United States

Department of

Agriculture

Forest

Service

White Mountain 

National Forest

719 N. Main Street

Laconia, NH 03246

Comm: (603) 528-8721

TTY: (603) 528-8722

Caring for the Land and Serving People Printed on Recycled Paper 

File Code: 2580

Date: January 26, 2009

Ms. Barbara Kwetz

Director, Planning and Evaluation Division

Bureau of Waste Prevention

Massachusetts Department of Environmental Protection

One Winter Street

Boston, MA 02108

Dear Ms. Kwetz:

On November 25, 2008, the Commonwealth of Massachusetts submitted a draft implementation 

plan describing your proposal to improve air quality regional haze impacts at mandatory Class I 

areas across your region. We appreciate the opportunity to work closely with the 

Commonwealth through the initial evaluation, development, and, now, subsequent review of this 

plan. Cooperative efforts such as these ensure that, together, we will continue to make progress 

toward the Clean Air Act’s goal of natural visibility conditions at our Class I wilderness areas 

and parks. 

This letter acknowledges that the U.S. Department of Agriculture, U.S. Forest Service has 

received and conducted a substantive review of your proposed Regional Haze Rule 

implementation plan. Please note, however, that only the U.S. Environmental Protection

Agency (EPA) can make a final determination about the document's completeness, and therefore, 

only the EPA has the ability to approve the document. The Forest Service's participation in the 

Commonwealth of Massachusetts’ administrative process does not waive any legal defenses or 

sovereignty rights it may have under the laws of the United States, including the Clean Air Act 

and its implementing regulations. 

We have attached comments to this letter from the perspective of a Federal Land Manager. We 

look forward to your response required by 40 CFR 51.308(i)(3). For further information, please 

contact Air Quality Specialists Ralph Perron at (802) 222-1444 or Scott Copeland at (307) 332-

9737.
Again, we appreciate the opportunity to work closely with the Commonwealth of Massachusetts. 

The Forest Service compliments you on your hard work and dedication to significant

improvement in our nation's air quality values and visibility.

Sincerely,

/s/ Thomas G. Wagner

THOMAS G. WAGNER

Forest Supervisor

cc: Scott A Copeland, Air Quality Specialist, USDA Forest Service

Ralph Perron, Air Quality Specialist, USDA Forest Service

Dave Conroy, Environmental Protection Agency, Region 1

Aimee Powelka, Environmental Analyst, MA Bureau of Waste Prevention
USDA Forest Service Comments Regarding 

Massachusetts Draft Regional Haze Rule State Implementation Plan 

On November 25, 2008, the Commonwealth of Massachusetts submitted a draft Regional Haze 

Rule State implementation plan (SIP), pursuant to the requirements codified in federal rule at 40 

CFR 51.308(i)(2), to the USDA Forest Service (FS). The air program staff of the FS conducted a 

substantive review of the Massachusetts draft plan, and have provided the comments listed 

below. We look forward to the Massachusetts Department of Environmental Protection (MDEP) 

response as per section 40 CFR 51.308(i)(3). For further information regarding these comments, 

please contact Ralph Perron at (802) 222-1444 or Scott Copeland at (307) 332-9737.

Overall Comment 

The MDEP has submitted a well-written draft Regional Haze SIP. The draft SIP addresses 

several important issue areas as well as acknowledging the many uncertainties faced by MANEVU in regards to emission inventories, modeling assumptions and modeling results. 

BART and CAIR

We concur that the application of BART analyses to BART eligible facilities is appropriate given 

the uncertainties associated with CAIR. 

Like our FLM partners, we are concerned about the adequacy of the BART determinations. We 

do not reproduce their detailed comments below, but support the comments they submitted to 

you.

Prevention of Significant Deterioration

The Forest Service routinely requests that SIPs include language linking the Regional Haze 

Program with the Prevention of Significant Deterioration program. We note that the PSD 

program can be an effective tool to prevent degradation of “Best Days”, and that new sources 

should be consistent with or accounted for in RH SIP revisions.

Section 10.5.3 Outdoor Hydronic Heaters

MDEP includes pending regulations to deal with outdoor wood-fired boilers (see page 129, 

Section 10.5.3 Regulation of Outdoor Hydronic Heaters). We recommend MDEP update this 

section, since regulations should be on the books at this time (draft SIP states by September 

2008), and include the State’s intention to submit these regulations as a part of the regional haze 

SIP.

Section 10.8 Enforceability of Long Term Strategy Control Measures

It would help in our evaluation of the SIP if MDEP would explicitly state which “expected” LTS 

components in Section 10 are currently enforceable and which are being evaluated for the 2013 

progress report.