### W ASHINGTON 

### DC R EGIONAL 

### H AZE 

### SIP
DDOE Response to FLM Comments

US Department of Interior, National Park Service & Fish and Wildlife Service Comments (March 18, 2010)

Figure 1.1. Include Class I areas in NH, VT and ME on the map as impacts at these Class I areas are discussed in subsequent sections.

DDOE RESPONSE: DDOE has added a new ma p of all Class I areas in MANE-VU and VISTAS to Chapter 1 (see Figure 1.2). To more directly demonstrate Class I areas located near the District, th e previous Figure 1.1 was replaced with a map that was initially in Chapter 9.

Section 3.3.1, States Notifying the District of Cont ribution to Haze. The final paragraph of this

section states that District’s contributions to MANE-VU and VISTAS Class I areas would be “...summarized below.” However, there is no contribution summary in Chapter 3. Please include in this section or highlight which chapter such a summary is available. DDOE RESPONSE: The contribution summary is located in Chapter 7. The document now refers to Chapter 7 instead of “below”.

Section 4, Emissions Inventory. This secti on describes 2002 base year emissions and 2018 future year emissions projects fo r the District and for MANE-VU states. These emissions data are used in MANE-VU air quality modeling (described in Section 6) to evaluate the District’s contribution to visibility impairment in nearby Cla ss I areas. It is importa nt that the assumptions

used in these inventor ies are clearly defined DDOE RESPONSE: A paragraph was added to 4.1.1 to describe District-specific data sources used to develop MANE-VU’s 2002 ba se year inventory. Although control assumptions incorporated into the future year inventory scenarios are listed in Chapter 10, they were added to 4.1.2. First, assumptions for the region are listed. Then, control factors that were applied for the Di strict specifically are discussed.

Section 4.1.2 defines the MANE-VU “best and fi nal” 2018 inventory as “developed to account for additional control measures considered as part of the development of the MANE-VU regional long-term strategy.” If this represents the emi ssions reductions that MANE-VU refers to as the “Ask”, please make that clear. It is important to define which of the additional control measures are being implemented as enforceable control meas ures and which are future goals that have not been enacted. Specifically, pleas e clarify which of the control measures included in the 2018 “best and final” MANE-VU inventory in Table 4.3 have been implemented in the District. DDOE RESPONSE: Emissions reductions repres ented in the “Ask” of other RPOs are included in Section 7.1. These requests are similar to the emissions reductions which represent MANE-VU’s reasonable progress goals (see Section 10.6.3):

- Timely implementation of BART

- Low-sulfur oil strategy

- EGU strategy (167 stacks)

- Other controls, including residential wood combustionThese emissions reductions are the same as those reflected in the “best and final’ scenario. The region, including the District, and other RPOs have 10 years (by 2018) to pursue these strategies as reasonable and neces sary. They are not necessarily enforceable

yet.

A statement was added to 4.1.2 to indicate that the “best and final” measures applied for the District (which are also part of the region’s reasonable progress goals) are future goals that have not been enacted.

Section 4.3.1. Tables 4.1, 4.2, and 4.3: Please explain the basis for differences betw een the 2018 On the Books/On the Way inventory and the 2018 Final inventory for the District. What controls were assumed to reduce the District’s area source SO2 by 90% and non-E GU point source SO2 by 30% between the two 2018 inventory versions? The docu ment should specifically cite th e emissions control measures taken by the District. If the em issions changes documented in Ta ble 4.3 are illustrating potential

emissions reductions rather than enacted control measures, this s hould be clearly described in the

text. Please revise Tables 4.2 and 4.3 so that th e order of presentation of emissions sectors is consistent, currently the order of area s ources differs between the two tables. DDOE RESPONSE: Language was added to 4.3 .1 and throughout Section 4 to address these concerns. The order of presentation of emissions sectors in the tables was made

consistent.

Please explain the basis for reductions in the MANE-VU regional 2018 emissions in Tables 4.6 (2018 On the Books/On the Way) and 4.8 (2018 Final Emissions Inventory). Are these

reductions the same as the MANE-VU “Ask”? Please explain if the emissions reduction

measures included in these tables have b een implemented. MANE-VU used the Final 2018 inventory as the basis for air quality modeli ng to define visibility improvements by 2018. Therefore, it is important to understand the extent that reductions beyond On the Books/ On the Way will be implemented. DDOE RESPONSE: Language was added to 4.3.2 to address these concerns.

Anthropogenic VOC emissions are only partially relevant to fine particulate mass because many of the anthropogenic volatile organic compounds do not react to form particles. It would be more helpful to report in Tables 4.1 to 4.9 prim ary organic carbon and primary elemental carbon emissions. Same comment for Figure 6.7. DDOE RESPONSE: The tables presented in th e District’s SIP are a result of MANE-VU

work. The District does not have the resources to revise the Tables 4.1 to 4.9 to include primary organic carbon and primary elem ental carbon emissions information.

