BART Resource Guide 

Prepared by 

NESCAUM 

For the Mid-Atlantic/Northeast Visibility Union (MANE-VU) 

Regional Planning Organization 

August 23, 2006
Members of Northeast States for Coordinated Air Use Management 

Arthur Marin, Executive Director 

Northeast States for Coordinated Air Use Management

Anne Gobin, Bureau Chief 

Connecticut Department of Environmental Protection, Bureau of Air Management 

James P. Brooks, Bureau Director 

Maine Department of Environmental Protection, Bureau of Air Quality 

Barbara Kwetz, Director 

Massachusetts Department of Environmental Protection, Bureau of Waste Prevention 

Robert Scott, Director 

New Hampshire Department of Environmental Services, Air Resources Division 

William O’Sullivan, Director 

New Jersey Department of Environmental Protection, Office of Air Quality Management 

David Shaw, Director 

New York Department of Environmental Conservation, Division of Air Resources

Stephen Majkut, Chief 

Rhode Island Department of Environmental Management, Office of Air Resources 

Richard A. Valentinetti, Director 

Vermont Department of Environmental Conservation, Air Pollution Control Division 
ii 

BART Resource Guide 

Prepared by 

NESCAUM 

for the Mid-Atlantic/Northeast Visibility Union (MANE-VU) 

Regional Planning Organization 

August 23, 2006 

Submitted to the United States Environmental Protection Agency, Region III 

in partial fulfillment of requirements for EPA agreement XA-97318101-0 

to the Ozone Transport Commission 

Project Director

 Gary Kleiman, NESCAUM 

Editors

 Paul Miller, NESCAUM 

 

Principle Contributors

 Iyad Kheirback, NESCAUM 

 Gary Kleiman, NESCAUM 

 Lisa Rector, NESCAUM 

US EPA Project Officer 

 Marcia Spink, US EPA Region III 
iii 

Acknowledgments 

This report was prepared by NESCAUM staff listed on the opposite page under 

“Principal Contributors.” 

NESCAUM gratefully acknowledges the funding support provided by the U.S. 

Environmental Protection Agency through their support of the MANE-VU Regional 

Planning Organization (Grant # XA-97318101-0). 

NESCAUM also thanks the following individuals for providing comments on this report: 

Anne Arnold, US Environmental Protection Agency – Region 1 

Doug Austin, Ozone Transport Commission 

Marc Cone, Maine Department of Environmental Protection 

Stephen Dennis, Massachusetts Department of Environmental Protection 

Nancy Herb, Pennsylvania Department of Environmental Protection 

Brian Hug, Maryland Department of Environmental Protection 

Wendy Jacobs, Connecticut Department of Environmental Protection 

Bob Kelly, US Environmental Protection Agency – Region 2 

John Kent, New York Department of Environmental Conservation 

Doug McVay, Rhode Island Department to Environmental Management 

Anne McWilliams, US Environmental Protection Agency – Region 1 

Gary Milbury, New Hampshire Department of Environmental Services 

Jack Sipple, Delaware of Natural Resources and Environmental Control 

Donald Squires, Massachusetts Department of Environmental Protection 

David Wackter, Connecticut Department of Environmental Conservation 

Printed: September 2006 
iv 

TABLE OF CONTENTS 

Acknowledgments..............................................................................................................iii 

Executive Summary........................................................................................................... vi 

1. Introduction.............................................................................................................. 1-1 

1.1. Overview of Regional Haze Program.............................................................. 1-1 

1.2. Overview of BART Rule ................................................................................. 1-1 

1.3. Overview of BART Process............................................................................. 1-2 

1.3.1. BART eligibility ...................................................................................... 1-2 

1.3.2. Cause or contribute to visibility impairment in a Class I area................. 1-3 

1.3.3. BART determinations .............................................................................. 1-3 

1.4. Overview of Report.......................................................................................... 1-4 

2. MANE-VU BART PROCESS................................................................................. 2-1 

2.1. BART Workgroup ........................................................................................... 2-1 

2.2. BART Recommendations ................................................................................ 2-1 

2.2.1. Recommendations regarding BART eligibility: ...................................... 2-1 

2.2.2. Recommendations regarding BART control reviews.............................. 2-2 

2.3. Recommended Presumptive BART Levels of Control.................................... 2-2 

2.4. BART Trading ................................................................................................. 2-3 

3. BART DETERMINATIONS................................................................................... 3-1 

3.1. EGUs................................................................................................................ 3-1 

3.1.1. CAIR........................................................................................................ 3-1 

3.1.2. Statutory factors....................................................................................... 3-2 

3.1.3. Engineering reviews................................................................................. 3-3 

3.1.4. MANE-VU staff BART recommendations ............................................. 3-3 

3.2. Other Industrial Sources .................................................................................. 3-3 

3.2.1. RACT....................................................................................................... 3-4 

3.2.2. Permit limitations..................................................................................... 3-4 

3.2.3. Statutory factors....................................................................................... 3-4 

3.2.4. MANE-VU staff BART recommendations ............................................. 3-5 

4. MODELING ............................................................................................................ 4-1 

4.1. Modeling Methods........................................................................................... 4-1 

4.1.1. REMSAD: SO2 tagging ........................................................................... 4-2 

4.1.2. CALPUFF approaches: NWS observation-based and MM5-based 

meteorology ............................................................................................................. 4-2 

4.1.3. Empirical approaches: emissions divided by distance or Q/d ................. 4-3 

4.1.4. Data analysis approach: percent time upwind ......................................... 4-4 

4.2. Anticipated Visibility Improvement as a Result of BART.............................. 4-4 

5. BART RESOURCES............................................................................................... 5-1 

5.1. Regulations ...................................................................................................... 5-1 

5.2. BART Eligibility Resources ............................................................................ 5-1 

5.3. Control Technology Information ..................................................................... 5-1 

5.4. Program Implementation Resources................................................................ 5-2 

5.5. Modeling Resources......................................................................................... 5-2 

5.6. Stakeholder Submitted Information................................................................. 5-3 

6. CONCLUSION........................................................................................................ 6-1 
v 

Appendix A: Regulations................................................................................................ A-1 

Appendix B: BART-Eligibility Resources ..................................................................... B-1 

Appendix C: Control Technology Options..................................................................... C-1 

Appendix D: Program Implementation Resources ......................................................... D-1 

Appendix E: Modeling Resources ...................................................................................E-1 

Appendix F: Stakeholder Provided Resources ................................................................F-1 

Appendix G: BART-Eligible Source Information by State............................................ G-1 
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Executive Summary 

This report was prepared by the Northeast States for Coordinated Air Use 

Management (NESCAUM) as part of an effort to assist states and tribes in implementing 

the Best Available Retrofit Technology (BART) requirements of the Regional Haze Rule. 

