STATE OF MICHIGAN

DEPARTMENT OF NATURAL RESOURCES & ENVIRONMENT

LANSING

JENNIFER M. GRANHOLM

GOVERNOR

November 5,2010

Ms. Susan Hedman, Administrator

U.S. Environmental Protection Agency

Region 5

Mail Code: R-19J

77 West Jackson Boulevard

Chicago, Illinois 60604-3507

Dear Administrator Hedman:

REBECCA A. HUMPHRIES

DIRECTOR

The Michigan Department of Natural Resources and Environment (DNRE) submits for your

approval the enclosed State Implementation Plan (SIP) for Regional Haze as required by

Section 169 of the Clean Air Act and the U.S. Environmental Protection Agency's Regional

Haze Rule.

The SIP submittal demonstrates that Michigan is meeting its reasonable progress goals and

best available retrofit technology plans for the two regional haze Class I areas in Michigan,

Isle Royale and Seney Wildlife Refuge.

If you have any further questions regarding this matter, please contact Mr. G. Vinson

Hellwig, Chief, Air Quality Division, at 517-373-7069; hellwigv@michigan.gov; or DNRE,

P.O. Box 30260, Lansing, Michigan 48909-7760.

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Rebecca A. Humphries

Director

517-373-7917

Enclosure

cc: Mr. Mike Koerber, LADCO

Mr. Jim Sygo, Deputy Director, Environmental Protection, DNRE

Mr. G. Vinson Hellwig, DNRE

Mr. Robert Irvine, DNRE

CONSTITUTION HALL· 525 WEST ALLEGAN STREET· P.O. BOX 30473 • LANSING, MICHIGAN 48909-7973

www.michigan.gov/dnre • (800) 662-9278
Michigan Department of Natural Resources and Environment 

Air Quality Division 

STATE IMPLEMENTATION PLAN SUBMITTAL 

FOR 

REGIONAL HAZE 

Michigan Department of Natural Resources and Environment 

Air Quality Division 

P.O. Box 30260 

Lansing, Michigan 48909-7760 

http://www.michigan.gov/deqair 

October 2010 
i

Table of Contents 

 Page

1 Background and Overview of the Federal Regional Haze Regulation ............................ 1 

 1.1 General Background/History of Federal Regional Haze Rule ............................. 1 

 1.2 Michigan’s Class I Areas ..................................................................................... 2 

 1.3 Other States’ Class I Areas ................................................................................. 2 

2 General Planning Provisions........................................................................................... 3 

3 Regional Planning ........................................................................................................... 5

 3.1 Midwest Regional Planning Organization (MRPO).............................................. 5 

 3.2 State Consultation ............................................................................................... 6 

 3.2.1 Northern Class I Area Consultation ......................................................... 6 

 3.2.2 MANE-VU Consultation ........................................................................... 8 

4 State and Federal Land Manager Coordination .............................................................. 9 

5 Modeling......................................................................................................................... 11 

 5.1 Methodology............ ........................................................................................ 11 

 5.2 Results ............................................................................................................... 12 

 5.3 CAIR Court Decision .......................................................................................... 15 

6 Assessment of Baseline and Natural Conditions ........................................................... 18 

 6.1 Isle Royale National Park Class I Area............................................................... 19 

 6.2 Seney Wilderness Area Class I Area ................................................................. 20 

7 Monitoring Strategy.. ...................................................................................................... 21

8 Emissions Inventory. ...................................................................................................... 22 

9 Best Available Retrofit Technology ................................................................................ 24 

 9.1 Process for Determining BART-subject Sources in the 

 State of Michigan................................................................................................ 24 

 9.2 Determination of BART Requirements for Identified Non-EGU 

 BART-subject Sources and Analysis of BART Controls for 

 Each Source....................................................................................................... 25 

 9.3 Determination of the Impacts of Visibility Impairing Pollutant 

 Emissions From Non-EGU BART-Subject Sources on Class I Areas................ 38 

10 Reasonable Progress Goals and Long-term Strategy ................................................... 40 

 10.1 Consultation ....................................................................................................... 40 
ii

Table of Contents, Continued 

 Page

 10.2 Basis for Emissions Reduction Obligations.........................................................40 

 10.2.1 Baseline Inventory ................................................................................40 

 10.2.2 Michigan’s Impact on Class I Areas......................................................40 

 10.2.3 States Impacting Michigan’s Class I Areas...........................................41 

 10.2.4 Pollutants and Sources Impacting Michigan’s Class I Areas................42 

 10.3 RPG Determination .............................................................................................44 

 10.3.1 General Approach to Determining RPG ...............................................45 

 10.3.2 DNRE’s Approach to RPG....................................................................46 

 10.4 Share of Emission Reductions ............................................................................56 

 10.5 Long-term Strategy..............................................................................................56 

 10.5.1 Emission Reductions Due to Ongoing Air Pollution 

 Programs ..............................................................................................56 

 10.5.2 Additional Emission Limitations and Schedules of 

 Compliance...........................................................................................57 

 10.5.3 Measures to Mitigate the Impacts of Construction Activities ................57 

 10.5.4 Source Retirement and Replacement Schedules.................................58 

 10.5.5 Agricultural and Forestry Smoke Management ....................................58 

 10.5.6 Enforceability of Emission Limitations and Control 

 Measures..............................................................................................59 

 10.5.7 Anticipated Net Effect on Visibility Resulting from 

 Projected Changes to Emissions..........................................................59 

 10.5.8 Potential Future Projects That Will Reduce Emissions.........................60 

 10.6 Reasonable Progress Goals................................................................................61 

 

11 Comprehensive Periodic Implementation Plan Revisions and 

 Determination of the Adequacy of the Existing Plan .......................................................62 

12 References......................................................................................................................64 
iii

Table of Contents, Continued 

List of Tables Page

Table 3.1.a. MRPO Members....................................................................................................5 

Table 5.2.a. Haze Results - Round 4 (Based on 2000-2004) .................................................13 

Table 5.2.b. Haze Results - Round 5.1 (Based on 2000-2004) ..............................................14 

Table 6.a. The average baseline dv of the 20 percent worst days with and 

 without missing data days ...................................................................................18 

Table 6.b. List of days added for Isle Royale and Seney showing the light 

 extinction for each fraction and the deciviews for the day...................................19 

Table 6.1.a. Baseline value, natural conditions, and uniform rate of progress 

 (URP) for 2018 for Isle Royale ............................................................................20 

Table 6.2.a. Baseline value, natural conditions, and uniform rate of progress 

 For 2018 for Seney..............................................................................................20 

Table 8.a. 2005, 2009 and 2018 Emissions Inventory Annual Emissions, 

 Tons Per Year .....................................................................................................23 

Table 9.1.a. Non-EGU BART-Subject Sources in the State of Michigan ................................25 

Table 9.2.a. Indurating Furnace NOx Control Technology......................................................34 

Table 9.2.b. Indurating Furnace SO2 Control Technology.......................................................35 

Table 9.2.c. Process Boiler SO2 Control Technology.............................................................35 

Table 9.2.d. Summary of Company Analysis for BART Controls ............................................37 

Table 9.3.a. BART Controls and Comparison of Visibility Impairing Pollutants 

 Impacts On Class I Areas....................................................................................39 

Table 10.2.2.a. Class I Areas impacted by Michigan .............................................................41 

Table 10.2.3.a. 2018 PSAT (Round 5) contribution to light extinction by state ......................42 

Table 10.3.2.a. Calpuff modeling, visibility and Q/d results for top ten (based on Calpuff) 

sources in Michigan impacting visibility at Isle Royale ..................................47 

Table 10.3.2.b. Calpuff modeling, visibility and Q/d results for top ten (based on Calpuff) 

sources in Michigan impacting visibility at Seney..........................................47 

Table 10.3.2.c. Top 30 facilities impacting visibility at Isle Royale, includes 

 facilities in and out of state ............................................................................48 

Table 10.3.2.d. Top 30 facilities impacting visibility at Seney, includes facilities 

 in and out of state..........................................................................................49 

Table 10.3.2.e. Summary of four-factor analysis of on-the-books controls ............................52 

Table 10.3.2.f. Comparison of Uniform Rate of Progress (URP) in 2018 

 With Projected Impacts for On-the-Books Controls.......................................53 

Table 10.3.2.g. Visibility Conditions, URP and RPG for Michigan’s Class I 

 areas (dv) ......................................................................................................55 

Table 10.6.a. Adjusted reasonable progress goals for Michigan’s Class I areas ................61 

Table 11.1. Activities prior to five year SIP assessment...................................................62 
iv

Table of Contents, Continued 

List of Figures Page

Figure 5.2.a. Visibility modeling results for Isle Royale and Seney. ............................. 12 

Figure 10.2.4.a. Comparison of pollutant contribution to visibility impact for 

 2002 base year, 2018 future year and 2064 natural conditions for 

Michigan’s Class I areas on the 20 percent worst days........................... 42 

Figure 10.2.4.b. Pollutant contribution to monthly light extinction values for 

 Michigan’s Class I areas (2000-2004) ..................................................... 43 

Figure 10.2.4.c. Isle Royale 2018 modeled extinction by sector for each specie 

 on 20 percent worst days ........................................................................ 43 

Figure 10.2.4.d. Seney 2018 modeled extinction by sector for each specie on 

 20 percent worst days ............................................................................. 44 

Figure 10.3.2.a. NOx and SO2 emissions in Michigan for 2005 and 2018 by 

 source category ....................................................................................... 46 

Figure 10.3.2.b. Source sector contribution to visibility improvement (deciviews) 

 at Isle Royale and Seney on the 20 percent worst days for 2018 

 for possible additional control measures ................................................. 54 

List of Appendices

1A: List of Class I Areas in or Impacted by Midwest RPO States 

2A: Public and FLM Comments and DNRE Responses 

3A: Midwest Regional Planning Organization, Principles for Regional Planning

3B: Regional Haze in the Upper Midwest: Summary of Technical Information

3C: MANE-VU Consultation Notes 

3D EPA Ask Letters 

5A: Original and Revised LADCO Technical Support Document for Regional Haze Modeling 

5B: Updated Glide Path Analyses for Regional Haze 

6A: Description of Isle Royale National Park and Seney Wilderness Area IMPROVE Sites 

8A: Emissions Inventory Methodology 

9A: DNRE BART Rules 

9B: Determining BART-Eligible and BART-Subject Facilities 

9C: Lafarge BART Technical Analysis 

9D: Lafarge Global Settlement/Consent Decree – Alpena Facility 

9E: St Mary’s Cement BART Technical Analysis 

9F: St Mary’s Cement BART Letter 

9G: St. Mary’s Cement Excerpts from ROP 

9H Tilden Mining Company BART Technical Analysis 

9I: Tilden Mining Company BART Letter 

9J: Tilden Mining Company Excerpts from ROP 

9K New Page Paper Company BART Technical Analysis 

9L: New Page Paper Company BART Letter 

9M: New Page Paper Excerpts from ROP 

10A: Minnesota’s Final Consultation Report 

10B: Conceptual Model - Causes of Haze in Seney Wilderness Area 

10C: Seney and Isle Royale Visibility Information 

10D: Calpuff Modeling, Q/d and Visibility for Isle Royale 

10E: Calpuff Modeling, Q/d and Visibility for Seney 

10F: OTC-LADCO Letter to EPA
v

LIST OF ACRONYMS 

AFGD 

AOI 

ASOA 

AQD 

B20% 

BACT 

BART 

BC 

Bext 

BOWA, BWCA 

BSOA 

CAA 

CAIR 

CALPUFF 

CAMR 

CAMx 

CEED 

CENRAP 

CFR 

CM 

CMAQ 

Commission 

DAA 

DSI 

EC 

ECR 

EFGR 

EGU 

EIMP 

ENVIRON 

EPA 

EPC 

FGD 

f(RH) 

FLM 

FPRM 

FS 

FWS 

HAPs 

ICI 

IDF 

IFGR 

IMPROVE 

IPM 

Advanced flue gas desulfurization 

Area of influence 

Anthropogenic secondary organic aerosol 

Air Quality Division 

Best 20 percent (days of visibility) 

Best Available Control Technology 

Best Available Retrofit Technology 

Boundary conditions 

Light extinction 

Boundary Waters Canoe Area Wilderness 

Biogenic secondary organic aerosol 

Clean Air Act 

Clean Air Interstate Rule 

California Puff Model 

Clean Air Mercury Rule 

Comprehensive Air Quality Model with extensions 

Center for Energy and Economic Development 

Central Regional Air Planning Association 

Code of Federal Regulations 

Coarse mass 

Community Multiscale Air Quality Modeling System 

Grand Canyon Visibility Transport Commission 

Dry absorption addition 

Dry Sorbent Injection 

Elemental carbon 

EC/R Incorporated consulting firm 

External flue gas recirculation 

Electric generating unit 

Empire Iron Mining Partnership 

ENVIRON International Corporation 

United States Environmental Protection Agency 

Escanaba Paper Company 

Flue gas desulfurization 

Relative Humidity adjustment factor 

Federal Land Manager 

Primary particulate (i.e. soil, crustal and metals) 

Forest Service 

Fish and Wildlife Service 

Hazardous Air Pollutants 

Institutional, commercial and industrial 

Indirect firing system 

Induced flue gas recirculation 

Interagency Monitoring of Protected Visual Environments 

Integrated Planning Model 
vi

ISLE1 

LADCO 

LNB 

LTO 

km 

LTS 

MACT 

MANE-VU 

MARAMA 

DNRE 

MDOT 

Mm-1 

MM5 

mmBtu 

MOBILE6 

MPCA 

MRPO 

NAAQS 

NEI 

NESCAUM 

NH4 

NO3 

NOx 

NOV 

non-EGU 

NPS 

NSR 

obs 

OC 

OMC 

OTB 

p80 

PM 

PM10 

PM2.5 

PMF 

POC 

PSAT 

PSD 

Q/D 

REMSAD 

RH 

RHR 

ROG 

Isle Royale National Park 

Lake Michigan Air Directors Consortium 

Low NOx Burner 

Low temperature oxidation 

kilometers 

Long-term strategy 

Maximum Achievable Control Technology 

Mid-Atlantic, Northeast Visibility Union 

Mid-Atlantic Regional Air Management Association 

Michigan Department of Natural Resources and Environment 

Michigan Department of Transportation 

Inverse Megameters 

Mesoscale Meteorological Model, 5th Generation (developed by 

Pennsylvania State University / National Center for Atmospheric 

Research PSU/NCAR) 

Million British thermal units 

MOBILE Vehicle Emission Modeling Software Version 6 

Minnesota Pollution Control Agency 

Midwest Regional Planning Organization 

National Ambient Air Quality Standards 

National Emissions Inventory 

Northeast State for Coordinated Air Use Management 

Ammonium 

Nitrate 

Nitrogen oxides 

Notice of Violation 

Non-electrical generating units 

National Parks Service 

New Source Review 

observed 

Organic carbon 

Organic mass carbon 

On-the-books 

80th percentile 

Particulate matter 

Particulate matter with aerodynamic diameters less than 10 microns 

Particulate matter with aerodynamic diameters less than 2.5 microns 

Positive matrix factorization method 

Particulate organic matter 

Particulate Matter Source Apportionment Technology 

Prevention of Significant Deterioration 

Emissions over distance (to Class I area) 

Regional Modeling Systems for Modeling and Deposition 

Relative Humidity 

Regional Haze Rule 

Reactive organic gasses 
vii

ROP 

RPG 

RPO 

RRF 

RVP 

SCR 

SDA 

SENE1 

SESARM 

SIP 

SMC 

SMP 

SNCR 

SO2 

SO4 

SOA 

SSCC 

TIP 

TMC 

tpy 

TSD 

URP 

VIP 

VISTAS 

VOC 

VOYA 

W20% 

WRAP 

WWESP 

Renewable operating permit 

Reasonable progress goal 

Regional Planning Organization 

Relative response factor 

Reid Vapor Pressure 

Selective catalytic reduction 

Spray dryer absorption 

Seney Wilderness Area 

Southeast State Air Resource Managers, Inc. 

State Implementation Plan 

St. Mary’s Cement 

Smoke Management Plan 

Selective non-catalytic reduction 

Sulfur dioxide 

Sulfate 

Secondary organic aerosol 

Smurfit Stone Container Corporation 

Tribal Implementation Plan 

Tilden Mining Company 

tons per year 

Technical Support Document 

Uniform rate of progress 

Visibility impairing pollutant 

Visibility Improvement State and Tribal Association of the Southeast 

Volatile organic compounds 

Voyageurs National Park 

Worst 20 percent (days of visibility) 

Western Regional Air Partnership 

Wet walled electrostatic precipitator 
1 Background and Overview of the Federal Regional Haze Regulation

1.1 General Background/History of Federal Regional Haze Rule

In the 1977 amendments to the Clean Air Act (CAA), Congress added Section 169 (42 USC 

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. 

Over the subsequent years, modest steps were taken to address the visibility problems in Class 

I areas. The control measures taken mainly addressed plume blight from specific pollution 

sources and did little to address regional haze issues in the Eastern United States. 

When the CAA was amended in 1990, Congress added Section 169B (42 USC 7492), 

authorizing further research and regular assessments of the progress being made. In 1993, the 

National Academy of Sciences concluded that “current scientific knowledge is adequate and 

control technologies are available for taking regulatory action to improve and protect visibility.”1

In addition to authorizing creation of visibility transport commissions and setting forth their 

duties, Section 169B(f) of the CAA mandated creation of the Grand Canyon Visibility Transport 

Commission (Commission) to make recommendations to the U.S. Environmental Protection 

Agency (EPA) for the region affecting the visibility of the Grand Canyon National Park. The 

Commission submitted its report to the EPA in June 1996, following four years of research and 

policy development. The Commission report, as well as the many research reports prepared by 

the Commission, contributed invaluable information to the EPA in its development of the federal 

Regional Haze Rule. 

The EPA’s Regional Haze Rule was adopted July 1, 1999, and went into effect on August 30, 

1999. The Regional Haze Rule aimed at achieving national visibility goals by 2064. This 

rulemaking addressed the combined visibility effects of various pollution sources over a wide 

geographic region. This wide-reaching pollution net means that many states – even those 

without Class I Areas – are required to participate in haze reduction efforts. The EPA 

designated five Regional Planning Organizations (RPOs) to assist with the coordination and 

cooperation needed to address the haze issue. The northern Midwest states of Indiana, Illinois, 

Michigan, Ohio, and Wisconsin formed the Midwest Regional Planning Organization (MRPO). 

The EPA’s Regional Haze rulemaking process was not without controversy and strife. On 

May 24, 2002, the U.S. Court of Appeals, D.C. District Court ruled on the challenge brought by 

the American Corn Growers Association against the EPA’s Regional Haze Rule of 1999. The 

court remanded to the EPA the Best Available Retrofit Technology (BART) provisions of the rule 

and denied industry’s challenge to the haze rule goals of natural visibility and no degradation 

requirements. The EPA has revised the Regional Haze Rule pursuant to the remand and on 

July 6, 2005, finalized its guideline for determining BART. 