The more pronounced impact of VOCs from the perspective of PM 2.5 (to address haze), rather than hydrocarbons (to address ozone), is explained on pages 4-2 through 4-5 of the

Contribution Assessment , along with a statement that, “we need further work to characterize the organic carbon contribution to regional haze in the Northeast and MidAtlantic states and to develop emissions inve ntories that will be of greater value for visibility planning purposes.” Language was added to Section 6.3.2 to emphasize the point.In Section 4.3.2 Emissions from the Dist rict Compared to MANE-VU Emissions

The final statement of this section includes the conclusion that the Distri ct contributes 0.1% to

0.3% of the SO2 emissions in the MANE-VU region. We recommend further language to explain why this conclusion is important to the overall consultation pro cess and development of the District’s long-term strate gy (i.e., linking the emission inve ntory results with the MANE-VU decision that consultation takes place among those states that contribute at least 2% SO2). DDOE RESPONSE: Language was added to Section 4.3.2 to address this comment.

In Section 5.0 Air Monitoring Strategy, the Distri ct should include language that commits the District to continuing support of ongoing visibility monitoring in Class I areas. Currently, the

IMPROVE network meets this mon itoring goal. Support, in this context, means the District agrees IMPROVE is an appropriate monitoring ne twork to track regional haze progress and that the District agrees to work with neighboring states and FLMs in meeting the goals of the IMPROVE program. DDOE RESPONSE: Language was added to Section 5.1 to address this comment.

Section 5.1, the third paragraph desc ribes the baseline visibility c onditions at the 20 percent most impaired days and the 20 percent least impa ired days for the baseline period 2000-2004. To define the pollutants contributing to visibility impairment, the District should include charts illustrating aerosol composition for IMPROVE monito rs in Class I areas nearest the District (e.g., Shenandoah National Park, Dolly Sods Wild erness Area, Brigantine Wildlife Refuge) on the 20% worst and 20% best days in 2000- 2004. These data can be found on the VIEWS

website at: http://views.cira.colostate.edu/web/Composition/

. DDOE RESPONSE: Section 5 is intende d to introduce monitoring and modeling methods and protocols, not the results of m onitoring or modeling. As mentioned in later in Section 5.1, “as a particip ant in MANE-VU, the District reviewed information about the chemical composition of baseline monitoring data at Class I areas in and near MANEVU in order to understand the sources of h aze causing pollutants. Section 6 of this implementation plan summarizes this analysis.”

Section 6.1 discusses which pollu tants contribute most to vi sibility impairment, based on analysis that can be found in the Contribution Assessment (Appendix K, particularly in Section 3). The second paragr aph states that, “In 2002, on the haziest 20 percent of days,

sulfate accounted for one-half two-thirds of total fine particle ma ss and was responsible for about three-quarters of total light extin ction at Class I site s...” Figure 6.1 portrays baseline results that compares sulfate to other contributors to haze on the 20 percent worst visibility days in seven Class I areas , including Brigantine, Shenandoah and Dolly Sods, which are all located n ear the District. The second paragraph also states that, “Even on the clearest 20 percent of days, sulfate typically constitutes 40 percent or more of total fine particulate mass in the region.”

We believe this existing information is suffici ent to define the pollutants contributing to visibility impairment.

Section 5.2 is an abbreviated description of the ai r quality models that were used in the MANEVU visibility assessment. The SIP should includ e the model performance evaluations for thesemodels to demonstrate th at the models have appropriate skill for the intended application. At a minimum, the SIP should cite the specific loca tion in the referenced documents where this information is provided. Because the District’s emissions are a very small fraction of total emissions in the MANE-VU region, these models are adequate to demonstrate the District’s relative contribution to visibility im pairment, as described in Section 6. DDOE RESPONSE: Model performance evalua tions from the Appendices are now more directly referenced throughout Section 5 (particularly in Section 5.2) of the SIP.

In Section 7, we recommend including the J une 7, 2007, statement that was approved by all

MANE-VU member states.

DDOE RESPONSE: The MANE-VU “Ask” of ot her RPOs was added to Section 7.1.

The similar MANE-VU statement for states within MANE-VU is already included in

Section 10.6.3.

In Section 8, the District shoul d state that that it supports the reasonable progress goals set by the Class I states, including those set by Virginia and West Virgin ia through the VISTAS process.

DDOE RESPONSE: A statement has been adde d to section 8.1 to address this comment.

The Section 9, the BART determination is missing. The District’s Implementation Plan is not complete without the required BART analysis. Please provide an opportu nity to review and

comment on the draft BART determination as soon as practical. We will then review the BART analysis and submit follow-up comments as necessary. DDOE RESPONSE: The BART chapter (Sec tion 9) was submitted to the FLMs for review on March 12, 2010. The FLMs concurre d with the results and did not submit follow-up comments.

