroad mobile and area 

sources. 

Figure 7.4. 2002 Annual Anthropogenic VOC Emissions by State 

and Percent by Source Type 

0%

25%

50%

75%

100%

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

million 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 well 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, architectural coatings, and dry cleaners. Point 

sources that emit VOCs include industrial facilities and petroleum refineries. 
October 2011 

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District of Columbia Regional Haze SIP 

7.2.3. Oxides of Nitrogen (NOx) 

NOx emissions contribute to visibility impairment in the eastern U.S. by forming light-scattering 

nitrate particles. Nitrate generally accounts for a substantially smaller fraction of fine particle 

mass and related light extinction than sulfate and organic carbon at northeastern Class I sites. 

Notably, nitrate may play a more important role at urban sites and in the wintertime. In addition, 

NOx may have an indirect effect on summertime visibility by virtue of its role in the formation of 

ozone, which in turn promotes the formation of secondary organic aerosols (NESCAUM, 

2001a). 

Figure 7.5 shows NOx emissions in the MANE-VU region at the state level. Since 1980, 

nationwide emissions of NOx 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 the transportation sector, as power plant combustion sources implemented 

modest emissions reductions during that time period. Most states in the MANE-VU region 

experienced declining NOx emissions from 1996 through 2002, except Massachusetts, Maryland, 

New York, and Rhode Island, which show an increase in NOx emissions in 1999 before 

declining to levels below 1996 emissions in 2002. 

Figure 7.5. State Level Nitrogen Oxides Emissions 

0.0

0.5

1.0

1.5

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

million t/y

NEI 1996

NEI 1999 V3

MANE-VU 2002 V3

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

NOx emissions from the District are the smallest portion of total regional emissions. The chart 

above illustrates that relationship and shows that NOx emissions from the District decreased 

steadily from 1996 to 2002. 
October 2011 

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District of Columbia Regional Haze SIP 

Figure 7.6, below, shows that in the District, mobile sources are the most important source of 

NOx emissions. In general, power plants and mobile sources dominate state and national NOx

emissions inventories. Nationally, power plants account for more than one quarter of all NOx

emissions, amounting for over six million tons. 

Figure 7.6. 2002 Annual Anthropogenic NOx Emissions by State 

and Percent by Source Type 

0%

25%

50%

75%

100%

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

million 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 sources – a category that mainly includes highway vehicles – 

dominate the NOx inventories for more urbanized Mid-Atlantic and New England states. 

Emissions from nonroad mobile sources, primarily diesel-fired engines, also represent a 

substantial fraction of the MANE-VU 2002 NOx inventory. Area sources are less important 

with respect to NOx. 

7.2.4. Primary Particulate Matter (PM10 and PM2.5) 

Directly emitted or “primary” particles (as distinct from secondary particles that form in the 

atmosphere through chemical reactions involving precursor pollutants such as SO2 and NOx) can 

also contribute to regional haze. For regulatory purposes, a distinction is made between particles 

with an aerodynamic diameter less than or equal to 10 micrometers and smaller particles with an 

aerodynamic diameter less than or equal to 2.5 micrometers (i.e., primary PM10 and PM2.5, 

respectively). 

Figure 7.7 and Figure 7.8 show PM10 and PM2.5 emissions for the MANE-VU states for the years 

1996, 1999, and 2002. Except Maine, states show a steady decline in annual PM10 emissions 
October 2011 

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District of Columbia Regional Haze SIP 

over this time period. By contrast, emission trends for primary PM2.5 are more variable. 

Emissions of PM10 and PM2.5 from sources in the District represent 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 PM10 Emissions 

0.0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

million 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 PM2.5 Emissions 

0.0

0.1

0.2

0.3

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

million 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 emissions. This category includes 

fugitive dust emissions from construction activities, paved and unpaved roads, and agricultural 

tilling. Comparisons between estimated emission rates for fine particles and observed 

concentrations of crustal matter in the ambient air at downwind receptor sites suggest that 

physical or chemical processes remove a significant fraction of crustal material relatively 

quickly. As a result, it rarely entrains into layers of the atmosphere where it can transport to 

downwind receptors. Because of this discrepancy between estimated emissions and observed 

ambient concentrations, modelers typically reduce estimates of total PM2.5 emissions from all 

crustal sources by applying a factor of 0.15 to 0.25 to the total PM2.5 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 (2000 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) that is not targeted under the Haze 

Rule. 

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

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District of Columbia Regional Haze SIP 

Figure 7.9. 2002 Annual Anthropogenic Primary PM10 Emissions 

by State and Percent by Source Type 

0%

20%

40%

60%

80%

100%

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

million 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 PM2.5 Emissions 

by State and Percent by Source Type 

0%

25%

50%

75%

100%

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

million 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 

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District of Columbia Regional Haze SIP 

The relative contribution of point sources is larger in the primary PM2.5 inventory than in the 

primary PM10 inventory since the crustal component (which consists mainly of larger or “coarsemode” particles) contributes mostly to overall PM10 levels. At the same time, pollution control 

equipment commonly installed at large point sources 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 ammonia emissions to the atmosphere) is an important constituent 

of airborne particulate matter, including ammonium sulfate and ammonium nitrate. Ammonium 

typically accounts for 10 to 20 percent of total fine particle mass. 

Figure 7.11 shows that estimated ammonia emissions 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

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

million t/y

NEI 1996

NEI 1999 V3

MANE-VU 2002 V3

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

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District of Columbia Regional Haze SIP 

Area and onroad mobile sources dominate, as found in Figure 7.12. 

Figure 7.12. 2002 Annual Anthropogenic NH3 Emissions 

by State and Percent by Source Type 

0%

25%

50%

75%

100%

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

million 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 source of ammonia emissions in the District, and 

as with other pollutants, the emissions from the District are a small portion of the regional total. 

Except in the District, area source 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 emissions contribution is wastewater treatment 

systems. 