On February 18, 2005, the U.S. Court of Appeals, D.C. Circuit Court issued a ruling based on a 

second suit, this one brought by the Center for Energy and Economic Development (CEED) 

challenging an optional emissions trading program (the WRAP Annex Rule). The EPA finalized 

revisions to the alternative trading programs on December 12, 2006. 

 

1 Protecting Visibility in National Parks and Wilderness Areas. National Research Council. Washington, DC: 1993. 
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze 

October 2010 

2

All Regional Haze State Implementation Plans (SIPs) were due three years after the EPA 

designates PM2.5 attainment and nonattainment areas. The EPA finalized PM2.5 designations 

for all areas of each state on December 17, 2004, and has determined that the Regional Haze 

SIPs were due by December 17, 2007. 

1.2 Michigan’s Class I Areas

Isle Royale National Park and Seney Wilderness Area are the two Class I areas in Michigan 

subject to the Regional Haze Rule. 

Isle Royale National Park, Michigan’s largest wilderness area, is an island, 571,790 acres in 

size, located in Lake Superior. Isle Royale was established as a national park in 1940 by 

President Franklin D. Roosevelt and was designated part of the National Wilderness 

Preservation System in 1976. In 1981, Isle Royale was designated an International Biosphere 

Reserve by the United Nations, giving it global scientific and educational significance. Well 

known for its timber wolves and moose, Isle Royale is the site of the longest running large 

mammal predator-prey study in the world. 

Seney Wilderness Area is 25,150 acres located in the western portion of the Seney National 

Wildlife Refuge in the Upper Peninsula of Michigan. The Refuge was established in 1935 and 

the Wilderness Area was designated by the U.S. Congress in 1970. Seney’s “string bogs” 

provide a unique habitat to a large variety of birds, mammals, and unusual plants. 

1.3 Other States’ Class I Areas

In accordance with 40 CFR 51.308, photochemical modeling has been performed to evaluate 

Michigan’s impact on other Class I areas. The criteria used to define one state’s “impact” on 

another state’s Class I area was not determined by the EPA; therefore, each state and RPO 

was given its own discretion to determine impacts. Based on the MRPO modeling and using a 

5 percent2

 or more contribution to total light extinction as impact criteria, emissions sources 

within Michigan impact only Isle Royale and Seney. More detailed analysis on Class I impacts 

is included in Appendix 1A. 

Additionally, the Michigan Department of Natural Resources and Environment (DNRE), formerly 

the Michigan Department of Environmental Quality, received letters from four states regarding 

impacts from Michigan sources. Based on the states’ analyses (see Appendix 1A), Class I 

areas within their jurisdiction are impacted by emissions from Michigan sources. The Class I 

areas are Acadia National Park and Moosehorn Wilderness Area in Maine, Great Gulf 

Wilderness Area in New Hampshire, Brigantine Wilderness Area in New Jersey, and Lye Brook 

Wilderness in Vermont.

 

2 Depending on the chosen impact level, more Class I areas may be impacted. Michigan chose a higher impact level 

of 5 percent. The states that make a 5 percent contribution or more to total light extinction accounts for 75-80 percent 

of total light extinction, whereas using a 2 percent contribution accounts for 90-95 percent of total light extinction. 

Since this is the first planning stage for regional haze, the DNRE believes the 5 percent contribution of states is more 

appropriate and can be tightened in later planning stages if needed. 
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze 

October 2010 

3

2 General Planning Provisions 

NOTE – THIS SIP IS BEING REVISED FOR THE THIRD TIME, WITH THE KEY REVISIONS 

BEING THE INCLUSION OF A SECTION ON BART (PART 9). THIS SECTION WAS NOT 

COMPLETE IN THE EARLIER VERSIONS OF THIS SIP, AS DETAILED BELOW. THE 

OTHER PARTS OF THIS SIP DOCUMENT HAVE MINIMAL CHANGES FROM THE 

PREVIOUS VERSION THAT RECEIVED PUBLIC COMMENT. 

Pursuant to the requirements of 40 CFR 51.308(a) and (b), the DNRE submits this SIP to meet 

the requirements of the EPA’s Regional Haze Rule adopted to comply with CAA requirements. 

Elements of this SIP address the Core Requirements pursuant to 40 CFR 51.308(d) and 

preliminary BART components of 40 CFR 50.308(e). In addition, the SIP addresses Regional 

Planning, state and Federal Land Manager (FLM) coordination, and contains a commitment to 

provide SIP revisions and adequacy determinations. 

The DNRE has authority to adopt the SIP under Part 55, Air Pollution Control, of the Natural 

Resources and Environmental Protection Act, 1994 PA 451, as amended (Act 451). 

The DNRE provided the first public notice of the opportunity to comment on the SIP on 

October 29, 2007, as well as an opportunity to request a public hearing. Although a hearing 

was tentatively scheduled for December 4, 2007, no requests for a hearing were received. 

Public comments were addressed and are summarized in Appendix 2A. 

Due to the extensive changes requested from the first comment period and the updating of 

information, a second public comment period was held. The DNRE provided the public notice of 

the second opportunity to comment on the SIP on September 29, 2008. The DNRE also 

provided notice of the opportunity to request a public hearing on September 29, 2008. Although 

a second hearing was tentatively scheduled for November 3, 2008, no requests for a hearing 

were received. Public comments were addressed and are summarized in Appendix 2A. 

The DNRE provided a third public comment period based on revisions made to the BART 

portion of the Regional Haze SIP. The DNRE provided the public notice of the third opportunity 

to comment on the SIP on May 24, 2010. The DNRE also provided notice of the opportunity to 

request a public hearing on May 24, 2010. A public hearing was tentatively scheduled for 

June 29, 2010, but no requests for a hearing were received. Public comments were addressed 

and summarized in Appendix 2A. 

Public comments for the 2007 Regional Haze SIP draft varied, from being generally supportive 

of the SIP to being very critical. Commenters supported the “Clean Air Interstate Rule (CAIR) 

equals BART” assumption and DNRE’s regional progress approach. Commenters also wanted 

monitoring to continue at the Class I areas, encouraged using the 2005 inventory for planning 

purposes, discussed the Isle Royale monitor location, and wanted glide path diagrams included 

in the SIP. The DNRE agreed with these comments and updated the SIP appropriately. One 

commenter wanted clearly defined milestones to 2064. The DNRE believes the Reasonable 

Progress Goals (RPGs) indicate these milestones. The FLMs were critical, expressing concern 

that a number of areas were not adequately addressed. Additional information was added to 

the document to address these concerns. 

Public comments for the 2008 draft of the Regional Haze SIP were received only from the FLMs 

and from Region 5 EPA. The FLMs generally repeated their comments from the 2007 public 
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze 

October 2010 

4

comment period. The EPA agreed with the comments submitted by the FLMs, commenting that 

BART and other control measures should be included in the SIP. The DNRE addressed these 

comments in Appendix 2A, as well as in the SIP document. The EPA also suggested some 

editorial changes, which the DNRE has made. 

Public comments for the 2010 draft of the Regional Haze SIP were received only from the FLMs 

and from Region 5 EPA. The FLMs repeated some comments from the 2008 public comment 

period, but also had several comments on the BART section of the SIP. The EPA had many 

similar comments as the FLMs. The DNRE addressed these comments in Appendix 2A, as well 

as in the SIP document. 
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze 

October 2010 

5

3 Regional Planning 

3.1 Midwest Regional Planning Organization (MRPO)

In 1999, the EPA and affected states/tribes agreed to create five RPOs to facilitate interstate 

coordination on Regional Haze SIP/TIPs. The State of Michigan is a member of the MRPO, 

although the organization is not actively involved in Regional Haze work because of lack of 

federal funding. Members of the MRPO are listed in Table 3.1.a., below: 

Table 3.1.a. MRPO Members 

Indiana Wisconsin 

Illinois Tribal Leaders (MI and WI) 

Michigan EPA Region V 

Ohio Federal Land Managers 

The Lake Michigan Air Directors Consortium (LADCO) was started in 1989 by the states of 

Illinois, Indiana, Michigan, and Wisconsin in conjunction with the EPA to oversee the Lake 

Michigan ozone study. Ohio later joined as the fifth state member. The EPA encouraged states 

to form regional partnerships to address the Regional Haze Rule and the MPRO was formed in 

1999. 

The MRPO established an active committee structure to address both technical and nontechnical issues related to regional haze. The three main committees are as follows: 

• The Policy Steering Committee provides the overall policy direction for the regional 

planning effort and serves as the forum for the resolution of disputes. This committee is 

composed of state environmental commissioners, tribal representatives, the EPA and 

the FLMs. 

• The Technical Steering Committee is responsible for the management of the regional 

planning effort. This committee is composed of the state air directors, as well as tribal, 

EPA, and FLM representatives. 

• The Project Team meets on a regular basis to carry out the directions of the Technical 

Steering Committee and to guide the development of the regional planning effort. The 

Project Team may form appropriate technical workgroups as necessary to address 

specific concerns (e.g., monitoring, emissions, data analysis, and modeling). 

LADCO provided supportive activities for the three committees (see Appendix 3A). 

MRPO technical workgroups

The MRPO has three technical workgroups that met monthly and/or as needed for project 

inputs. The workgroups are for data analysis, emissions inventory, and modeling. 

Meetings were scheduled separately for each technical workgroup. Most information was 

shared through conference calls, via e-mail, and in person at annual or semi-annual 

conferences. Because of its centrally located staff, the MRPO also communicated and provided 

data, tools, and information individually to states based on specific needs. 
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze 

October 2010 

6

This SIP utilizes data analysis, modeling results and other technical support documents 

prepared for MRPO members. The LADCO staff provided much of the technical resources for 

the MRPO. Many of these technical analyses, as well as minutes for the Northern Class I area 

consultation process, can be found on their Web site. 

3.2 State Consultation

A chief purpose of the RPO was to provide a means for states to confer on all aspects of 

regional haze, including consulting on reasonable progress goals and long-term strategies 

based on determinations of baseline and natural visibility conditions. The MRPO provided a 

forum for the member states and tribes to consult on the determination of visibility conditions in 

each of the Class I areas. 

The DNRE has worked with states that are members of the Central Regional Air Planning 

Association (CENRAP), MRPO, and the Western Regional Air Partnership to convene meetings 

of representatives from the states and tribes that impact visibility in the four Northern Class I 

areas – Boundary Waters and Voyagers in Minnesota and Isle Royale and Seney in Michigan – 

along with FLMs and EPA representatives involved with the Northern Class I areas. This group 

engaged in extensive consultation about visibility conditions and control strategies needed to 

improve visibility at these four Class I areas. 

The DNRE also worked with states from the Mid-Atlantic, Northeast Visibility Union (MANE-VU) 

region that identified Michigan as contributing to five of their Class I areas. Any state that 

contributes >2 percent sulfate, >0.1ug/m3

 sulfate, or one of the top ten sulfate-contributing 

states based on the 20 percent worst days were contacted by MANE-VU (MANE-VU, 2007). 

The five MANE-VU Class I areas are Acadia National Park and Moosehorn Wilderness Area in 

Maine, Great Gulf Wilderness Area in New Hampshire, Brigantine Wilderness Area in New 

Jersey, and Lye Brook Wilderness in Vermont. 

3.2.1 Northern Class I Area Consultation

As described above, consultation among states is a requirement of the Regional Haze Rule. As 

part of the long-term strategy for regional haze, a state whose emissions are “reasonably 

anticipated” to contribute to impairment in other states’ Class I area(s) must consult with those 

states; likewise, a Class I host state must consult with those states whose emissions affect its 

Class I area(s) (40 CFR 51.308(d)(3)). The Northern Class I area consultation was convened to 

assist in the SIP development for the Class I areas in Michigan and Minnesota. 

Participants

The Northern Class I areas consultation process included the states of Michigan, Minnesota, 

North Dakota, Wisconsin, Iowa, Illinois, Indiana, and Missouri. The consultation process also 

included representatives from other governments, such as the Ontario Ministry of the 

Environment and tribes including the Leech Lake Band of Ojibwe, Mille Lacs Band of Ojibwe, 

Fond du Lac Band of Lake Superior Chippewa, Grand Portage Band of Chippewa, Upper/Lower 

Sioux, and Huron Potawatomi. 

The Northern Class I consultation process included representatives from federal agencies, 

including the FLMs from the U.S. Department of the Interior National Park Service and the U.S. 

Department of Agriculture Forest Service, as well as representatives from the EPA. This 

consultation partially fulfills the DNRE’s requirement under 40 CFR 51.308(i) to coordinate and 
Michigan Department of Natural Resources and Environment 

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consult with FLMs on areas such as implementation, assessment of visibility impairment, 

recommendations regarding the reasonable progress goal, and strategies for improvement. 

Process

In 2004 and 2005, a number of discussions were held between state and tribal representatives 

in the upper Midwest concerning air quality planning to address regional haze in the four Class I 

areas in Michigan and Minnesota. 

Formal discussions geared toward specific SIP requirements began in July 2006, when the 

DNRE participated in a conference call with representatives from North Dakota, Iowa, 

Wisconsin, Minnesota, the Mille Lacs and Leech Lake Bands of Ojibwe, and FLMs, RPO, and 

EPA representatives. This group determined that additional parties should be added to the 

process and that this group should continue the dialog through conference calls approximately 

every three weeks during the development of the Regional Haze SIPs. 

The first several months of calls focused on developing an agreed-upon technical base of 

information about the visibility conditions in the four Class I areas. This included documenting 

baseline and natural visibility conditions and determining the chemical constituents of haze and 

key contributors to visibility impairing emissions (i.e., geographical location, type of sources, and 

source categories). The shared technical work is documented in a technical memo, “Regional 

Haze in the Upper Midwest: Summary of Technical Information,” (see Appendix 3B). 

The consultation group also shared modeling results, discussed visibility improvement expected 

to result from on-the-books controls, and discussed BART and other control strategies. As part 

of the consultation process, LADCO managed a contract where various control strategies were 

evaluated based on the designated four factors. The four factors of cost, time necessary for 

compliance, energy and other impacts, and remaining equipment life must be considered in 

establishing a reasonable progress goal (RPG) toward achieving natural visibility conditions in 

mandatory Class I areas. The consultation group provided input to LADCO on each part of the 

project. The control strategies that were evaluated included on-the-books controls, various 

sector level controls, and some facility-specific control measures (Battye, et. al., 2007). 

The states involved in the consultation group also collaborated to ensure that a consistent future 

year scenario was used by all states. For example, it was agreed to use version 3.0 of the 

EPA’s Integrated Planning Model (IPM) as the basic prediction tool for EGU emissions in 2018. 

All documentation of the Northern Class I areas consultation process can be found on the 

LADCO/MRPO Web site. This Web site includes documentation of the minutes from each 

group conference call, including a list of participants, as well as various other documents related 

to the Northern Class I consultation process. The minutes and documents show the major 

decisions that the members of the Northern Class I consultation process felt were important to 

discuss and document at the group level. 
Michigan Department of Natural Resources and Environment 

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3.2.2 MANE-VU Consultation

The four MANE-VU states containing Class I areas are Maine, Vermont, New Jersey and New 

Hampshire, and they contacted the DNRE in “Ask” letters. These letters indicated that Michigan 

was impacting their Class I areas and requested consultation with the DNRE and several other 

states outside of MANE-VU to fulfill the consultation requirements of the Regional Haze Rule. 

The DNRE and MANE-VU had several telephone calls and an in-person conference on 

August 6, 2007 (see Appendix 3C). MANE-VU shared the results of their modeling and their 

requests for emissions reductions from other states. This information is detailed in MANE-VU’s 

“Inter-RPO Consultation Briefing Book,” (MANE-VU, 2007) and is outlined in Section 10 of this 

SIP. In addition, the LADCO and MANE-VU states formed a workgroup to develop a proposal 

to give EPA for a CAIR replacement rule and ICI boiler controls. The joint letter to EPA 

discusses the proposal where all states were in agreement. The separate letters from LADCO 

and MANE-VU are areas where the groups did not agree, thus sent separate letters with each 

group’s proposal. The letters sent to EPA as a result of these discussions are shown in 

Appendix 3D. 
Michigan Department of Natural Resources and Environment 

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4 State and Federal Land Manager Coordination 

Coordination between state/tribes and the FLMs is required by 40 CFR 51.308(i). Opportunities 

have been provided by the MRPO for the FLMs to review and comment on the technical 

documents developed by the MRPO. The DNRE has provided agency contacts to the FLMs as 

required. In development of this SIP, the FLMs were consulted in accordance with the 

provisions of 40 CFR 51.308(i)(2). FLMs participated in the Northern Class I area calls, as well 

as the MANE-VU consultation, as described in Section 3. 

The DNRE provided the FLMs an opportunity for consultation prior to the scheduled date of a 

public hearing on the SIP. Since no public hearings were requested, none were held. 

During the consultation process, the FLMs were given the opportunity to provide their: 

• Assessment of the impairment of visibility in any Class I areas; 

• Recommendations on the development of reasonable progress goals; and 

• Recommendations on the development and implementation of strategies to address 

visibility impairment. 

The DNRE sent the draft SIP to the FLMs on October 16, 2007. The DNRE notified the FLMs of 

the opportunity for a public hearing tentatively scheduled for December 4, 2007. Comments 

received from the FLMs were addressed. A summary of the FLM comments and responses is 

included in Appendix 2A. 

The DNRE held a second comment period and opportunity to request a public hearing on the 

Regional Haze SIP due to extensive comments, additional information (e.g., the emissions 

inventory), and changes due to the CAIR vacatur. The draft SIP was sent to the FLMs on 

September 30, 2008. The DNRE notified the FLMs of a tentatively scheduled public hearing for 

November 3, 2008. Comments received from the FLMs were addressed, and a summary of the 

FLMs comments and responses is included in Appendix 2A. 

The DNRE held a third comment period and opportunity to request a public hearing on the 

Regional Haze SIP due to completion of the BART portion of the SIP. The draft SIP was sent to 

the FLMs in May 2010. The DNRE notified the FLMs of a tentatively scheduled public hearing 

for June 29, 2010. Comments received from the FLMs on the SIP were addressed and a 

summary of the FLMs comments and responses were included in Appendix 2A. 

In response to the FLM comments to date, the DNRE has made significant updates to the 

emissions inventory, monitoring, and RPGs for the best and worst 20 percent visibility days, 

areas of influence, modeling information, wildland fires, contingency measures, and information 

in periodic reports. The DNRE also made some editorial corrections as suggested by the FLMs. 

The FLMs made several comments about BART being incomplete and not including electric 

generating units (EGUs). The DNRE acknowledged that BART was incomplete and is 

submitting BART determinations in this 2010 regional haze SIP submittal. 

The DNRE commits to coordinate and consult with the FLMs during the development of future 

progress reports and SIP revisions, as well as during the implementation of programs having 

the potential to contribute to visibility impairment in the mandatory Class I areas. The FLMs will 

be consulted in the following instances: 
Michigan Department of Natural Resources and Environment 

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• Development and review of Regional Haze SIP revisions; 

• Review of five-year progress reports; and 

• Development and implementation of other programs that may contribute to impairment 

of visibility in Class I areas. 
Michigan Department of Natural Resources and Environment 

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5 Modeling 

A description of the photochemical modeling performed for this SIP can be found in Regional Air 

Quality Analysis for Ozone, PM2.5 and Regional Haze: Final Technical Support Document 

(LADCO 2008, Appendix 5A). Section 5 of this document discusses the modeling analysis and 

Section 10 discusses reasonable progress for regional haze. 

