# Appalachian Mountain Club

Main office • Five Joy Street, Boston, MA 02108-1490 617-523-0655

Pinkham Notch Visitor Center • Route 16, Box 298, Gorham, NH 03581-0298 603-466-2721 Highland Center at Crawford Notch • General Delivery, Route 302, Bretton Woods, NH 03575-9999 603-278-4453 www.outdoors.org Appalachian Mountain Club (AMC) Comments on the Draft Final New Hampshire Regional Haze SIP Revision May 22, 2009

Submitted June 26 th , 2009

AMC is very concerned about pollution that causes regional haze because of the importance of clean air and clear views to our 90,000 members, almost 10,000 of whom are NH residents. Fine particulate pollution, that causes poor visibility, is detrimental to the health of outdoor enthusiasts and the recreation experience in the mountains of the Eastern US. AMC has monitored fine particulate concentrations and its associated acidity since 1988 in the White Mountains of NH, adjacent to the two Class I areas Great Gulf and Presidential Dry River Wildernesses, and recently published our findings (see Murray, et al., 2009 1 ). We sees more than 500,000 visitors annually to our front and backcountry NH facilities, the majority of whom greatly value natural resources such as sprawling views from ridgelines. AMC’s Mountain Watch visibility monitoring, with more than 2,500 participants, and its 1990’s visibility studies 2 have also documented how backcountry visitors value high visibility days in NH’s mountains. The White Mountains see more than 6 million visitors annually seeking natural beauty, clean air, and clear vistas. These statistics highlight the convergence of economic and natural resource values that clear views contribute to the state of NH, and support the urgent need to address the Congressionally-mandated visibility requirements under the Clean Air Act and implementation of the Regional Haze Rule.

AMC has been an active participant in the MANE-VU stakeholder process and we continue to track the development of Regional Haze State Implementation Plans (RH SIPs) by individual states in the Northeast and Mid-Atlantic area. We appreciate the efforts by the NH DES staff in the Regional Haze planning process, including their valuable contributions to the MANE-VU regional planning organization.

AMC supports NH’s and MANE-VU’s general approach to addressing regional haze by applying the Regional Haze and BART regulation and guidelines. AMC did express our concern through the public comment process about whether the issuance of the Merrimack Station’s Temporary Permit TP-0008, to install the wet scrubber to reduce SO2 emissions, followed proper New Source Review regulations. Further, AMC believes that issues of overall cost of compliance, including the most recent cost estimates and taking into account all state and federal regulations, along with stakeholder input, should be considered as part of the states decision to move ahead with the scrubber compliance option on Merrimack Station. However those specific concerns are not the focus of these comments, which instead will address the overall regional haze requirements and compliance strategy proposed in NH’s RH SIP.

1 Abstract Web Link: http://dx.doi.org/10.1016/ j.atmosenv.2009.03.060

2 See Publication: http://www.fs.fed.us/rm/pubs/r mrs_p015_5/rmrs_p015_5_304_311.pdf last

viewed 6/25/09

# Appalachian Mountain Club

Main office • Five Joy Street, Boston, MA 02108-1490 617-523-0655

Pinkham Notch Visitor Center • Route 16, Box 298, Gorham, NH 03581-0298 603-466-2721 Highland Center at Crawford Notch • General Delivery, Route 302, Bretton Woods, NH 03575-9999 603-278-4453 www.outdoors.org MANE-VU Ask We strongly support the MANE-VU 167 targeted stack strategy that looks to control, by 90% or more, EGUs SO2 emissions that contribute to visibility impairment at Class I areas in the region. Three NH stacks, two of which are BART-eligible sources, were identified in the MANE-VU 167 stack strategy. We applaud the MANE-VU states, including NH, for going beyond BART and the on-the-way (OTW) regulations by developing a low sulfur fuel oil strategy.