7.3. Data Analysis and Modeling 

Further quantitative data and modeling analyses 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 sulfate 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 

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District of Columbia Regional Haze SIP 

Regional Haze Modeling 

Air quality modeling to assess regional haze was performed cooperatively by several modeling centers 

within MANE-VU. These modeling efforts included emissions data processing, meteorological input 

analyses, and chemical transport modeling to perform 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-term emissions management strategy for 

MANE-VU Class I Areas. 

Several modeling tools were utilized for these analyses: 

• The Fifth-Generation Pennsylvania State University/National Center for Atmospheric 

Research (NCAR) Mesoscale Model (MM5), version 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 emissions inventories for input into the air quality 

models (SMOKE, 2007). 

• The Community Mesoscale Air Quality model (CMAQ), version 4.5.1, was used for the 

primary SIP modeling (Byun and Ching, 1999). 

• The Regional Model for Aerosols and Deposition (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 selected 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 are 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 from projections made by MANE-VU. However, 

because the District’s emissions are a very small fraction of total emissions in the MANE-VU region, 

these models are adequate to demonstrate the District’s relative contribution to visibility impairment. 
October 2011 

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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 table 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/m3) 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 contribution 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 another method used to identify and rank states’ 

contributions to sulfate at MANE-VU and nearby Class I areas using 2002 data. A simple 

technique for deducing the relative impact of emissions from specific point sources on a specific 

receptor site involves calculating the ratio of annual emissions (Q) to source-receptor distance 
October 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 of southern 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-scaled Q/d technique. Emissions of SO2 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/m3. 

Figure 7.13. Ranked state percent sulfate contributions 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 model, while the other center used National 

Weather Service rawinsonde-based meteorology. The models predicted annual average SO4 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 impacts from emissions in the District would be 

0.0005 μg/m3

 at Acadia, 0.0030 μg/m3 at Brigantine, 0.0006 μg/m3 at Lye Brook, and 0.0013 

μg/m3

 at Shenandoah. The NWS-based CALPUFF modeling predicted impacts from emissions 

in the District would be 0.0004 μg/m3 at Acadia, 0.0021 μg/m3 at Brigantine, 0.0005 μg/m3 at 

Lye Brook, and 0.0016 μg/m3

 at Shenandoah. 
October 2011 

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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 contribution 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 contributions 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 relative probabilities of each state contributing to pollution 

transport. Based on this technique, 2002 SO2 emissions from within the District contributed less 

than 0.01 percent to the transport of sulfur to Acadia, Lye Brook, Brigantine, or Shenandoah. 
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7.4. Comparison of Techniques 

Finally, results from the multiple analysis 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 Shenandoah National Park and Brigantine 

Wilderness, the two Class I areas receiving the largest impacts from sources in the District. 

Figure 7.15 (a and b). Comparison of normalized (percent contribution) results 

using different techniques for ranking state contributions to sulfate levels 

at the Shenandoah and Brigantine Class I Areas 

 Source: Figure 8-1 from the Contribution Assessment (Appendix K) 
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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 SO2. 

When results of using various analysis tools and techniques are normalized and compared, there 

is broad general agreement concerning the top contributing 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 contribution are unlikely to change due to further refinements of data 

inputs. Given that as much as 30 to 50 percent of the ambient sulfate found at northeastern Class 

I sites on hazy days appears to originate within neighboring RPOs, coordination and consultation 

is likely to be critical if MANE-VU is to achieve its visibility goals for 2018 and beyond. 
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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 requires the State to address regional haze in 

each mandatory Class I Federal area located within 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 contribute greater than 0.1 μg/m3 or two percent sulfate contribution to any 

nearby Class I areas, which is the threshold established by MANE-VU states with Class I areas 

for contributing to meet the reasonable progress goals for 2018. The highest impacts, at the 

Brigantine Wilderness Area and Shenandoah National Park, are well below these thresholds. 

Table 7.1 summarizes the District-specific results of the various data analyses described in 

Section 7. 

Table 8.1. Percent Annual Average Sulfate Contribution 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 goals 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/m3

 or 

greater than two percent sulfate contribution to the Brigantine Wilderness Area, will 

need to document in their Regional Haze Plan that they have obtained their share of 

emission reductions necessary to reach the first progress goal for the Brigantine 
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District of Columbia Regional Haze SIP 

Wilderness Area, unless any of the top 167 EGU stacks is located in the states. Rather, 

New Jersey would like to see these MANE-VU members, 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/m3

 or two percent sulfate to any nearby 

Class I area, and does not contain any of the top 167 EGU stacks (see Figure 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-VU’s consultation with 

VISTAS states, including Virginia and West Virginia. 

VISTAS conducted its own contribution assessment and did not request additional emission 

reductions from the District. 
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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 emissions 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 following pollutants whose emissions affect fine particle formation, 

and thus contribute to regional haze: sulfur dioxide (SO2), oxides of nitrogen (NOx), volatile 

organic compounds (VOC), ammonia (NH3), and particles with an aerodynamic diameter less 

than or equal to 10 and 2.5 μm (i.e., primary PM10 and PM2.5). 

The following source categories were included in the District’s emissions inventory: stationary 

point sources, stationary area sources, onroad mobile sources, and nonroad mobile sources. An 

inventory of biogenic emissions was also prepared for the region as part of the modeling process. 

These emissions categories are discussed further later in Section 9.4. 

Section 9.1 begins the overview of the development of baseline and future year emission 

inventories for modeling. 

9.1. Baseline and Future Year Inventories for Modeling 

The baseline inventory is intended to be used to assess progress in making 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 inventory year for regional haze. 

To meet the requirements of EPA’s Consolidated Emissions Reporting Rule (CERR; 40 CFR 

Part 51), a consolidated 2002 inventory of point, 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 for 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 improve this initial inventory, so the final 2002 

baseline inventory summarized in this document may differ slightly from the District’s original 

2002 baseline inventory submittal. 
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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 well as emissions reductions expected from the 

implementation of control measures. 