 5.1 Methodology

LADCO performed the modeling for both 2002 and 2005 base years using the Comprehensive 

Air Quality Model with extensions (CAMx). The most recent modeling run, for 2005, is called 

Base M. Examination of multiple base years provides for a more complete technical assessment. The future year of interest for the Haze SIP is 2018, the first milestone year, and 

therefore was modeled as well (page 47 of TSD, Appendix 5A). 

A “base” control scenario was prepared for each future year based on the following “on-thebooks” controls: 

On-Highway Mobile Sources 

 Federal Motor Vehicle Emission Control Program, low-sulfur gasoline and ultra-low 

sulfur diesel fuel. 

 Inspection - maintenance programs, including Illinois’s vehicle emissions tests (northeast 

Illinois), Indiana’s vehicle emissions testing program (northwest Indiana), Ohio’s E-check 

program (northeast Ohio), and Wisconsin’s vehicle inspection program (southeast 

Wisconsin) – note: a special emissions modeling run was done for the Cincinnati/Dayton 

area to reflect the removal of the state’s E-check program and inclusion of low Reid 

Vapor Pressure (RVP) gasoline. 

 Reformulated gasoline, including Chicago-Gary, Lake County in Illinois and Indiana; and 

Milwaukee, Racine in Wisconsin; and Low RVP in Southeast Michigan. 

Off-Highway Mobile Sources 

 Federal control programs incorporated into NONROAD model (e.g., nonroad diesel rule), 

plus the evaporative Large Spark Ignition and Recreational Vehicle standards. 

 Heavy-duty diesel (2007) engine standard/low sulfur fuel. 

 Federal railroad/locomotive standards. 

 Federal commercial marine vessel engine standards. 

Area Sources (Base M only) 

 Consumer products/solvents. 

 AIM coatings. 

 Aerosol coatings. 

 Portable fuel containers. 

Power Plants 

 Title IV (Phases I and II). 

 Nitrogen oxides (NOx) SIP Call. 

 CAIR. 

Other Point Sources 

 VOC 2-, 4-, 7-, and 10-year MACT standards. 

 Combustion turbine MACT. 

Other controls included in the modeling include consent decrees (refineries, ethanol plants, and 

ALCOA), NOx RACT in Illinois and Ohio, and BART for a few non-EGU sources in Indiana and 
Michigan Department of Natural Resources and Environment 

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Wisconsin. Modeling will be redone to include BART for Michigan when emissions information 

for the Lafarge controls is determined. These data are scheduled to be available no later than 

2016. Other BART sources in other states are expected to have controls in place by this date 

as well, allowing for revised modeling. 

 5.2 Results

The uniform rate of visibility improvement values for the 2018 planning year were derived for the 

20 percent worst visibility days based on a straight line between baseline concentration value 

(plotted in the year 2004 -- end year of the 5-year baseline period) and natural condition value 

(plotted in the year 2064 -- date for achieving natural conditions). The 20 percent best visibility 

days should not degrade from the 2004 baseline values over the 60-year period. Plots of these 

“glide paths” for the 20 percent worst days (downward sloping line) and the 20 percent best 

days (horizontal line) for Isle Royale and Seney with the Base M modeling results are presented 

in Figure 5.2.a. (LADCO, 2008, see Appendix 5A). An updated glide path analysis was 

performed by LADCO in February 2010 and can be found in Appendix 5B. Tabular summaries 

of measured baseline and modeled future year deciview (dV) values for both areas are provided 

in Table 5.2.a. (2002 base year) and Table 5.2.b. (2005 base year) (LADCO, 2008, see 

Appendix 5A). 

Isle Royale Seney 

Figure 5.2.a. Visibility Modeling Results for Isle Royale and Seney 
Michigan Department of Natural Resources and Environment 

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October 2010 

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Table 5.2.a. Haze Results - Round 4 (Based on 2000-2004) 

Source: LADCO TSD p 99 
Michigan Department of Natural Resources and Environment 

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October 2010 

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Table 5.2.b. Haze Results - Round 5.1 (Based on 2000-2004) 

Source: LADCO TSD, p. 100 
Michigan Department of Natural Resources and Environment 

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October 2010 

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The haze modeling results show that several Class I areas in the Eastern United States are 

expected to be greater than (less improved than) the uniform rate of visibility improvement 

values for 2018, including those in northern Michigan and several in the Northeastern United 

States. Many other Class I areas in the Eastern United States are expected to be less than 

(more improved than) the uniform rate of visibility improvement values for 2018. As noted 

above, states should consider these results, along with information on the other four factors, in 

setting reasonable progress goals. 

For Seney, the 20 percent best days shows a slight increase in baseline values by 2018. Since 

the increase at Seney is small (only a few percent), a reasonable interpretation of the modeling 

is that there is little expected change in the clean day visibility levels. In looking at the clean day 

model results, it appears that there is a significant increase in nitrate levels due apparently to 

greater ammonia emissions (in 2018). While growth for ammonia was assumed for 2018, and 

no controls on ammonia emissions were added, any assumptions regarding levels of ammonia 

emissions are estimates at best. An assumption could also be made that no growth occurs; in 

that case, the modeling would show a decrease in the 2018 clean day visibility levels. Thus the 

modeled change should not be interpreted to reflect a negative change. Further, the 2018 

modeling generally did not include BART emission reductions from non-EGUs. Thus BART 

controls in northern Minnesota, Wisconsin, and Michigan will result in lower values than those 

shown in the Base M modeling. In addition in recent model runs (see Appendix 5B) the actual 

values (red triangles) are lower than the modeled values. The values on the 20 percent best 

days are well below the baseline values and the values for the 20 percent worst days are in line 

with uniform rate of progress. While modeled values continue to be refined, there remains 

much uncertainty, and modeled values may be over predicting the actual values. 

5.3 CAIR Court Decision

On December 23, 2008, the U.S. Court of Appeals for the D.C. Circuit issued its opinion 

remanding the CAIR rule to the EPA. The EPA has been working on a CAIR replacement rule, 

and in August 2010 the proposed CAIR replacement rule, called by some the Clean Air 

Transport Rule (CATR) was published in the Federal Register. It is unclear how similar the new 

rule will be to CAIR Phase II until CATR is finalized. 

LADCO did some additional modeling of a scenario reflecting emissions from EGUs with only 

CAIR Phase 1 in place along with other known EGU emission reductions. An explanation of the 

modeling methodologies and results can be found in a revised Technical Support Document in 

Appendix 5B.

Because of the timing constraints under which the DNRE is operating for submitting the Haze 

SIP, this SIP document reflects haze planning, modeling, etc. with CAIR still in place. However, 

the DNRE acknowledges that EGU future emissions may be different when CATR is finalized. 

Current controls on EGUs in Michigan are detailed below. 

The following data was taken from the Michigan Air Emissions Reporting System (MAERS): 

Marquette Board of Light and Power

Boiler #2, 22 MW with Baghouse 

Boiler #3 44 MW with flue gas desulphurization (dry scrubber) and Baghouse 
Michigan Department of Natural Resources and Environment 

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October 2010 

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Consumers Energy JH Campbell

Boiler #1 265.2 MW with ESP and low NOx Burners 

Boiler #2 403.92 MW with ESP and low NOx Burners 

Boiler #3 855.43 MW with ESP, low NOx Burners and SCR 

Consumers Energy B. C. Cobb Plant

Boiler #1 809 MMBTU with Low NOx Burners*

Boiler #2 809 MMBTU with Low NOx Burners*

Boiler #3 809 MMBTU with Low NOx Burners*

Boiler #4 156.25 MW with ESP 

Boiler #5 156.25 MW with ESP 

Consumers Energy Karn-Weadock Facility

Karn Boiler #1 272 MW with ESP and SCR 

Karn Boiler #2 272 MW with ESP, low NOx Burners and SCR 

Karn Boiler #3 692.5 MW with Low NOx Burners**

Karn Boiler #4 709.75 MW with Low NOx Burners**

Weadock Boiler #7 156.25 MW with ESP 

Weadock Boiler #8 156.25 MW with ESP 

DTE Monroe Power Plant

Boiler #1 800 MW with ESP, low NOx Burners and SCR 

Boiler #2 800 MW with ESP and low NOx Burners 

Boiler #3 800 MW with ESP, low NOx Burners, SCR and Wet Scrubber 

Boiler #4 800 MW with ESP, low NOx Burners, SCR and Wet Scrubber 

DTE St Clair / Belle River

St Clair boiler #1 150 MW with ESP 

St Clair boiler #2 150 MW with ESP 

St Clair boiler #3 150 MW with ESP 

St Clair boiler #4 150 MW with ESP 

St Clair boiler #5 with ESP (Not operating) 

St Clair boiler #6 350 MW with ESP 

St Clair boiler #7 450 MW with ESP 

Belle River Unit #1 697 MW with ESP 

Belle River Unit #2 635 MW with ESP 

Has several small diesel generators that are uncontrolled. 

Wisconsin Electric Power Co 

Boiler #3 44 MW with Baghouse 

Boiler #4 44 MW with Baghouse 

Boiler #5 79 MW with Baghouse, ESP and Low NOx Burners 

Boiler #6 79 MW with Baghouse, ESP and Low NOx Burners 

Boiler #7 79 MW with Baghouse, ESP and Low NOx Burners 

Boiler #8 79 MW with Baghouse, ESP and Low NOx Burners 

Boiler #9 79 MW with Baghouse, ESP and Low NOx Burners 

* Natural gas fired

** Permitted to burn natural gas and fuel oil
Michigan Department of Natural Resources and Environment 

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October 2010 

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Escanaba Power Plant

Boiler #1 12.5 MW with multi-cyclone and ESP 

Boiler #2 12.5 MW with multi-cyclone and ESP 

In addition, some of the sources submitted information about proposed or installed controls 

directly to our unit. The following data was obtained from DTE: 

DTE Trenton Channel 

Unit 9A 520 MW with ESP and Low NOx Burners w/ OFA Installed 2005
Michigan Department of Natural Resources and Environment 

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October 2010 

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6 Assessment of Baseline and Natural Conditions 

Under the CAA, the Regional Haze SIPs must contain measures to make reasonable progress 

toward the goal of achieving natural visibility. Comparing natural visibility levels to current 

baseline conditions helps indicate how much progress we should try to make in the next five 

years. Determining natural visibility conditions is a SIP element and each state containing a 

Class I area (in consultation with FLMs and other states) must estimate natural visibility levels. 

The MRPO calculated dV estimates for the 20 percent best and worst days using the new 

Interagency Monitoring of Protected Visual Environments (IMPROVE) equation. However, the 

MRPO, along with Minnesota, discovered several days in the data set that had high sulfate or 

nitrate (which would be in the worst 20 percent), but due to missing data (e.g., coarse mass, 

soil), were not included in the estimate. Since sulfates and nitrate are from anthropogenic 

sources, the MRPO and Minnesota included these days in our estimated 20 percent worst days. 

Table 6.a. shows the average baseline deciviews for the 20 percent worst day averages with 

and without the missing days and the difference in deciviews between the two averages. 

Table 6.b. shows the days that were added for Isle Royale and Seney. 

Table 6.a. The average baseline dv of the 20 percent worst days with and 

without the missing data days 

 

Average 

Worst Day 

(dV), per RHR

Average Worst Day 

(dV), with Missing 

Data Days 

Difference 

Isle Royale 20.74 21.59 0.85 

Seney 24.16 24.37 0.22 

Source: Kenski, 2007 
Michigan Department of Natural Resources and Environment 

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October 2010 

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Table 6.b. List of days added for Isle Royale and Seney showing the light extinction for 

each fraction and the deciviews for the day 

Date 

Fine 

Soil 

(Mm-1)

Ammonium 

Nitrate 

(Mm-1)

Light 

Absorbing 

Carbon 

(Mm-1)

Course 

Mass 

(Mm-1)

Ammonium 

Sulfate 

(Mm-1)

Organic 

Mass 

(Mm-1)

p80 Deciview 

Isle Royale 

2/23/2000 83 4.9 33.7 11.4 16.4 26.7

8/5/2000 0.4 3.6 7.9 22.7 13 16.4 17.8

8/12/2000 0.3 2.8 7.8 20.2 10.2 16.4 16.7

3/29/2001 53.8 4 36.7 6.9 18 24.3

4/1/2001 5.2 3.1 53.6 5.2 18 20.7

9/8/2002 1.6 4.1 132.9 18.9 16.9 28.3

2/26/2003 0.5 61.4 4.4 16.2 15.9 22.5

3/16/2003 140.3 6.2 51.6 12.3 15.9 31

7/26/2003 3.8 5.8 50.1 21.3 15.9 22.3

8/19/2003 3.4 5.4 62 21.5 15.9 23.4

9/9/2003 3.7 5.4 88.1 15.4 15.9 25.2

9/12/2003 2.2 6.7 299.7 11.7 15.9 35

3/25/2004 47.6 5.2 58 15.5 15.7 26.3

Seney 

3/22/2000 0.2 25.7 0.8 48.3 19.5 21.6

12/12/2001 105.9 5.8 60.8 17.7 22 30.1

9/8/2002 4.1 6.4 351.6 19.5 21.6 36.7

 6.1 Isle Royale National Park Class I Area

The Isle Royale National Park Class I area has an established baseline visibility of 6.77 dV for 

the cleanest 20 percent of the days and 21.59 dV for the 20 percent worst visibility days. This is 

based on data at the Isle Royale (ISLE1) IMPROVE monitoring site (near Eagle Harbor), 

described in Appendix 6A. A 5-year average (2000 to 2004) was calculated to derive each 

baseline value (see Table 6.1.a.) in accordance with 40 CFR 51.308(d)(2), and is detailed on 

pages 6 and 7 of Appendix 3B. 

Natural background represents the visibility goal for each Class I area to be reached in 2064 

and is visibly representative of the conditions before human activities affected air quality in the 

area. The EPA guidance provides a “default” method of estimating natural visibility, which the 

MRPO used to estimate natural visibility. The Isle Royale Class I area has an estimated natural 

background visibility of 3.72 on the best days and 12.36 on the worst 20 percent of days. These 

best and worst 20 percent conditions were calculated using the above-referenced EPA 

Source: Kenski, 2007 
Michigan Department of Natural Resources and Environment 

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October 2010 

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guidelines, and the baseline and natural conditions along with the URP line are shown in 

Figure 5.2.a., above. 

Table 6.1.a. Baseline value, natural conditions, and uniform rate of progress (URP) for 

2018 for Isle Royale 

 2000 2001 2002 2003 2004 

Baseline 

Value 

2018 

URP 

Value 

Natural 

Conditions

20% Worst 

Days 20.53 23.07 21.97 22.35 20.02 21.59 19.43 12.36

20% Best Days 6.49 7.16 7.07 6.99 6.12 6.77 3.72

 6.2 Seney Wilderness Area Class I Area

The Seney Wilderness Area Class I area has an established baseline visibility of 7.14 dV for the 

cleanest 20 percent of the days and 24.37 dV for the 20 percent worst visibility days. This is 

based on onsite data at the Seney (SENE1) IMPROVE monitoring site, described in Appendix 

6A. A five-year average (2000 to 2004) was calculated to derive each baseline value (see 

Table 6.2.a.) in accordance with 40 CFR 51.308(d)(2), and is detailed on pages 6 and 7 of 

Appendix 3B. 

Natural background represents the visibility goal for each Class I area to be reached in 2064, 

visibly representative of the conditions before human activities affected air quality in the area. 

The Seney Class I area has an estimated natural background visibility of 3.73 on the best days 

and 12.65 on the worst 20 percent of days. These best and worst 20 percent conditions were 

calculated using the above-referenced EPA guidelines, and the baseline and natural conditions 

along with the URP line are shown in Figure 5.2.a., above. 

Table 6.2.a. Baseline value, natural conditions, and uniform rate of progress 

for 2018 for Seney 

 2000 2001 2002 2003 2004 

Baseline 

Value 

2018 

URP 

Value 

Natural 

Conditions

20% Worst 

Days 22.94 25.91 25.38 24.48 23.15 24.37 21.64 12.65

20% Best Days 6.5 6.78 7.82 8.01 6.58 7.14 3.73

Modified from Appendix 3B, p. 8 

Modified from Appendix 3B, p. 8 
Michigan Department of Natural Resources and Environment 

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October 2010 

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7 Monitoring Strategy 

A monitoring strategy for measuring, characterizing, and reporting regional haze visibility 

impairment that is representative of all mandatory Class I areas within the state of Michigan is 

required by 40 CFR 51.308(d)(4) of the federal Regional Haze Rule. The monitoring strategy 

relies upon participation in the IMPROVE network. 

The state evaluates its monitoring network periodically and makes changes as needed. 

However, to be able to assess whether reasonable progress goals are being achieved in each 

of Michigan’s mandatory Class I areas, the federal IMPROVE monitors are needed. 

The DNRE commits to meeting the requirements under 40 CFR 51.308(d)(4)(iv) to report to the 

EPA visibility data for each of Michigan’s Class I areas annually based on IMPROVE data. 

Should federal funding be eliminated for the IMPROVE network, the state of Michigan may not 

be able to continue monitoring at Isle Royale and Seney. The DNRE has eliminated several 

monitors in other locations of Michigan because of state budget problems and reduced EPA 

funding. Michigan cannot afford to maintain additional monitors. Should federal funding be 

eliminated, the state would seek funding from other sources. 
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October 2010 

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8 Emissions Inventory 

A statewide emission inventory of pollutants that are reasonably anticipated to cause or 

contribute to visibility impairment in any mandatory Class I area is required by 

40 CFR 51.308(d)(4)(v). The DNRE believes that sulfur dioxide (SO2) and NOx are the main 

components of regional haze and thus are included in our analyses. As specified in the 

applicable EPA guidance, the pollutants inventoried by the DNRE include volatile organic 

compounds (VOCs), NOx, fine particulate (PM2.5), coarse particulate (PM10), ammonia, and 

SO2. 

A description of the methodology used to prepare the inventory appears in Appendix 8A. Mobile 

emissions were prepared by the MRPO contractor using traffic and vehicle information provided 

by the Michigan Department of Transportation (MDOT). A summary of the emissions inventory 

is shown in Table 8.a. The DNRE will update this inventory every three years. 