AMC urges NH to include federally enforceable controls in its SIP to meet its commitment of a 90% reduction in SO2 emissions under the Targeted EGU Strategy. Preferably, NH should add a specific commitment to reduce SO2 emissions at NT1, a BART-eligible source, by 90%. NH should exhaust all possible options (fuel switching to natural gas, earlier use of 0.5%-S fuel oil, and/or an increase in enforceable reduction at Merrimack station to greater than 90%) to reduce the overall emissions for the 3 targeted stacks by 90%. AMC provides the following table to clarify the difference between the emission reduction targets from the MANE-VU Ask and the NH SIP. We recognize that NH and other states are provided some flexibility in meeting their regional haze obligations, and that NH has worked extensively to achieve the planned reductions included in this draft. However, it would be a missed opportunity to further improve NH air quality to not require 90% reduction of SO2 from each target EGU. Furthermore, the example put forth in NH’s RH SIP commitments will provide our state important leverage as we ask other states to control emissions that impact visibility in our Class I airsheds.

Visibility Metrics AMC generally supports the use of the “alternative method” for calculating baseline and natural visibility in deciviews. This approach was vetted through the IMPROVE steering committee and has valid scientific principles behind it.

BART Provisions AMC strongly supports NH’s decision to not ex empt any BART-eligible sources from the BART determination process, consistent with MANE-VU’s position. Furthermore, AMC agrees with NH that CAIR should not equal BART and appreciate that NH is committed to revisiting its RH SIP once the EPA issues a response to the CAIR remand. The courts found error in EPA’s CAIR, in part, due to the use of cap and trade to address

# Appalachian Mountain Club

Main office • Five Joy Street, Boston, MA 02108-1490 617-523-0655

Pinkham Notch Visitor Center • Route 16, Box 298, Gorham, NH 03581-0298 603-466-2721 Highland Center at Crawford Notch • General Delivery, Route 302, Bretton Woods, NH 03575-9999 603-278-4453 www.outdoors.org specific locations NAAQS non-attainment. Simi larly the CAA visibility requirements, with the BART provisions as one tool, look to clean up sources impacting visibility in Class I National Parks and Wilderness areas. Therefore a cap and trade approach is an unacceptable solution to addressing regional haze.

Section 11.4.3 Table 11.1 The final column in this table appears to have incorrect values for NT1 2018

SO2 Emissions and the Total Emissions for 2018.

Section 11.8 Page 133 NH DES should clarify in this section, as they did in section 10.3, that the alternative method was used to calculate baseline and natural visibility.

Page 134 The 3 rd bullet states that the glide slope was “created by linear interpolation between the 20 percent worst visibility baseline value in 2004 and the 20 percent worst visibility value under natural conditions in 2064.” The glide slope should be based on linear interpolation between the average 20 percent worst visibility baseline value from

2000-2004 and the 20 percent worst visibility value under natural conditions in 2064. It is difficult to read the values off the graph and determine what the actual glide slope is (in dv/year) and therefore difficult to determine what method was actually used by NH DES. The agency correctly refers to the baseline visibility average values (2000-2004) throughout the SIP, however it needs to clarify what was used to calculate the glide slope and what the actual rate of change is.

Section 11.11 Page 140-141 NH DES discusses its obligation to ensure that control measures are federally enforceable to comply with the RHR requirements. Earlier in the SIP NH states that existing NOx and PM controls are considered BART; however, it is unclear that these controls will be federally enforceable with the information and attachments provided. This can be resolved by NH DES submitting as part of the RH SIP the appropriate Title V permits that provide f ederally enforceable requirements for operation of the SCR and ESP. While year round SCR is currently expected due to NOx RACT requirements, it is important to see the permit documents that identify this. We recognize that NH does not have a merged construction and Title V permitting program, but the Temporary Permit referred to (TP-0008) does not identify enforcement of NOx

and PM controls.

AMC appreciates the opportunity to provide comments to NH DES as part of the RH SIP process. We urge NH to finalize an enforceable emission reduction strategy that adheres to the most aggressive reductions found in the MANE-VU Ask, providing important reductions in regional haze pollution and improving NH’s air quality.

Sincerely,

Georgia Murray

AMC Staff Scientist gmurray@outdoors.org

603-466-2721 x8111