VT Responses to U.S. Federal Land Management Agency and U.S. Environmental 

Protection Agency Comments on 12/18/08 and 1/15/09 Draft Revisions to 

Vermont's Regional Haze State Implementation Plan (SIP) 

On December 22, 2008, Vermont submitted a 12/18/08 draft of its State Implementation 

Plan (SIP) Revision for Regional Haze for 60-day review by the Federal Land 

Management Agencies, including the Forest Service of the U.S. Department of Agriculture 

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

of the Interior (DOI). On January 15, 2009, Vermont submitted a slightly revised 1/15/09 

draft of its Regional Haze SIP Revision for 30-day review by the U.S . Environmental 

Protection Agency (EPA). 

Vermont received comments back from the Forest Service and the DOI on February 19, 

2009, and from EPA on February 24, 2009, and has subsequently made revisions which are 

incorporated into the June 2009 version of the VT Regional Haze SIP. The following is a 

summary of the comments received and Vermont's responses to them. 

1 . VT Responses to 2/19/09 USDA Forest Service Comments on 12/18/09 VT 

Draft Regional Haze SIP 

Forest Service Comment: 

A correction has been addressed regarding the NY Kodak Park Division S02 emissions (p. 

90), via an email with Ms. Heidi Hales . 

Vermont Response: 

Misplaced commas were corrected in Table 10.3 on page 90 of the Draft SIP. 

Forest Service Comment: . 

In Section 5 .3, Lye Brook Wilderness Monitoring Strategy, we feel that a haze camera 

would be a beneficial addition to the monitoring site . A haze camera has the benefit of 

providing a picture every 15 minutes, accessed through a public web site, of the conditions 

on site, which are instantly understood by the lay person, as well as the scientist. 

Understanding the limitations of budgetary constraints, a future consideration might 

include one haze camera which is shared by multiple Class I areas. The camera could be 

located at Lye Brook for a one or two year period. The camera could then go to another 

Class I area, and at a future time return to Lye Brook. 

Vermont Response: 

Vermont agrees that an automated haze camera with Internet Link would be a desirable 

addition to the Lye Brook monitoring site . The following was added to Section 5.3 : 

Vermont currently lacks the funding and personnel resources to support enhancements to 

existing IMPROVE visibility monitoring at Lye Brook, but would be interested in 

discussing future options, including possibilities for sharing a haze camera with multiple 

Class I areas, with the Forest Service, other states and/or other Federal Land Management 

agencies. 
2. VT Responses to 2/19/09 DOI National Park Service and U.S. Fish and Wildlife 

Service Comments on 12/18/09 VT Draft Regional Haze SIP 

DOI Comment: 

As noted in your discussion, most of the impairment from such sources comes from 

outside of your State. We request that the final SIP clarify whether the inclusion of these 

impact thresholds under the Long-Term Strategy for Regional Haze protection, if approved 

by EPA, are intended to apply to sources in other States . 

Vermont Response: 

This is the intent of the revised impact thresholds . The following sentences have been 

added to the end of the first paragraph on page 136: 

It is Vermont's intention to use these revised "levels of significant impact" to determine 

whether newly proposed (or existing) sources, located within Vermont (or in upwind 

states), are significantly contributing to exceedances of Vermont's sulfate standard, and 

therefore significantly contributing to Lye Brook visibility impairment. When this SIP has 

been approved by EPA, Vermont assumes that sources exceeding this significance level 

will be considered by EPA to be interfering with Vermont's ability to assure reasonable 

progress toward the Clean Air Act § 169 national visibility goal. 

DOI Comment: 

Page 56: Recommend changing title of Table 6.4 to "Updated Scenario" from "Most 

Recent Inventory" to reflect narrative of emission scenarios on page 50. 

Vermont Response: 

Table 6.4 caption was revised by adding ("Updated Scenario"). 

DOI Comment: 

Also, we would like the State to explain why there is only a minimal difference in 

Vermont's inventories for 2018 OTB/OTW and 2018 BOTW (25 tons decline in VOCs 

and 1 ton increase in PM2.5, respectively) . The assumption could be the small difference is 

due to the minimal efforts the State has to do in regards to ozone regulations. Nonetheless, 

the draft SIP could better explain these data. 