In addition, emissions were projected to 2009 and 2018 to support the RFP demonstration. The 

base year, 2009, and 2018 modeling inventories were prepared by LADCO. LADCO did not do 

any formal emissions processing for 2012; instead they simply interpolated between 2009 and 

2018. Therefore, 2009 emissions are reported since they were determined by modeling. The 

future year projections take into account existing control measures and measures that were 

known to be on the way (e.g., CAIR measures). This inventory is referred to as the LADCO 

Base M inventory. Procedures used to prepare these inventory products can be found in the 

“Regional Air Quality Analyses for Ozone, PM2.5, and Regional Haze: Technical Support 

Document,” prepared by LADCO (see Appendix 5A). LADCO has produced numerous 

summary reports with state and county total emissions and has posted them on their Web site 

at: http://www.ladco.org/tech/emis/current/index.php. 
Michigan Department of Natural Resources and Environment 

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Table 8.a. 2005, 2009 and 2018 Emissions Inventory Annual 

Emissions, Tons Per Year 

2005 NH3 NOx SO2 PM10 PM2.5 ROG* 

EGU 140 120,332 350,701 5,392 2,358 1,418 

nonEGU 806 85,898 58,284 13,038 6,505 32,774 

onroad 11,084 244,345 4,211 5,530 3,652 119,431 

nonroad 82 70,541 6,830 7,739 7,340 156,755 

MAR 14 26,280 5,824 977 894 2,151 

area 231 39,085 13,294 65,505 65,090 252,114 

NH3 55,132 0 0 0 0 0 

total 67,489 586,482 439,145 98,181 85,839 564,643 

 

2009 NH3 NOx SO2 PM10 PM2.5 ROG 

EGU 774 83,118 227,296 13,784 8,931 1,351 

nonEGU 813 89,534 57,440 13,691 6,716 35,526 

onroad 11,382 159,356 1,489 4,508 2,673 88,734 

nonroad 84 58,717 1,088 6,589 6,231 137,022 

MAR 10 16,694 2,795 588 539 1,399 

area 208 39,756 13,051 66,140 71,630 221,739 

NH3 60,099 0 0 0 0 0 

total 73,369 447,176 303,159 105,301 96,720 485,771 

 

2018 NH3 NOx SO2 PM10 PM2.5 ROG 

EGU 774 79,544 242,853 13,784 8,931 1,351 

nonEGU 798 88,062 56,724 13,288 6,537 34,512 

onroad 11,963 56,758 1,201 3,463 1,683 50,965 

nonroad 89 34,486 106 3,987 3,743 99,199 

MAR 10 12,820 1,553 409 375 1,174 

area 192 37,879 11,891 63,821 69,216 199,720 

NH3 64,331 0 0 0 0 0 

total 78,156 309,549 314,328 98,753 90,485 386,921 

*ROG = Reactive organic gases. 
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze 

October 2010 

24

9 Best Available Retrofit Technology 

On June 15, 2005, the EPA issued final amendments to its July 1999 Regional Haze Rule. 

These amendments apply to the provisions of the Regional Haze Rule that require emission 

controls known as Best Available Retrofit Technology, or BART, for industrial facilities emitting 

air pollutants that reduce visibility. These pollutants include PM2.5 and compounds that 

contribute to PM2.5 formation such as NOx, SO2, certain VOCs, and ammonia. The amendments include final guidelines, known as BART Guidelines, for states to use in determining 

which facilities must install controls and the type of controls the facilities must use. 

The DNRE developed BART rules (see Appendix 9A) that describe the process for determining 

BART and the applicability provisions. One such provision states that the CAIR addresses 

BART for EGUs. The DNRE is evaluating whether the CATR will also address BART for EGUs. 

Section 9.1 describes the process for identifying non-EGU sources subject to BART. 

 9.1 Process for Determining BART-subject Sources in the State of Michigan

The non-EGU BART-subject sources were identified using the methodology in the Guidelines 

for BART Determinations under the Regional Haze Rule, 40 CFR Part 51, Appendix Y. The first 

step taken by the DNRE was to determine all potentially affected sources based on the criteria 

listed in the BART Guidelines. The DNRE identified 35 non-EGU facilities with a total of 84 

emission units within the state that were potentially subject to BART (i.e., BART-eligible) based on 

dates of installation and commencement of operations (see Table 1 in Appendix 9B). 

Next, using emission inventory data from the years 2002 and 2004, the DNRE evaluated the 

quantity of emissions in relationship to the distance from Michigan’s Class I areas and other 

Class I areas in the region. This is called the Q/d analysis and was used as a screening method 

to identify those facilities most likely to impact the Class I areas. It was determined that a Q/d 

value of 10 tons per year/km is a reasonable threshold such that facilities at or above 10 would be 

likely to significantly impact a Class I area. This analysis reduced the BART-eligible facilities to a 

total of six (see Table 2 in Appendix 9B.) 

The BART Guidelines recommend addressing the visibility-impairing pollutants SO2, NOx, and 

particulate matter. The DNRE addressed these three pollutants and used particulate matter 

less than ten (10) microns in diameter (PM10) as an indicator for particulate matter to identify 

BART-eligible units. 

Culpability analyses by both CAMx and CALPUFF models have indicated that regional 

particulate background concentrations are based mostly upon secondary particulate 

contributions (nitrates and sulfates). Similar analyses indicate primary particulates tend to 

contribute mostly in a near field manner. As such, comprehensive PM2.5 studies now include 

“hot spot” analysis to address near field impacts of primary particulates in conjunction with 

regional transport and impact of secondary particulates. Consistent with the BART Guidelines, 

the DNRE did not evaluate emissions of ammonia and VOCs in BART determinations for these 

reasons: 

• Ammonia: In the BART Guidelines, the EPA recommends that states consider ammonia 

as a precursor to PM2.5 formation on a case-by-case basis, describing that “states are 

required to make BART determinations only for stationary sources that fall within certain 

industrial categories.” A review of the specific industrial categories in Michigan indicates 
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze 

October 2010 

25

that these sources do not emit ammonia in a “significant” (potential to emit 250 tons per 

year or more) amount. Thus, the inclusion of ammonia, while a potential contributor to 

visibility impairment, would not impact the DNRE BART eligibility determination. 

However, ammonia from sources that may contribute to visibility impairment is included 

in the regional scale modeling used in this SIP. 

• VOCs: In the BART Guidelines, the EPA suggests that states consider VOCs as a 

precursor to PM2.5 formation on a case-by-case basis. Only specific VOC compounds 

form secondary organic aerosols that affect visibility, and these compounds are a 

fraction of the total VOCs reported in the emissions inventory. For the BART analysis, 

the DNRE does not have the breakdown of VOC emissions necessary to model those 

that only impair visibility. Although not included in BART, VOCs, both anthropogenic and 

biogenic, are included in the regional scale modeling used in this SIP 

The next step involved CALPUFF modeling for each of the six facilities using 2002 through 2004 

meteorological data in a 36 km resolution grid. Emissions data for the same time period was 

based on the best available estimate of maximum actual 24-hour emissions. Any facility that 

was determined to contribute 0.5 dV or more for seven or more days during any year at any 

Class I area was considered subject to BART regulations. Facilities that contributed less than 

this threshold were eliminated from further review. This final step resulted in six non-EGU 

BART-subject sources, as follows: Lafarge Midwest, Inc.; St. Mary’s Cement; Smurfit-Stone 

Container Corp.; New Page Paper; Tilden Mining Co; and Empire Mining Co., shown in Table 3, 

Appendix 9B. When a source was determined to be BART-subject, the DNRE then required a 

detailed BART engineering analysis from the source. 

However, in the process of doing BART reviews for the six sources, Empire Mine provided new 

information that one furnace had been permanently shut down. With the resulting lower 

emissions, Empire modeling showed that the facility does not exceed the 0.5 dV threshold 

BART level. Therefore this facility is no longer subject to BART. Michigan’s remaining nonEGU BART-subject sources are shown in Table 9.1.a. 

Table 9.1.a. Non-EGU BART-subject Sources in the State of Michigan

BART-Subject Facility Name City SIC 

Lafarge Midwest, Inc. Alpena 3241 

New Page Paper Company Escanaba 2611 

St. Mary’s Cement Charlevoix 3241 

Smurfit-Stone Container Ontonagon 2611 

Tilden Mining Co. Marquette 1011 

 9.2 Determination of BART Requirements for Identified Non-EGU BART-Subject

Sources and Analysis of BART Controls for Each Source

Five non-EGU BART-eligible sources were identified for engineering analysis, including two 

Portland cement plants, one taconite plant, and two paper products plants. These sources have 

submitted a BART engineering analysis to the DNRE that includes their evaluation of potential 

BART options and their proposed BART control strategies and are summarized in Table 9.2.d. 
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze 

October 2010 

26

The proposed BART determinations from the five sources have been reviewed by the DNRE. In 

addition, comments from the EPA regarding certain methodologies for CALPUFF modeling 

criteria and concepts of the Regional Haze Rule were discussed with the sources. An additional 

BART analysis discussion summary, for each source, is included in this section. 

For detailed information of BART controls and analysis submitted by sources, see Appendices 

9C through 9J. 

The following is a summary of the Non-EGU BART-subject sources’ control options and 

emission limit determinations by the DNRE. 

Lafarge Midwest (Lafarge)

Affected Emission Units 

The BART subject emission units include five Portland cement manufacturing kilns: EU-KILN 

19, EU-KILN 20, and EU-KILN 21 are part of Kiln Group 5 (KG 5); EU-KILN 22 and EU-KILN 23 

are part of Kiln Group 6 (KG 6). 

Lafarge BART Analysis

The BART analysis submitted by the company discussed the following control systems for PM, 

NOx and SO2: 

PM 

In accordance with Regional Haze Rule, BART for PM emissions was determined to be 

equivalent to the Portland Cement MACT, which regulates PM as a surrogate to hazardous air 

pollutants (HAPs). Lafarge has emission controls (baghouses) in place to control HAPs and 

thereby meets both the MACT requirements and the BART for PM. 

NOx 

• Process optimization 

• Low NOx Burners 

• Selective non-catalytic NOx reduction (SNCR) and 

• Selective catalytic NOx reduction (SCR) 

Lafarge’s analysis states that the only cost-effective control for all emission units for NOx 

emissions was SNCR with a control efficiency of 38 percent. 

SO2

• Duct Sorbent injection; and 

• Flue Gas Desulfurization (FGD). 

Lafarge’s analysis states that wet scrubbers (FGD) are the cost-effective control for SO2

emissions for the two larger kilns (KG 6) with a control efficiency of over 80 percent. For the 

three smaller kilns (KG 5), Lafarge’s analysis states that no SO2 controls are cost-effective. 

This BART analysis as submitted by the company is included in Appendix 9C. 

 
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze 

October 2010 

27

Additional BART Analysis 

On March 18, 2010, Lafarge entered into a Global Settlement/Consent Decree (hereinafter 

Consent Decree) with the EPA and Michigan to reduce NOx and SO2 emissions at the Alpena 

facility along with other Lafarge facilities in the United States. 

The emission controls in the Consent Decree include SNCR for Kiln Groups KG 5 and KG 6 for 

NOx control. For SO2 control, wet scrubbers for kiln group KG 6 and a Dry Absorption Addition 

(DAA) system for Kiln Group KG 5 are required. These controls are consistent with the BART 

Guidelines to control visibility impairing pollutants (NOx and SO2) emissions and are acceptable 

to Michigan. It should be noted that an additional control not included in the BART analysis but 

agreed to in the Consent Decree is the DAA system for SO2 controls on KG 5. Michigan 

includes all controls contained in the Consent Decree, including the DAA system, as part of the 

BART controls. 

The Lafarge Alpena facility will reduce NOx and SO2 according to the schedule and conditions 

given in the Consent Decree (see Appendix 9D). Beginning January 1, 2011, Lafarge will 

maintain an interim, facility-wide, 12-month rolling tonnage limit for NOx of 8,650 tons per year 

and SO2 at 13,100 tons per year. The final emission limits will be established according to the 

Consent Decree “Control Technology Demonstration Requirements,” as given in the Appendix 

of the Consent Decree. The control technology demonstration describes in detail a stepwise 

emission control optimization program to establish the 30-day rolling average emission limits for 

NOx and SO2 at individual affected kilns. Additional requirements include a demonstration 

phase, facility-wide, 12-month rolling average NOx emission limit of 4.89 lb NOx per ton clinker 

and an SO2 emission limit of 3.68 lb SO2 per ton clinker. The demonstration phase limit will be 

followed by a period of testing of control efficiency and subsequently establish a 30-day rolling 

average limit for both NOx and SO2 to be calculated at the end of each 24-hour period. 

BART Limits 

PM 

The DNRE accepts the MACT limit for PM at 0.30 lb PM per ton of dry feed as BART at subject 

kilns in KG 5 and KG 6 and has taken the approach that BART equals MACT for all affected 

sources. 

NOx and SO2

The DNRE also accepts the Consent Decree requirements as BART. The specific limits to date 

are as follows: 

• The NOx limits are 8,650 tons per year and 4.89 lb NOx per ton clinker.

• The SO2 limits are 13,100 tons per year and 3.68 lb SO2 per ton clinker.

The DNRE will assure that the final limits will be made legally enforceable in the facility permits. 

More details of emission limits can be found in the Lafarge Consent Decree dated March 18, 

2010. The portions relevant to this Lafarge plant are in Appendix 9D. The Web link to the 

consent decree is http://www.epa.gov/compliance/resources/cases/civil/caa/lafarge.html. This 

URL is subject to change. In case of change, please contact the DNRE for further information. 
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze 

October 2010 

28

New Page Paper Company (New Page) 

Affected Emission Units 

The BART subject emission units for this Kraft pulp mill include No. 8 Boiler (EU8B13), No. 9 

Boiler (EU9B03), No. 10 Recovery Furnace (EURF15), Smelt Dissolving Tank (EUST15), and 

Lime Kiln (EULK29). 

New Page BART Analysis

The BART analysis submitted by New Page reviewed the following for BART-subject units: 

PM

The recovery furnace, smelt dissolving tank, and lime kiln are subject to the MACT for Kraft, 

soda, sulfite, and stand-alone semi chemical pulp mills (40 CFR Part 63, Subpart MM), which 

contains PM emission limits of 0.044 grain per dry standard cubic foot corrected to 8 percent 

oxygen for the recovery furnace; 0.064 grains per dry standard cubic foot, corrected to 10 

percent for the lime kiln; and 0.2 pounds per ton of black liquor, or 0.15 lbs per 1,000 lbs of 

exhaust gases for the smelt dissolving tank. Boiler Nos. 8 and 9 will be subject to the Boiler 

MACT when it is revised by the EPA. The original Boiler MACT was vacated by the U.S. Court 

of Appeals. The company’s existing PM permit limits for Boiler No. 9 are: when wood residue 

heat input is greater than 75 percent of total heat input, 0.50 lbs per 1,000 lbs of exhaust gases, 

measured at operating conditions, corrected to 50 percent excess air; and when wood residue 

heat input is less than or equal to 75 percent of total heat, 0.67 lbs per 1,000 lbs of exhaust 

gases, measured at operating conditions, corrected to 50 percent excess. There is no PM 

permit limit for Boiler No. 8. 

NOx 

For the recovery furnace, smelt dissolving tank, and lime kiln, New Page did not find control 

technologies available as none have been installed on such processes. New Page currently 

uses combustion control techniques and judges them to be BART. Current NOx emission limits 

are 400 parts per million (ppm) by volume or 468 lbs per hour for the recovery furnace. There 

are no NOx limits for the smelt tank and lime kiln. 

For Boilers Nos. 8 and 9, New Page examined the following: 

• Selective Catalytic Reduction (SCR) 

• Low NOx Burners 

• Selective Non-Catalytic Reduction (SNCR) 

• Combustion Controls 

For the No. 8 boiler, the analysis shows costs of the options are greater than $10,000 per ton, 

except for the use of low NOx burners with an approximate $4,000 per ton cost-effectiveness. 

However, New Page rejects this option as their visibility modeling does not indicate it will result 

in a significant visibility improvement (i.e., at least 0.5 deciviews). Therefore, New Page 

concludes that the existing operation of the flue gas recirculation system during the ozone 

season is BART. The existing NOx emission limit for the No. 8 boiler is, when firing gas, 

0.20 lbs/MMBtu (limit effective only during ozone control period, May 1 through September 30) 

and, when firing residual oil, 0.40 lbs/MMBtu (limit effective only during ozone control period, 

May 1 through September 30). 
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze 

October 2010 

29

For the No. 9 boiler, the company’s report showed that all options had costs of greater than 

$10,000 per ton and thus judged not to be cost-effective. New Page concluded that operation of 

the existing overfire air combustion control with a NOx emission limit as specified in Table 81 of 

DNRE Rule 336.1801 when the boiler meets the definition of fossil fuel-fired emission unit per 

DNRE Rule 336. 1801(1)(b) is BART. However, No. 9 boiler primarily burns wood residue, but 

may also burn natural gas and paper cores. When burning natural gas the NOx emission limit 

from Table 81 is 0.2 lbs per million BTU of natural gas. 

SO2 

For the recovery furnace, smelt dissolving tank, and lime kiln, New Page did not find control 

technologies available as none have been installed on such processes. Currently SO2 emission 

limits are, for the recovery furnace, 250 ppm by volume or 407 lbs per hour, and, for the lime 

kiln, 9 lbs per hour. There is no limit for the smelt tank. 

For the No. 8 boiler, New Page examined the following: 

• 100 percent Natural Gas Fuel 

• Switch to the No. 2 Fuel Oil 

• Wet Scrubbing 

• Dry Scrubbing 

• Semi-Dry Scrubbing 

The company’s analysis showed that all options except the switch to exclusive use of natural 

gas were not cost-effective, with costs above $30,000 per ton of SO2 controlled. The natural 

gas use cost is $4,200/ton. However, New Page rejects all options as their visibility modeling 

does not show significant visibility improvements from any of the five options. Therefore, New 

Page concludes that the existing operation of No. 8 boiler is BART. There is no current SO2

emission limit for No. 8 boiler. 

For the No. 9 boiler, New Page evaluated the following: 

• Switching to Caustic in the Wet Scrubber 

• Dry Scrubber 

• Semi-Dry Scrubber 

New Page determined that the dry and semi-dry scrubber options were not technically feasible, 

as none have been installed on such biomass-fired stoker grate boilers. The analysis showed 

the cost of the switch to caustic scrubbing media as more than $21,000/ton, which New Page 

concluded was not cost-effective. New Page concluded that use of the current inherently low 

sulfur biomass fuel constitutes BART. There is no current SO2 limit for the No. 9 boiler. 

For details of the New Page BART analysis, see Appendix 9I. 

Additional BART Analysis 

In a letter dated February 2, 2010, New Page reaffirmed that the methods, data, and 

conclusions in their January 2007 BART submittal remain accurate and complete. New Page 

contends that although there are technically feasible and cost-effective NOx and SO2 options for 

the No. 8 boiler, the demonstration that no significant visibility improvement will result justifies 

eliminating these options. 
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze 

October 2010 

30

The February 2, 2010 letter is attached in Appendix 9J. 

BART Limits 

The DNRE accepts New Page’s existing PM, NOx, and SO2 limits as representing BART for the 

subject emission units as described in the New Page BART Analysis section above. 

An excerpt containing the emission limits from the renewable operating permit (ROP) is in 

Appendix 9M. For more details of permit conditions see ROP No. MI-ROP-A0884-2008, at the 

AQD Web site for ROP at: www.deq.state.mi.us/aps/downloads/rop/pub_ntce/pub_ntce.shtml. 