Both baseline and future year inventories were processed for use in regional modeling. This 

required MARAMA and its contractors to revise the format of the emissions inventory and 

provide it to NESCAUM and other modeling centers. The modeling centers then further 

processed the emissions data using 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 the modeling domain (outside MANE-VU) were 

obtained from other RPOs, such as VISTAS. EPA 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-VU 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 inventory began in April 2004. To meet the 

requirements of the CERR, a consolidated inventory of point, area, onroad, and nonroad sources 

was submitted by MANE-VU state and local agencies 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 through September 2005) involved 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 changes to the NONROAD2005 

 

2 EPA. Basic Format & Content Checker 3.0 (Formerly known 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 Assurance 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.
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District of Columbia Regional Haze SIP 

model by EPA. During the same time period, the New York Department of Environmental 

Conservation also developed the biogenics inventory for the entire MANE-VU region. 

Version 3.0 of the 2002 base year emission inventory was used in the regional modeling. 

A technical support document explaining the data sources, 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 point source data for CO, NH3, NOx, SO2, 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 source categories, except 

for categories for which the District elected to use data from MANE-VU-sponsored inventories 

(i.e., outdoor wood burning, paved roads, composting, and open burning). For the nonroad 

inventory, there was no District or NEI data available for aircraft. 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 modeling, 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 implementation 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 Emission 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 emissions growth due to projected increases in 

economic activity, as well as the emissions reductions 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 MANE-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 developed by a contractor hired by VISTAS on behalf 
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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 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 implemented because they were 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 NOx SIP Call Phase I (NOx Budget Trading 

Program); NOx SIP Call Phase II; NOx RACT in 1-Hour Ozone SIPs; NOx OTC 2001 

Model Rule for ICI Boilers; 2-, 4-, 7-, and 10-year MACT Standards; Combustion 

Turbine and RICE MACT; Industrial Boiler/ Process Heater MACT; Refinery 

Enforcement Initiative; and Source Shutdowns; and 

• Area source control factors included 2001 OTC 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 included in the inventory for the District. 

Area source control factors that applied for the 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 residential 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 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) 

In addition, Federally-enforceable controls were incorporated in the EGU and mobile source 

models. These include CAIR; the Nonroad Diesel Rule, the 2007 Highway Diesel Standards, 

Tier 2 Motor Vehicle Standards, and the Large Spark Ignition and Recreational Vehicle Rule. 
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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 NOx 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 PM10 and PM2.5 measure (commercial heating oil); SO2 measures (commercial 

heating oil and ICI boilers using #2 or #4 or #6 fuel oil and coal); and a VOC measure 

(adhesives and sealants application); and 

• Area source control factors included NOx measures (ICI boilers using natural gas, #2 and 

#4 and #6 fuel oil, and coal; and residential and commercial home heating oil); primary 

PM10 and PM2.5 measures (residential and commercial home heating oil); SO2 measures 

(residential and commercial home heating oil and ICI boilers using distillate oil); and 

VOC measures (adhesives and sealants; emulsified 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 refined and incorporated into a second BOTW, or 

“best and final” inventory, and include: 

• Top 167 EGU stacks strategy; 

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

• BART implementation strategy; and 

• Continued evaluation of additional control measures. 

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

The District does not contribute more than 0.1 μg/m3 to visibility impairment at any Class I area, 

so chose not to adopt measures in the BOTW or “best and final” scenarios, as further discussed 

in Section 10.2. 

9.4. Brief Summary of Calculation Methods 

This section provides a general description of the emission source classifications in the MANEVU emissions inventories and summarizes information 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 

• Biogenic 
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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, the 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 the roadway system. Nonroad mobile sources are 

equipment that can move but do not use the roadways, 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 large individual sources. Generally, point sources 

have permits to operate and their emissions are individually calculated based on source-specific 

factors on a regular schedule. The largest point sources are inventoried 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 total HAP. Emissions from smaller 

sources are also calculated individually but less frequently (every three years). Point sources are 

grouped into EGU sources and other industrial point sources, termed as non-EGU point sources. 

(Appendix E) 

• Electricity Generating Units (EGU) 

The base year inventory for large EGU sources 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 SO2 and NOx from these large sources. 

Emission profiles are used to estimate emissions of other pollutants (volatile organic compounds, 

carbon monoxide, ammonia, fine particles, soil) based on measured emissions of SO2 and NOx. 

(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 necessary 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 NOx and SO2 caps. However, the IPM® model 

results are not the best basis upon which to reliably predict plant closures. Plant closures are 

addressed in Section 12.7. 

• Point Sources other than EGUs 
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District of Columbia Regional Haze SIP 

The non-EGU point source category used annual emissions as reported by states and the District 

for the CERR for the base year 2002. These emissions were temporally allocated to month, day, 

and source category code (SCC) based 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 collective activity such as fuel usage, 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 factors for future emission reductions from the 

OTB/W control regulations. This data was supplemented with state-specific growth factors as 

appropriate. (Appendix E) 

9.4.3. Onroad Mobile Sources 

For onroad vehicles, MOBILE6.2 was used to estimate emissions. For future year emissions, the 

model considers that a certain number of the vehicle 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 inventory 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). All new mobile source measures and standards, as well as any 

benefits from implementation of individual state Inspection and Maintenance 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 NONROAD 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 the benefits received from lower 

sulfur gasoline in nonroad vehicles (see Section 12.5.4). 

Aircraft engine, railroad locomotives and commercial marine are not estimated using the 

NONROAD model. For these sources, growth and 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 these sources (applies to controls only). 
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District of Columbia Regional Haze SIP 

The District of Columbia used alternative growth 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 control programs) were used to apply controls to 

the DC locomotive emissions. The control factors were “additive” and were used on the base 

year emission without back-calculating uncontrolled emissions, since the 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 NOx. Biogenic 

emissions used for modeling remained constant from 2002 to 2018. Emissions from the District 

were about 0.1 percent of the regional 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 (baseline), E (future years for non-EGU point, area, and nonroad 

sources), F (future years for EGUs), and G (future 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 are 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 NOx PM2.5 PM10 NH3 SO2

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 D 
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Table 9.2. DC 2018 OTB/W Emissions Inventory Summary 

(Tons/Year) 

Type of Source VOC NOx PM2.5 PM10 NH3 SO2

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 SO2 and NOx between the 2002 inventory and 2018 OTB/W 

inventories are primarily due to CAIR. The declines in area source PM and VOC estimates are 

presumably due to residential wood burning controls. Between the same two inventories, the 

large differences in onroad and nonroad emissions are due to the implementation of Federal rules 

to reduce emissions from nonroad diesel and heavy duty diesel engines and motor vehicles, 

including low sulfur diesel rules, Tier 2 vehicle standards, fleet turnover as reflected in 

modeling, and similar efforts. 