Vermont Response: 

This assumption is correct. The following sentences have been added at top of page 56 : 

It may be noted that there is virtually no change in Vermont's estimated emissions from 

the 2018 OTB/OTW scenario to the 2018 BOTW (beyond on the way) scenario. This is 

because Vermont is currently in attainment of old (and new) NAAQS for both ozone and 

PM2,5 (nor is VT a CAIR state for ozone or PM2.5) . Thus no additional emissions 

reductions are anticipated for those specific programs. 
DOI Comment: 

We wanted to note that earlier in the draft SIP, Vermont identifies Wisconsin as a 

contributor to visibility impairment and invites Wisconsin to consult in the regional haze 

process. However, in terms of the Contribution Assessment,- Wisconsin is never identified 

as a top contributor based o n the three ranking criteria adopted by MANE-VU. Under the 

reasonable progress goal (RPG) discussion, the draft SIP does mention that there is only 

one source identified in Wisconsin (as part of the "167 Stacks" strategy) . We would like to 

encourage the State to include language that clarifies Wisconsin was identified to consult 

with not through the Contribution Assessment but through the development of the "167 

Stack" strategy . 

Vermont Response: 

There had previously been an explanation in the first paragraph on page 30 indicating that : 

Independent of the other MANE-VU states with Class I areas, Vermont separately 

identified Wisconsin as having the potential to impact the Lye Brook Wilderness Area 

based on CALPUFF regional modeling using the VTDEC modeling platform which 

predicts Wisconsin impacts on sulfate there as equivalent to those from Illinois, ie 4% {see 

page D-54 of the NESCAUM report, "Contributions to Regional Haze in the Northeast and 

Mid-Atlantic United States", August 2006 (Attachment A) . 

In addition to that, a new footnote was added on page 22 indicating : 

Vermont independently determined based on CALPUFF modeling, which was not considered in developing Table 2.2, 

that Wisconsin has the potential to contribute to visibility impairment in Lye Brook. Therefore, Vermont asked 

Wisconsin to consult. See Section 3 .2.1 and Table 3.4. 

"Wisconsin" was also added to the list of states targeted for coordinated actions on page 85 

along with a modified footnote on that page indicating that : 

Independently from other MANE-VU modeling and assessments, Vermont CALPUFF modeling identified Wisconsin as 

a significant contributor to visibility impairment at the Lye Brook Wilderness Class I Area (See Section 3 .2 .1) . 

DOI Comment: 

Page 109, Section 10.4 : This section is somewhat misleading and we suggest clarifying 

more explicitly the terms of the "2018 glideslope" and "2018 projected progress." It is 

important to make clear that the 2018 Projected Progress bars are based on inclusion of the 

MANE-VU/Vermont Ask in the May 2008 modeling results, strategies that are not 

necessarily adopted by all states (which the draft SIP does acknowledge throughout, but no 

so clear here). Better clarification within the text could help interpret the tables or another 

option would be to change the title of yellow bars to "2018 Additional Progress" or "20Y8 

Ask Progress." Also, referencing Section 11 .8 may help, because there is a better 

description of projected visibility for 2018 under this section entitled "Estimated Effects on 

visibility from LTS ." 

Vermont Response: 

The following sentences have been added at the bottom of page 109: 
While the MANE-VU states agree that these modeled 2018 visibility changes result from 

required and reasonable control measures, it should be noted that source-specific VISTAS 

and MRPO RPOs projected 2018 emissions are similar to but different from those 

requested in the MANE-VU ask, and consequently the future impacts on Lye Brook 

visibility may be different from what been projected here. See sections 3.2, and 10 .2 for 

additional detail . 

DOI Comment: 

No information is given within the regional haze portion of the SIP on current State 

regulations dealing with agricultural or wild land prescribed burns. The SIP should 

indicate that the State will continue to review the impacts from agricultural use of fire and 

prescribed fire for forest or ecosystem management. If those impacts become important 

for maintaining reasonable progress in the future, revisions to the regional haze SIP should 

contain a smoke management plan. We did not see any commitment for further work or 

coordination in terms of prescribed fire regulations in the current draft. Vermont does 

have regulations on the books for outdoor wood smoke, which is a larger contributor to 

haze at this time. 

Vermont Response: 

The following sentences were added to the end of Section 11 .7 on page 129 : 

Vermont will continue to review the impacts from agricultural use of fire and prescribed 

fire for forest or ecosystem management. If those impacts become important for 

maintaining reasonable progress in the future, revisions to the regional haze SIP will 

include a smoke management plan. Vermont will continue to consult with the US Forest 

Service regarding potential impacts of prescribed fire on visibility in the Lye Brook 

Wilderness . 

DOI Comment: 

We would like to see a commitment to work with Federal agencies as a team if economic 

challenges are faced by the monitoring program. 

Vermont Response: 

The following sentences were added to section 5 .3 on page 46: 

Vermont routinely participates in the IMPROVE monitoring program by serving as the 

NESCAUM regional representative to the IMPROVE Steering Committee. Vermont is 

committed to working with other state, regional and federal IMPROVE partners to assure 

that adequate resources are available to provide continued monitoring representative of 

visibility conditions and trends in Lye Brook and other Class 1 areas . 