This URL is subject to change. In case of change, please contact the DNRE for further 

information. 

St. Mary’s Cement (SMC)

Affected Emission Units 

There is only one BART-subject emission unit, the in-line kiln with a pre-calciner system 

(EUKILN). 

SMC BART Analysis

The BART analysis submitted by the company discussed the following control systems for PM, 

NOx and SO2. 

PM 

The Regional Haze Rules allow application of other standards such as MACT to regulate a 

pollutant. The Portland Cement MACT regulates PM as a surrogate to hazardous air pollutants. 

SMC has MACT controls (baghouse on main stack and ESP on bypass stack) for HAPS and 

thereby meets both the MACT requirements and the BART for PM. 

NOx 

• Selective catalytic NOx reduction (SCR) 

• Mid-Kiln firing 

• Biosolids injection 

• CemStarTM 

• Low NOx Burners (LNB) [Indirect Firing System (IDF)] 

• Use of pre-calciner 

• Selective non-catalytic NOx reduction (SNCR) 

The SMC NOx emissions control analysis demonstrates that all of the controls listed above, 

except for the IDF and pre-calciner, are technically infeasible or not cost-effective. SMC 

proposes that the existing IDF controls for the kiln are equivalent to LNB. SMC believes that the 

existing pre-calciner also reduces some of the NOx emissions. 

SMC proposes to reduce 15.3 percent of NOx emissions by continuing to optimize existing NOx 

controls, which include the IDF for the kiln burners and a pre-calciner system ahead of the main 

kiln. 

SMC has taken the existing SNCR (installed to fulfill Michigan’s NOx SIP rule for the summer 

ozone season) out of its BART proposal for control of NOx emissions. Operating the system 

has caused problems for SMC, and operating it year round would increase the problems. For 
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze 

October 2010 

31

example, SMC’s BART engineering analysis claims that the existing SNCR is technically 

infeasible due to very cold external temperatures. The hard freezing temperatures during 

winters in Charlevoix cause problems keeping the reactant chemicals at certain operational 

temperatures. To overcome these operational difficulties, extensive heating lines are needed to 

prevent solidification of reactant chemicals in pumps and piping. This results in higher 

installation and operating costs to keep the system operating throughout the year. Also, 

frequent buildup of materials inside the ductwork between the kiln and pre-calciner, which is the 

optimal location for the reactant chemicals to be effective, requires frequent cleanups causing 

loss of production time, thus making the SNCR control very expensive to sustain throughout the 

year. SNCR is not cost-effective as per BART Guidelines. 

SO2

• Advanced Flue Gas Desulfurization (AFGD)

• Wet Flue Gas Desulfurization (wet FGD)

The analysis indicates that AFGD for SO2 retrofit control is not a technically viable option for 

SMC. The wet FGD is not cost-effective. SMC will try to minimize sulfur input through 

managing the raw feed content of sulfur of the quarried raw material (lime/limestone) that is 

processed in the kiln (EUKILN). This could reduce SO2 emissions monthly by about 16 percent. 

For details of the BART analysis submitted by SMC, see Appendix 9E. 

Additional BART Analysis 

In final negotiations between SMC and the DNRE in February 2010, SMC proposed the 

incorporation of more restrictive emission limits for BART permit conditions, but stated that the 

limits should be conditional on the resolution of issues identified in the EPA’s Notice of Violation 

dated September 29, 2009. The proposed limits are contained in a document, attached in 

Appendix 9F. However, the DNRE is not in a position at this time to accept this conditional 

SMC proposal because the DNRE is not involved in the Notice of Violation between SMC and 

the EPA, and therefore has no control of the outcome of this matter. 

BART Limits 

The DNRE has accepted the original SMC proposal as BART. The BART limits will remain the 

same as the existing permitted limits for the PM, NOx, and SO2, as follows: 

• The PM limit is 0.30 lbs/ton of dry feed. 

• The NOx limits are 6.5 lbs/ton of clinker from May through September and 7.67 lbs/ton of 

clinker from October through April.

• The SO2 limits are 2800 lbs per hour, 550 tons per month, 4404 tons per year.

An excerpt containing the emission limits from the renewable operating permit (ROP) is in 

Appendix 9G. For more details of permit conditions see ROP No. MI-ROP-B1559-2008, at the 

AQD Web site for ROP at: www.deq.state.mi.us/aps/downloads/rop/pub_ntce/pub_ntce.shtml. 

This URL is subject to change. In case of change, please contact the AQD for further 

information. 
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze 

October 2010 

32

Smurfit Stone Container Corporation (SSCC) 

Affected Emission Units 

There is only one BART-subject emission unit at this facility. It is the Riley Boiler # 1 (EUBR 1). 

Smurfit Stone BART Analysis

The BART analysis submitted by SSCC reviewed the following for the BART-subject unit: 

PM

Riley Boiler # 1 will be subject to the Boiler MACT when it is revised by the EPA. The original 

Boiler MACT was vacated by the U.S. Court of Appeals. The company’s existing PM permit 

limits for Riley Boiler # 1 are: the particulate emissions shall not exceed 0.25 lbs per 1,000 lbs of 

exhaust gases, corrected to 50 percent excess air. 

NOx 

Current NOx emission limits are 0.95 lbs per million BTU heat input averaged over the ozone 

control period. Total NOx emissions not to exceed 350 lbs per hour. 

For the Riley Boiler # 1, SSCC examined the following control: 

• Low NOx Burners 

• Mobotec’s Rotating Opposed Fire Air (ROFA) fan system 

SO2 

Current SO2 emission limits are 2.50 lbs per million BTU heat input. 

For the Riley Boiler # 1, SSCC examined the following control: 

• Limestone injection. The Mobotec’s Furnace Sorbent Injection (FSI) system 

The company’s analysis (see Appendix 9N) showed that the existing control system would be 

the most cost-effective option for controlling all BART subject emissions including PM, NOx and 

SO2. The current control system, the Mobotec integrated system, currently controls PM and 

NOx and has the retrofit capability for SO2 controls. Control of SO2 can be achieved through 

addition of the Mobotec furnace injection of limestone sorbent (“furnace sorbent injection” or 

FSI). SO2 control is cost-effective since the system allows retrofit addition for FSI using most of 

the capabilities of the existing Mobotec integrated system. 

BART Limits 

The DNRE accepts SSCC’s existing PM permitted limits as representing BART for the subject 

emission unit as described in the SSCC BART Analysis section above. 

The DNRE has accepted the original SSCC proposal as BART. The acceptable BART limits for 

PM, NOx, and SO2, are as follows: 

• The PM limit is 0.25 lbs per 1,000 lbs of exhaust gases, corrected to 50 percent excess 

air. 

• The NOx limits are 0.39 lbs per million BTU heat input at 375 BTU per hour fuel load.

• The SO2 limits are 0.97 lbs per million BTU heat input at 375 BTU per hour fuel load.
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze 

October 2010 

33

The BART limits for NOx and SO2 will be put in an enforceable NSR permit if the company 

begins operation in the future. 

An excerpt containing the emission limits from the renewable operating permit (ROP) is in 

Appendix 9O. For more details of permit conditions see ROP No. MI-PTI-ROP-A5754-2007b, at 

the AQD Web site for ROP at: 

www.deq.state.mi.us/aps/downloads/rop/pub_ntce/pub_ntce.shtml. 

This URL is subject to change. In case of change, please contact the DNRE for further 

information. 

Tilden Mining Company LLC (TMC)

Affected Emission Units 

The BART-subject emission units include indurating furnace/grate-kiln EUKILN 1, EU PRIMARY 

CRUSHER, EU COOLER 1, EU DRYER 1, EU BOILER 1, and EU BOILER 2. 

TMC BART Analysis

The BART analysis submitted by the company discussed the following control systems for PM, 

NOx and SO2: 

PM 

The Regional Haze Rules allow application of other standards such as MACT to regulate a 

pollutant. The taconite MACT regulates PM as a surrogate to HAPs and TMC has MACT 

controls (wet scrubbers on dryer, scrubber and primary crusher; electrostatic precipitator for 

kiln) for HAPS and thereby meets both the MACT requirements and the BART for PM. 
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze 

October 2010 

34

NOx 

 Table 9.2.a. Indurating Furnace NOx Control Technology – 

 Availability, Applicability, and Technical Feasibility 

 (Taken from Table 5-9 of TMC BART submittal): 

NOx Pollution Control 

Technology

Available Applicable Technically 

Feasible

External Flue Gas 

Recirculation (EFGR)

Yes No No

Low NOx Burners (LNB) Yes Yes No

Induced Flue Gas 

Recirculation Burners (IFGR)

Yes Yes No

Energy Efficiency Projects Yes Yes Project 

Dependent

Ported Kilns 

(Applies to Grate-Kilns Only)

Yes Yes No

Alternative Fuels Yes Yes

Yes - 

Not Required 

by BART

Process Optimization Yes No No

Non-Selective Catalytic 

Reduction (NSCR)

Yes No No

Selective Catalytic 

Reduction (SCR) with 

conventional reheat

Yes Yes Yes

Regenerative SCR Yes No No

Selective Non-Catalytic 

Reduction (SNCR)

Yes No No

Low Temperature Oxidation 

(LTO)

Yes No No

The only technically feasible control for NOx emissions is SCR with conventional reheat. 

However, the company’s analysis indicates that the cost per ton of NOx removal is $8,416, 

which is not cost-effective for this source. 

Compared to the indurating furnace (EUKILN 1), the other BART eligible emission units (EU 

PRIMARY CRUSHER; EU COOLER 1; EU DRYER 1; EU BOILER 1; and EU BOILER 2), with 

existing controls, have negligible visibility impairing pollutant (VIP) emissions. No additional 

analysis was performed for these emission units. 
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze 

October 2010 

35

SO2 

 Table 9.2.b. Indurating Furnace SO2 Control Technology – 

 Availability, Applicability, and Technical Feasibility

 (Taken from Table 5-1 of TMC BART submittal) 

SO2 Pollution Control 

Technology Available Applicable Technically Feasible

Wet Walled Electrostatic Precipitator 

(WWESP)

Yes Yes Yes

Wet Scrubbing Yes Yes Yes

Dry sorbent injection (DSI) Yes Yes Yes

Spray Dryer Absorption (SDA) Yes Yes Yes

Energy Efficiency Projects Yes Yes Project Dependent

Alternative Fuels Yes Yes Yes – Not Required by BART

Coal Processing No No No

All the technically feasible controls for SO2 emissions are shown not to be cost-effective for this 

emission unit. The minimum cost of controls is $6,557 per ton SO2, and the maximum cost is 

$22,407 per ton. This cost range is not cost-effective. 

Table 9.2.c. Process Boilers SO2 Control Technology – 

Availability, Applicability, and Technical Feasibility 

(Taken from Table 5-17 of TMC BART submittal): 

SO2 Pollution Control 

Technology

Available Applicable Technically 

Feasible

Wet Walled Electrostatic Precipitator 

(WWESP)

Yes Yes Yes

Wet Scrubbing Yes Yes Yes

Spray Dry Absorption (SDA) Yes Yes Yes

Dry sorbent injection (DSI) Yes Yes Yes

Energy Efficiency Projects Yes Yes Project Dependent

Alternative Fuels Yes Yes

Yes - Not 

Required by BART

Tilden concluded that all four of the technically feasible controls for SO2 removal in the BARTsubject process boilers are not cost-effective. 

Compared to the indurating furnace (EUKILN 1) and the boilers (EU BOILER 1 and EU BOILER 

2), the other BART-eligible emission units (EU PRIMARY CRUSHER; EU COOLER 1; 

EU DRYER 1) with existing controls have negligible VIP emissions. No additional analysis was 

performed for these emission units. For details of BART analysis initially submitted, see 

Appendix 9G. 

Additional BART Analysis 

In a technical memorandum dated February 19, 2010, Tilden proposed a revised BART 

scenario for the indurating furnace. For PM, the taconite MACT limit is BART, as previously 

stated. For NOx and SO2, emissions were modeled to determine visibility impacts based on the 

maximum 24-hour actual emissions for each visibility impairing pollutant emitted from the 

indurating furnace. To evaluate the maximum rate for NOx and SO2 as mandated by BART, 
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze 

October 2010 

36

100 percent natural gas usage for NOx emissions and 100 percent coal usage for SO2

emissions were assumed. The modeling results showed SO2 emissions do not cause visibility 

impairment to the Class I areas. Therefore, the company concluded that the current Title V 

permit limits for SO2 emissions of 28,800 lbs per calendar day should be considered BART, and 

the BART proposal should focus on NOx emissions. 

For NOx, due to the lack of sufficient emissions data representing good combustion practices 

and the range of operating conditions that influence NOx emissions, the company believes, it is 

currently not possible to propose a NOx emission limit that corresponds to BART for EUKILN 1. 

Tilden proposes to develop a NOx emission factor in pounds of NOx per million BTU of heat 

input by collecting sufficient emissions data through stack testing to determine appropriate limits 

based on “good combustion practices.” The establishment of the NOx emission factor through 

stack testing is similar to the requirements in the Minnesota Regional Haze SIP for taconite 

facilities. The established NOx emission factor can then be incorporated into Tilden’s Title V 

ROP, pursuant to 40 CFR Part 51 Appendix Y. 

The Tilden Technical Memorandum dated February 19, 2010, is attached in Appendix 9H. 

BART Limits 

The DNRE accepts that existing permit conditions for PM and SO2 limits represent BART, based 

on currently available information. The BART limits will remain the same as the existing 

permitted limits for the PM and SO2, as follows: 

• The PM limit for magnetite is 0.01 grains per dry standard cubic foot (gr/dscf) and 

0.03 gr/dscf for hematite (taconite MACT limit). 

• The SO2 limit is 28,800 lbs SO2 per calendar day. 

The DNRE accepts Tilden’s proposal to set a BART NOx emission limit in a manner similar to 

the Minnesota Regional Haze SIP. The new NOx limits will be set after testing to determine 

appropriate limits based on “good combustion practices” before December 31, 2012. An 

excerpt containing the emission limits from the ROP is in Appendix 9J. For more details of 

permit conditions see ROP No. MI-ROP-B4885-2008 at the AQD Web site for ROP at: 

www.deq.state.mi.us/aps/downloads/rop/pub_ntce/pub_ntce.shtml. This URL is subject to 

change. In case of change, please contact AQD for further information. 

BART Summary 

The analyses from the five companies and DNRE BART conclusions are summarized in 

Table 9.2.d. 
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze October 2010 

37

Table 9.2.d. Summary of Company Analysis for BART Controls

Source 

Name 

SO2 Controls 

Considered in BART 

Analysis 

SO2

Control 

Cost 

($/ton) 

Selected 

Controls 

SO2 Control 

Eff. (%) 

NOx Controls Considered 

in BART Analysis 

NOx Control Cost 

($/ton) 

Selected Controls 

NO

Con

Eff. 

Lafarge Cement 

1. Sorbent injection KG5 2. Sorbent injection KG6 3. Wet LSFO FGD KG5 4. Wet LSFO FGD KG6 

$3,367 

$754 

$7,952 $1,087 

25 25 90 90 

1. Process optimization 2. LNB burners 3. SNCR KG5 4. SNCR KG6 

Existing Existing 

$713 $498 

N/N/

35 40 

New Page No. 8 Boiler 

1. 100% natural gas fuel 2. Switch to No. 2 fuel oil 3. Wet scrubber 4. Dry scrubber 5. Semi-dry scrubber 

$4,200 

$39,426 $30,855 

$129,390 $118,822 

99 91 61 25 25 

1. SCR 2. Low NOx burner 3. SNCR 4. Flue gas recirc. operate year-round 

$15,500 

$3,600 

$43,100 $44,600 

90 40 20 12 

New Page No. 9 Boiler 

1. Wet scrubber, Caustic 2. Dry scrubber 3. Semi-dry scrubber 

$21,808 

N/A N/A 

50 1. SCR 

2. Low NOx Burner 3. SNCR 4. Flue gas recirc. 

$13,761 $18,884 $10,741 $19,200 

90 40 35 20 

St. Mary’s Cement 

1. Dry Scrubbers $4,012 80 1. Process optimization 

2. (IDF)=LNB burners 3. Use of pre-calciner 4. SNCR 

Existing Existing Existing 

$7,568 10 

SmurfitStone Mobotec’s Furnace Sorbent Injection (FSI) 

system. 

$1337 60 Mobotec’s Rotating 

Opposed Fire Air (ROFA) fan system. 

Existing, installed in 

2007 to comply with 

Boiler MACT 

57 

TMC 1. Wet scrubbing 

2. Spray dryer absorption 3. Wet walled ESP 4. Dry sorbent injection 

$6,557 

$22,407 $15,091 $15,729 

80 90 80 55 

1. Low NOx burners 2. Induced flu gas recirc. burners 3. Energy eff. projects 4. Ported kilns 5. Alternate fuels 6. Coal processing 7. Low temp. oxidation 8. SCR 9. SNCR 10. Process optimization parametric monitoring 

N/A N/A N/A N/A N/A N/A N/A 

$8,416 

N/A N/A 

80 
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze 

October 2010 

38

9.3 Determination of the impacts of visibility impairing pollutant emissions from Non-EGU 

BART-subject sources on Class I areas

The two Class I areas in Michigan, Isle Royale National Park and Seney Wilderness Area, are 

affected by the emissions of visibility impacting pollutants (VIP). The Pre-BART CALPUFF 

modeling has shown that the five BART-subject sources impact Isle Royale, Seney, or both. 

Details of the CALPUFF modeling analysis showing pre-BART and post-BART impacts and the 

visibility are given below in Table 9.3.a. 
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze October 2010 

39

Table 9.3.a. BART Controls and Comparison of Visibility-Impairing Pollutant Impacts on Clas

Controls for BART 

Pre-BART 

Emissions 

Post BART 

Emissions 

Name of 

Source SOx NOx SOx lb/day 

ton/day 

NOx lb/day ton/day 

SOx lb/day ton/day 

NOx lb/day ton/day 

3 yr. 98th. Pctl. Ave. Pre-BART deciviews 

3 yr. 98th. Pctl. Ave. Post BART deciviews 

233,610 94,363 24,197 32,153 

Lafarge DAA scrubber SNCR 

116 47 12.1 16.1 1.22 

to be 

determined 

see comments 

Po

avecoTe

9,236 13,053 9,236 13,053 

 0.7 0.7 Ex

New Page Existing 

controls 

4.62 6.51 4.62 6.51 lim

67,200 31,460 67,200 31,460 

 1.06 1.06 Ex

St. Mary's Cement Existing controls 

33.6 15.73 33.6 15.73 

22500 8400 8730 3510 

Pla

Smurfit FeStone 

Furnace Sorbent Injection (FSI) 

Rotating Opposed fire Air (ROFA) 11.25 4.2 4.37 1.76 0.71 0.46 

6,552 26,208 6,552 26,208 Ex

lim

3.27 13 3.27 13 0.55 0.55 

Tilden Mining 

Existing controls 
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze 

October 2010 

40

10 Reasonable Progress Goals and Long-term Strategy 

The DNRE is required under 40 CFR 51.308(d)(1) to establish, for each Class I area within the 

state, goals (in deciviews) that provide for reasonable progress towards achieving natural 

visibility. The goals should provide improvement in visibility over the SIP period for the most 

impaired days and ensure no degradation in visibility for the least impaired days. 

