# ~**~NHoEs** The State of New Hampshire 

### DEPARTMENT OF ENVIRONMENTAL SERVICES Thomas S. Burack, Commi ss io ner

David Co nroy , C hi ef , Air Programs Branch U.S . Env ironm enta l Protection Agency, Region I 5 Post Office Square, Suite 100 Boston , MA 02109-3912 December 29 , 2015

Re: Revision to New Hampshire Sta te Implementation Plan to Meet the Requirements of the C le an Air Act, Section 110(a )(2) for the 2008 Ozone, 2010 N itrogen Dio xi de , and 2010 S ulfur Dioxide NAAQS Dear Mr. Conroy: In acknowledgement of the fact that E PA ' s September 13 , 2013 1 guidance to states regarding i-SIP s does not require states to make SIP s ubmitta l s to address th e vis ibility pro v i s ions fo und at sectio n 11 O(a)(2)(J) of the C lea n Air Act, New Hamp s hire Department of E nv ironmental Services (NHDES) requests w ithdrawa l of the s ubmitta l s mad e to address thi s aspect of 11 O(a)(2)(J) w ithin the following infrastruct ure SIP s ubmitta l s : I. 2 008 ozo ne NAAQS s ubmitta l dated 12/3 1 / 20 12 , w herein on page 11 of13 refere nce is made regarding v is ibility pro tection in severa l ar eas under the head in g , " Subparagraph 11 O(a)( 2 )(J): PSD and Visibility Protection " ; 2 . 2010 N02 NAAQS s ubmittal dated 1 /2 8/2013 , wherein on page 10of1 2 reference is made regarding vi s ibility protection in several area s under the heading , " Subparagraph 11 O(a)(2)(J): PSD and Vi s ibility Protection" ; and , 3. 20 10 S02 NAAQS submittal dated 9/13 /2013 , wherein o n page 13of45 refere nce is made regarding v isibi li ty protection in severa l area s under the heading, " Subparagraph 11 O(a)(2)(J): PSD and Visibility Protection " . Attac hed are rep lacement page s for the above referenced s ubmittals that have the reference to vis ibili ty provisions removed. Ifyou have any q ues tions r egarding thi s s ubmittal , pleas e contact Fe li ce Jane ll e at (603) 27 1-4848 .

Enc losures S in cere l y ,

# ~djAl- Craig Wright Director Air Re s ourc es Division

cc: Ann e A rn o ld , USE PA, Reg io n I

1 EPA Memoran dum , S te p hen D. P age to R eg ion a l A ir Di vi s io n Dir ecto rs, "G uidan ce on Infras tru cture S ta t e Impl e me nta ti on Pl an (S IP) E le me nts Re quired Und e r C le an Air A c t Secti o ns l l O (a) ( I ) and I l O (a)(2) ", S epte mb er 13 , 20 l 3. D ES Web S ite: www . des .nh. gov P . O . Box 95 , 29 Ha ze n Driv e, C o nco r d, ew Ha mp s hire 0 33 0 2

- 0095 Te l ep hone : (603 ) 27 1 -35 03 Fax : (603) 27 1

-28 67 TDD Ac cess : Re lay NH 1

- 800- 7 35-29 64Page 11of1 3

..,. Subparagraph 110(a)(2)(J): PSD CAA Citation:

' 'Each such plan shall ... meet the applicable requirements of...part C (relating to prevention of significant deterioration of air quality and visibility protection); ... " Applicable NH Laws and Regulations: • RSA 125:81 , XIV (recodified as RSA 125-C:6 , XIV) authorizes the agency to establish and operate a statewide system under which permits shall be required for the construction and operation of new and modified stationary sources. • Env-A 6 1 9: Prevention of Significant Deterioratio n addresses PSD and visibility protection and i s essential to meeting the requirements of 40 CFR 5 1 . 1 66 and 40 CFR 52.2 1 . 

# I Additional Information: Revisions to Env-A 619 (and Env-A 100 : Organi zati on al Rul es ) pertaining to the regulation of greenhouse gases were approved by EPA in a final rule published on February 6, 2012. (See 77 FR 5700 .) Subsequent revisions to Env-A 619 were submitted as a SIP revision for EPA's approval on November 15 , 2012 .

..,. Subparagraph 110(a)(2)(K): Air Quality Modeling/Data CAA Citation:

" Each such plan shall. . . " prov ide for

- (i) the performance of such air quality modeling as the Administrator may prescribe for the purpose of predicting the effect on ambient air quality of any emissions of any air 1 pollutant for which the Administrator has established a national ambient air quality standard, and (ii) the