9.5.2. Emissions from the District Compared 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 used 2002 as the baseline year. Note that 

EGU and non-EGU point sources are combined. 

Table 9.3. Regional Summary of the 2002 MANE-VU Emissions Inventory 

(Tons/Year) 

Type of Source VOC NOx PM2.5 PM10 NH3 SO2

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 D 
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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 NOx PM2.5 PM10 NH3 SO2

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 SO2 emissions in the MANE-VU region, and area 

source emissions make up the second largest category of SO2 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 District represent the largest percentage of the 

regional emissions, along with area source NOx emissions due to fuel combustion. 

Tables 9.5 and 9.6 display the 2018 MANE-VU emissions 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 MANE-VU 2018 OTB/W Emissions Inventory 

(Tons/Year) 

Type of Source VOC NOx PM2.5 PM10 NH3 SO2

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 Emissions from Sources in the District 

(Percent) 

Type of Source VOC NOx PM2.5 PM10 NH3 SO2

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 0.3 
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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 NOx. Table 9.6 indicates 

that the District would contribute 0.3 percent of the SO2 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 potential non-EGU controls than other states, 

although total SO2 emissions in the region would drop. 
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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 District 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 with 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 consult with those States 

which may reasonably be anticipated to cause or contribute to visibility impairment in 

the mandatory Class I Federal area. In any situation in which the State cannot agree with 

another such State or group of States that a goal provides for reasonable progress, the 

State must describe in its submittal the actions taken to resolve the disagreement. In 

reviewing the State's implementation plan submittal, the Administrator will take this 

information into account in determining whether the State's goal for visibility 

improvement provides for reasonable progress towards natural visibility conditions. 

As a member of MANE-VU, the District worked in cooperation with MANE-VU Class I states 

as those states established reasonable progress goals for their Class I areas. MANE-VU also 

sponsored meetings and conference calls to facilitate 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 path, on which goals for each implementation period 

leading up to 2064, the target date for returning to natural visibility, are established. MANE-VU 

states with Class I areas established the following deciview conditions4

, rate of progress targets, 

and natural visibility goals for the Class I areas near the District. 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. 
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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/documents/VISTAS_Summary_May232007.pdf

The District supports the reasonable progress goals set by the Class I states, including those set 

by Virginia and West Virginia through the VISTAS process. 

10.2. Relationship to the Long-Term Strategy 

According to the Regional Haze Rule [40 CFR Part 51 (July 1, 1999)], if reasonable measures 

can be identified to meet the reasonable progress 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 modeling run). Appendix I explains that the BOTW 

measures were developed as additional reasonable measures, in part due to presumptions about 

the effectiveness of CAIR. MANE-VU also acknowledges 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 H 
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District of Columbia Regional Haze SIP 

The control measures in the OTB/W scenario are reasonable for the District’s long-term strategy 

because the District’s contribution to regional haze is less than 0.1 μg/m3 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 emissions 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 projections that include the OTB/W scenario 

assume the implementation of EPA’s Clean Air Interstate Rule (CAIR). CAIR established a cap 

and trade program in the eastern United States intended to reduce emissions of SO2 and NOx

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 potentially affected by emissions from 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 uniform rate of progress because the District’s BART 

measures account for the CAIR replacement rule, as discussed in Section 11. 
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District of Columbia Regional Haze SIP 

11.Best Available Retrofit Technology 

The Best Available Retrofit Technology (BART) requirement of Section 169A of the Clean Air 

Act (42 U.S.C.§7491(b)(2)(A)) and implementing rules (40 CFR §51.308(e) and 40 CFR §51 

Appendix Y) are intended to reduce 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 containing emission limitations representing Best 

Available Retrofit Technology (BART) and schedules for compliance with BART for each 

BART-eligible source that may reasonably be anticipated to cause or contribute to any 

impairment of visibility in any mandatory Class I Federal area, unless it can demonstrate that an 

emissions trading program or other alternative will achieve greater reasonable progress toward 

natural visibility conditions. Visibility impairing pollutants are defined by the EPA as sulfur 

dioxide (SO2), oxides of nitrogen (NOx), and particles with an aerodynamic diameter less than or 

equal to 10 and 2.5 μm (i.e., PM10 and PM2.5, respectively). (40 CFR 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 contributes to visibility impairment in any 

Class I area (is “subject to BART”); 

3. Determine if additional controls or emission limits are necessary (BART determination). 

11.1. BART Eligibility 

BART eligibility is based on three conditions. First, it is limited to sources in one of 26 

stationary source categories under the Federal Clean Air Act: 

1. Fossil-fuel fired steam electric plants of more 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, and 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; 
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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 facilities 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 installed 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 requirements 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 Haze Rule preamble, once the State has compiled 

its list of BART-eligible sources, it needs to determine whether the source is “subject to BART”, 

and thus requires a BART determination. A source that may not reasonably be anticipated to 

cause or contribute to any visibility 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 statutory threshold of 250 tons per year 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 restricting 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 Haze Rule, “a State is not required to make a 

determination of BART for SO2 or NOx if a BART-eligible source emits less than 40 tons per 

year of such pollutant(s), or for PM10 if a BART-eligible source emits less than 15 tons per year 

of such pollutant.” A BART-eligible facility may 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”. 
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District of Columbia Regional Haze SIP 

11.2.3. CAIR 

Section 51.308(e)(2) of the Regional Haze Rule provides that, “a State may opt to implement an 

emissions trading program or other alternative measure 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 other alternative measure will achieve greater reasonable progress 

than would be achieved through the installation and operation of BART.” To make this 

demonstration, the State must submit an implementation plan containing the elements listed in 

Section (e)(2). 