 10.1 Consultation

In determining a reasonable progress goal (RPG) and long-term strategies for each Class I 

area, 40 CFR 51.308(d)(3)(i) requires the DNRE to consult with other states/tribes that are 

reasonably anticipated to cause or contribute to visibility impairment in each of these Class I 

areas. The DNRE had monthly consultation calls with MRPO states, Minnesota, several 

CENRAP states, tribes, FLMs, the Ontario Ministry of Environment, and Region 5 EPA. Minutes 

from these calls can be found on the MRPO Web site at: 

http://www.ladco.org/reports/rpo/consultation/. 

 10.2 Basis for Emissions Reduction Obligations

The DNRE is required to demonstrate that its implementation plan includes all measures 

necessary to obtain its fair share of emission reductions needed to meet RPGs at all Class I 

areas where visibility is impacted by emissions from Michigan (40 CFR 51.308(d)(3)(ii)). 

Determining that fair share of emission reduction requires knowledge of which Class I areas are 

most impacted by emissions from Michigan and which states’ emissions most impact visibility in 

Michigan’s Class I areas. 

The DNRE relied on technical analyses developed by MRPO to demonstrate that the state’s 

emissions reductions, when coordinated with those of other states, are sufficient to achieve all 

RPGs. The DNRE used the following steps to determine Michigan’s contribution to visibility 

impairment at various Class I areas. 

10.2.1 Baseline Inventory

The DNRE used MRPOs Base M emissions inventory to assess RPGs as a baseline for 2005 

and 2018. The MRPO developed two inventories. Base K is based on the 2002 emissions 

inventory and Base M is based on the 2005 inventory. Both base years are SIP quality 

inventories; however, the DNRE focused on the 2005 inventory since the more recent inventory 

should be more accurate due to greater understanding of emissions changes that occurred or 

will be occurring. These inventories were compared in LADCO’s Technical Support Document 

(LADCO 2008, Appendix 5A). 

10.2.2 Michigan’s Impact on Class I Areas

Michigan contributes to its two Class I areas in the state: Seney and Isle Royale. Based on the 

MRPO’s 2018 particulate source apportionment modeling, Michigan contributes from 12 percent 

to 18 percent of the visibility impairment at both Class I areas (See Table 10.2.2.a. and 

Appendix 3B). Using the DNRE’s determination that a significant contribution to visibility 
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze 

October 2010 

41

impairment is a contribution over 5 percent3

, Michigan is not expected to significantly contribute 

to visibility impairment at any other Class I area. 

Table 10.2.2.a. Class I areas impacted by Michigan 

Class I Areas Michigan’s Contribution to Light Extinction in 2018 

Round 4 (2002 base year) Round 5 (2005 base year) 

Isle Royale 12.7% 13.4% 

Seney 13.8% 18.1% 

Michigan had less than a 5 percent impact on Minnesota’s Class I areas and was not indicated 

by Minnesota as contributing to their Class I areas (See Appendix 10A). 

Michigan contributed less than 5 percent to all other Class I areas (see Appendix 1A); however, 

four states in the MANE-VU region indicated that Michigan contributed to their Class I areas: 

Acadia and Moosehorn in Maine, Great Gulf in New Hampshire, Brigantine in New Jersey, and 

Lye Brook in Vermont (MANE-VU, 2007). MANE-VU used a very low threshold of 2 percent 

sulfate contribution or 0.1 ug/m3

 sulfate contribution to the 20 percent worst days as their 

significance level. 

The MANE-VU states requested states they identified to 1) reduce sulfate emissions by 

90 percent from their key list of EGUs; 2) reduce non-EGU SO2 emissions by 28 percent; and 

3) BART sulfate reductions (MANE-VU, 2007). The five EGUs from four Michigan facilities 

MANE-VU specifically identified as contributing to their Class I areas are Detroit Edison’s 

Monroe (two units), St. Clair and Trenton Channel power plants, and Consumers Energy‘s Karn 

Weadock power plants. 

10.2.3 States Impacting Michigan’s Class I Areas

The DNRE identified the states expected to contribute significantly to Michigan’s Class I areas, 

defined as more than 5 percent contribution to visibility impairment at either Seney or Isle 

Royale, using MRPO’s Round 5 2018 PSAT modeling. The states that are contributing are 

Michigan, Wisconsin, Illinois, Indiana, Minnesota and Iowa (see Table 10.2.3.a.). In the MRPO 

initial PSAT modeling, Round 4, Missouri was also identified; however, Missouri fell below the 

5 percent contribution level in the later modeling (see Table II-2 in Appendix 3B). 

 

3

 Depending on the chosen impact level, more Class I areas may be impacted. Michigan chose a higher impact level 

of 5 percent. The states that make a 5 percent contribution or more to total light extinction accounts for 75-80 percent 

of total light extinction, whereas using a 2 percent contribution accounts for 90-95 percent of total light extinction. 

Since this is the first planning stage for regional haze, the DNRE believes the 5 percent contribution of states is more 

appropriate and can be tightened in later planning stages if needed. 

Source: Appendix 3B, p. 45 
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze 

October 2010 

42

Table 10.2.3.a. 2018 PSAT (Round 5) contribution to 

light extinction by state 

 Isle Royale Seney 

Michigan 13.4% 18.1%

Minnesota 9.5% 1.6%

Wisconsin 14.7% 10.9%

Illinois 8.7% 14.3%

Indiana 5.2% 11.6%

Iowa 8.3% 3.8%

Missouri* 4.6% 4.8%

 * Missouri is not considered culpable. 

10.2.4 Pollutants and Sources Impacting Michigan’s Class I Areas

The main pollutants predicted to impact visibility at Michigan’s Class I areas on the 20 percent 

worst days for the base year, 2018, and 2064 are sulfate, nitrate and organic matter (see Figure 

10.2.4.a., also Appendix 3B and Appendix 10B). Based on observed visibility (Appendix 10C), 

sulfate is a significant component year around, whereas nitrate is significant in the winter and 

organic carbon is most abundant in the summer (Figure 10.2.4.b.). Organic carbon is largely 

from biogenic sources and wildfires (Sheesley and Schauer, 2004, and Appendix 3B, page 19), 

which is more reflective of background conditions and will not be pursued for control. The 

DNRE will focus on sulfate and nitrate reductions. 

observed 2018 2064 observed 2018 2064

Isle Royale Seney 

Figure 10.2.4.a. Comparison of pollutant contribution to visibility impact for 2002 

base year, 2018 future year and 2064 natural conditions for Michigan’s Class I 

areas on the 20 percent worst days. 

Source: Appendix 3B, p. 45 

Source: Appendix 3B, p 21 
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze 

October 2010 

43

Figure 10.2.4.b. Pollutant contribution to monthly light extinction values for Michigan’s 

Class I areas (2000-2004). 

The information portrayed in Figures 10.2.4.c. and 10.2.4.d. shows expected extinction by 

source sector and by pollutant. It shows the large impact of SO4 coming from EGUs, with a 

lesser amount from non-EGUs, at both Isle Royale and Seney. 

Figure 10.2.4.c. Isle Royale 2018 (LADCO, Round 5) modeled extinction by sector for 

each species on 20% worst days. 

Source: Appendix 3B, p. 5 

Source: Appendix 3B, p. 43 
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze 

October 2010 

44

Figure 10.2.4.d. Seney 2018 (LADCO, Round 5) modeled extinction by sector for each 

species on 20 percent worst days. 

These figures document the anthropogenic sources of visibility impairment by regional sources 

in developing the long-term strategy according to 40 CFR 51.308(d)(3)(iv). 

10.3 RPG Determination

The EPA released its final guidance on June 1, 2007 to use in setting RPG. The guidance 

states: 

RPGs are interim goals that represent incremental visibility improvement over time 

toward the goal of natural background conditions. In determining what would 

constitute reasonable progress, Section 169A(g) of the CAA requires States to 

consider the following four factors: 

• The costs of compliance; 

• The time necessary for compliance; 

• The energy and non-air quality environmental impacts of compliance; and 

• The remaining useful life of existing sources that contribute to visibility 

impairment. 

States must demonstrate in their SIPs how these factors are taken into consideration in selecting the RPG for each Class I area in the State ... the RHR establishes 

an additional analytical requirement for States in the process of establishing the 

RPG. This analytical requirement requires States to determine the rate of improvement in visibility needed to reach natural conditions by 2064, and to set each RPG 

taking this “glide path” into account. ... The glide path is not a presumptive target, 

and states may establish a RPG that provides for greater, lesser, or equivalent 

visibility improvement as that described by the glide path. 

The glide path, also known as the uniform rate of progress (URP), is a line between the baseline 

conditions for the 20 percent worst days to the natural background conditions for 2064. Seney 

Source: Appendix 3B, p. 41 
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze 

October 2010 

45

would require a 0.19 deciview decrease in visible impairment per year, and Isle Royale would 

require a 0.15 deciview decrease per year to reach natural conditions by 2064. For more 

details, see Section 6 above and pages 6-8 of Appendix 3B. 

10.3.1 General Approach to Determining RPG

The DNRE used the following approach to determine its RPG. The specific methodology was 

developed by MRPO (2005b) and is based on EPA’s draft guidance for setting reasonable 

progress goals. 

The general steps laid out for determining the RPG were as follows, with more specifics found in 

Section 10.3.2: 

Identify and Prioritize Sources: Determine the existing visibility conditions, examine which 

sources and geographic regions are contributing to worst and best visibility days, and identify 

the major anthropogenic sources/sectors contributing to worst visibility days (i.e., priority 

sources). 

 

The priority emission sources agreed upon by the Northern Class I consultation group were: 

1) SO2 from EGUs and non-EGUs; 2) NOx from EGUs, non-EGUs and mobile sources; and 

3) NH3 from agricultural sources. These sources were further evaluated by a contractor, ECR 

(Battye, et. al., 2007) for the MRPO and Minnesota. 

The ECR report also evaluated these sources in a three-state region (Michigan, Wisconsin, and 

Minnesota) and a nine-state region (these three states plus Illinois, Indiana, Iowa, Missouri, 

North Dakota, and South Dakota). 

Identify Control Options for Priority Sources: Develop control options for reducing the 

emissions from the priority sources, including existing and expected control programs 

(e.g., CAIR, BART, and nonattainment area controls) and other possible control programs. 

These various control strategies were examined in Reasonable Progress in the Northern 

Midwest—Factor Analysis (Battye et. al., 2007). 

Assess Effect of Existing Programs for Priority Sources: Assess the expected emission 

reduction from existing control programs for the priority sources, especially for the important 

visibility impairing pollutants (i.e., SO2 and NOx). 

Evaluate Control Options for Priority Sources: Using the four statutory factors, evaluate the 

control options for all priority sources and determine which measures may be reasonable. 

Compare Control Strategies with Uniform Rate of Progress: Compute the appropriate 

visibility metrics for the existing/expected controls and the reasonable controls for the Class I 

areas. Compare the expected improvement in visibility from these controls with the 60-year 

glide path to natural conditions. If the expected improvement is above the URP line, then the 

state must calculate the year in which natural conditions would be met if the reasonable 

progress rate expected between 2000-2004 and 2018 is held constant. 
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze 

October 2010 

46

10.3.2 DNRE’s Approach to RPG

The states involved in the Northern Class I consultation process worked together to identify and 

prioritize sources, assess the impact of existing control programs on priority sources, and direct 

a contract to investigate and evaluate control options for those priority sources. This effort 

served as the primary method the DNRE used to evaluate an RPG approach for the state. 

From the outset of this effort, the DNRE has approached the decision on RPG with a focus on 

“reasonableness” of controls needed to reduce haze by 2018, following the haze rule guidance. 

For the DNRE, a key consideration in making a reasonableness determination is the level of 

controls already in place on the primary impacting sources and the reductions being achieved 

by these sources to meet other programs such as the PM2.5 and ozone SIPs. For the largest 

impacting sources, the EGUs, considerable expense and effort already has been directed at 

meeting NOx SIP reductions and CAIR reductions. 

Identify and Prioritize Sources: The DNRE identified the major sources of sulfate and nitrates 

within the state. Figure 10.3.2.a. shows the emissions in tons of the major sources for 2005 and 

2018. Point sources are a major contributor. NOx emissions for onroad sources are expected 

to decrease significantly. EGU sources are expected to have large reductions based on current 

CAIR requirements; however, they still remain a large contributor in 2018. 

The major pollutant and source impacting Michigan’s Class I areas appears to be SO2 from 

EGUs, which forms ammonium sulfate. As discussed in Section 10.2, modeling and visibility 

data show that sulfate is one of the main components of haze at Isle Royale and Seney on the 

20 percent worst days (pages 2-5 in Appendix 3B and Appendix 10C). EGU SO2 emissions 

from Michigan, Wisconsin, Illinois, Indiana, Iowa, and Minnesota appear to be the key 

contributors. Ammonium nitrate is also an important anthropogenic contributor to visibility 

impairment, with EGUs being the second largest source behind mobile sources. 

0

100,000

200,000

300,000

400,000

500,000

600,000

700,000

2005 2018 2005 2018

NOx SO2

Tons/year

NH3

area

MAR

nonroad

onroad

nonEGU

EGU

Figure 10.3.2.a. NOx and SO2 emissions in Michigan for 2005 and 2018 by source 

category. Source: DNRE generated from LADCO emission inventories

SO2
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze 

October 2010 

47

The individual Michigan point sources with the highest impacts for Isle Royale and Seney are 

shown in Appendices 10D and 10E, respectively. The top ten contributing sources indicated by 

modeling and Q/d for in-state sources indicate EGUs and BART-subject sources. EGUs are 

subject to CAIR and the proposed CATR rule. Other BART-subject sources were evaluated for 

BART controls (see Tables 10.3.2.a. and 10.3.2.b.). 

Table 10.3.2.a. Calpuff modeling, visibility and Q/d results for top ten (based on 

CALPUFF) sources in Michigan impacting visibility at Isle Royale. 

Gaps reflect unavailable data 

FACILITY CITY 

Facility 

ID 

Calpuff 

results 

1/(M-m) 

Visibility 

(dv) 

2018 Q/d for 

NOx (tons/ 

day*km) 

2018 Q/d for 

SO2 (tons/ 

day*km) 

Wisconsin Electric Power Co.1 Marquette B4261 0.775 0.839 0.141 0.342

Empire Iron Mining Partnership2 Ishpeming B1827 0.766 0.037 0.087 0.011

Tilden Mining Company L.C.2 Ishpeming B4885 0.209 0.175 0.164 0.059

Stone Container Corporation2 Ontonagon A5754 0.205 0.025 0.051

J. H. Campbell Plant1 West Olive B2835 0.088 0.507 0.028 0.304

Detroit Edison/Monroe Power1 Monroe B2816 0.084 0.136 0.029 0.253

Escanaba Paper Company2 Escanaba A0884 0.067 0.053 0.039

Marquette Board Of Light & Power1 Marquette B1833 0.064 0.019 0.043

Neenah Paper - Michigan, Inc. Munising B1470 0.046 

Lafarge North America - Alpena2 Alpena B1477 0.040 0.170 0.060 0.137

1 EGUs subject to CAIR 

2 BART-subject sources 

Table 10.3.2.b. Calpuff modeling, visibility and Q/d results for top ten (based on 

CALPUFF) sources in Michigan impacting visibility at Seney. 

Gaps reflect unavailable data 

FACILITY CITY 

Facility 

ID 

Calpuff 

results 

1/(M-m) 

Visibility 

(dv) 

2018Q/d for 

NOx (tons/ 

day*km) 

2018Q/d for 

SO2 (tons/ 

day*km) 

Wisconsin Electric Power Company1 Marquette B4261 0.565 0.222 0.139 0.336

Empire Iron Mining Partnership2 Ishpeming B1827 0.494 0.067 0.081 0.011

J. H. Campbell Plant1 West Olive B2835 0.493 0.768 0.040 0.428

Escanaba Paper Company2 Escanaba A0884 0.316 0.105 0.076

Karn - Weadock Facility1 Essexville B2840 0.311 0.270 0.038 0.206

St Marys Cement Inc2 Charlevoix B1559 0.187 0.096 0.097

B. C. Cobb Plant1 Muskegon B2836 0.182 0.021 0.124

Tilden Mining Company L.C.2 Ishpeming B4885 0.148 0.109 0.149 0.053

Escanaba Power Plant1 Escanaba B1573 0.128 

Manistique Papers Inc Manistique A6475 0.120 0.016 0.061

1 EGUs formerly subject to CAIR 

2 BART-subject sources 

The top 30 sources both, within and outside the state, are shown in Table 10.3.2.c. for Isle 

Royale and Table 10.3.2.d. for Seney. Of these sources, most are EGUs or BART-subject 

sources that may already be installing controls or are being evaluated for BART controls. 
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze 

October 2010 

48

Table 10.3.2.c. Top 30 facilities impacting visibility at Isle Royale, includes facilities 

in and out of state 

 

Area Deciviews State County Facility ID Facility Name

ISLE1 0.83927 MI Marquette B4261 WI_Electric 

ISLE1 0.50708 MI Ottawa B2835 JH_Campbell 

ISLE1 0.44585 MN Sherburne 2714100004 NSP 

ISLE1 0.43193 WI Sheboygan460033090 WPL_Alliant 

ISLE1 0.35391 WI Brown 405032870 FortJames 

ISLE1 0.34702 MN Itasca 2706100004 MinnesotaPower_Bos 

ISLE1 0.33165 WI Columbia 111003090 Alliant 

ISLE1 0.27882 MN Cook 2703100001 MinnesotaPower_Tac 

ISLE1 0.23289 IL Will 197809AAO MidwestGen 

ISLE1 0.22347 WI Outagamie445031180 Intl_Paper 

ISLE1 0.17458 MI Marquette B4885 TildenMining 

ISLE1 0.16985 MI Alpena B1477 LaFarge 

ISLE1 0.16743 ND Mercer 11 NA 

ISLE1 0.16559 ND Oliver 1 NA 

ISLE1 0.15244 ND McLean 17 NA 

ISLE1 0.14597 MI St_Clair B2796 BelleRiver 

ISLE1 0.14482 IN Spencer 20 IN_MI_Power 

ISLE1 0.13599 MI Monroe B2816 Detroit_Ed 

ISLE1 0.13172 MI Bay B2840 Karn_Weadock 

ISLE1 0.11052 ND Mercer 4 NA 

ISLE1 0.10953 ND Mercer 1 NA 

ISLE1 0.1088 MN StLouis 2713700005 US_Steel 

ISLE1 0.07696 MN StLouis 2713700113 EVTAC_Mining 

ISLE1 0.06756 IN Jefferson 1 IKEC 

ISLE1 0.05745 MN StLouis 2713700063 KeewatinTaconite 

ISLE1 0.05186 IL Massac 127855AAC ElectricEnergyInc 

ISLE1 0.04685 IN Floyd 4 PSI_EnergyGallagher 

ISLE1 0.03674 MI Marquette B1827 EmpireIronMining 

ISLE1 0.03061 MN StLouis 2713700061 HibbingTaconite 

ISLE1 0.02097 MN StLouis 2713700062 IspatInlandMining 

ISLE1 0.0194 OH Clemont 1413100008 Cinergy 

sum = 6.1
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze 

October 2010 

49

Table 10.3.2.d. Top 30 facilities impacting visibility at Seney, includes facilities 

in and out of state 

 