DOI Comment: 

Page 31-32 : The text includes follow-up MRPO coordination but does not include how the 

consultation with VISTAS was resolved. 
Vermont Response: 

This is an accurate observation, as some issues between MANE-VU and VISTAS were not 

fully resolved during the regional haze consultations . The following sentences have been 

added at the bottom of page 36 : 

Vermont and other MANE-VU states are committed to continuing consultation with states 

in the MRPO and VISTAS regions, through participation in the State Collaborative 

Process, in which new regional control strategies are discussed to reduce future emissions 

of multiple pollutants of common regional concern . 

In Addition, the following sentences have been added at the bottom of page 109 : 

While the MANE-VU states agree that these modeled 2018 visibility changes result from 

required and reasonable control measures, it should be noted that source-specific VISTAS 

and MRPO RPOs projected 2018 emissions are similar to but different from those 

requested in the MANE-VU ask, and consequently the future impacts on Lye Brook 

visibility may be different from what been projected here. See sections 3.2, and 10.2 for 

additional detail . 

DOI Comment: 

Page 33 : Vermont indicates that it will be meeting the terms of the MANE-VU Ask by 

adopting the low Sulfur fuel strategy . There is not mention that the State also has other 

control programs on the books, e.g ., new standards for outdoor wood boilers. We therefore 

recommend the State include a reference to Section 11 .2, which outlines the State's 

regulations regarding outdoor wood boilers. We also recommend that the State commit to 

investigating sources of cleaner energy, which is also highlighted in the Ask. 

Vermont Response: 

MANE-VU's strategies for reasonable progress goals at all class I areas in MANE-VU 

have focused on control of the most significant contributing air pollutant implicated 

in haze at these areas. The focus of these strategies for 2018 is to reduce "sulfate" formed 

from sulfur emissions. Vermont's OWB regulations are more likely to gain reductions in 

carbonaceous particulate matter and VOCs. Emissions reductions from these sources were 

not included in the MANE-VU "Ask" or in modeling of Reasonable Progress Goals, and 

would not produce significant improvements in visibility at Lye Brook or other class I 

areas until the sulfate-dominated visibility impairment has been reduced and overall 

visibility brought closer to natural conditions. Therefore, Vermont is not including 

references its OWB regulations in its visibility SIP at this time, but will continue to 

evaluate the need to include these and other control measures in future visibility SIP 

submissions . 

In addition, the following sentences have been added in Section 3 .2 .2 .2 on page 32 : 

Vermont intends to adopt a rule specifying the low sulfur fuel limits for "outer zone" 

MANE-VU states in the near future . After this rule is adopted, Vermont will submit the 
rule to EPA for approval into the Vermont SIP. Vermont will also continue investigating 

sources of cleaner energy. 

DOI Comment: 

Page 3, last paragraph, first sentence : "must include" not "must including" 

Vermont Response: 

Page 3 text was revised accordingly. 

DOI Comment: 

Page 27, Table 3.1 : "MANE-VU Members" not "MANE-VIEW Members" 

Vermont Response: 

Table 3 .1 text was revised accordingly. 

DOI Comment: 

Page 59, first paragraph, last sentence : "(Attachment F)." 

Vermont Response: 

Page 59 text was revised accordingly. 

DOI Comment: 

Page 64, Section 8.2, second paragraph" "Table 8.1 displays the result of one just one of 

the methods used . . ." 

Vermont Response: 

Page 64 text was revised accordingly. 

DOI Comment: 

Page 78, first sentence : "While there are occasionally large-Canadian fire impacts at Lye 

Brook, these infrequent natural sources and not subject to regulatory controls ." 

Vermont Response: 

Page 78 text was revised accordingly. 

DOI Comment: 

Page 109, last sentence : Suggest including national parks in addition to wilderness areas to 

achieve natural conditions by 2064. 

Vermont Response: 

Page 110 text was revised accordingly. 
3. VT Responses to 2/24/09 U.S. EPA Comments on 1/15/09 VT Draft Regional 

Haze SIP 

EPA comment: 

1 .5 The Basics of Haze 

1) When discussing the visibility on the 20 percent cleanest days and 20 percent haziest 

days at Lye Brook, it would be helpful to include the visibility range (in kilometers) for 

each to give the reader a better context. 

VT Response: 

Second sentence on page 9 revised to: At Lye Brook Wilderness over the 5 year period 

from 2000 through 2004, reconstructed extinction averaged 6.4 dv (visual range of 222 

kilometers) on the 20 percent cleanest days and 24.5 dv (visual range of 38 kilometers) on 

the 20 percent haziest days. 