According to Section IV of EPA’s Regional Haze Regulations and Guidelines for Best Available 

Retrofit Technology (BART) Determinations Preamble, CAIR would achieve greater reasonable 

progress that BART for SO2 and NOx, 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 SO2 and NOx at BART-eligible EGUs in CAIR 

affected States and therefore may be treated as a program in lieu of BART for those 

sources. In doing so, we discussed the Regional Haze Rule Section 308(e)(2) as 

precedent for the policy of allowing trading programs to substitute for BART. However, 

noting that the CAIR trading program affected only one category of BART-eligible 

sources (EGUs), rather than all BART-eligible categories as envisions for Statedeveloped BART-alternative programs under Section 308(e)(2), we proposed adding a 

308(e)(3) applicable only to CAIR. This section would provide that States that comply 

with the CAIR by subjecting EGUs to the EPA administered cap and trade program may 

consider BART satisfied for NOx and SOx from BART-eligible EGUs. In the CAIR SNPR 

and supporting documentation, we provided analyses demonstrating that CAIR would 

achieve greater emission reductions than BART, and would make greater reasonable 

progress according to the two-pronged visibility test previously proposed in the BART 

guidelines. 

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

CAIR rule. EPA requested a rehearing, and, after reviewing briefs on the issues, 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. 

On July 6, 2011, EPA finalized a CAIR replacement rule to respond to the Court’s concerns. 

The Cross-State Air Pollution Rule (CSAPR) requires 27 states to reduce power plant emissions 

through participation in four air quality-assured trading programs for SO2 and NOx. Emissions 

reductions will begin in 2012, with CAIR implemented through the 2011 compliance periods. 

EPA has not released guidance on whether emissions reductions under the CSAPR may be used 

in lieu of BART. 
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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 determine the “best system of continuous emission 

control technology available and associated emission reductions achievable.” 

11.3.1. Description of BART-Eligible Sources in the District 

Based on a review 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 Columbia, nearby counties in Maryland, and the mid-Atlantic electric 

grid. The plant typically operates only during high 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 categories eligible for BART (“fossil-fuel fired 

steam electric plants of more than 250 million BTUs per hour heat input”). Units 15 and 16 were 

installed in 1968 and 1972, respectively, 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 the District of Columbia 

Source and Unit Pollutant Location AFS Facility I.D 

Oil-fired steam 

generating Unit #15 PM, NOx, SO2

PPR Benning 

Road facility 11/001/00001 

Oil-fired steam 

generating Unit #16 PM, NOx, SO2

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 Pepco Holdings, Inc. (“PHI”), one of the largest 

energy delivery companies in the mid-Atlantic region. PHI companies supply energy to PJM 

Interconnection, LLC (“PJM”), the regional transmission 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 MANE-VU is eligible 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. 
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District of Columbia Regional Haze SIP 

11.3.3. BART for BRGS 

Initially, the District planned to use its participation in CAIR to exempt Units 15 and 16 from 

BART for SO2 and NOx. Units 15 and 16 units are the only electric 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 place5

. 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 agreed that if BRGS continued to operate after 

December 17, 2012, they would accept a de minimis cap on actual emissions of PM10 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 from BART based on their acceptance of the de minimis

cap. States are not required 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 learned that no District 

facilities are included in any CSAPR trading program. On July 18, 2011, the District and EPA 

met with Pepco representatives to re-evaluate options for SO2 and NOx 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, without alternative conditions in lieu of 

shutting down. This means that the plant is exempt from all BART requirements for SO2, NOx, 

and PM because the EGUs will no longer be BART-eligible. 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 includes 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 requirement 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 the intent of the rule: that BART is in place “as expeditiously as practicable 

but no later than 5 years after EPA approves 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. 
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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 the units will result in 83 tons of SO2 reductions and 103 

tons of NOx reductions, in addition to those anticipated 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. 
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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 Haze SIPs must contain measures to make reasonable 

progress toward the goal of achieving natural visibility. Title 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 enforceable emissions limitations, compliance schedules, 

and other measures necessary to achieve the reasonable progress goals established by the states 

where the Class I areas are located. Each state containing a Class I area must consult with 

other states affecting the Class I area to develop coordinated emission management strategies. 

Each state must demonstrate that it has included all measures necessary to obtain its share of 

the emission reductions needed to meet the reasonable 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 obligations 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 reductions necessary to meet 

reasonable progress goals in each Class I area affected by the State’s emissions. 

The District relied on technical analyses developed by MANE-VU to demonstrate that the 

District is not obligated to reduce emissions to meet the reasonable progress goals because it 

contributes less than 0.1 μg/m3

 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 adopted by other states and tribes, the anticipated 

emissions reductions of this long-term strategy will provide additional 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 Problems 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) 
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District of Columbia Regional Haze SIP 

• Contributions to Regional Haze in the Northeast and Mid-Atlantic United States

(Appendix K) 

• Assessment of Reasonable Progress for Regional 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 District 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 within the MANE-VU region by 2018 or earlier. As 

a participant in MANE-VU, the District supported 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 the Northeast and Mid-Atlantic United States

(Appendix K) 

• Assessment of Reasonable Progress for Regional 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 District adopted as its long-term strategy. 

Section 12.7 describes additional measures reviewed 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 haze 
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District of Columbia Regional Haze SIP 

control measure options. OTC provided the contractor with a “master list” of some 900 

potential control measures, based on experience and previous state implementation plan work. 

With the help of an OTC control measure workgroup, the contractor also identified available 

regional haze control measures for MANE-VU’s further consideration. MANE-VU then 

developed an interim list of control measures for regional haze, 

The next step was to further refine the interim list. The CAIR Plus Report6 documents the 

analysis of the cost of additional SO2 and NOx 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 analysis is provided in the 

NESCAUM document entitled, “Assessment of Control Technology Options for BART-Eligible 

Sources: Steam Electric Boilers, Industrial Boilers, Cement Plants and Paper and Pulp 

Facilities” (Appendix R). Highlights of these detailed analyses are provided below. 