The Regional Haze Rule requires states to determine the most stringent technologically 

feasible system of controls that can reasonably be installed at each facility determined to 

be BART-eligible. Criteria that determine whether a specific control technology is 

deemed reasonable include: cost of the controls, other control technology in use at the 

source, energy and other non-air quality environmental impacts, remaining useful life of 

the source, and the degree of visibility improvement anticipated to result from installation 

of the controls. 

This report provides information designed to assist states as they determine what 

emission limits and controls are necessary for the December 17, 2007 SIP submittal. 

This SIP submittal requires that states submit a list of sources eligible for BART, a 

BART determination for each source, and a compliance schedule for installing controls. 

This report seeks to provide states with resources to complete this task. The report 

provides information on BART requirements, BART determination, BART modeling and 

other resources to assist states in the BART process. States will need to conduct an 

individual analysis for each facility prior to making a BART determination. This 

information is intended to facilitate that process by collecting available information into a 

single reference document. 

 The report finds that the BART program could represent a significant emission 

reduction opportunity for the Northeast and Mid-Atlantic States if implemented strictly. 

Electrical generation units (EGUs) represent the greatest potential single source category 

for emission reductions but due to EPA’s determination that CAIR will serve as BART 

for covered facilities there may be a reduction in BART effectiveness from this category. 

BART may yield particulate matter emission reductions from EGUs however, since 

CAIR only applies to nitrogen oxides (NOX) and sulfur dioxide (SO2) emissions. In 

addition, states that choose to use the flexibility provided in the BART rule may be able 

to “harvest” the emissions reductions from several other source sectors in that refinery, 

cement plant and ICI boiler RACT programs being considered for NAAQS compliance to 

maximize emission reductions under the BART program. 
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1. INTRODUCTION 

1.1. Overview of Regional Haze Program 

In 1977, Congress outlined goals in the federal Clean Air Act (CAA) to restore 

pristine visibility conditions in national parks and wilderness areas. Section 169 of the 

CAA calls for the prevention of any future, and the remedying of “any” existing, manmade visibility impairment in all Class I areas.1

 Upon adoption of this legislation, EPA 

took relatively modest steps to remedy visibility impairment at Class I areas around the 

country. Control measures were largely confined to addressing plume blight from 

specific pollution sources near Class I areas. However, these actions did little to address 

the pervasive, regional nature of haze throughout the eastern United States. Most of the 

regional emission reductions occurred through implementation of other CAA programs, 

such as the National Acid Rain Program. 

Subsequent to the adoption of the 1977 goals, visibility in the nation’s Class I 

areas continued to deteriorate. In eastern areas, average visual range decreased from 90 

miles to 15-25 miles. In the West, visual range decreased from 140 miles to 35-90 miles.2 

Given the lack of improvement in visibility, the US EPA issued a new set of regulations 

in 1999 (64 Fed. Reg. 35,714, July 1, 1999) aimed at achieving visibility goals by 2064. 

These rules, commonly known as the “Regional Haze Rule,” developed a program to 

restore natural visibility conditions at Class I areas across the country. Under the 

Regional Haze Rule states or tribes are required to develop and submit State 

Implementation Plans (SIPs) or Tribal Implementation Plans (TIPs) to EPA by December 

17, 2007. EPA requires these plans to: 

• Demonstrate states’ efforts to make reasonable progress towards the 2064 

national visibility goals. 

• Create a long-term strategy for achieving the national regional haze goal 

with an implementation period to 2018 and reassessment every ten years 

thereafter. 

• Identify sources subject to the Best Available Retrofit Technology 

(BART) provisions and determine controls for those units. BART 

provisions provide a mechanism for achieving visibility improvements in 

haze SIPs. 

1.2. Overview of BART Rule 

 In June 2001, EPA released a proposed rule on BART. This rule outlined the 

method for determining if a facility is eligible for BART, subject to BART provisions, 

and methods for conducting a BART control review. 

 In 2002, industry groups challenged the method EPA outlined in the Regional 

Haze Rule to determine the degree of visibility improvement resulting from application 

 

1

 The Class I designation applies to national parks exceeding 6,000 acres; wilderness areas and national 

memorial parks exceeding 5,000 acres; and all international parks that were in existence prior to 1977. 

2

 http://epa.gov/oar/visibility/what.html 
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of BART controls. Under EPA’s interpretation of the statute, a state would deem sources 

subject to BART if they emitted emissions into a geographic area or region that likely 

transports pollutants downwind into a protected area. In May 2002, the D.C. Circuit 

Court of Appeals agreed with industry petitioners and vacated those portions of the 

Regional Haze Rule dealing with BART. 

 In June 2005, EPA released the final BART rule. Under the final rule, the BART 

program requires states to develop an inventory of sources within each state or tribal 

jurisdiction that could be subject to control. Specifically, the rule: 

• Outlined methods to determine if a source is “reasonably anticipated to cause or 

contribute to haze;” 

• Defined the methodology for conduction of a BART control analysis; 

• Provided presumptive limits for electricity generating units (EGUs) larger than 

750 Megawatts; 

• Provided a justification for the use of the Clean Air Interstate Rule (CAIR) as 

BART for CAIR state EGUs. 

Beyond the specific elements listed above, EPA provided the states with a large 

amount of latitude to implement the BART program. The following section provides 

information on the BART eligibility determination and control review process. 

1.3. Overview of BART Process 

 The BART program applies to facilities in one of 26 source categories that have 

units installed and operating between 1962 and 1977 with the potential to emit more than 

250 tons per year of a visibility impairing pollutant. Once a source is found to be BARTeligible it must undergo a case-by-case analysis to determine if what emission controls 

are appropriate. The BART process has three steps. These steps include: 

• Determining if a source is BART-eligible; 

• Determining if a source reasonably causes or contributes to visibility impairment 

in any Class I area; 

• Determining if additional controls or emission limits are necessary (BART 

determination). 

1.3.1. BART eligibility 

 There are three factors used to determine if a source is BART-eligible under the 

CAA. Applicability is limited to those sources that: 

1. Are in one of 26 specific source categories as identified in the Clean Air Act 

(see Table 2.1 for a list of these categories); 
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2. Have units that were in existence on August 7, 1977,

3

 but had not been in 

operation for more than fifteen years as of that date (prior to August 7, 1962); 

3. Have a potential to emit (PTE) 250 tons per year (TPY) or more of any single 

visibility impairing pollutant from units that satisfy criterion #2. These 

pollutants include SO2, NOX, VOCs, PM10 and ammonia. EPA in the final 

Regional Haze rule, however, allowed states flexibility in addressing 

ammonia and VOC sources. 

Appendix B contains detailed information on MANE-VU’s BART eligibility process.

