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''L PRO"' UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 1 1 CONGRESS STREET , SUITE 1100 BOSTON , MASSACHUSETTS 02114- 2023
February 24 2009 Richard A. Valentinetti , Director Air Pollution Control Division 

### Vennont Department of Environmental Conservation Building 3 South 103 South Main Street Waterbur, Vennont 05671- 0402 Dear Mr. Valentinetti: On January 15 , 2009 , we received Vennont's proposed Regional Haze State Implementation Plan (SIP) and proposed Interstate Transport SIP. EP A staff have reviewed these proposals and you 

### wil find the Agency s comments in the Enclosures. If you have any questions on these comments , please contact 

### Ane McWiliams at (617) 918- 1697. Sincerely,

,.,,



### Ane Arold , Manager 

### Air Quality Planing Unit Enclosures

cc: Corie Dunn (VT DEC) Heidi Hales (VT DE

Toll Free. 1- 888- 372- 7341 Intemet Address (URL) . http://www. epa. gov/region1 Recycled/Recyclable .Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% postconsumer)Enclosure 

### EP A Comments on Vermont' 

### s Proposed Regional Haze SIP (1115/09)


### 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. 

### 1.6 Anatomv of Ree:ional Haze 2) We suggest the first full paragraph on page 11 be revised as follows: About half of the worst visibility days in Lye Brook occur in the summer when meteorological conditions are more conducive to the fonnation of sulfate from
S02 and to the oxidations of organic aerosols. In addition , '

liinter and summer transport patterns are different , possibly leading to diff-eent contributions from 

### upwind source regions. As a result The remaining worst visibility days are divided nearly equally among spring, winter and fall. In addition, winter and summer transport patterns are different, possibly leading to different contributions from upwind source regions
1 States Contributine: to Visibilty 

### Impairment at Lve Brook 3) It is not clear why Wisconsin is absent from Table 2.2 , "

States that Contribute to 

### Visibility Impainnent in the 

### MAN- 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 Impainnent at Vennont's Lye Brook Wilderness Areas.
2 Meetine: the " 

### Ask" - Vermont 4) This section states , "



### Vennont contains no BART-eligible sources , but intends to meet the tenns of the 

### MAN- VU agreement by pursuing the low-sulfur fuel oil strategy. Vennont should include more detail on the mechanism by which this wil become an enforceable par of the Vennont SIP (e. , does Vennont plan to adopt a rule and submit it to EP A for approval into the SIP?) 

### 2.4 Consultation Issues 5) Vennont should include more detail regarding its consultation with contributing states in particular expanding upon the statement that, "

A few non-

### MAN- VU states did not respond to Vennont' s consultation requests or responded by downplaying the magnitude of their states ' contributions to visibility impainnent at the Lye Brook Wilderness area. 

### 9. Best Available Retrofit Technoloe:v (BART) 6) The last full paragraph on page 82 should be revised as follows:

... there are currently 

## !!

BART -eligible sources in Vennont."A BART-eligible source , which by definition is a source that was installed and operated

between 1962 and 1977 , is not something that 

### wil later come into existence. Therefore the word " currently" is not appropriate. 

### 1 Bart-

### Elieible EGUs and the Role of CAIR 7) In the third bullet on page 83 

### , Vennont should delete Massachusetts from the list of non- CAIR states. 10. 

### 2.4 Tareeted EGU Strateey for S02 Reduction 8) Vennont should include a description of visibility improvement expected from controlling the 167 stacks in addition to the discussion of expected improvement in PM levels. 

### 11.9 Vermont' s Share of Emission 

### Reductions 9) Vennont states that it expects a nearly 85% reduction ofVennont's S02 emissions 

### from ICI boilers and residential heating units via MAN-VU' s low sulfur fuel oil 

### strategy. Vennont also cites the implementation of the Low Emissions Vehicle regulations and Vennont' 

### s regulation controllng Outdoor wood- fire boilers. Vennont wil need to submit all regulations that the State is taking credit for in its Regional Haze SIP to EP A for approval into the SIP.EPA Comment on Vermont Proposed 1l0(a)(2)(D) Transport SIP(1I15/09)

1. In Section V , Vennont should add reference to its proposed Regional Haze SIP.