Appendix 1A 

List of Class I Areas In or Impacted by 

Midwest RPO States 
 

List of Class I Areas In or Impacted by Midwest RPO States 

The purpose of this paper is to provide a draft list of Class I areas located within or impacted by 

a Midwest Regional Planning Organization (MRPO) State. A variety of technical analyses were 

considered in developing the draft list, including base year (2002) and future year (2018) 

modeling, back trajectories, and other data analyses. This information shows that every MRPO 

State impacts multiple Class I areas in the eastern U.S. 

Regulatory Requirements 

EPA’s regional haze rule requires a state to “address regional haze in each mandatory Class I 

Federal area located within the State and in each mandatory Class I Federal area located 

outside the State which may be affected by emissions from within the State.” (40 CFR Part 

51.308(d)) EPA has interpreted this provision as requiring a table identifying each mandatory 

Class I Federal area located within the State and each mandatory Class I Federal area located 

outside the State affected by emissions from within the State (see Draft EPA Checklist for 

Regional Haze SIPs Submitted Under 40 CFR 51.308 - 7/13/06 Staff Draft ).

Discussion 

Technical analyses conducted by the RPOs were consulted to obtain information on areas of 

influence and culpability for Class I areas in the eastern U.S.1

 A summary of this information is 

provided below and in Table 1. 

For the MRPO analyses, a state was assumed to affect visibility impairment in a Class I area if it 

contributes 2% (or more) to total light extinction. This criterion was selected based on a review 

of the back trajectory and modeling results which showed that states contributing 2% (or more) 

make-up about 90-95% of total light extinction, whereas states contributing 5% (or more) makeup only about 75-80% of total light extinction. For the other RPO analyses, deference was 

given to the criteria established by each group to identify contributing states. 

(1) MRPO Back Trajectory Analyses 

An initial trajectory analysis was conducted using data for 1997-2001 (all sampling days), a start 

height of 200 m, and a 72-hour (3-day) trajectory period (Cite: “Quantifying Transboundary 

Transport of PM2.5: A GIS Analysis”, May 2003, LADCO). By combining trajectory frequencies 

with concentration information, the average contribution to PM2.5 mass and individual PM2.5

species was estimated (which, in turn, was used to estimate the average contribution to light 

extinction). The results for 17 Class I areas in eastern U.S. were examined to identify those 

Class I areas where an MRPO state had at least a 2% contribution to total light extinction 

(based on all days). 

 

1 Back trajectories and modeling conducted by the WRAP indicate that the Midwest RPO States are not 

important contributors to visibility impairment due to sulfates and nitrates in western Class I areas (Cite: 

“Attribution of Haze Phase I Report, Geographic Attribution for the Implementation of the Regional Haze 

Rule”, March 14, 2005). The analyses show only five groups of western Class I areas with at least 5% 

contribution from states outside the WRAP. The outside-WRAP contribution is generally small (on the 

order of 0-15%), and is likely due mostly to nearby CENRAP states. 

1
 

A second trajectory analysis was conducted using data for 2000-2003 (20% highest and lowest 

days), a start height of 200m, and a 120-hour (5-day) trajectory period (Cite: “Sensitivity 

Analysis of Various Trajectory Parameters”, June 2005, LADCO). Back trajectory plots were 

prepared for each of the four northern Class I areas in Michigan and Minnesota for the high 

extinction days (see Figure 1 – note: areas in orange are mostly likely upwind and the areas in 

green are least likely upwind on poor visibility days). Although somewhat qualitative, these 

results provide additional information in identifying states impacting the northern Class I areas. 

 Voyageurs Boundary Waters 

S# S#

S#

S#

ISLE

VOYA

SENE

BOWA

 

S# S#

S#

S#

ISLE

VOYA

SENE

BOWA

 Isle Royale Seney

S# S#

S#

S#

ISLE

VOYA

SENE

BOWA

 

S# S#

S#

S#

ISLE

VOYA

SENE

BOWA

Figure 1. Contoured trajectory plots for poor visibility days for Class I areas in northern 

Minnesota and Michigan 

(2) MRPO PSAT Modeling 

A photochemical grid model (CAMx) was applied to provide source contribution information for 

2018 conditions. Specifically, the model estimated the impact of 18 geographic source regions 

and 6 source sectors (EGU point, non-EGU point, on-road, off-road, area, and ammonia 

sources) at Class I areas in the eastern U.S. Example results for four Class I areas (Seney, 

Mammoth Cave, Mingo, and Shenandoah) are presented in Figure 2. The results for 13 Class I 

areas in eastern U.S. were examined to identify those Class I areas where an MRPO state had 

at least a 2% contribution to total light extinction. 