1.3.2. Cause or contribute to visibility impairment in a Class I area 

 Once a facility is found to be “eligible” for the BART program, states must 

determine if that facility causes haze or contributes to the formation of haze at any Class I 

area. EPA’s 2005 rule outlines three options to determine if a source reasonably causes or 

contributes to regional haze in any Class I area. These options include: 

• Individual source assessment (Exemption Modeling) – This assessment uses 

CALPUFF or other EPA approved modeling methods. Results of modeling 

would be compared to natural background conditions. EPA defined “cause” as an 

impact of 1.0 deciview or more and “contribute” as an impact of 0.5 deciview or 

more. The rule, however, gave states discretion to set lower thresholds for 

contribution. 

• Cumulative assessment of all BART "eligible sources” – Under this method, a 

state can choose to find that all eligible sources are subject to BART. This 

method could also be used to analyze an area’s contribution to visibility 

impairment and demonstrate that no sources are subject, based on cumulative 

modeling. 

• Assessment based on model plants – This method provides a mechanism to 

exempt sources with common characteristics that are found not to impair visibility 

at Class I areas. 

1.3.3. BART determinations 

 Once a facility has been identified as BART-eligible and found to cause or 

contribute to haze in a Class I area, it must conduct an engineering review to determine if 

the installation of new control requirements is appropriate. This review takes into 

consideration five factors: 

• Cost 

• Energy and non-air environmental impacts 

• Existing controls at source 

 

3August 7, 1977 is the date that Congress adopted the 1977 Clean Air Act Amendments. 
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• Remaining useful life of source 

• Visibility improvement reasonably expected from the technology. 

1.4. Overview of Report 

 This report is intended to integrate all the information states could use to finalize 

their BART information for the December 2007 SIP submittal. This report provides an 

overview of MANE-VU’s BART process, BART determinations, BART modeling, and 

BART resources. A brief review of the findings and their implications can be found in 

Appendix G, which, at this time, is only available to the individual state agency charged 

with conducting BART reviews for the specific facilities. 
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2. MANE-VU BART PROCESS 

The following sections provide an overview of BART activities undertaken by 

MANE-VU and guiding actions for the region. 

2.1. BART Workgroup 

MANE-VU formed the BART workgroup as part of an effort to assist states and 

tribes as they prepare to comply with the Best Available Retrofit Technology (BART) 

requirements of the Regional Haze Rule. Membership in the MANE-VU BART 

workgroup is open to states and tribes in the MANE-VU region, EPA regional offices 

and the Federal Land Management agencies. This group worked together to refine the 

BART-eligible identification process. In addition, the group has developed 

recommendations to the MANE-VU Directors on assumptions for identifying BARTeligible sources and in making BART control determinations. To date, states have made 

substantial progress in identifying sources that are BART-eligible. This, however, is only 

the first step in the process. Once a source is identified as “BART-eligible,” an analysis 

must be conducted to determine what will constitute BART for each facility. 

2.2. BART Recommendations 

 The Regional Haze Rule requires states to determine the most stringent 

technologically feasible system of controls that can reasonably be installed at each 

facility eligible for BART. The BART workgroup developed a list of recommendations 

for the BART control process that have been approved by the MANE-VU Directors. The 

recommendations include overall BART policies and specific “presumptive” levels and 

types of control. These recommendations will serve as a regional foundation for 

conducting BART engineering reviews on a state-by-state basis. The recommendations 

have been grouped by the three steps of the BART process that they affect. 

2.2.1. Recommendations regarding BART eligibility: 

• Any BART-eligible facility may “cap-out” of BART via a permit emission limit, 

however all permit modifications must be finalized prior to December 16, 2006 

in order to eliminate BART eligibility. Caps must limit emissions from BARTeligible units below 250 tons per year of any visibility impairing pollutant. Caps 

must be in place prior to December 16, 2006 in order to enable states to take 

action to get permit limitations in place and achieve emission limits prior to SIP 

public notice and hearing processes. 

• If data do not exist to accurately determine the installation date for emission 

unit(s) within a facility, then the unit will be treated as though it is within the 

BART date range unless the facility can provide proof otherwise (i.e., proof that 

the unit was in operation prior to 1962). Many states are having difficulty 

identifying installation dates for pre-1977 units. All states felt they could easily 

identify post-1977 units. Therefore, the workgroup supported a policy position 

that when the state could not accurately determine the "in existence" date, the 
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burden of proof lay with the facility in proving that the unit was installed prior to 

1962. 

2.2.2. Recommendations regarding BART control reviews 

• If a source is eligible for BART, it is subject to the BART determination process

(i.e., no exemptions will be given; note this does not necessarily mean that 

controls will be required). 

• Regional performance standards or cost thresholds are appropriate for many 

individual categories of BART-eligible sources. The next section contains an 

initial round of recommended presumptive levels of control for EGUs, industrial 

boilers, and cement kilns. The workgroup may develop additional presumptive 

levels in the future. 

• Remaining useful life of a source will be considered in the following way:

Facilities have the option to either control a BART-eligible facility prior to 2013 

or accept a federally enforceable permit limitation or retirement date prior to 

December 16, 2006.

• Control technology in place will likely have to be dealt with on a source-bysource basis (i.e., no regional recommendation). 

• Energy and non-air quality environmental impacts will likely have to be dealt 

with on a source-by-source basis (i.e., no regional recommendation). The 

workgroup, however, is still considering regional recommendations for non-air 

quality environmental impacts. 

2.3. Recommended Presumptive BART Levels of Control 

 The workgroup reviewed other regional control initiatives and attempted to 

harmonize those efforts with BART. This review resulted in the development of a 

recommended level of presumptive control for EGUs (CAIR and non-CAIR units) and 

industrial boilers. In addition, the group developed a list of control technologies that 

must be reviewed for cement kilns. Specific information on presumptive levels is 

provided below: 

Non-CAIR EGUs:

• SO2 – Coal - 95% control or 0.15 lb/MMBtu* 

 Oil - 95% control or 0.33 lb/MMBtu (0.3% sulfur content)* 

• NOX 

o in NOX SIP call area, extend use of controls to year-round 

o 0.1 – 0.25 lb/MMBtu, depending on boiler and fuel type 

• PM – 0.02 – 0.04 lb/MMBtu** 

 

CAIR EGUs:
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• SO2 – CAIR requirements 

• NOX – CAIR requirements 

• PM – 0.02- 0.04 lb/MMBtu** 

If an EGU is only enrolled in CAIR for one or two pollutants, it still must complete an 

analysis for the remaining visibility impairing pollutants such as particulate matter. 

Industrial Boilers 

• SO2 – 90% control, MACT acid gas control level, ICI-RACT, or 0.55 lb/MMBtu 

(0.5% fuel sulfur limit) 

• NOX 

o 0.1 – 0.4 lb/MMBtu, depending on boiler and fuel type*** 

• PM – 0.02 - 0.07 lb/MMBtu 

Cement Kilns

No common emission threshold has been identified. The following lists, however, 

recommend control technologies to evaluate. 