submission, upon request , of data related to such a ir quality modeling to the Administrator. " Applicable NH Laws and Regulations: • RSA 125:81 (recodified as RSA 1 25-C : 6 ) authorizes the department to exercise general sup erv ision of the administration and enforcement of the statute and all rule s adopted and orders promulgated under it ; to de ve lop a comprehensive program and provide services for the study, prevention , and abatement of air pollution ; to conduct and encourage studies relating to air quality ; to collect and dis seminate the results of studies relating to air quality; to advise, consult, and cooperate with the cities and towns and other agencie s of the state, federal government , interstate agencies , and other affected agencies or groups in matters relating to air quality ; and, among other authorities , to exercise all incidental powers nece ssary to carry out the purposes of the sta tute . • Env-A 6 1 3.02: Denial of Permit Issuance authorizes NHDES to deny the i ssuance of a construction permit if modeling shows that a major source propo sing to construct or make modifications in a nonattainment area will cause or contribute to a v iolation of the NAAQS for a pollutant for which that area i s in attainment. • Env-A 619 . 03: PSD Progr am Require me nts incorporates by reference numerous paragraphs of 40 CFR 52.21 , including (k)(l) , (1) , and (m) , which require modeling by major sources prior to construction or major modifications. :...,.Subsection 110(a)(2)(J): Public Notification CAA Citation: "Each such plan shall ... meet the applicable requirements of ... section 127 (relating to public notification), . . . " Applicable NH Laws and Regulations: Page 10of12

• RSA 125:81 (recodified as RSA 125-C:6) provides as follows: " In addition to the other powers and duties granted herein , the agency shall have and may exercise the following power s and duties: ... IV. To collect and disseminate the results of studies relating to air pollution ; V. To advise , consult , and cooperate with the cities and towns and other agencies of the state, federal government , interstate agencies , and other affected agencies or groups in matters relating to air pollution ; VI. To encourage local units to promote cooperation by the people , political subdivisions, industries, and others in preventing and controlling air pollution in the state; ..." Additional Information: N02 and other oxides of nitrogen (NOx) are chemical precursors to ground-level ozone and presumed precursors to fine particle formation. On days when ambient o z one or PM2 . 5 concentrations are predicted to be high, NHDES exercises the authority granted under RSA 125:81 (recodified as RSA 125-C:6) to issue public alerts. NHDES makes pres s releases and posts website notices advising people on how to help prevent air pollution and minimize the worst health effects of poor air quality . NHDES i s one of the state partners in EPA's AIRNOW and Enviroflash Air Quality Alert programs. (See www.aimow.gov .) 

# I.... subsection 110(a)(2)(J): PSD 

# ICAA Citation:

"Each such plan shall ... meet the app licable requirements of. .. part C (relating to prevention of significant deterioration of air quality and v isibility protection); .. . " Applicable NH Laws and Regulations: • RSA 125:81 , XIV (recodified as RSA 125-C:6 , XIV) authori z es the agenc y to establish and operate a statewide system under which permits shall be required for the construction and operation of new and modified s tationary sources. • Env-A 619: Prevention of Significant Deterioration addresses PSD and visibility protection and is essential to meeting the requirements of 40 CFR 51.166 , 40 CFR 52 . 21 and RSA 125-C . 1**~~ ~~~~~~~**  . .**~~~ ~~~~** **'· ~~** **~~~~~~~~~~~~~~~ ~**  

# I ...,.subsection 110 (a)(2)(K) : ' Air Quality M odeling/Data 

# ICAA Citation:

" Eac h such plan sh all . .. " provide for

- (i) the p erform ance of such air qu ali ty mod e ling as th ePage 13 of45 people , political subdivisions, industries , and others in preventing and controlling air pollution in the state ; ..." Additional Information: S0 2 is a chemical precursor, and one of many known contributors, to fine particle (PM2 . 5) pollution . On days when ambient PM 2 . 5 (or ozone) concentrations are predicted to be high , NHDES exercises the authority granted under RSA 125:81 (recodified as .RSA 1 25-C:6 .) to issue public alerts. NHDES makes press releases and posts website notices advis ing people on how to help prevent air po llution and minimize the worst health effects of poor air quali ty. NHDES is one of the state partners in EPA's AIRNOW and Enviro:flash Air Quality Alert programs. (See .www.airnow.gov .. ) 

# I .,.. Subsection 110(a)(2)(J): PSD 

# I CAA Citation: "Each such plan shall. ..meet the applicable requirements of ...part C (relating to prevention of significant deterioration of air quality and visibility protection); ... " Applicable NH Laws and Regulations: • RSA 125:8 1 , XIV (recodified as RSA 125-C:6 ., XIV) auth orizes the agency to establish and operate a statewide system under which permits shall be required for the construction and operation of new and modified stationary sources. 

# I • . Env-A 619: Prevention of S i gnificant Deterioration. addresses PSD and visibility protection and is essential to meeting the requirements of .40 CFR 51.166., .40 CFR 52.21. and . RSA 125- C..



# I .,.. Subsection 110(a)(2)(K): Air Quality Modeling/Data

CAA Citation: "Each such plan shall. .. "provide for

- (i) the performance of such air quality modeling as the Administrator may prescribe for the purpose of predicting the effect on ambient air quality of any emissions of any air pollutant for which the Administrator has established a national ambient air quality standard , and (ii) the submission , upon request , of data relate d to such air quality modeling to the Administrator. " Applicable NH Laws and Regulations: 

# I . RSA 125:81 (recodified as RSA 1 25-C:6 . ) authori zes the department to exercise general supervision of the administration and enforcement of the statute and all rules adopted and orders promulgated under it ; to develop a comprehensive program and provide services for the