Area Deciviews State County Facility ID Facility Name

SENE1 0.76837 MI Ottawa B2835 JH_Campbell 

SENE1 0.50992 IL Will 197809AAO MidwestGen 

SENE1 0.47144 WI Sheboygan460033090 WPL_Alliant 

SENE1 0.40775 MI St_Clair B2796 BelleRiver 

SENE1 0.34743 WI Columbia 111003090 Alliant 

SENE1 0.32325 IN Spencer 20 IN_MI_Power 

SENE1 0.32295 MI Monroe B2816 Detroit_Ed 

SENE1 0.30828 MI Alpena B1477 LaFarge 

SENE1 0.29421 MN Sherburne 2714100004 NSP 

SENE1 0.29202 WI Brown 405032870 FortJames 

SENE1 0.27039 MI Bay B2840 Karn_Weadock 

SENE1 0.22242 MI Marquette B4261 WI_Electric 

SENE1 0.19289 WI Outagamie445031180 Intl_Paper 

SENE1 0.18886 IN Jefferson 1 IKEC 

SENE1 0.14692 MN Itasca 2706100004 MinnesotaPower_Bos 

SENE1 0.11993 IN Floyd 4 PSI_EnergyGallagher 

SENE1 0.11411 ND Mercer 11 NA 

SENE1 0.10921 MI Marquette B4885 TildenMining 

SENE1 0.10301 ND McLean 17 NA 

SENE1 0.10086 IL Massac 127855AAC ElectricEnergyInc 

SENE1 0.09836 ND Oliver 1 NA 

SENE1 0.07361 ND Mercer 4 NA 

SENE1 0.06732 ND Mercer 1 NA 

SENE1 0.06681 MI Marquette B1827 EmpireIronMining 

SENE1 0.06078 OH Clemont 1413100008 Cinergy 

SENE1 0.04868 MN Cook 2703100001 MinnesotaPower_Tac 

SENE1 0.02468 MN StLouis 2713700005 US_Steel 

SENE1 0.02044 MN StLouis 2713700113 EVTAC_Mining 

SENE1 0.01312 MN StLouis 2713700063 KeewatinTaconite 

SENE1 0.00874 MN StLouis 2713700061 HibbingTaconite 

SENE1 0.00535 MN StLouis 2713700062 IspatInlandMining 

sum = 6.1

The ECR study evaluated some of the major source categories for impacts and costs to control 

in the Northern Class I region. Besides EGUs, the source categories of industrial, commercial, 

institutional (ICI) boilers, reciprocating engines and turbines, ammonia from agricultural 

operations, mobile sources, and several specific manufacturing operations were evaluated. 

EGUs accounted for the bulk of SO2 emissions in the multistate area in 2002, and are also 

projected to account for the bulk of SO2 emissions in 2018. Mobile sources contributed the bulk 

of NOx emissions in 2002, followed by EGUs. NOx emissions from both EGU and mobile 

sources are projected to decline between 2002 and 2018, but they are still projected to be the 

largest sources of NOx in 2018. Agricultural sources account for the bulk of ammonia 

emissions in both 2002 and 2018. (See Table 2-1 and Figure 3-4 in the ECR document titled 

Reasonable Progress in the Northern Midwest—Factor Analysis, Battye et al, 2007). 
Michigan Department of Natural Resources and Environment 

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The same ECR document (Battye, et. al., 2007) contains a summary of the analysis of these 

source categories, found in Tables 6.5-2 and 6.5-3 in the document. While the cost-effectiveness expressed in dollars per ton in Table 6.5-3 would be considered reasonable for the 

majority of the options considered, the visibility impacts in deciviews shown in Table 6.5-2 are 

more varied. EGU controls clearly provide the most improvement and are therefore high priority 

sources to control. Agricultural source emission reductions are also shown to provide significant 

visibility improvement, but are not currently being considered because of the large uncertainty of 

the emission estimates and because of the complexity of regulating this source sector at this 

time. ICI boilers do show potential for measurable visibility improvements, although not nearly 

to the degree EGUs do. The DNRE is worked with other states in the region and Northeast to 

find acceptable emission limits for this source category (see Appendix 3D). 

A rationale for DNRE’s determination of the reasonable progress goal in light of the ECR 

information is located in part 10.5.2 of this document. 

Identify Control Options for Priority Sources: The DNRE first identified those controls that 

are currently in place or legally required. These “on-the-books” control measures are: 

• Clean Air Interstate Rule 

• The top 30 sources, both within and outside the state, are shown in Table 10.3.2.c for 

Isle Royale and Table 10.3.2.d for Seney. Of these sources, most are EGUs and BARTsubject sources. 

• MACT 

o Reciprocal Internal Combustion Engines 

o Industrial Boilers and Process Heaters 

• Onroad Mobile Source Programs 

o 2007 Highway Diesel Rule 

o Tier II/Low Sulfur Gasoline 

• Nonroad mobile source programs 

o Nonroad Diesel Rule 

o Control of Emissions from Unregulated Nonroad Engines 

o Federal railroad/locomotive standards 

o Federal commercial marine vessel engine standards 

Next, a number of other control options or scenarios were examined, as follows: 

• EGU control scenarios setting regional emission limits based on 

o Strategy 1: SO2 limits of 0.15 lbs/MMBtu 

 NOx limits of 0.10 lbs/MMBtu 

o Strategy 2: SO2 limits of 0.10 lbs/MMBtu 

 NOx limits of 0.07 lbs/MMBtu 

• ICI Boilers 

o Strategy 1: SO2 reduction of 40 percent from 2018 baseline emissions 

 NOx reduction of 60 percent from 2018 baseline emissions 

o Strategy 2: SO2 reduction of 77 percent from 2018 baseline emissions 

NOx reduction of 70 percent from 2018 baseline emissions 
Michigan Department of Natural Resources and Environment 

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51

• Reciprocating Engines and Turbines-89 percent reduction for reciprocating engines and 

84 percent reduction for turbines depending on size class: 

o Strategy 1: emissions greater than 100 tpy 

o Strategy 2: emissions greater than 10 tpy 

• Ammonia Emission from Agriculture Sources 

o Strategy 1: 10 percent reduction in emissions 

o Strategy 2: 15 percent reduction in emissions 

The majority of EGUs whose emissions significantly affect Isle Royale and Seney are subject to 

CAIR and may be subject to the proposed CATR rule. However, DNRE is assuming that CAIR 

and its replacement rule will be equal to BART. The DNRE and other states in the region are in 

the process of determining which EGUs are proceeding with their CAIR plans, and LADCO will 

be doing model runs to determine the affect of any changes. 

Control options for various other control measures were evaluated in the ECR report for the 

MRPO and Minnesota (Battye et. al., 2007). As mentioned above, control options for ICI 

boilers, mobile sources, agricultural or ammonia sources and reciprocating engines were 

examined in this report. 

Assess Effect of Existing Programs for Priority Sources: The DNRE will obtain emissions 

reductions from some of the priority sources. The impact of the existing programs is discussed 

in the ECR report. Table 10.3.2.e., below from the ECR report (Table 4.2 in report, Battye, et. 

al, 2007) indicates results of the four factors for on-the-books controls. Table 10.3.2.f., 

(Table 4.5.1 in Battye, et. al, 2007) shows the change in deciviews predicted from on-the-books 

controls, including CAIR. (Since it is taken from the ECR report, it includes the two Minnesota 

Class I areas.) 
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze 

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52

Table 10.3.2.e. Summary of four-factor analysis of on-the-books controls

 Factor 1 Factor 2 Factor 3 Factor 4 

Control Strategy 

Costeffectiveness 

($/ton) 

Percent Emission 

Reductions from 

2002 baseline in 

2018 

Percent Emission 

Reductions from 

2002 baseline at 

full implementation Energy 

Solid 

waste 

produced 

(1000 

tons/yr) 

Remaining 

Useful Life 

3-State 

SO2:

13% 3-State 

SO2:

47% 2,383

NOx: 75% NOx: 75% 

9-State 

SO2:

34% 9-State 

SO2:

48% 

CAIR and other 

cap-and-trade 

programs (e.g., 

Acid Rain, NOx 

SIP Call) for 

EGUs 

$720 - 

$2,600 

NOx: 79% NOx: 80% 

4.5% of 

total 

energy 

consume

d 

The IPM 

model 

projects 

that 53 

units will 

retire by 

2018. 

BART: Based on 

company BART 

analyses from MN 

and ND for nonEGUs 

$248 - 

$1,770 

 

Combustion 

MACTs 

$1,477 - 

$7,611 

9-State 

SO2:

10% 9-State 

SO2:

10% 

 NOx: 5% NOx: 5% 

Highway vehicle 

programs 

$1,300 - 

$2,300 

3-State 

NOx:

83% 3-State 

NOx:

83% 

 9-State 

SO2:

80% 9-State 

SO2:

80% 

Nonroad mobile 

sources 

($1,000) - 

$1,000 

3-State 

NOx:

39% 3-State 

NOx:

39% 

 9-State 

SO2:

27% 9-State 

SO2:

27% 

350 MM 

gallons of 

fuel 

saved 

 

Source: Battye, 2007, p. 16 
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze 

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53

Table 10.3.2.f. Comparison of Uniform Rate of Progress (URP) in 2018 

with Projected Impacts for On-the-books Controls 

Estimated visibility impairment on the 20% worst visibility 

days (deciviews)a

Boundary 

Waters Voyageurs 

Isle 

Royale Seney 

Baseline conditions (2000-

2004)a

 19.86 19.48 21.62 24.48 

Projected conditions in 2018 

with on-the-books controlsb 18.94 19.18 20.04 22.38 

Net change 0.92 0.3 1.58 2.1 

Glide path/URP 17.7 17.56 19.21 21.35 

a

 The baseline condition values reflect the recent adjustments proposed by the Midwest RPO to include several 

missing days. The adjusted values are, on average, less than 0.5 dV greater than those provided on the IMPROVE 

Web site. 

b

 Based on CAMX modeling by the MRPO. These modeling analyses used preliminary estimates of the impacts of 

BART controls, which are generally larger than the impacts estimated in industry BART analyses. 

Source: Battye, 2007, p.20 

Evaluate Control Options for Priority Sources: Again, many control options for priority 

sources were evaluated in the ECR report. Particular attention was paid in the Northern Class I 

consultation group to the “EGU1” control strategy proposed by MRPO, which is a 0.15 lb/MMBtu 

SO2 limit and a 0.10 lb/MMBtu NOx limit assumed to take effect in 2013. Many in the Northern 

Class I consultation group also believe it is important to take a look at ICI boilers and the control 

strategies proposed by MRPO for those sources, including a 40 percent reduction in SO2 limit 

and a 60 percent reduction NOx by 2013. Figure 10.3.2.b. depicts the impacts on visibility of 

the various control scenarios evaluated in the ECR report (Battye, et al, 2007). 

The states in the Northern Class I consultation process have largely agreed on the priority 

pollutants (SO2 and NOx) and sources (EGU, and to a lesser extent ICI boilers), with each state 

adding some specific priority sources or source categories. For purposes of this SIP analysis, 

the DNRE considers EGUs as the primary priority source, but is also evaluating additional 

controls for ICI boilers. 
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze 

October 2010 

54

0.000

0.200

0.400

0.600

0.800

1.000

1.200

1.400

1.600

1.800

2.000

Strategy

1

Strategy

2

Strategy

1

Strategy

2

Strategy

1

Strategy

2

Strategy

1

Strategy

2

3 State 9 State 3 State 9 State

Visiblity Improvement (deciviews)

EGU

Mobile

Agriculture

Turbines

Reciprocating

engines

ICI boilers

Isle Royale Seney

Figure 10.3.2.b. Source sector contribution to visibility improvement (deciviews) at Isle 

Royale and Seney on the 20 percent worst days for 2018 for possible additional control 

measures Source: DNRE-generated from Battye, 2007.

Improvements in visibility are for both NOx and SO2 controls (the mobile category does not have 

two strategy levels, thus the same level was used for both). The dashed line shown in 

Figure 10.3.2.b indicates the deciview improvement needed to reach the EPA’s suggested URP 

glide path for 2018. 

For most states in the nine-state region to implement either of the EGU strategies (EGU1 or 

EGU2) described in the ECR report, large reductions in EGU emissions would be needed 

beyond what CAIR would have required. With the current status of the CAIR rule, EGU controls 

are very uncertain. The DNRE will continue to evaluate EGU controls in light of the proposed 

CATR rule. 

EGUs are clearly the top priority source category for control in order to realize significant 

visibility improvement at Michigan’s two Class I areas. EGUs are automatically presumed to be 

achieving reasonable emission reductions via the CAIR rule and the proposed CATR rule. 

Some of the largest EGUs, such as DTE’s Monroe power plant and Consumer Energy’s 

Campbell plant, have installed or are in the process of installing CAIR-compliant controls. 

EGUs in other states that have been shown to impact Michigan’s Class I areas (see Section 

10.3.2 of this document) also are expected to install and operate CAIR-compliant controls. 

Since all EGUs are subject to CAIR and will likely be subject to the proposed CATR, the DNRE 

believes that no further controls on EGUs should be considered as reasonable for purposes of 

reasonable progress at this time. 

A number of non-EGU facilities also have significant impact on the two areas, as identified in 

Section 10.3.2 of this document. These facilities are subject to BART analysis and have been 

evaluated to determine if additional controls represent BART. Those ICI boilers that are not 
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze 

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55

addressed by BART may eventually be controlled further. The DNRE and other LADCO states, 

along with a number of Northeast states, have been evaluating reasonable control levels for ICI 

boilers in the region. State rules or federal rules for these sources may be forthcoming in the 

next several years. 

Other controls evaluated in the ECR report, Battye, et. al, 2007 are evaluated as follows: 

ICI Boiler Emissions – The DNRE worked with LADCO and the Northeast states to develop 

recommendations for a federal ICI boiler rule. Several of these states have sent a letter to the 

EPA requesting a cooperative work effort to reduce pollutants from EGUs, ICI boilers and 

mobile sources (see Appendix 3D). A federal ICI boiler rule would be much more effective for 

emissions reductions from these sources because they would be reduced regionally. The 

proposed timing of this rule would occur before the first milestone year of 2018. 

Other Point Source Emissions − Reciprocating engines and turbines appear to be a sector with 

potential cost-effective NOx controls; the ECR report estimates the cost of NOx controls to be 

between $240 - $8,200/ton, but visibility impacts are small compared to EGUs and ICI boilers. 

The DNRE currently has a rule for large reciprocating engines. The DNRE will review this 

sector in more detail in the future. 

Mobile Source Emissions − There appears to be relatively few additional cost-effective NOx 

controls on mobile sources available to states, partially due to the large reductions resulting 

from federal requirements (Battye, et. al., 2007). 

Ammonia and Agricultural Sources − More study on ammonia is needed to improve our understanding of the role of ammonia in haze formation and potential ammonia controls. The DNRE 

does not have resources to conduct such research and encourages the EPA and the regional 

planning organizations to continue work in these areas. Due to the uncertainties, the DNRE is 

not considering controls for this sector at this time. 

Compare Control Strategies with Uniform Rate of Progress: At this time, the DNRE can 

only identify the “on-the-books” controls (includes CAIR) as being a reasonable level of control 

for setting Michigan’s RPG. A more detailed rationale is found in Section 10.5.2. Comparison 

to the URP has been made in Table 10.3.2.g and has been discussed in other sections of this 

document as well. The DNRE believes, however, that additional controls will be in place that 

will lower the RPG by 2018. Some other such scenarios have been modeled recently by 

LADCO and are also reflected in Table 10.6.b (see Section 10.6). 

Table 10.3.2.g. Visibility Conditions, URP and RPG for Michigan’s 

Class I areas (dv) 

 Baseline Baseline URP RPG Natural Natural 

 W20% B20% W20% W20% W20% B20% 

Isle Royale 21.59 6.77 19.43 20.86 12.36 3.72 

Seney 24.37 7.14 21.64 23.58 12.65 3.73 
Michigan Department of Natural Resources and Environment 

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10.4 Share of Emission Reductions

Each state must obtain its share of emission reductions needed to attain the RPG. Between 

now and 2018, there will be reductions in emissions of SO2 and NOx in Michigan and the region 

impacting Michigan’s Class I areas due to both on-the-books control strategies and additional 

emission control measures. However, because of each state’s attainment status for criteria 

pollutants and contribution towards haze, each state must ultimately make its own decision as to 

which control measures are reasonable. Many of the states that contribute to visibility impairment in Michigan’s Class I areas are tackling multiple SIP issues at once (haze, PM2.5 and 

ozone) and have or will submit their haze SIPs at a future date. Thus the RPG for Michigan’s 

two Class I areas remains somewhat uncertain, but is expected to be lower as other states 

develop SIPs with additional controls impacting the Class I areas. 

All of the control measures that Michigan currently plans to undertake are included in the longterm strategy and described in the following section. The RPG is set at the visibility level shown 

to result from the application of all the elements of the DNRE’s long-term strategy, along with all 

currently known controls being applied by other states. However, several of these control 

measures include CAIR controls that currently are being revised by the EPA. 

10.5 Long-term Strategy

The DNRE is required by 40 CFR 51.308(d)(3) to submit a long-term strategy that addresses 

regional haze visibility impairment for each mandatory Class I federal area within and outside 

the state that may be affected by emissions from within the state. The long-term strategy must 

include enforceable emissions limitations, compliance schedules and other measures necessary 

to achieve the reasonable progress goals established by states where the Class I areas are 

located. This section describes how the DNRE meets the long-term strategy requirements. 

10.5.1 Emission Reductions Due to Ongoing Air Pollution Programs

Under 40 CFR 51.308(d)(3)(v)(A), the DNRE is required to consider emission reductions from 

ongoing pollution control programs. The DNRE considered the following ongoing or expected 

programs in developing its RPG. 

Clean Air Interstate Rule (CAIR)

Although a CAIR replacement rule is being developed, several EGUs in the region have already 

begun to install controls for CAIR. The timing for CATR (Phase I-2012 and Phase II-2014) is 

adequate to address the 2018 milestone for regional haze. The DNRE is still evaluating how 

CATR will affect regional haze and BART for EGUs. 

Best Available Retrofit Technology (BART)

Five non-EGU sources in Michigan are subject to BART. Final BART determinations for 

Michigan’s five non-EGUs have been completed. Emission reduction information from BART 

controls is located in Section 9 of this document. 