Section 10, Long Term Strategy. Figure 10.2 is conf using because several of the Class I areas identified in the map are not in MANE-VU states . We recommend you delete this figure. The brief paragraph above the map correctly reports that impacts from wood smoke at MANE-VU Class I areas are likely due to emissions from MANEVU states. Were emissions strategies to

reduce wood smoke considered? DDOE RESPONSE: The previous Figure 10.2 on wood smoke emissions has been

deleted. All consideration of th e wood smoke is now in Section 10.7.3.

A common concern for SIPs submitted by the MANE- VU states is the modeling results that are used to evaluate progress are based on emissions assumptions for MRPO and VISTAS states that differ from the emissions assumptions made by those states. As a result, regional model projections for MRPO and VISTAS differ from projections made by MANE-VU. For example, VISTAS results projects Dolly Sods, WV w ill meet uniform rate of progress by 2018 while

MANE

- VU results which use different assumptions fo r the VISTAS states, projects that Dolly

Sods will not m eet uniform rate of progress. Section 10.9 cites VISTAS results for Dolly Sods,

but MANE-VU results for Shenandoah. Please use the rate of progress results for Dolly Sods and Shenandoah that are used by WV and VA in their respective State Implementation Plans

rather than the MANE-VU results for these site s. Or if you choose not to use these states’ results, please explain th e basis for your decision.DDOE RESPONSE: Please refer to footnote 10 in section 10.8, which has been added to

address this comment. At the time of subm ittal of the District’s implementation plan, Virginia’s final Regional Haze SIP was not ava ilable. This is why MANE-VU results are

sited for Shenandoah in this SIP.

It is important to include in S ection 10 the specific measures that the District has taken to implement the MANE-VU recommendations for emissions management. DDOE RESPONSE: The District has agreed to pursue MANE-VU recommendations as appropriate and necessary, as mentioned throughout Section 10.6 and summarized in

Section 10.9.

As part of the Reasonable Progress demonstratio n, the regional haze rule requires a four-factor analysis of potential emissions reduction options . The District should cite the MANE-VU Four Factor Report and define which of the source categories in the MANE-VU report are represented in the District’s inventory. The District should evaluate potential SO2 emissions reduction options for non-EGU point sources and area sources in the District, for instance low sulfur fuel

oil.

DDOE RESPONSE: MANE-VU’s four-factor analysis of additional reasonable emissions reduction strategies considered dur ing development of the long-term strategy

for all MANE-VU states is summarized in Section 10.6. There is no inventory documentation for this analysis, but the “best and final” emissions i nventory results (see Section 4.2.7 and Section 10.9.1), which reflec ts MANE-VU’s final reasonable progress goals, does consider potential SO 2 emissions reductions for non-EGU point sources and

area sources in the District. Please re fer to discussion related to Appendix I.

We also recommend in order to satisfy the veri fication requirements of th e regional haze rule, that the District commits to using the five-year review to look at wh ere the District is in terms of emission projections. In the five-year review, if the District is not meeting projections, a SIP revision would be triggered allowing the FLMs a nd the public to review how the District plans on meeting projections.

DDOE RESPONSE: The District commits to evaluating progress within five years of submittal of this initial plan in Section 2 of the SIP. Minimal clarification has been added

to address this comment.

It is critical for each MANE-VU member agency to commit to the goal of improving visibility. This includes the need to link all District progr ams together, such as regional haze planning and other District permitting programs, such as New Source Review (NSR) and Prevention of Significant Deterioration (PSD). For example, it is important to consider projected emission growth under NSR and PSD and how that may impact regional haze and reasonable progress goals. DDOE RESPONSE: Language has been adde d to Section 3.4.3 (#2 and subsequent paragraph) to clarify our unders tanding of this requirement to link all District programs together, such as regional haze planning and permitting.US Department of Agriculture, Fo rest Service Comments (March 20, 2010)

The SIP lacks a 5-factor analysis of the pot ential emission control options for the BART

determination. DDOE Response: The BART chapter (Section 9) is now complete.

The SIP lacks the actual BART determination base d on the options of different sulfur contents

for the fuel oil. DDOE Response: The BART chapter (Section 9) is now complete.

When discussing impacted Class I Wilderne ss areas, please include Otter Creek Class I Wilderness area. It is acceptable to discuss Doll y Sods and Otter Creek similarly since they are relatively close together, but as they are distinct Class I areas it is important to identify both

areas. DDOE Response: The Otter Creek Wilderne ss area was not modeled in some of the MANE-VU exercises where Dolly Sods was mo deled. This made it difficult to mention Otter Creek in some parts of the SIP. Where appropriate, the District has included

references to Otter Creek.

Please confirm that DC DEQ DOE is committed to following the MANE-VU modeling and recommendations included throughout the SIP. Most of the work is from MANE-VU, and the Forest Service would like to be sure that Washington DC supports that work and is committed to following through with the recommendations of the Regional Planning Organization. DDOE Response: Language has been added to section 3.1 to a ddress this comment.