• SO2 

o in process removal 

o wet or dry scrubbers 

o conversion from wet kiln to dry kiln 

• NOX 

o Combustion optimization 

o Low NOX burners 

o Secondary combustion control (SNCR/SCR) 

o Mid-Kiln firing 

o Flame shape adjustment 

• PM 

o baghouse 

o electrostatic precipitator 

o baghouse/ESP upgrades of existing controls 

*Consistent with EPA presumptive BART for EGUs and OTC Control Strategy 

** PM measures are based on front-half (Method 5) particulate matter measures 

*** Consistent with OTC Control Strategies and NOX SIP call emission limits 

2.4. BART Trading 

 EPA proposed rules regarding BART trading in July 2005. As of the writing of 

this report, final rules had not been promulgated. The 2005 EPA proposal (see 

Appendices) requires that a trading program demonstrate results better than those 

achieved by the source-by-source BART program and that all BART sources in a sector 

participate. The MANE-VU BART workgroup continues to be interested in and 

investigate the possibility of developing a BART trading program but several significant 

barriers exist, including limited resources to manage a trading program. 
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3. BART DETERMINATIONS 

 In determining what system of controls constitute BART, the category of fossilfuel fired steam-electric plants with greater than 250 MMBtu/hr heat input (hereafter 

Electrical Generating Units or EGUs) have been considered separately. Many options for 

reducing emissions from this category of sources exist and are widely available. While 

options for reducing emissions from the other 25 BART-eligible source categories also 

exist – and in many cases are the same options used by EGUs – they are often more 

source-specific with respect to their applicability or capital costs. We begin the 

discussion of BART determinations with EGUs. 

3.1. EGUs 

 The BART-eligible EGUs in MANE-VU represent the largest emissions 

reduction potential among the various BART-eligible source categories. The population 

of BART-eligible EGUs within the MANE-VU domain can be broadly divided into three 

groups: 

• Those in states eligible for participation in the U.S. EPA Clean Air Interstate 

Rule (CAIR) program on a year-round basis (Delaware, District of Columbia, 

Maryland, New Jersey, New York and Pennsylvania for SO2 and NOX), 

• Those in states that participate in the seasonal CAIR program (Connecticut 

and Massachusetts for summertime NOX), and 

• Those in states that are not eligible to participate in the CAIR program 

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

Given the decision by the US EPA that CAIR will satisfy the SO2 and NOX requirements 

for BART, a discussion of those CAIR facilities is separated from the non-CAIR EGUs. 

We then turn in section 3.1.2 to consideration of how BART determinations are 

conducted for other EGUs. 

3.1.1. CAIR 

 The Clean Air Interstate Rule – or CAIR – is a cap and trade program for SO2 and 

NOX emissions intended to address interstate transport of these pollutants. By requiring a 

large number of eastern states to reduce emissions of these pollutants, the level of 

transported sulfate and nitrate fine particulate matter, as well as ground-level ozone and 

precursor pollutants, is anticipated to be greatly reduced. Whether this regulation will 

deal adequately with transported air pollution and its precursors in the context of NAAQS 

attainment is a larger question, but within the context of the CAIR regulation, the states’ 

ability to seek emissions controls from upwind states beyond those required under CAIR 

is limited. There is an opportunity; however, for additional emission reductions through 

the Regional Haze Rule’s Reasonable Progress Goals and the inter-RPO consultation 

process where addressing national visibility goals may also help achieve compliance with 

various other mandated Clean Air Act programs. 

 EPA has stated that a state’s participation in the CAIR program will satisfy the 

BART control requirements for BART-eligible EGUs that are also subject to the CAIR 
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provisions. Those facilities, however, will still need to conduct an analysis for PM. This 

includes all BART-eligible EGUs in Delaware, District of Columbia, Maryland, New 

Jersey, New York, and Pennsylvania. EGUs located in Connecticut and Massachusetts 

are also included in the CAIR program, but only for ozone season NOX. 

While BART determinations still must be conducted for all BART-eligible 

sources, it is anticipated that in CAIR states, adoption of the CAIR program will satisfy 

BART for the BART-eligible EGUs participating in the CAIR program for the specific 

pollutants covered under the rule. This means that all States must still consider whether 

PM and VOC controls are warranted at facilities where SO2 or NOX controls may be 

covered under CAIR. In addition, CAIR-participating EGUs in Delaware, New Jersey, 

Connecticut and Massachusetts will still have to identify appropriate SO2 controls to 

serve as BART, as well as controls for NOX in the non-ozone season (October through 

April). Identification of controls for these pollutants, however, must be done with proper 

consideration of the statutory factors contained in the BART regulations as for any other 

pollutant. Discussion of issues related to this determination for potential PM, VOC, or 

non-ozone season NOX controls is in the following section and is germane for all controls 

– including SO2 and ozone season NOX – being considered by the non-CAIR states of 

Rhode Island, New Hampshire and Maine.4

3.1.2. Statutory factors 

 The BART determination process includes an engineering review, which requires 

the identification of the most stringent technologically feasible system of controls that 

can be installed at a facility. An engineering review for each facility in the MANE-VU 

region will be time-consuming and labor intensive. For states like New York or 

Pennsylvania, which have a large number of BART-eligible sources, it may be more 

efficient to conduct the mandatory review of statutory factors – and here we are primarily 

thinking of energy and non-air quality environmental factors, other controls already in 

place, and degree of visibility improvement that could result from installation of controls 

– prior to conducting a detailed engineering review for some facilities. The degree of 

visibility improvement must be considered in conjunction with the other statutory factors, 

but this analysis can be done before the engineering review. For many facilities, these 

statutory considerations could eliminate the reasonable installation of controls and 

obviate the need for an engineering review. 

 Regardless of which system of controls or control strategy is identified as meeting 

the objectives of the BART program, states are required to consider (1) the cost of 

compliance, (2) any energy or non-air quality impacts of compliance, (3) any existing 

pollution control technology in use at the source, (4) the remaining useful life of the 

source, and (5) the degree of visibility improvement that may reasonably be anticipated 

from the use of BART. Given that EPA has established a presumptive level of SO2

control for previously uncontrolled EGUs greater than 750 MW that is consistent with the 

MANE-VU recommendation for all EGUs, if a state feels that the MANE-VU 

 

4

 Note that Vermont has no known BART-Eligible sources. 
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presumptive levels of control are appropriate at an individual EGU facility, states will not 

necessarily have to justify the imposition of SO2 controls, but may have to justify why 

NOX and PM controls are reasonable at the levels specified through a statutory factor 

analysis as described in EPA guidance. If, after review of the statutory factors, a state 

still believes that controls on the BART-eligible facilities are reasonable, then a full 

engineering review should be conducted in order to establish the most stringent 

technologically feasible system of controls that is appropriate for that facility. Resources 

to assist in this process are discussed in the following section. 