During MANE-VU’s internal consultation meeting in March 2007, the District and other 

member states reviewed the interim list of control measures to make further refinements. 

These additional measures beyond the OTB/W scenario are not in the District’s long-term 

strategy for 2018. 

12.4. Key Anthropogenic Sources of Visibility Impairment 

Title 40 CFR Section 51.308(d)(3)(iv) requires the District to identify all anthropogenic 

sources of visibility impairment considered in developing its long-term strategy. 

12.4.1. Sources of SO2 Emissions 

For the reasons described in Section 7, the emphasis in developing this SIP was placed on 

sources of SO2. Emissions inventory analysis summarized shows that point sources dominated 

the regional 2002 inventory of SO2 emissions, except in the District, where area sources 

(primarily commercial and residential heating, and smaller industrial facilities) contributed 

most to SO2 emissions. Additional SO2 source categories analyzed include oil-fired 

installations at residential, commercial, institutional, or industrial facilities; industrial, 

commercial, and institutional (ICI) boilers; and cement and lime kilns. 

Roughly 70 percent of the 2.3 million tons of SO2 emission in the 2002 MANE-VU emissions 

inventory Version 3.0 were from EGUs, making them the largest SO2 source category in terms 

of visibility impairing emissions. MANE-VU found through modeling analysis documented in 

the Contribution Assessment (Appendix K) that emissions from specific EGUs were important 

contributors to visibility impairment in MANE-VU Class I areas in 2002. Figure 12.1 shows 

the locations of 167 EGU stacks that impair visibility 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_FDReport_053007v1.pdf. 
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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 outside 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 MANE-VU region primarily come from area and 

onroad mobile sources. Area sources include solvents, architectural coatings, and dry cleaners. 

NOx emissions are primarily from power plants and mobile sources. Mobile sources dominate 

the NOx inventories for more urbanized parts of the region, including the District. Primary 

particulate matter (PM10 and PM2.5) originates mostly from area sources such as construction 

activities, paved and unpaved roads, and agricultural tilling. Ammonia emissions in the 
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District of Columbia Regional Haze SIP 

District are primarily from highway vehicles, but throughout the region also come from 

agricultural sources and 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 discussed more in Section 12.7.3. 

12.5. Emission Reductions Due to Ongoing Air Pollution Programs 

Title 40 CFR 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 implemented because they were proposed but not yet 

final (OTB/W). These measures represent 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 from 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 (SO2) and nitrogen oxides (NOx) in the eastern United States by 2015. When fully 

implemented, CAIR would have reduced SO2 emissions in the CAIR region by more than 70 

percent and NOx 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 emissions 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 following regulations governing EGU 

emissions: 

 

7

 Although the IPM® model runs also anticipated the implementation of EPA’s Clean Air Mercury Rule (CAMR), 

that rule has since been vacated by the courts. However, it is anticipated the adjustments to the predicted SO2

emissions from electric generating units (EGUs) used in the air quality modeling, which were based on statespecific comments on the amount of SO2 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 believes the adjustments based on state-specific comments 

improved the reliability of the inventory and made the modeling results more dependable.
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District of Columbia Regional Haze SIP 

1. Reg. 1144, Control of Stationary Generator Emissions, SO2, PM, VOC and NOx

emission control, State-wide, Effective January 2006. 

2. Reg. 1146, EGUs, Electric Generating Unit (EGU) Multi-Pollutant Regulation, SO2

and NOx emission control, State-wide, Effective December 2007. SO2 reductions will 

be more than regulation specifies 

3. Regulation No. 1148, Control of Stationary Combustion Turbine Electric Generating 

Unit Emissions, SO2, NOx and PM2.5 emission control, State-wide, Effective January 

2007. 

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

affected units: 

• SO2 2002 levels of 32,630 to 8,137 in 2018 (75 percent) 

• NOx 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 SO2 levels of 29,747 will drop to 608 in 2018 (98 percent). NOx 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 NOx, SO2, mercury, and CO2. These regulations will achieve an approximately 50 percent 

reduction in NOx emissions and 50 to 75 percent reduction in SO2 emissions compared to 

previous emissions. Depending upon the compliance path selected by the affected facilities, 

the facilities will comply with the output-based NOx and SO2 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 achieve a 77 percent cut in nitrogen oxide (NOx) 

emissions by 2009 and a 73 percent cut in sulfur dioxide (SO2) emissions by 2013. This 

legislation establishes annual caps on both SO2 and NOx emissions for the two primary utility 

companies in North Carolina, Duke Energy and Progress Energy. These reductions must be 

made in North Carolina, and allowances are not saleable. 

Consent Agreements in the VISTAS region: The 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 continuous emission control equipment for 

PM/SO2/NOx emissions; comply with system-wide annual PM/SO2/NOx emissions 

limits; agree not to buy, sell or trade SO2/NOx allowances allocated to Santee Cooper 

System as a result of 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-reduction measures to reduce emissions while 
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District of Columbia Regional Haze SIP 

the permanent controls are designed and installed; and retire pollution emission 

allowances that Tampa Electric or others could use, or sell to others, to emit additional 

NOx, SO2 and PM. 

• VEPCO: Virginia Electric and Power Co. agreed to spend $1.2 billion between by 2013 

to eliminate 237,000 tons of SO2 and NOx emissions each year from eight coal-fired 

electricity generating plants in Virginia and West Virginia. 

• Gulf Power 7: A 2002 agreement calls for Gulf Power to upgrade its operation to cut 

NOx emission rates by 61 percent at its Crest 7 generating plant by 2007 with major 

reductions beginning in early 2005. The Crest plant is a significant 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 SO2 by 54,000 tons per year 

and its emissions of NOx by 8,000 tons per year, by installing and operating selective 

catalytic reduction (SCR) technology; low-NOx burners, and PM and mercury 

Continuous Emissions Monitors at the utility’s Spurlock, Dale and Cooper Plants. 