2
 

Figure 2. Source region contributions to light extinction based on MRPO PSAT modeling for 

select Class I areas: Seney, Mammoth Cave, Mingo, and Shenandoah 

(3) MANE-VU Contribution Assessment 

A weight-of-evidence report was prepared by NESCAUM (on behalf of MANE-VU) to 

understand the causes of sulfate-driven visibility impairment at Class I areas in the northeastern 

and mid-Atlantic portions of the U.S. (cite: “Contributions to Regional Haze in the Northeast and 

Mid-Atlantic United States”, August 2006) The report provides information on the relative 

contribution of various emissions sources and geographic source regions. The analytical and 

assessment tools considered include Eulerian and Lagangian air quality models, and data 

analysis techniques, such as source apportionment analyses, back trajectories, and 

examination of emissions and monitoring data. Sulfate impacts were quantified using five 

analytical techniques based on 2002 conditions: REMSAD, Q/d, CALPUFF (w/ NWS data), 

CALPUFF (w/ MM5 data), and percent time upwind (based on trajectory analyses). Figure 3 

summarizes the five sets of results for three MANE-VU Class I areas. Although no specific 

criteria were identified in the report to determine a significant contribution, the States of 

Vermont, New Hampshire, Maine, and New Jersey assumed a 2% sulfate impact in recent 

letters to other states inviting them to consult on reasonable progress goals. The MRPO States 

identified as contributing to a MANE-VU Class I area were Illinois, Indiana, Michigan, and Ohio. 

3
 

Figure 3. Percent contribution results using different techniques for ranking state contributions 

to sulfate levels at MANE-VU Class areas (cite: “Contributions to Regional Haze in the 

Northeastern and Mid-Atlantic Portions of the U.S.”, August 2006) 

4
 

(4) Missouri-Arkansas Contribution Assessment 

The draft Consultation Plan for the two Missouri and two Arkansas Class I areas provides 

information on source regions affecting these Class I areas (i.e., areas of influence) using a 

variety of data and analyses. (cite: “Central Class I Areas Consultation Plan”, States of Missouri 

and Arkansas, February 2007) A decision on whether a given state is a contributor to visibility 

impairment in these Class I areas was based on the combined results of three approaches: 

areas of influence (see Figure 4), PSAT modeling (based on 2018 conditions), and monitoring 

data analyses (PMF and back trajectories). According to the draft plan, if a state was a major 

contributor for at least two of the three approaches (for either sulfate or nitrate), then it was 

determined to be a significant contributor. The MRPO States identified as contributing to a 

central CENRAP Class I area were Illinois, Indiana, and Ohio. 

Figure 4. Areas of Influence for Central CENRAP Class I Areas (cite: “Central Class I Areas 

Consultation Plan”, States of Missouri and Arkansas, February 2007) 

(5) VISTAS Area of Influence Analysis 

Areas of influence (AOI) were identified for Class I areas in the southeastern U.S. using 

residence time plots based on wind trajectory direction and frequency, and weighted by visibility 

impact (light extinction by ammonium sulfate, ammonium nitrate, or elemental carbon). 

(Cite: “VISTAS Areas of Influence Analysis”, Draft, February 28, 2007). These extinctionweighted residence time analyses were overlayed on gridded emissions (for both 2002 and 

2018) to define emission sources in the areas of greatest influence for each Class I area. 

Figure 5 shows the plots for two VISTAS Class I areas. AOIs were defined on the basis of 

residence times greater than 10%. The MRPO States identified as contributing to a VISTAS 

Class I area were Illinois, Indiana, and Ohio. 