Other Federal Programs

The DNRE also anticipates significant emission reductions resulting from several federal rules 

that will be implemented in the next several years. These reductions were included in the 

modeling of predicted 2018 emissions. 
Michigan Department of Natural Resources and Environment 

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• Tier II for on-highway mobile sources. 

• Heavy-duty diesel (2007) engine standards. 

• Low sulfur fuel standards. 

• Federal control programs for nonroad mobile sources. 

10.5.2 Additional Emission Limitations and Schedules of Compliance

The DNRE is required under 40 CFR 51.308(d)(3)(v)(C) to identify additional measures to meet 

visibility goals when ongoing programs alone are not sufficient. However, the EPA haze rule is 

clear that the basis for setting the visibility goal for a Class I area is determination of reasonable

controls based on the four factors plus visibility impacts. Therefore sufficient controls are those 

that are shown to be reasonable. The DNRE believes that reasonable controls are “on-thebooks” controls, including CAIR and its replacement rule for EGUs. For non-EGUs, BART will 

also suffice for reasonable controls, and ICI boiler controls may also be pursued when the 

current study addressed elsewhere in this report is completed. 

The DNRE’s rationale for determining that “on-the-books” controls meet the reasonable controls 

provisions of the Regional Haze Rule is as follows: As has already been described herein, the 

study by the LADCO contractor ECR evaluated the primary source categories that may impact 

Class I areas in the region. The category of sources having the largest impact on Class I areas 

is EGUs. All major EGUs are subject to CAIR and will be subject to CATR. The DNRE is still 

evaluating CATR to determine if this can be considered as adequate to meet the 

reasonableness criteria of the haze rule for EGUs. 

Another category reviewed by the consultant, which showed potentially reasonable additional 

controls on a cost basis, is ICI boilers. This category has been extensively reviewed by a 

workgroup formed by a collaborative group of Midwest and Northeast states. As a result, a joint 

letter for additional controls on ICI boilers was sent to the EPA on September 2, 2009. 

Therefore it is premature for the DNRE to proceed with its own set of controls for ICI boilers. 

The other categories of sources analyzed by ECR have less impact on the Class I areas than 

EGUs and boilers and are not being pursued for control beyond what is already on the books. 

The facilities in other states that have the largest impact on Michigan’s Class I areas are 

primarily EGUs and other sources that are subject to BART. Therefore Michigan expects to 

receive the benefit of future controls from these sources on our Class I areas. Future LADCO 

modeling will account for these additional controls and will show their impact on Michigan’s 

Class I areas. 

10.5.3 Measures to Mitigate the Impacts of Construction Activities

Under 40 CFR 51.308(d)(3)(v)(B), the DNRE is required to consider measures to mitigate the 

impacts of construction activities. Some of the main impacts of construction activities include 

the impacts of emissions from nonroad mobile and diesel engine emissions and fugitive 

emissions resulting from land clearing and construction. 

Emissions from nonroad mobile sources and diesel engines will be decreased between now and 

2018 due to federal on-the-books control strategies. The impact of construction activities will 
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze 

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58

continue to be mitigated through the federal general conformity and transportation conformity 

rules. These rules are already included in the DNRE’s SIP. 

In terms of the construction of new major sources, the visibility impacts of such sources will 

continue to be managed in conformance with existing requirements pertaining to New Source 

Review (NSR) and Prevention of Significant Deterioration (PSD). This involves analysis of 

visibility impacts and consultation with FLMs in determining if a new major source or major 

modification is installing BACT and if it has an adverse impact on visibility in Class I areas. The 

DNRE’s RFP plans include growth factors and the controls required by PSD, thus Michigan 

should attain its visibility goals even if new sources are permitted. 

10.5.4 Source Retirement and Replacement Schedules

Source retirement and replacement schedules, which must be considered under 40 CFR 51.308 

(d)(3)(v)(D) in developing reasonable progress goals, will be managed in conformance with 

existing requirements under the PSD program. 

10.5.5 Agricultural and Forestry Smoke Management

Under the requirements of 40 CFR 51.308(d)(3)(v)(E), the DNRE must consider smoke 

management techniques for the purposes of agricultural and forestry management in 

developing the long-term strategy to achieve the reasonable progress goal. 

Organic carbon (OC) and elemental carbon (EC) are formed from fire; however, neither are 

unique products of fire. EC is produced from combustion of any carbon fuels and therefore can 

come from diesel emissions as well as vegetative burning. OC comes from both primary 

emissions and secondary formation from gas phase emissions. OC can be attributed to 

anthropogenic sources of VOCs or to biogenic emissions from plants and trees in the summer 

growing season. 

OC is generally a large component of PM2.5 mass measured in the warmer months at Isle 

Royale and Seney. When light extinction is calculated from the filter measurements, OC is 

proportionally less significant but still an important pollutant (see Appendix 10C). 

In general, biogenic emissions of OC are not easily distinguished from emissions from fire, but 

several studies have been done to determine the causes of high OC in the Class I areas. It 

appears that most OC seen in the Northern Class I areas is biogenic, coming from plants as 

opposed to fire. 

Sheesley and Schauer (2004) conducted a study at Seney Wilderness that examined the 

sources of OC affecting the area. Using a marker species associated with vegetative burning, 

they found the highest levels of this marker in the winter months, likely indicating burning due to 

use of wood stoves and fireplaces. There was a lesser peak from June through September, 

possibly indicating fires in Canada. The summertime levels of other marker species indicated 

secondary organic aerosols from biogenic sources as the main source of OC, not primary 

emissions from wood smoke. 

These findings were reviewed in an MRPO (2005) issue paper, which concluded that “the 

contribution of fires to annual average PM2.5 concentrations and visibility impairment in the 
Michigan Department of Natural Resources and Environment 

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upper Midwest is relatively small. Nevertheless, fires may cause problems on an episodic 

basis.” 

To further investigate the impact of fire, an MRPO contractor (Boyer, et. al., 2004) developed an 

inventory of fire emissions from agricultural, prescribed, and wildfire burning in 2001 – 2003 for 

the Midwest states. The report shows that Michigan has low emissions from fires, although 

Michigan’s fire activity for prescribed and agricultural burns is likely underreported. 

The MRPO (2007) identified three days at Isle Royale and one day at Seney that had high OC. 

Using back trajectories and satellite maps of fires, it appears that monitoring data for all of the 

days was influenced by wildfires in Canada. Subtracting these days from the 20 percent worst 

days had a 0.2 dV reduction for Isle Royale and no change at Seney. 

Although the data show that fires do have some impact on visibility at Isle Royale, the impacts 

on the 20 percent worst days tend to be only a few poor visibility days in the summer caused by 

wildfires. Often these wildfires occur in Canada. For these reasons, the DNRE determined that 

OC particles are not good candidates for additional controls as part of the long-term strategy. 

Emissions from wildfires should be included in natural condition estimates, and any 

transboundary fire impacts must be addressed by the EPA. 

Per the RHR guidelines, the DNRE has determined that emissions from prescribed fires are not 

significantly affecting Class I areas in Michigan, thus current approaches to forestry and 

agricultural burning are adequate for long-term progress. However, the DNRE is currently 

developing further smoke management approaches for prescribed fire using basic smoke 

management practices that may become the basis for a Michigan Smoke Management Plan 

(SMP) if needed. 

10.5.6 Enforceability of Emission Limitations and Control Measures

Under 40 CFR 51.308(d)(3)(v)(F) the DNRE is required to ensure that emission limitations and 

control measures used to meet the RPG are enforceable. 

The CAIR requirements have been adopted as state regulations and the CATR requirements 

will also likely be adopted as state regulations as well. The BART control evaluations are 

required by a state rule adopted on September 11, 2008, and the limits and provisions of each 

source’s BART determination are enforceable through consent order and permits. The state 

rulemaking that makes BART an applicable requirement for stationary sources can be found in 

Appendix 9A. 

10.5.7 Anticipated Net Effect on Visibility Resulting from Projected Changes to 

Emissions

Under 40 CFR 51.308(d)(3)(v)(G), the DNRE is required to address the net effect on visibility 

resulting from changes projected in point, area, and mobile source emissions by 2018. 

The emission inventory used for this SIP addresses changes to point, area, and mobile source 

inventories by the end of the first implementation period resulting from population growth; 

industrial, energy and natural resources development; land management; and air pollution 

control. These changes, and their net effect on visibility, are described in Section 8 and 

Appendix 10F for the base year and LADCO’s Technical Support Document (LADCO 2008) for 
Michigan Department of Natural Resources and Environment 

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future year inventories. Table 10.6.a provides the net impact on visibility based on the original 

“on-the-books” scenario, as well as other possible control scenarios. 

10.5.8 Potential Future Projects That Will Reduce Emissions

Other actions are likely to take place over the next 10 years that will improve visibility in the 

Class I areas in 2018, but which are not included in the RPG, as follows: 

Renewable Energy

Michigan has adopted a Renewable Energy Portfolio, which will require 10 percent of the state’s 

energy to come from renewable sources by 2015. This is likely to lead to less fuel usage and 

more non-fossil fuel based energy generation, perhaps leading to lower future emissions from 

electricity generating units. 

Mercury/Multi-pollutant Rules

The DNRE developed state rules for mercury reductions from coal-fired EGUs. These rules will 

reduce mercury emissions throughout the state by 90 percent or approximately 2,000 lbs/year 

by 2015. Since intrastate trading is not allowed, all coal-fired EGUs will be required to comply. 

Several EGUs in the state will be upgrading their ESPs to baghouses to conform to mercury 

removal controls. The resultant reduction in particulate emissions may contribute to a reduction 

in haze. 

A second option the mercury rule provides is a multipollutant strategy. This option would allow 

a 75 percent reduction for mercury as long as the project garners 85 to 90 percent reduction in 

NOx and 85 to 95 percent reduction in SO2. This reduction also may contribute to a reduction in 

regional haze. 

PM2.5 and Ozone SIPs

As the EPA continues to tighten the National Ambient Air Quality Standard (NAAQS) for ozone 

and PM2.5, parts of Michigan and other surrounding states may become nonattainment for one 

or both of these pollutants, requiring reductions in precursor pollutants. Any such additional 

reductions in precursor emission will likely further reduce haze by 2018. Some programs that 

will contribute to this effort have already been mentioned. The DNRE, along with LADCO and 

the Northeast states, have made a proposal for ICI boiler control to the EPA, suggesting the 

EPA promulgate a federal rule. The DNRE also may further investigate control measures that 

were shown by the ECR report to be potentially reasonable under the four factors analysis, as 

resources allow. 

Greenhouse Gas Programs

Governor Jennifer M. Granholm issued Executive Directive 2009-4 to implement the 

recommendations of the Michigan Climate Action Council in its Climate Action Plan. Although 

any measures undertaken will be intended to reduce greenhouse gases, it is likely that some 

reductions may have the added benefit of reducing emissions of fine particulate matter and its 

precursors and thereby reducing haze. 
Michigan Department of Natural Resources and Environment 

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10.6 Reasonable Progress Goals

Section 10.5.1 of this document describes the control programs that constitute Michigan’s RPG 

for meeting the 2018 interim date. This decision is based on an analysis of the four factors and 

visibility in relation to the priority sources of haze, as described in previous portions of this 

document. This reasonable progress goal results in the deciview levels shown in the 

Table 10.6.a. While “on-the-books” controls are considered the primary RPG, the other 

scenario depicted as “LADCO Scenario B” may more accurately reflect the level of control for 

determining the RPG. This will be further clarified when the CATR is finalized and the DNRE 

and other LADCO states evaluate future EGU emission reductions reflecting compliance with 

the CATR. 

Table 10.6.a. Adjusted Reasonable Progress Goals for Michigan Class I Areas 

Class I area 2018 

Visibility 

20% Worst 

Days (dv) 

2018 

Visibility 

20% Best 

Days (dv) 

Projected 

Annual 

Improvement 

2004-2018 

(W20%, dv) 

Projected 

Improvement 

by 2064 

(W20%, dv) 

Year 

Reaching 

Natural 

Conditions 

(W20%) 

On-the-books controls including CAIR 

Isle Royale 20.09 6.60 0.11 6.43 2090 

Seney 22.59 7.71 0.13 7.67 2096 

 LADCO Scenario B 

Isle Royale 20.86 6.76 0.05 3.13 2181 

Seney 23.58 7.78 0.06 3.43 2209 

Source: DNRE 

Note: LADCO Scenario B reflects on-the-books controls, but only including those CAIR EGU controls that are 

currently enforceable by state consent orders or permits. 

The RPG provides for less annual progress by 2018 than is reflected in the URP. 

Table 10.3.2.f. shows 2018 URP values of 19.21 at Isle Royale and 21.35 at Seney. Following 

the rate of progress of the DNRE, RPG provides the values in the last column of Table 10.6.a. 

However, these values are of little meaning since they are so distant into the future. The DNRE 

believes that the RPG set in this SIP meets the provisions of the haze rule for making 

reasonable progress, and that there will be many more reductions in emissions over the next 10 

years and beyond that will continue to bring the Class I areas closer to natural background. At 

this time, it is not known whether natural conditions will be met by 2064. Further analysis will be 

made for the 2012 haze rule-required review process and periodically as required in the haze 

rule. 
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze 

October 2010 

62

11 Comprehensive Periodic Implementation Plan Revisions and Determination of the 

Adequacy of the Existing Plan 

Under 40 CFR 51.308(f), a state is required to revise its regional haze implementation plan and 

submit a plan revision to the EPA by July 31, 2018 and every ten years thereafter. In 

accordance with these requirements of the Regional Haze Rule, the DNRE commits to revising 

and submitting this regional haze implementation plan by July 31, 2018 and every ten years 

thereafter. 

In addition, 40 CFR 51.308(g) requires periodic reports evaluating progress towards the 

reasonable progress goals established for each mandatory Class I area. In accordance with the 

requirements listed in Section 51.308(g) of the federal rule for regional haze, the DNRE will 

submit a report on reasonable progress to the EPA every five years following the initial submittal 

of the SIP. The report will be in the form of a SIP revision. The reasonable progress report will 

evaluate the progress made towards the reasonable progress goal for each mandatory Class I 

area located within Michigan. No mandatory Class I area located outside Michigan is expected 

to be affected by emissions from within Michigan. All requirements listed in Section 51.308(g) 

will be addressed in the SIP revision for reasonable progress. 

The DNRE will be developing emissions inventories every three years as required by the EPA. 

LADCO will continue to update modeling. The DNRE will use this information as well as 

monitoring data to determine if the two Class I areas are meeting their RPGs. 

In addition, the DNRE will be reviewing several aspects of the SIP. The actions laid out in 

Table 11.1 will be occurring prior to the five-year report. More information on these actions is 

described elsewhere in the SIP.

Table 11.1. Activities Prior to Five-year SIP Assessment 

Description Responsible Party 

Continue to determine BART emission limit determinations for nonEGU BART-subject facilities (complete determinations expected in 

2016)

DNRE 

Incorporate non-EGU BART emission limits into facility permits, orders DNRE 

Determine controls for EGUs for CATR, incorporate in facility permits, 

orders 

DNRE, EPA 

Track emission changes in Michigan and in other states contributing to 

Michigan Class I areas 

DNRE 

Other states 

The DNRE will continue to have periodic calls as needed with the Northern Class I consultation 

group including states, tribes, FLMs, and EPA. The LADCO states and Minnesota will continue 

to do technical evaluations that will be necessary to determine if the Class I areas are reaching 

their RPGs. 

In the five-year report, the DNRE will undertake an emission review to determine if the emission 

reductions projected to occur through the application of BART, CATR, the mercury rule, and the 

other components of the DNRE’s long-term strategy have occurred. The review will also look at 

what new emission sources have begun operation. 
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze 

October 2010 

63

Depending on the findings of the five-year progress report, the DNRE commits to taking one of 

the actions listed in 40 CFR 51.308(h). The findings of the five-year progress report will 

determine which action is appropriate and necessary. 

List of Future Actions from 40 CFR 51.308(h) Scenarios 

1. If the DNRE determines that the existing SIP requires no further substantive revision to 

achieve established goals, the DNRE would provide to the EPA Administrator a negative 

declaration stating that further revision of the SIP is not needed at that time. Monitoring 

data from the Class I areas would need to be on track or lower than the 2012 visibility 

estimate, based on MRPO’s modeling for 2012, and therefore no revision action would 

be necessary. 

2. If the DNRE determines that the existing SIP may be inadequate to ensure reasonable 

progress due to emissions from other states that participated in the regional planning 

process, the DNRE would notify the EPA Administrator and the states that participated in 

regional planning. The DNRE would collaborate with states through the regional 

planning process, as resources allow, to address the SIP’s deficiencies. (Federal 

funding for RPO activities has ended. Unless funds are restored, there may be limited 

collaboration among states and limited future RFP analyses.) 

3. If the DNRE determines that the existing SIP may be inadequate to ensure reasonable 

progress due to emissions from another country, the DNRE would provide notification, 

along with available information, to the EPA Administrator. 

4. If the DNRE determines that the existing SIP is inadequate to ensure reasonable 

progress due to emissions from within the state of Michigan, the DNRE would revise its 

SIP to address the plan’s deficiencies within the required time period. The DNRE would 

evaluate contingency measures, including ICI boilers, other point sources (such as 

reciprocating engines), mobile sources, or any other sources as appropriate to 

determine which should be adopted. 

 
Michigan Department of Natural Resources and Environment 

SIP Submittal for Regional Haze 

October 2010 

64

12 References 

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areas in the Northern Midwest – Factor Analysis. Prepared for Lake Michigan Air Directors 

Consortium and Minnesota Pollution Control Agency. ECR, Inc. 

Boyer K., Battye W., Fudge S., and Barrows R., 2004, September 30, Fire Emissions Inventory 

Development for the Midwest Regional Planning Organization: Final Report. EC/R, Inc. 

Kenski D., 2007, March 12; revised 2007, June 19, Impact of Missing Data on Worst Days at 

Midwest Northern Class I areas. Prepared for Midwest RPO and Northern Class I area 

consultation group. 

LADCO. 2008. Regional Air Quality Analysis for Ozone, PM2.5 and Regional Haze: Final 

Technical Support Document. April, 25, 2008. 

MANE-VU, 2007, Inter-RPO Consultation Briefing Book. 

MANE-VU, 2006, August 31, Contributions to Regional Haze in the Northeast and Mid-Atlantic 

United States. 

 

MRPO, 2005a, April 20, Draft Issue Paper: Fires. 

MRPO, 2005b, September 29, Approaches for Meeting Reasonable Progress for Visibility at 

Northern Class I areas (DRAFT). 

MRPO 2007, April 2, Estimating Reasonable Progress Goals for the Northern Class I areas: 

Treatment of Organic Carbon. 

Sheesley R. J. and Schauer J. J., 2004, Source Apportionment of Fine Particulate Matter 

Collected at the Seney Wildlife Refuge. May 2004. 

U.S. EPA, Office of Air Quality Planning and Standards, 2007, June 1, Guidance for Setting 

Reasonable Progress Goals Under the Regional Haze Program. 

U.S. EPA, 1999, Visibility Monitoring Guidance, June 1999.