According to the EPA, total emissions from the plants will decrease between 50 and 75 

percent from 2005 levels. As with all Federal consent decrees, EKPC is precluded from 

using reductions required under other programs, such as CAIR, to meet the reduction 

requirements of the consent decree. EKPC is expected to spend $654 million to install 

pollution controls. 

• AEP: American Electric Power agreed to spend $4.6 billion dollars to eliminate 72,000 

tons of NOx emissions each year by 2016 and 174,000 tons of SO2 emissions each year 

by 2018 from sixteen plants located in Indiana, Kentucky, Ohio, Virginia and West 

Virginia. 

CAIR was included in visibility modeling runs for the District. 

12.5.2. Non-EGU Point Source Controls Expected by 2018 Due to Ongoing Air 

Pollution Control Programs 

As discussed in Section 9, control factors were applied to the 2018 MANE-VU inventory to 

represent the following OTB/W national, regional, or state control measures: 

• NOx SIP Call Phase I (NOx Budget Trading Program) 

• NOx SIP Call Phase II 

• NOx RACT in 1-hour Ozone SIPs 

• NOx OTC 2001 Model Rule for ICI Boilers 

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

• Combustion Turbine and RICE MACT 

• Industrial Boiler/Process Heater MACT8

• EPA’s Refinery Enforcement Initiative 

 

8 The inventory was prepared before the MACT for Industrial Boilers and Process Heaters was vacated. Control 

efficiency was assumed to be at 4 percent for SO2 and 40 percent for PM. 
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None of these measures were included in the inventory for the District. 

In addition, states provided specific control measure information about specific sources or 

regulatory programs in their state. MANE-VU used the state-specific 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 domain 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 absorption pollution control equipment by September 1, 2009, 

resulting in emission reductions of approximately 1,000 tons SO2 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 SO2 emissions of 

the #8 Power Boiler. This control device should result in reductions of over 3,500 tons 

of SO2 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 District relied on MANE-VU’s Version 3.0 Emissions 

Inventory for 2002. In general, the 2018 inventory 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 regional control measures: 

• 2001 OTC VOC Model Rules 

• Federal On-Board Vapor Recovery (OBVR) 

• New Jersey Post-2002 Area 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, Massachusetts revised their 

inventory of area source heating oil 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 version used 2001. These two changes significantly 

altered the 2002 SO2 emissions for area source heating oil combustion. Massachusetts 

provided revised 2002 PE and EM tables, which MACTEC used in preparing the 

2009/2012/2018 projection inventories 
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District of Columbia Regional Haze SIP 

The District of Columbia discovered a gross error in the 2002 residential, non-residential and 

roadway construction. As requested by the District, the following values were used for the 

2002 base year as the basis for 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 PM10-PRI 8.2933 

Residential Construction PM2.5-PRI 1.6587 

2311020000 PM10-PRI 486.1951 

Indust/Comm/Inst Const PM2.5-PRI 97.239 

2311030000 PM10-PRI 289.8579 

Road Construction PM2.5-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 MANE-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 into 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 NOx and non-methane 

hydrocarbons (NMHC) of 0.20 g/bhp-hr and 0.14 g/bhp-hr, respectively. These NOx and 

NMHC standards will be phased in together between 2007 and 2010 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 sulfur 
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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 (ultra-low sulfur diesel, or ULSD). 

Tier 2 Motor Vehicle Standards. Tier 2 is a fleet averaging program, modeled after the 

California LEV II standards. Manufacturers can produce vehicles with emissions ranging from 

relatively dirty to zero, but the mix of vehicles a manufacturer sells each year must have 

average NOx emissions below a specified value. 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 NOx, hydrocarbons (HC), and carbon monoxide (CO) from several groups of 

previously unregulated nonroad engines. Included in these are large industrial spark-ignition 

engines and recreational vehicles. Nonroad spark-ignition engines are those powered by 

gasoline, liquid propane, or compressed natural gas rated over 19 kilowatts (kW) (25 

horsepower). These engines are used in commercial and industrial applications, including 

forklifts, electric generators, airport baggage transport vehicles, and a variety of farm and 

construction applications. Nonroad recreational vehicles include snowmobiles, off-highway 

motorcycles, and all terrain vehicles. These rules were initially effective in 2004 and were 

assumed to be fully phased-in by 2012. 

All of these measures are Federally 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 emission 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 that will result from those measures. 

12.6.1. Identification of Key Source Categories 

Based on available information about emissions and potential impacts, the MANE-VU 

Reasonable Progress Workgroup selected the following source categories 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 combustion and open burning. 
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Prior to making this determination, the District worked with other members of the OTC and 

MANE-VU to consider a wide variety of potential emission reduction strategies covering a 

wide range of sources of SO2 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 additional 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 assessment of pollutants and 

associated source categories affecting visibility in Class I areas in and near MANE-VU, lists 

possible control measures for those pollutants and source categories, and develops the requisite 

four factor analysis. Table 12.3 presents a summary of the four factor analysis for the source 

categories analyzed in the Reasonable Progress Report. 
October 2011 

District of Columbia Regional Haze SIP 

Table 12.3. Summary of Results from the Four Factor Analysis 

Source 

Category 

Primary 

Regional 

Haze 

Pollutant 

Control Measure(s) 

Average Cost in 2006 

dollars (per ton of 

pollutant reduction) 

Compliance 

Timeframe 

En

Electric 

Generating 

Units 

SO2

Switch to a low sulfur coal (generally <1% 

sulfur), switch to natural gas (virtually 0% 

sulfur), coal cleaning, Flue Gas Desulfurization 

(FGD)-Wet, -Spray Dry, or -Dry. 