3.1.3. Engineering reviews 

 The engineering reviews should consider control technologies that have been 

discussed in the MANE-VU document: Assessment of Control Technology Options for 

BART-Eligible Sources (Appendix C1). Chapter 2 of that document provides a detailed 

listing of pre-combustion, combustion and post-combustion options for a variety of EGU 

types that are prevalent in the MANE-VU region. Information regarding the typical 

installation costs for these facilities has also been included. States, however, are 

responsible for reviewing these data to ensure they represent facility-specific installation 

costs. Other sources of control technology information can be found in US EPA 

guidance documents (especially its RACT/BACT/LAER clearinghouse). In addition, 

other RPOs have developed information beyond what is included in the MANE-VU 

Assessment. Finally, STAPPA/ALAPCO has also developed a control technology 

assessment for particulate matter that reviews EGUs and many other categories of point, 

area, and mobile source emissions (see Chapter 5 for additional resources). 

3.1.4. MANE-VU staff BART recommendations 

 MANE-VU staff developed preliminary BART control recommendations, where 

possible, based upon review of facility data, including their emission characteristics and 

controls already in place. Complete data for many facilities are still not available and 

thus MANE-VU staff was limited in its ability to develop recommendations for many 

facilities in some states. For each state, a separate spreadsheet has been created with all 

of the relevant information compiled along with technology or program recommendations 

for states to consider as a starting point. These are based on consideration of control 

technologies in place and the presumptive levels established by the MANE-VU BART 

workgroup. These spreadsheets are available to the state agencies and are not public at 

this time. These data will continue to evolve as states and MANE-VU staff continues the 

process of conducting BART determinations over the next several months. 

 

3.2. Other Industrial Sources 

 In addition to EGUs, there are 25 BART-eligible categories including cement 

plants, paper and pulp facilities, and industrial boilers. These three categories are 

prevalent in the MANE-VU region and represent the greatest emission reduction 
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3-4 

possibilities for the BART program outside the EGU sector. Because the CAIR rule is 

limited to EGUs, there are no special considerations with respect to CAIR that must be 

considered when conducting BART determinations. There are, however, other programs 

with may interact with BART and these are discussed below. 

3.2.1. RACT 

 The MANE-VU member states are also members of the Ozone Transport 

Commission. At present time, the Ozone Transport Commission is coordinating the 

development of an integrated set of control strategies that will meet state needs for 

emission reductions under 8-hour ozone and fine particulate national ambient air quality 

standards (NAAQS) as well as regional haze regulations. Among the strategies being 

discussed is the application of Reasonably Achievable Control Technologies (RACT) at 

industrial, commercial, and institutional (ICI) boilers, refineries, and cement plants. In 

instances where a BART-eligible boiler or other facility is being considered for RACT, it 

is anticipated that RACT controls will already be in place by 2009, and that no additional 

control will be needed under BART for the pollutants covered by the RACT analysis. 

Thus for those sources brought into an OTC RACT program, the BART determination 

would consist of documenting the controls that will be installed and then justifying that 

no further controls for the relevant pollutants are reasonable in light of the statutory 

factors. 

3.2.2. Permit limitations 

 Many BART-eligible facilities in the MANE-VU region are relatively small 

emission sources with potential emissions that exceed the statutory threshold of 250 tons 

per year or more, but with actual emissions below 250 tons in any year. These facilities 

may wish to accept a permit limitation that restricts their emissions by law to less than 

250 tons per year. The MANE-VU BART workgroup has recommended that if a facility 

accepts such a permit limitation prior to December 16, 2006, that facility will no longer 

be BART-eligible and may be eliminated from the BART list for that state. The 2006 

date was selected in order to give state agencies one full year to submit their regulatory 

package to a full public hearing and adoption process prior to submitting their SIP to the 

US EPA. 

3.2.3. Statutory factors 

 In the event that a non-EGU source is not brought into an OTC control program 

being contemplated for 8-hour ozone or fine particulate NAAQS compliance, and is not

able to accept a permit limitation rendering a facility ineligible for BART, then full 

BART determinations must be conducted. A starting point would be to consider any 

controls in place and the degree of visibility impairment that could be achieved by the 

installation of controls, followed by engineering reviews to identify the most stringent 

technologically feasible system of controls to satisfy BART. 
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 This process is very similar to that described above for EGUs, but many of the 

technology options and resources identified for EGUS may not be applicable for several 

of the specific source categories within the MANE-VU states (e.g., FGD/scrubbers may 

be appropriate for EGU or large ICI boilers, but may not be appropriate for a chemical 

plant with many small emission units). MANE-VU has explored technology options for 

EGUs, ICI boilers, paper and pulp facilities, and cement plants in the 2005 technology 

assessment (Appendix C1). Beyond that assessment, the American Forest & Paper 

Association (AFPA) and the Council of Industrial Boiler Owners (CIBO) have submitted 

their own documentation for technology options and other considerations to take into 

account when conducting BART determinations. MANE-VU has provided this 

information as submitted for the states’ consideration in Appendix F. 

 As with EGUs, other sources of control technology information are available as 

listed in the US EPA guidance document (note especially its RACT/BACT/LAER 

clearinghouse) and other RPOs may have additional information beyond what is included 

in the MANE-VU Assessment. STAPPA/ALAPCO has also undertaken a control 

technology assessment for particulate matter and a draft report is now available. This 

report reviews EGUs and many other categories of point, area and mobile source 

emissions (See Chapter 5 for additional resources). 

 For many facilities that are not within the EGU, industrial boiler, cement, or paper 

industrial sectors, states will need to develop facility-specific technology assessments of 

which controls are feasible and cost estimates for such controls. EPA guidance suggests 

methods for determining which control option (among several possibilities) will serve as 

BART for a given source. 

 

3.2.4. MANE-VU staff BART recommendations 

 As in the case of EGUs, MANE-VU has developed preliminary BART 

recommendations based on a review of actual facility characteristics, emission 

characteristics, and controls already in place. Complete data for many facilities – 

particularly in the non-EGU source categories – are still not available at this time and 

thus MANE-VU staff was limited in its ability to develop recommendations for many 

facilities in some states. Detailed spreadsheets for each state have been developed and 

are available to the state agencies (they are not public at this time) and will continue to 

evolve as MANE-VU states and staff continue the process of conducting BART 

determinations over the next several months. 
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4. MODELING 

 US EPA guidance suggests several detailed modeling approaches for exemption 

modeling. Given that MANE-VU states have opted to consider all BART-eligible 

sources as subject to BART, no exemption modeling needs to be conducted for MANEVU BART-eligible sources. The US EPA is less specific about modeling methods that 

must be employed in order to determine the degree of visibility improvement that will 

result from installation of controls or how to consider that improvement, but they do 

discuss modeling approaches for performing this “visibility improvement determination” 

and it is worth repeating the following excerpt from the US EPA’s guidance here: 

“When making this determination, we believe you have flexibility in setting 

absolute thresholds, target levels of improvement, or de minimis levels since the 

deciview improvement must be weighed among the five factors, and you are free 

to determine the weight and significance to be assigned to each factor.”