EPA comment: 

1 .6 Anatomy of Regional Haze 

2) We suggest the first full paragraph on page 11 as follows : 

About half of the worst visibility days in Lye Brook occur in the summer when 

meteorological conditions are more conducive to the formation of sulfate from SOZ and to 

the oxidation of organic aerosols. 

As a fesu4t-, The remaining worst visibility days are divided nearly equally among spring, 

winter, and fall . In addition, winter and summer transport patterns are different possiblX 

leading to different contributions from upwind pollutant source regions. 

VT Response : 

This paragraph on page 11 was revised as recommended. 

EPA comment: 

2.1 States Contributing to Visibility Impairment at Lve Brook 

3) It is not clear why Wisconsin is absent from Table 2.2, "States that Contribute to 

Visibility Impairment in the MANE- VU Class I Areas of Acadia, Moosehorn, Great 

Gulf, Lye Brook, and Brigantine," when it is included in Table 3 .4, "States (Listed by 

Regional Planning Organization) and Provinces Contributing to Visibility Impairment at 

Vermont's Lye Brook Wilderness Areas". 

VT Response: 

A footnote was added at end of second paragraph in section 2 .1 on page 22 indicating that 

"Vermont independently determined based on CALPUFF modeling, which was not 

considered in developing Table 2.2, that Wisconsin has the potential to contribute to 

visibility impairment in Lye Brook. Therefore, Vermont asked Wisconsin to consult. See 

Section 3 .2 .1 and Table 3.4" 
"Wisconsin" was also added to the list of states identified in the list of states in the first 

paragraph of section 10.2, and the footnote at the bottom of page 85 was revised to : 

"Independently from other MANE-VU modeling and assessments, Vermont CALPUFF 

modeling identified Wisconsin as a significant contributor to visibility impairment at the 

Lye Brook Wilderness Class I Area (See Section 3.2 .1) ." 

EPA comment: 

3 .2 .2 .2 Meeting _ the "Ask" - Vermont 

4) This section states, "Vermont contains no BART-eligible sources, but intends to meet 

the terms of the MANE-VU agreement by pursuing the low-sulfur fuel oil strategy. 

Vermont should include more detail on the mechanism by which this will become an 

enforceable part of the Vermont SIP (e.g, does Vermont plan to adopt a rule and submit 

it to EPA for approval into the SIP?) 

VT Response: 

Vermont does intend to adopt a rule enforcing the low sulfur fuel requirements specified in 

the MANE-VU Ask. The following sentences have been added to Section 3.2 .2 .2 on p. 32: 

Vermont intends to adopt a rule specifying the low sulfur fuel limits for "outer zone" 

MANE-VU states in the near future . After this rule is adopted, Vermont will submit the 

rule to EPA for approval into the Vermont SIP. Vermont will also continue investigating 

sources of cleaner energy . 

EPA comment: 

3.2.4 Consultation Issues 

5) Vermont should include more detail regarding its consultation with contributing states 

in particular expanding upon the statement that , "A few non-MANE-VU states did not 

respond to Vermont's consultation requests or responded by downplaying the magnitude of 

their states' contributions to visibility impairment at the Lye Brook Wilderness area." 

VT Response: 

This sentence in Section 3 .2 .4 on page 34 has been revised to: 

Some states in the MRPO and VISTAS regions had interpretations of the requirements for 

BART and for establishing Reasonable Progress Goals which differed from those in the 

MANE-VU states . 

More detail on RPO differences on future emissions inventory assumptions is added in 

Section 10 .4, and the following sentence was added to the end of Section 3 .2 .4 : 

Vermont and other MANE-VU states are committed to continuing consultation with states 

in the MRPO and VISTAS regions, through participation in the State Collaborative 

Process, in which new regional control strategies are discussed to reduce future emissions 

of multiple pollutants of common regional concern . 

EPA comment: 
9. Best Available Retrofit Technology (BART) 

6) The last full paragraph on page 82 should be revised as follows: 

" . . . there are etiffently no BART -eligible sources in Vermont." 

VT Response: 

This sentence on page 83 was revised as recommended. 

EPA comment: 

9.1 Bart-Eligible EGUs and the Role of CAIR 

7) In the third bullet on page 83, Vermont should delete Massachusetts from the list of 

non-CAIR states . 

VT Response: 

The third bullet on page 84 has been revised to : 

" Non-CAIR states : EGUs in states not eligible to participate in the CAIR annual or 

seasonal programs (Maine, New Hampshire, Rhode Island, and Vermont). 

