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Summary of Stakeholder Comments on the 

Reasonable Progress Modeling Draft Report 

January 29, 2008 

The draft report entitled, “MANE-VU Modeling for Reasonable Progress Goals” was 

completed by NESCAUM on December 10, 2007. On December 12, 2007, MARAMA 

requested comments from MANE-VU Stakeholders by January 9, 2008. Six stakeholders 

have commented on the document and their comments are summarized below. Comments 

were received from the following: the Council of Industrial Boiler Owners (CIBO) via 

John Woolf of Bracewell and Giuliani LLP, Dominion Resources Services, Inc., Midwest 

Ozone Group (MOG) via Edward Kropp of Jackson Kelly PLLC, John Shimshock of 

Reliant Energy, Inc., Utility Air Regulatory Group (UARG) via Andrea Field of Hunton 

and Williams, and MARAMA via Angela King. 

Comments

UARG stated that it is not necessary or appropriate for MANE-VU to ask other states to 

change course now to include additional control measures in their regional haze SIPs, 

especially since these regulatory requirements come up very late in the regional haze 

state implementation plan (SIP) development process. Existing measures and other 

measures included in the state plans that have been drafted or proposed for comment are 

adequate (and, in some cases, more than adequate) to achieve visibility improvements 

approaching or going beyond the uniform rate of progress for their own and other states’ 

Class I areas. In these circumstances, neither the Clean Air Act nor EPA’s rules and 

guidance would require states to include additional control measures in their regional 

haze SIPs. The fact that MANE-VU claims that additional “measures are reasonable to 

implement” (Draft RPG Modeling Report at 6-1) does not change anything: no EPA rules 

or guidance requires other regional planning organizations at this late date to revise their 

draft or final regional haze plans to address or incorporate the list of additional control 

measures included in the draft MANE-VU reports. 

MOG stated that requiring the implementation of control strategies that result in visibility 

improvement beyond the improvement necessary to meet the uniform glide slope is 

neither necessary under the Regional Haze Rule nor an efficient use of resources. MOG 

therefore urges MANE-VU to accept the benefits of on the books control strategies, many 

of which not yet fully implemented and that result in attainment of reasonable progress as 

defined by EPA, rather than continue to press for implementation of additional control 

strategies that are simply unnecessary to comply with the Regional Haze Rule and, more 

importantly, strain an already unstable economy. CIBO agrees with MOG, stating 

controls beyond those required to meet already stringent standards is neither justified by 

applicable law, nor by the significant additional burden on sources that will result. 

Sources have made significant capital investments to meet mandatory measures and the 

resulting environmental benefits will likewise be significant. 
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Reliant stated that further emission reductions beyond “on-the-books/on-the-way” 

regulations are unnecessary for achieving the 2018 regional haze rule milestones. Before 

any further emission reductions are mandated, Reliant Energy recommends that U.S. 

EPA plan a comprehensive assessment of the effects on measured visibility of the first 

Regional Haze Rule implementation period and a reassessment of model performance at 

that time. 

Dominion noted that all Class I areas within the MANE-VU region will achieve 

significant visibility improvements beyond the uniform glide path by 2018. Therefore 

emission reduction measures already in progress or that will be implemented to meet 

CAIR and other regulatory requirements are sufficient and in fact exceed requirements to 

demonstrate reasonable progress under EPA’s Regional Haze Regulation. 

Dominion also stated that while the MANE-VU analysis accounts for and captures 

projected visibility improvements from source-specific BART requirements in the 

Northeast region, it does not account for the potential impact of BART-specific 

reductions in neighboring regional planning organizations (RPOs) that could provide 

some additional level of visibility improvement in MANE-VU Class I areas. 

Dominion questions whether MANE-VU is justified in determining from a broad-based 

perspective that a 90 percent sulfur dioxide (SO2) reduction for all electric generating 

units (EGUs) identified as affecting visibility in the MANE-VU region is reasonable 

under the reasonable progress provisions of the regional haze rules. Furthermore, sources 

already subject to BART are in the process of completing the required BART analysis, 

which encompasses an assessment of the same factors that must be addressed in 

establishing reasonable progress. Thus, any source that has already been subject to a 

BART determination assessment should be exempt from any further requirements. EPA 

implies this conclusion in its final guidance, observing that it is not necessary for states to 

reassess the reasonable progress factors for sources subject to BART for which the states 

have already completed a BART analysis (EPA Guidance for Setting Reasonable 

Progress Goals Under the Regional Haze Program, June 1, 2007, page 5-1). 

Dominion noted that several of the EGUs identified by MANE-VU as “most likely to 

affect” visibility in certain Class I areas within the MANE-VU region are owned and 

operated by Dominion. Specifically, Mt. Storm Units 1-3, Chesterfield Units 4-6, 

Chesapeake Energy Center Units 3 and 4, Yorktown Units 1-3, Brayton Point Units 1-3, 

and Salem Harbor Units 1-3. 

Dominion stated it is already implementing an aggressive emission reduction control 

program across its fossil generation fleets in the Mid-Atlantic, New England, and 

Midwest regions. This program includes the very sources identified in the MANE-VU list 

of 167 “select” EGUs. For more information on the controls and the specific facilities and 

units see the Dominion comment. 