While the US EPA goes on to describe a basic visibility improvement determination 

modeling approach involving the same basic CALPUFF platform described for 

exemption modeling, it is less specific about how the results are used in concert with 

other factors to determine what level of control should be considered BART.5

 

 Given this flexibility, MANE-VU feels comfortable in its approach of developing 

multiple modeling and data analysis platforms for the analysis of single source impacts 

and providing these (along with a protocol explaining the development of each platform 

and results) to each state for their own consideration of how to weight the results relative 

to the other factors that must be considered in making BART determinations. 

4.1. Modeling Methods 

 A separate requirement of the Regional Haze Regulation requires the 

development of a contribution assessment, or a pollution apportionment for visibility 

impairment. As a part of the technical effort supporting the development of the MANEVU contribution assessment, several modeling platforms and data analysis methods were 

developed that are capable of distinguishing single source impacts and are now available 

to support BART modeling in the context of the visibility improvement determination. In 

addition, a number of additional modeling and data analysis platforms have been 

developed that are appropriate only for more aggregated (generally state-by-state) 

contributions and thus are not included here. All methods and how they are used to 

develop a weight-of-evidence approach to geographic and regional contribution 

 

5

 US EPA suggests a default approach of relying on the CALPUFF modeling platform with parameter 

settings taken from the Interagency Workgroup on Air Quality Modeling (IWAQM) Phase II 

recommendations (US EPA, 1998). Any deviations or departures from these recommendations should be 

identified and explained in the modeling protocol. 
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determinations are described in the MANE-VU contribution assessment.6

 Each of the 

methods for single source contribution assessment is described briefly below and 

references are provided to more detailed descriptions of each platform. This is followed 

by discussion of the results from this set of modeling exercises. 

4.1.1. REMSAD: SO2 tagging 

 A principal method for assessing the contributions of individual sources to 

observed sulfate at Federal Class I areas is based on the REMSAD model. REMSAD is a 

computationally efficient grid model that has simplified photochemistry (this represents a 

limitation for calculating ozone concentrations with accuracy) but has good performance 

for many components of PM2.5, including sulfate. Newer versions of REMSAD 

incorporate an emission tagging feature that allows for the apportionment of simulated 

sulfate, nitrate, or mercury among different tagged emission components. MANE-VU 

has used this platform to tag SO2 emissions from each state in the eastern U.S. as part of 

the pollution apportionment. This tagging feature can also be used to assess the 

contribution of individual BART-eligible facilities to the measured sulfate at Class I sites 

before and after controls for a visibility improvement determination. Full details on the 

REMSAD platform, including emissions inventory development and processing, 

meteorological data, meteorological model performance, and overall model performance 

are included in the MANE-VU contribution assessment (Appendix C in footnote 6) and 

are not repeated here. 

 Given the time required to process emissions for an annual run and the time 

required for an annual REMSAD simulation itself, we do not anticipate running each and 

every BART-eligible source as an independent tag through REMSAD, but will work with 

the BART workgroup to identify the priority sources and attempt to model as many of 

these sources as possible. 

4.1.2. CALPUFF approaches: NWS observation-based and MM5-based 

meteorology 

 In addition to the REMSAD modeling platform, MANE-VU has also developed 

two different CALPUFF modeling systems. The Vermont Department of Environmental 

Conservation and the Maryland Department of the Environment (through their contractor 

ERM) have jointly developed a set of emissions input files for CALPUFF based on the 

MANE-VU emission inventory version 2 (MARAMA, 2006), and supplemented these 

data with Continuous Emission Monitoring System (CEMS) data for 869 large power 

plants that reported SO2 emissions to that system for the full year in 2002. 

 

6

 NESCAUM, Contributions to Regional Haze in the Northeast and Mid-Atlantic United 

States: the Mid-Atlantic/Northeast Visibility Union (MANE-VU) Contribution 

Assessment, ,August, 2006. 
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 The primary difference between the two CALPUFF platforms involves different 

meteorological datasets developed by each team. ERM developed CALMET-processed 

meteorology on a large domain (extending from Oklahoma City, OK up to Prince Edward 

Island, Canada). The CALMET meteorology was processed directly from the MM5 

model output developed on a 12-km horizontal grid by the University of Maryland for the 

OTC modeling committee and MANE-VU. The Vermont team developed CALMET 

meteorology (for the identical domain) driven by the National Weather Service’s surface 

observation network, rawinsonde network, and supplemented by the Airport Surface 

Observation System (ASOS) network. This observation-based dataset provides an 

alternative to the gridded wind fields generated by the diagnostic model MM5. 

 Both data sets have been used to estimate contributions of individual states and 

large facilities within states to the sulfate burden observed at MANE-VU Class I areas for 

the purposes of the MANE-VU pollution apportionment.

7

 The platforms are now ready 

to be used for estimating source contributions of individual BART-eligible facilities as 

states provide modeling parameters for those facilities. Details on the platform are 

available in the MANE-VU contribution assessment (Appendix D in footnote 6). 

4.1.3. Empirical approaches: emissions divided by distance or Q/d 

 As one of the screening approaches suggested by the US EPA in its guidance for 

exemption modeling, it describes a very simple approach involving a review of the ratio 

of a source’s emissions divided by the distance to a receptor of interest. Based on a 

review of a memorandum from the North Carolina Department of Natural Resources, the 

US EPA suggests that a ratio of 20 may be an appropriate level of significance to use as a 

threshold level of impact (when emissions are expressed in tons per year of the sum of 

NOX and SOX and distance is expressed in kilometers). 

 MANE-VU has modified and included this basic approach as one method for 

inclusion in visibility improvement determinations. The basic approach is extremely 

simplistic, ignoring meteorological and chemical dynamics of the real atmosphere. 

Nonetheless, it can be a fairly reliable predictor of relative impact. By comparing the 

emissions divided by distance, or Q/d, ratio to CALPUFF-calculated source impacts, a 

strong linear relationship can be established for a given wind sector. Thus by scaling our 

Q/d results within a given wind sector to CALPUFF-modeled impacts for sources within 

that wind sector, we develop a metric that represents the functional empirical approach of 

the emissions divided by distance method, but takes into account the relative importance 

of some sources given prevailing winds. The metric is also scaled according to 

CALPUFF calculated chemical loss rates (see footnote 6 for details). While this method 

is dependent on the CALPUFF platform for establishing the absolute magnitude of 

estimated impacts, it is a completely independent empirical method for establishing the 

relative importance of individual sources within a given wind-sector. As such, it can 

provide evidence of relative improvement with respect to visibility in Class I sites. 