EPA comment: 

10.2 .4 Targeted EGU Strategy for S02 Reduction 

8) Vermont should include a description of visibility improvement expected from 

controlling the 167 stacks in addition to the discussion of expected improvement in PM 

levels . 

VT Response : 

The discussion at the bottom page 95 and Figure 10 .3 on page 97 provide an illustration of 

reductions in annual average PM2.5 mass concentrations estimated to result if 90% 

emission reductions were applied to the 167 EGU sources identified as the largest 

contributors to sulfate at MANE-VU Class 1 areas . This illustration, as well as similar 

average PM2,5 mass model results for other individual elements of the MANE-VU strategy 

(such as BART, low sulfur oil S-1 and S-2, can be found in the NESCAUM Report 

"MANE-VU Modeling for Reasonable Progress Goals" (Attachment U). It might be 

conceptually feasible to provide similar calculations for the visibility impacts of these 

individual strategy elements, as well as the OTB/OTW element including CAIR, and other 

adjustments to the modeled emission inventory discussed in Attachment U and further 

modified as described in Attachment O ("2018 Visibility Projections") following further 

inter-RPO consultations . However, the calculations would be extremely complex, since 

the worst 20% days will differ for the different locations on the map, and different f(RH) 

adjustments would be needed for each day and location . In addition, the EGU emissions 

reductions that would result from CAIR, other OTB/OTW mechanisms and the 167 source 

strategies are combined in complex ways in the final MANE-VY 2018 modeling inventory 

(see Attachment O). Furthermore, the "partial strategy" visibility results would not be 

especially meaningful since the final model results reflect the combination of all control 

elements taken together, but a change in (nonlinear) deciviews resulting from any 

individual control element is dependent on the order in which the individual elements were 

executed - with the largest deciview benefits generally attributed to whatever control 

element is imposed first. The estimated visibility improvements resulting from all 
elements of the MANE-VU strategy to determine the reasonable progress goals for Lye 

Brook are presented in Table 10.8 on page 108. The modeled improvements in Lye Brook 

visibility on best and worst 20% days are presented graphically in Figure 11 .1 on page 131, 

and the modeled reductions in the individual aerosol species components on best and worst 

days are shown in Figure 11 .2 on page 132 . 

EPA comment: 

11 .9 Vermont's Share of Emission Reductions 

9) Vermont states that it expects a nearly 85% reduction of Vermont's S02 emissions from 

ICI boilers and residential heating units via MANE-VU's low sulfur fuel oil strategy . 

Vermont also cites the implementation of the Low Emissions Vehicle regulations and 

Vermont's regulation controlling Outdoor wood-fire boilers. Vermont will need to submit 

all regulations that the State is taking credit for in its Regional Haze SIP to EPA for 

approval into the SIP. 

VT Response : 

Vermont intends to meet the terms of the MANE-VU Ask by pursuing the low-sulfur fuel 

oil strategy and by continued evaluation of other control measures. As discussed above, 

Section 3 .2 .2 .2 has been revised to indicate that Vermont plans to adopt a rule establishing 

low sulfur fuel limits and then submit the rule to EPA for approval into the Vermont SIP. 

Emission reduction strategies such as Vermont's Low Emission Vehicle (LEV) regulations 

and outdoor wood-fired boiler (OWB) regulations will help reduce future emissions, but 

are not elements of the MANE-VU Ask (see Section 3 .2 .2.1) . Further, given Vermont's 

low sulfur emission contributions and commitment to adopt a rule establishing low sulfur 

fuel limits, these strategies are not required to obtain Vermont's share of emission 

reductions needed to meet the reasonable progress goals in this first 10-year planning 

cycle. MANE-VU's strategies for reasonable progress goals at all class I areas in MANEVU have focused on control of the most significant contributing air pollutant implicated 

in haze at these areas. The focus of these strategies for 2018 is to reduce "sulfate" formed 

from sulfur emissions. LEV and OWB control programs are strategies more likely to gain 

reductions in carbonaceous particulate matter and VOCs, and would not produce 

significant improvements in visibility at Lye Brook until the sulfate-dominated visibility 

impairment has been reduced and overall visibility brought closer to natural conditions . 

Therefore, Section 11 .9 has been revised to delete cites to Vermont's LEV and OWB 

regulations. Moreover, including the LEV regulations in Vermont's SIP would be 

particularly onerous because of the frequent changes to California's LEV program and 

could stifle Vermont's adoption of future LEV amendments. In addition, Vermont's OWB 

regulations are currently undergoing major revisions. Vermont will, however, continue to 

evaluate the need to include these and other control measures in future visibility SIP 

submissions.