IPM® * v.2.1.9 predicts 

$775-$1,690. $170-$5,700 

based on available literature 

2-3 years following SIP 

submittal 

F

p

i

el

c

Industrial, 

Commercial, 

Institutional 

Boilers 

SO2

Switch to a low sulfur coal (generally <1% 

sulfur), switch to natural gas (virtually 0% 

sulfur), switch to a lower sulfur oil, coal 

cleaning, combustion control, Flue Gas 

Desulfurization (FGD)- Wet, -Spray Dry, or -

Dry. 

$130-$11,000 based on 

available literature. Depends 

on size. 

2-3 years following SIP 

submittal 

F

p

is

en

Cement and 

Lime Kilns SO2

Fuel switching, Dry Flue Gas DesulfurizationSpray Dryer Absorption (FGD), Wet Flue Gas 

Desulfurization (FGD), Advanced Flue Gas 

Desulfurization (FGD). 

$1,900-$73,000 based on 

available literature. Depends 

on size. 

2-3 years following SIP 

submittal 

en

Heating Oil SO2 Lower the sulfur content in the fuel. Depends on the state. 

$550-$750 based on 

available literature. There is 

a high uncertainty 

associated with this cost 

estimate. 

Currently feasible. 

Capacity issues may 

influence timeframe for 

implementation of new 

fuel standards 

ef

Residential 

Wood 

Combustion 

PM 

State implementation of NSPS, Ban on resale of 

uncertified devices, installer training 

certification or inspection program, pellet 

stoves, EPA Phase II certified RWC devices, 

retrofit requirement, accelerated changeover 

requirement, accelerated changeover 

inducement. 

$0-$10,000 based on 

available literature 

Several years -

dependent on 

mechanism for 

emission reduction 

R

in

c

Source: Appendix P
October 2011 

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Guided by this analysis, the list of measures was further refined. MANE-VU arrived at a suite of 

suggested control measures that the MANE-VU states agreed to pursue as a region by 2018. The 

corollary was that the MANE-VU Class I states (Maine, New Hampshire, Vermont, and New 

Jersey) also asked states outside of MANE-VU that also contribute to visibility impairment to 

pursue similar strategies for reducing sulfate emissions 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/m3 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 measures have been considered by the MANE-VU region. 

12.7.1. Source Retirement and Replacement Schedules 

Title 40 CFR Section 51.308(d)(3)(v)(D) requires States to consider source retirement and 

replacement schedules in developing reasonable progress goals. Retirement and replacement 

must comply with existing Federal requirements, 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 States to consider measures to mitigate the 

impacts of construction activities. 

MANE-VU’s consideration of measures to mitigate the impacts of construction can be found in 

the MANE-VU document entitled, Technical Support Document on Measures to Mitigate the 

Visibility Impacts of Construction 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 not targeted under 

the Regional Haze Rule. Nevertheless, the crustal fraction at any given location can be heavily 
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influenced by the proximity of construction activities; and construction activities occurring in the 

immediate vicinity of MANE-VU Class I Areas could have a noticeable effect on visibility. 

Section 605 of Title 20 District of Columbia Municipal Regulations, 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) requires States to consider smoke management 

techniques for the purposes of agricultural and forestry management in developing reasonable 

progress goals. 

The MANE-VU Technical Support Document on Agricultural 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 wood combustion. According to Appendix B of the 

document, wood smoke also contributes to visibility impairment, with contributions typically 

higher in rural areas than urban areas, winter peaks in northern areas from residential wood 

burning, and occasional large summer impacts at all sites from wildfires. Wood smoke 

impacting MANE-VU Class I areas is more local in origin than sources of SO2, 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 urban 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 fires are not needed in the District’s SIP. 

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

Title 40 CFR 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, area and mobile source emissions 

by 2018. 

The District has adopted the control measures in the OTB/W scenario, and has met the BART 

requirement. 

12.9. Share of Emission Reductions 

Title 40 CFR 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. 
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District of Columbia Regional Haze SIP 

The District’s contribution to visibility impairment at nearby Class I areas is less than 0.1 μg/m3

or two percent sulfate, so states 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 involved 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 expected 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 deciview impacts of the OTB/W scenario on VISTAS 

states, since OTB/W measures are specific to MANE-VU. VISTAS did not request emissions 

reductions for Shenandoah National Park or the other 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 MANE-VU, the District is meeting more than its 

share of emissions reductions. 

12.10. Changes to Emissions by 2018 

The emission inventory for the District projects changes to point, area, and mobile source 

inventories by 2018, the end of the first implementation period, resulting from population 

growth; industrial, energy and natural resources development; land management; and air 

pollution control. A summary of SO2 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 Electric Generating Units in the Eastern U.S. for 

MANE-VU’s Regional Haze Modeling (Appendix F). 
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District of Columbia Regional Haze SIP 

Table 12.2. Emissions from Point, Area, and Mobile Sources in MANE-VU (SO2 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, and Mobile Sources in the District (SO2 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 OTB/W and BART measures are 

enforceable. 

12.11. Enforceability of Emission Limitations and Control Measures 

Title 40 CFR 51.308(d)(3)(v)(F) requires the District to ensure that emission limitations and 

control measures used to meet reasonable progress goals are enforceable. 

Of the OTB/W controls accounted for in the 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) 
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District of Columbia Regional Haze SIP 

The following sections of the DC Municipal Regulations are also included in the District SIP and 

are therefore Federally enforceable: 

• Section 604 of Title 20 District of Columbia Municipal Regulations prohibits open 

burning within the District (Appendix U). 

• Section 605 of Title 20 District of Columbia Municipal Regulations, Control of Fugitive 

Dust, requires reasonable precautions to minimize 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. 
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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 zone 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 sulfur 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 percent-0.50 percent sulfur by weight by no later than 2018, 

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

and 

• Further reduce the sulfur content of distillate oil to 15 ppm by 2018 depending on 

supply and availability; and 

4. A 90 percent or greater reduction in sulfur dioxide (SO2) 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 visibility 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 SO2 and nitrogen oxide (NOx) 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 implementation of reasonable and cost-effective NOx

and SO2 control measures as appropriate and necessary. 

The District remains committed to the goal of improving visibility, and 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 reasonable progress goals of Class I areas near the 

District.