5
 

Figure 5. Areas of Influence for Shenandoah (left) and Mammoth Cave (right) for 2018 conditions 

(cite: “VISTAS Area of Influence Analyses” PowerPoint presentation, November 28, 2006) 

Note: green circles indicate 100- and 200-km radii from Class I area, red line perimeter indicate 

AOI with residence time > 10%, and orange line perimeter indicate AOI with residence time > 5% 

6
 

Table 1. Draft List of Class I Areas Impacted by MRPO States - References

AREA NAME IL IN MI OH WI 

81.401 Alabama. 

Sipsey Wilderness Area (1) (1) 

81.404 Arkansas. 

Caney Creek Wilderness Area (2), (4) (2), (4) (2), (4) 

Upper Buffalo Wilderness Area (1),(2a),(4),(5) (2a), (4) (2), (4) (2) 

81.408 Georgia. 

Cohotta Wilderness Area 

Okefenokee Wilderness Area 

Wolf Island Wilderness Area 

81.411 Kentucky. 

Mammoth Cave NP (1a), (2), (5) (1a), (2a), (5) (1), (2) (1), (2a), (5) 

81.412 Louisiana. 

Breton Wilderness Area 

81.413 Maine. 

Acadia National Park (3) (3) (3) (3) 

Moosehorn Wilderness Area. (3) (3) (3) (3) 

81.414 Michigan. 

Isle Royale NP. (1a), (2a) (1), (2a) (1), (2a) (1a), (2a) 

Seney Wilderness Area (1a), (2a) (1a), (2a) (1a), (2a) (1), (2) (1a), (2a) 

81.415 Minnesota. 

Boundary Waters Canoe Area 

Wilderness (2) (2) (2) (1a), (2a) 

Voyageurs NP (2) (2) (1a), (2a) 

81.416 Missouri. 

Hercules-Glades Wilderness Area (2a), (4), (5) (2a), (4), (5) (2), (4) (2)

Mingo Wilderness Area (2a), (4), (5) (2a), (4), (5) (2) (2a), (4) (2)

81.419 New Hampshire. 

Great Gulf Wilderness Area (3) (3) (3) (1), (3) 

Pres. Range-Dry River Wilderness 

Area. 

7
 

81.42 New Jersey. 

Brigantine Wilderness Area (3) (3) (1), (3) (1), (3) 

81.422 North Carolina. 

Great Smoky Mountains NP{1} (1) (1) (1) 

Joyce Kilmer-Slickrock Wilderness 

Area{2} 

Linville Gorge Wilderness Area. 

Shining Rock Wilderness Area. 

Swanquarter Wilderness Area 

81.426 South Carolina. 

Cape Romain Wilderness 

81.428 Tennessee. 

Great Smoky Mountains NP{1}. (1) (1) (1) 

Joyce Kilmer-Slickrock Wilderness{2} 

81.431 Vermont. 

Lye Brook Wilderness (2), (3) (2), (3) (2), (3) (1), (2), (3) 

81.433 Virginia. 

James River Face Wilderness. (2) (2) (2) (2a), (5) 

Shenandoah NP (2), (3) (1), (2a), (3) (2), (3) (1a),(2a),(3),(5)

81.435 West Virginia. 

Dolly Sods/Otter Creek Wilderness. (2), (3) (1), (2a), (3) (1), (2), (3) (1a),(2a),(3),(5)

Key 

(1) MRPO Back Trajectory Analyses having a 2%-5% impact 

(1a) MRPO Back Trajectory Analyses having >5% impact 

(2) MRPO PSAT Modeling having a 2%-5% impact 

(2a) MRPO PSAT Modeling having >5% impact 

(3) MANE-VU Contribution Assessment 

(4) Missouri-Arkansas Contribution Assessment 

(5) VISTAS Areas of Influence 

8
1

Appendix 2A 

Public and FLM Comments 

and 

DNRE Responses 

(The following 3 pages contain the DNRE notice of the second public comment 

period, which was held in May 2010, as published in DNRE’s biweekly Calendar of 

Events.) 
2
3
4
5

General Summary of Comments from the 2010 Public Comment Period

and DNRE Responses

Three sets of comments were received: one from the Forest Service (FS), a joint set 

from the Fish and Wildlife Service (FWS) and National Park Service (NPS), and one set 

from the Environmental Protection Agency (EPA). 