Dominion does not believe that the implementation of a “blanket” control strategy across 

a select list of sources that are either already taking measures to reduce emissions under 
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CAIR or already undertaking BART analyses is needed to demonstrate reasonable 

progress. According to Dominion, as the MANE-VU modeling analysis clearly shows, 

existing and planned programs already “on-the-books” and “on-the-way” will achieve 

progress beyond the requirements identified in the uniform glide paths the states have 

already set for Class I areas. 

Reliant is concerned that MANE-VU’s base year 2002 inventory is different from 

emissions estimates originally submitted to the states by industrial facilities. They stated 

that some estimates of sulfur dioxide, nitrogen oxides (NOx), and fine particulate matter 

(primary PM2.5) emissions in the future year inventories appear to be implausible. Reliant 

would welcome the opportunity to work with MANE-VU and NESCAUM to develop a 

mutually-agreeable 2002 emission inventory for their facilities and to investigate and 

critically review the assumptions used to develop the future year’s inventories. With 

regards to the future year inventories, Reliant Energy understands that these do not 

incorporate recent New Source Review settlements that have specified the installation of 

control equipment and the permanent retirement of allowances which would be made 

available through the operation of this emissions control equipment. 

Reliant stated that results from various future year model runs are presented in the report 

and in several instances, the conclusions deduced by NESCAUM do not appear to be 

supported by the model runs. 

Section 1

Reliant stated that a critical review of the 2009 and 2018 projected emissions inventories 

needs to be performed. Reliant asserts that a 153 percent and a 360 percent increase in 

PM2.5 emissions in 2009 from New Jersey and Pennsylvania EGUs, respectively, is 

implausible considering that emissions of SO2 and NOx are predicted to decrease by at 

least 45 percent. 

Section 2

Reliant stated that poor modeled meteorological performance during the summer period 

has significant implications for conclusions regarding source attribution for regional haze 

impacts. 

Reliant stated that some of the figures presented in the report have best fit lines drawn in 

that do not appear to match the line one would eyeball that would pass through the peak 

values. Since the peak values are most important in determining the trend of the worst 20 

percent regional haze days, it makes sense to reconsider the best-fit lines for this purpose. 

These alternative slopes lead to conclusions that the CMAQ model’s peak predictions are 

too high (i.e., the model is over-responding, especially on the worst 20 percent regional 

haze days), and can result in a conclusion that certain emission components have an 

exaggerated effect on visibility. 
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Section 3

Reliant stated that the issue of how natural background is determined for the PSD Class I 

areas should be re-evaluated. The report indicates that ammonium sulfate is identified as 

the largest contributor to haze at MANE-VU Class I areas and virtually all ammonium 

sulfate is assumed to be the result of man-made emissions. However, the contribution of 

natural biogenic sources of ammonia, organic carbon, and sulfates may not be properly 

considered in the determination of naturally-occurring background visibility. 

Section 5

Reliant stated that there may be double-counting of benefits with the “167 EGU 

Strategy.” 

Reliant stated that all the control strategies tested result in insignificant changes in PM2.5

concentrations, even though the report mentions that the 167 EGU emission reductions 

will result in “significant reductions.” 

Reliant stated that the projected rates of visibility improvement do not appear to account 

for SO2 and NOx emission reductions required under Phase II CAIR. 

Reliant stated that for the “167 EGU Strategy,” there are apparent inconsistencies 

between the average change in 24-hour PM2.5 concentrations and projected visibility 

improvement at selected Class I areas located in the northern NESCAUM states. 

Reliant stated that there are insufficient details regarding the modeling runs, such as those 

conducted under the reduced sulfur fuel content control strategy. The details of emissions 

inputs to all of the modeling runs described in the report need to be made available to the 

public. 

Minor Changes

MARAMA pointed out that on page 1-3, footnote number 3 should be moved to page 1-

2. 

MARAMA stated that on page 1-11, the password for the MARAMA ftp site needs to be 

included so that the MANE-VU inventory can be accessed. The password is “exchange.” 

Please make this change throughout the document (i.e. page 1-12, regarding MRPO’s 

BaseK inventory). 

MARAMA stated that on page 1-15, the password for the second MARAMA ftp site 

needs to be included so that the CENRAP point source inventory can be accessed. The 

password is “emisdata.” Please make this change through the document. 

MARAMA noted that on page 1-19, sub-section 1.3.5, in number 5, the word “into” 

should be change to “in.” 
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MARAMA noted that after page 1-21, the page numbers are inconsistent (i.e. chapter 2 

begins with page 2-22, in chapter 2 page 28 does not have a chapter number, section 2.2 

starts on page 2-1, section 3 begins with page 3-10, etc). 

MARAMA stated that at the bottom of page 2-2, the second to last paragraph is repeated. 

MARAMA stated that on page 2-3, Figures 2-16 and 2-17 are numbered incorrectly. 

Reliant stated that in section 4, results from both CMAQ and REMSAD are shown, but 

there is little discussion regarding the consistency of these modeling results. 

Reliant stated that section 4 says that an important “region” for Acadia especially is 

“SE_BC”, but the meaning of this term and others in the figures needs more explanation.