 

7

 A pollution apportionment is a required element of the long term emissions management strategy required 

by EPA for compliance with the Regional Haze Rule. 
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4.1.4. Data analysis approach: percent time upwind 

 MANE-VU has developed one additional data analysis approach that can also be 

used in a relative sense (i.e., to identify potential improvement relative to current impacts 

on Class I areas) on an individual facility basis. By using back trajectories to identify the 

“upwind residence time” or the fraction of time that a selected location spent upwind of a 

Class I area, and multiplying that time by the total emissions from a facility at that 

location, we can develop a crude metric for relative source impact. Again, by comparing 

this measure of impact before and after an emissions reduction, we can estimate the 

degree of visibility improvement. 

4.2. Anticipated Visibility Improvement as a Result of BART 

 The preceding section lays out several potential modeling and data analysis 

approaches for assessing the degree of visibility improvement anticipated to result from 

installation of BART controls. MANE-VU will apply these techniques to an individual 

state’s BART-eligible sources and provide results in the spreadsheets that have been 

developed for state reference as the states conduct their final BART determinations. 

While these analyses are being provided to states as a resource, they are not necessarily 

the final word on modeling or data analysis for BART determinations. Rather, these 

methods are provided as a regionally consistent foundation for assessing the degree of 

visibility improvement that could result from installation of controls at each BART 

source. Each state will then have the opportunity to supplement these data with its own 

modeling or require individual sources within a state to conduct modeling of their own, 

thus enabling each state to tailor its BART determination process to individual state 

needs. 
BART Resource Guide Page 5-1

5. BART RESOURCES 

 This resource book provides links and references to materials useful to states as 

they conduct BART determinations, in addition to clarifying the requirements for BART 

determinations, identifying what progress toward BART determinations has been 

accomplished by MANE-VU to date, and providing an outline for next steps in the 

BART determination process. A wide-variety of resources have been collected, 

including relevant regulations, technical memos and reports identifying potentially 

BART-eligible sources, information on and assessments of potential control 

technologies, modeling and data analysis protocols, the US EPA and industry provided 

guidance for states’ consideration, as well as state workgroup recommendations 

representing regional consensus on specific issues. A brief description of the documents 

that are cited and their relevance is included here. 

5.1. Regulations 

 The US EPA issued the Regional Haze Rule, which included BART provisions, in 

1999. This regulation was subsequently litigated and the BART provisions of the rule 

were remanded to EPA. A revised “BART Rule” was proposed and finalized in April 

2005. Both the initial Regional Haze Rule and the final BART Rule are attached here as 

Appendices A1 and A2. Appendix A3 includes a subsequent regulation that addresses 

how states can implement a trading program in lieu of BART. This is termed the “BART 

Trading Rule.” 

5.2. BART Eligibility Resources 

 In 2001, NESCAUM produced a report that contained a preliminary list of 

BART-eligible EGUs in the MANE-VU region. This was followed in 2003 with a 

preliminary list of BART-eligible sources from the other 25 categories of stationary 

sources. Both of these documents provided lists that included potential BART-eligible 

sources. State have subsequently reviewed the NESCAUM lists and further developed 

them. This has been provided to MANE-VU staff and serves as the basis for the current 

list of BART-eligible sources. The NESCAUM documents, which describe the 

methodology for developing the preliminary lists for both EGUs and non-EGUs, are 

attached as Appendices B1 and B2. 

5.3. Control Technology Information 

 In 2005, NESCAUM published a report entitled Assessment of Control 

Technology Options for BART-Eligible Sources that reviews potential technology choices 

for EGUs, industrial boilers, cement kilns, and paper and pulp facilities. While there are 

clearly other types of BART-eligible sources in the region that may need controls under 

the BART program, the majority of potential emissions that might be reduced under 

BART come from these four categories. These categories also share the characteristic of 
BART Resource Guide Page 5-2

having fairly generic control options. It is likely that other facilities, like petroleum 

refineries or chemical plants, will require very unique control combinations given the 

diversity of equipment and usage at each facility. While paper and pulp facilities and 

industrial boilers don’t necessarily have a “one-size-fits-all” control method, they do tend 

to have some more common control approaches that have been utilized previously, and in 

sufficient numbers to allow the development of a report with cost estimates for typical 

installations. This report has been attached as Appendix C1. 

 Additional control technology assessments have been developed or are under 

development by other groups and RPOs and are provided here for state consideration. 

The US EPA maintains a RACT/BACT/LAER clearinghouse with control technology 

options by source category available at: http://cfpub.epa.gov/rblc/htm/bl02.cfm. 

STAPPA/ALAPCO has a contract with M.J. Bradley and Associates to identify potential 

controls for a wide-variety of source categories, including many of the BART categories.8 

This work should be completed in the very near future, which the states may want to 

consider. The Midwest RPO hired MACTEC Engineering and Consulting, Inc. to 

conduct a survey of control technology options for BART and its final report is available 

at: 

http://www.ladco.org/reports/rpo/MWRPOprojects/Strategies/Final%20Control%20Meas

ures.pdf. The VISTAS RPO has developed an Excel spreadsheet with control 

technology information that may serve as a useful reference. These links and resources 

are attached as Appendices C2, C3 and C4, respectively. 

5.4. Program Implementation Resources 

 MANE-VU has formed a state working group to formulate regional positions on 

BART program implementation to the extent that consensus exists. This workgroup has 

developed a list of recommendations for the air directors’ consideration as BART 

determinations are made. These recommendations cover several aspects of program 

implementation and include presumptive levels of controls for some source categories. 

They are contained in Appendix D. 

5.5. Modeling Resources 

 In 2005, NESCAUM published an interim contribution assessment report that 

contains detailed results from seven different modeling platforms or data analysis 

methods used to attribute sulfate pollution in MANE-VU Class I areas. The modeling 

platforms and analysis techniques are described in great detail in the technical appendices 

of that document. Each of these analysis platforms has been refined and updated with 

new results based on current meteorological and emission inventory inputs. A final 

contribution assessment is being published concurrently with this BART resource book 

that contains the results of that refined analysis.6

 Insofar as four of the seven methods 

have been discussed here (see Chapter 4) as potential methods for visibility improvement 

 

8

 STAPPA/ALAPCO, Controlling Fine Particulate Matter Under the Clean Air Act: A Menu of Options, 

draft, March, 2006. 
BART Resource Guide Page 5-3

determinations for BART, the full technical descriptions of these analysis platforms are 

resources to be provided for state consideration. The final MANE-VU contribution 

assessment is attached as Appendix E. 

5.6. Stakeholder Submitted Information 

 In addition to technical information generated by MANE-VU, the US EPA, other 

RPOs, and a number of interested stakeholders have provided MANE-VU with their own 

assessments of control technology and program implementation options. These materials 

are presented here as submitted by the various groups so that states can take this 

information into consideration when conducting their BART determinations. MANE-VU, 

however, provides no guarantees as to their accuracy. It has not developed these 

materials nor been involved with their development. MANE-VU does feel it is important 

for states to be aware of the perspectives of the industry associations that they are 

regulating. 