Comment: Two comments (FS and EPA) expressed a concern for how the reasonable 

progress goals (RPGs) will account for BART. The reasonable progress goals are 

based on modeling runs that do not reflect BART determinations in Michigan and other 

states. While future haze levels are difficult to predict, especially due to uncertainties 

regarding utility control requirements and control levels, the EPA will expect Michigan to 

establish reasonable progress goals that reflect at least an approximation of BART 

control levels. There is still no statement in the State Implementation Plan (SIP) as to 

when remodeling will be done that shows the effect of BART determinations such as 

Lafarge and other sources in Michigan and elsewhere. How will the RPGs in the SIP be 

revised to reflect the implementation of BART in Michigan and other states? 

Response: The DNRE will redo modeling to include BART when we have definite 

emissions information based on final Lafarge controls. This data is scheduled to be 

available no later than 2016. Other BART sources in other states are expected to have 

controls in place by this date as well, allowing for revised modeling for RPGs (see 

Section 5.1). 

Comment: The FS commented that Michigan should include details on current controls 

on electric generating units (EGUs) and controls being installed, by date and by level of 

emissions reductions expected. As discussed later in their letter, they are particularly 

interested in planned controls for the top contributing sources as illustrated in Tables 

10.3.2a-d. 

Response: The DNRE has added information on EGU controls to Section 5.3 of the 

SIP document. 

Comment: Two comments (FS and FWS/NPS) questioned how Michigan responded to 

the MANE-VU ask. According to the Regional Haze Rule, such consultations are not 

expected to result in agreement on everything, but the areas of agreement and 

disagreement that occur via consultation are to be documented in the SIP. They found 

some lengthy meeting notes but no list of specific areas of agreement and disagreement between Michigan and MANE-VU. Their questions include: 1) Much of the 

material is dated (was from 2007). What happened after that? 2) Is MANE-VU satisfied 

that the stacks they identified in Michigan are controlled adequately? 3) What is 

planned for control of those stacks and of those projects, how many are in enforceable 

documents? 

Response: LADCO and MANE-VU continued discussions on a CAIR replacement rule 

and ICI boilers and sent ask letters to the EPA. The joint letter shows areas of agreement between LADCO and MANE-VU and the other two separate LADCO and MANEVU letters indicate areas of disagreement. These letters have been included in the SIP 
6

in Appendix 3D. The DNRE had no specific dialogue with MANE-VU to address 

whether MANE-VU was satisfied with controls on stacks identified by MANE-VU. 

Comment: The FWS and the NPS commented that the Regional Haze Rule requires 

that RPGs be established to protect the 20% cleanest days (i.e., visibility on the 

cleanest days cannot degrade). The SIP assumes that RPGs are met, despite data 

showing that the cleanest days are in fact getting dirtier. (See Table 5.2b, Haze 

Results). Therefore, progress in meeting regional haze goals is not demonstrated in the 

plan as it is currently drafted. 

Response: The DNRE believes that there are several reasons that could explain the 

cleanest days showing degradation. Modeling is not an exact science and a reasonable 

interpretation of the modeling is that there is little expected change in the clean day 

visibility levels. Also growth for ammonia was assumed for 2018, and no controls on 

ammonia emissions were added. Any assumptions regarding levels of ammonia 

emissions are estimates at best. In addition, BART controls were generally not 

modeled which also may improve the visibility. Recent measured visibility values are 

actually below the modeled values, indicating the models may be over-predicting the 

actual values. More detail on this issue is included in Section 5.2 of the SIP. 

Comment: The FWS/NPS requested more information in several areas: 

• Modeling that was performed, the tools used, and a description of model 

performance establishing the level of confidence in the results, should be 

included in the SIP narrative. 

• Response: This information is provided in Appendix 5A starting on page 47. 

• More information based upon the IMPROVE monitoring data, which illustrates 

the importance of sulfate, nitrate, and organic carbon to visibility impairment, 

and how Michigan is using these data to define its emission control priorities. 

• Response: Over time, as the DNRE continues to evaluate the haze problem in 

Michigan, we will determine whether our emission control priorities need to be 

revised. 

• More discussion regarding all emission inventories, the inventory development 

methods, and the assumptions made with all iterations in inventory development. 

• Response: The emissions inventory is thoroughly discussed in Appendix 8A. 