 First, a white paper from the Council of Industrial Boiler Owners (CIBO) 

(Appendix F1) reconciles the differences between cost estimates for control programs 

when developed by different groups as opposed to the regulated industry itself. The 

white paper is supported by a presentation from Black and Veatch that reviews cost 

differences between the US EPA and industry cost estimates for NOX and SO2 controls. 

 From the American Forest and Paper Association (AF&PA), MANE-VU received 

a number of control cost estimates, reports and statistics. The National Council for Air 

and Stream Improvement (NCASI) has published a paper – provided in Appendix F2 – 

that reviews currently available control technologies for NOX, SO2, and PM for the major 

emission sources at paper and pulp mills. 

 AF&PA also provided Appendices F3, F4, F5, and F6 that contain a summary of 

points to consider when retrofitting boilers at paper and pulp facilities, AF&PA’s own 

analysis of control costs for paper and pulp boilers relative to EPA’s assessments, and 

two reports developed by consulting firms for the industry to support its cost information. 

 AF&PA has also submitted a discussion of emissions trading programs and what 

might be accomplished through the application of such a program – as opposed to a 

source-by-source application of BART—in the CENRAP states. The discussion and the 

CENRAP white paper are presented as Appendices F7 and F8. 

 Finally, AF&PA provided an Excel file showing the diversity of emission rates 

from various boilers. These data are intended to demonstrate that fixed percentage 

reduction targets may be difficult to achieve in many cases given the starting baselines, 

controls, fuels, etc. This spreadsheet is contained in Appendix F9. 
BART Resource Guide Page 6-1

6. CONCLUSION 

 The BART program represents a significant emission reduction opportunity for 

the Northeast and Mid-Atlantic States as they seek to attain 8-hour ozone and PM2.5

standards and demonstrate reasonable progress toward national visibility goals under the 

Regional Haze Rule. While the BART program is described clearly in guidance 

documents and regulations, there are a number of provisions that require significant 

analytical effort. This document is intended to assist states in navigating the 

requirements and completing BART determinations for each BART-eligible source in the 

region. 

 Many of the BART-eligible emissions reductions are necessarily included in the 

CAIR caps within states that participate in either the seasonal or annual CAIR program 

and the US EPA has been fairly prescriptive in how emissions reductions will be 

achieved from these sources. States may have flexibility with respect to how they choose 

to “harvest” the emissions reductions from several other source sectors. This may allow 

states to require controls under either the BART program or under RACT programs with 

fewer regulatory “hoops.” Finally, many small facilities that emit less than 250 tons per 

year of any visibility impairing pollutant may be capped out of the BART program if 

permit changes occur prior to the end of 2006. 

 MANE-VU has provided program recommendations, modeling resources, and 

preliminary control recommendations for those sources that could be, after consideration 

of the many interactions between BART and other regulatory programs, controlled under 

the BART program. This information is provided for the states’ consideration. MANEVU is now prepared to work with individual states to provide further state-by-state 

assistance as they conduct detailed engineering reviews and prepare BART SIP 

submissions. 
BART Resource Guide Page A-1

Appendix A: Regulations 

Appendix A: Regulations 

A.1. 1999 Regional Haze Rule & Preamble 

A.2. 2005 Regional Haze Rule (Final BART Provisions) 

A.3. 2005 Regional Haze Rule Preamble (Final BART Provisions) 

A.4. 2005 Proposed BART Trading Rule 

A.5. 2005 BART Trading Rule Preamble
BART Resource Guide Page B-1

Appendix B: BART-Eligibility Resources 

Appendix B: BART-Eligibility Resources 

B.1. A Basis for Control of BART-Eligible Sources, 2001 (EGUs Only) 

B.2. Technical Memorandum #6 – Development of a List of BARTEligible Sources in the MANE-VU Region: Interim Report, 2003 (nonEGUs) 
BART Resource Guide Page C-1

Appendix C: Control Technology Options 

Appendix C: Control Technology Options 

C.1. Assessment of Control Technology Options for BART-Eligible 

Sources, 2005 (EGUs, Industrial Boilers, Cement Plants, and Paper and 

Pulp) 

C.2. US EPA RACT/BACT/LAER Clearinghouse (web link) (L01: 

http://cfpub.epa.gov/rblc/htm/bl02.cfm) 

C.3. Midwest RPO Control Technology Assessment (web link) (L02: 

http://www.ladco.org/reports/rpo/MWRPOprojects/Strategies/Fin

al%20Control%20Measures.pdf) 

C.4. VISTAS BART Control Spreadsheet 
BART Resource Guide Page D-1

Appendix D: Program Implementation Resources 

Appendix D: Program Implementation Resources 

D.1. MANE-VU BART Workgroup – Program Recommendations 
BART Resource Guide Page E-1

Appendix E: Modeling Resources 

Appendix E: MANE-VU Final Contribution Assessment 
BART Resource Guide Page F-1

Appendix F: Stakeholder Provided Resources 

 

Appendix F: Stakeholder Provided Resources 

F.1. CIBO: Industrial Air Pollution Control Project Costs with Control 

Equipment Cost Representations. 

F.2. National Council on Air and Stream Improvement (NCASI): 

Retrofit Control Technology Assessment for NOX, SO2, and PM 

Emissions from Kraft Pulp and Paper Mill Unit Operations, by Arun V. 

Someshwar. 

F.3. American Forest & Paper Association (AF&PA): Special 

Considerations for Boiler Controls at Paper and Pulp Mills. 

F.4. American Forest & Paper Association (AF&PA): EPA Cost 

Estimates for NOX Controls on Pulp and Paper Boilers are too Low by 

100->300%. 

F.5. - American Forest & Paper Association (AF&PA): Stone & 

Webster report on Control Technology Costs for Paper and Pulp 

Industry. 

F.6. American Forest & Paper Association (AF&PA): BE & K report 

on Control Technology Costs for Paper and Pulp Industry. 

F.7. American Forest & Paper Association (AF&PA): Why Emissions 

Trading is Important. 

F.8. American Forest & Paper Association (AF&PA): CENRAP 

Regional Haze Emissions Trading Straw Proposal. 

F.9. American Forest & Paper Association (AF&PA): Boiler 

Emissions - Control Distribution Figures. 

 
BART Resource Guide Page G-1

Appendix G: BART-Eligible Source Information 

by State 

Appendix G: BART-Eligible Source Information by State 

(including: Facility IDs, controls already in place, current 

emissions, recommended BART, estimated post-BART 

emissions, and modeling parameters) 

G.1. Connecticut 

G.2. Delaware 

G.3. District of Columbia 

G.4. Maine 

G.5. Maryland 

G.6. Massachusetts 

G.7. New Hampshire 

G.8. New Jersey 

G.9. New York 

G.10. Pennsylvania 

G.11. Rhode Island