In addition the modeling inventory is discussed in Appendix 5A starting on 

page 51. 

Comment: The EPA commented that given the regional nature of regional haze, 

Michigan’s test for significance, based on whether a state contributes 5% of the regional 

haze, is too exclusive a test. Although the EPA does not specify a particular test of 

significance for states to use, the alternative contemplated by Michigan, based on 

whether a state contributes 2% of the regional haze, likely provides a better indicator of 

whether a state has a contribution that warrants addressing. 

Response: The DNRE disagrees. As explained in Appendix 1A, the back trajectory 

and modeling results showed that states contributing 2% (or more) make up about 90 to 

95% of total light extinction, whereas states contributing 5% (or more) make up about 
7

75-80% of total light extinction. Since this is the first planning period for regional haze, 

we believe that focusing on a 5% grouping of states is adequate. In future years this 

will be re-evaluated and a larger impacting group of states may be appropriate. 

Comment: The EPA commented that they do not agree that the Midwest Regional 

Planning Organization (RPO) is dormant. In any case, the DNRE should note that 

LADCO continues to perform work on regional haze and other related air pollution 

issues, currently based primarily on state funding. 

Response: The DNRE removed this language from Section 3.1 of the SIP. The RPO 

has no federal funding for regional haze activities. The DNRE acknowledges that 

LADCO is an integral part of the DNRE’s modeling and other related activities. 

However, modeling priorities continue to focus on PM2.5 and ozone. 

Comment: The EPA commented that the discussion of factors to be considered in 

defining BART lists instead the statutory factors for evaluating reasonable progress. 

The Clean Air Act has a set of five factors for BART that differs somewhat from the four 

factors listed on page 7. 

Response: On page 7, the discussion is about reasonable progress factors. There is 

no discussion about the BART factors in this section. 

Comment: The FS questions why Michigan did not ask for emission reductions from 

the other contributing states shown in Table 10.2.3.a. 

Response: Several states contributing to Michigan Class I areas were planning 

emission reductions in their states. Therefore, the DNRE did not deem it necessary to 

ask for additional reductions. 

Comment: The FS noted that efforts spent to achieve compliance with the PM2.5 and 

ozone ambient standards don’t preempt compliance with other parts of the Clean Air Act 

(i.e., regional haze). The nonattainment areas are generally in the opposite end of the 

state from the Class I areas so the sources determined to have the most contribution to 

the state’s nonattainment problems may not be the same ones who contribute the most 

to visibility impairment in the Class I areas. 

Response: Some large sources of visibility-impairing emissions, EGUs, will achieve 

reductions under CAIR and the new proposed Clean Air Transport Rule (CATR), and 

some are located in ozone and PM2.5 nonattainment areas. Therefore, improvements 

from these sources to address the ozone and PM2.5 nonattainment areas will have an 

effect on visibility. 

Comment: The FS commented that to support Regional Haze SIPs, a large amount of 

resources were spent to produce technical information such as the list of most culpable 

sources in Tables 10.3.2.a and b. While a broad cap and trade system such as CAIR 

can improve visibility at the Class I areas, Tables 10.3.2.a and b show that the most 

benefit will be seen from reductions at specific plants. Yet after presenting the technical 

information, no explanation is given as to what pollution controls are planned for any of 

these sources (and how much of the planned projects are included in any enforceable 

documents), or whether Michigan asked any of the specified sources to implement 
8

controls, including asking the contributing states (e.g., Minnesota and Wisconsin) 

regarding their sources in the tables. 

Response: Most of the sources in Tables 10.3.2.a and b are either BART-subject or 

EGUs subject to CAIR and the proposed CATR. Information on EGU controls has been 

added to Section 5.3. The DNRE is still evaluating the proposed CATR to determine 

how EGUs will be affected. Several states contributing to Michigan Class I areas were 

planning emission reductions in their states. Therefore, the DNRE did not deem it 

necessary to ask for additional reductions. 

Comment: The FS commented that Michigan notes that the majority of EGUs whose 

emissions significantly affect Isle Royale and Seney are subject to CAIR and may be 

subject to the CAIR replacement rule. However, the DNRE is assuming that the CAIR 

replacement rule will still be deemed a substitute for BART. What if CAIR or its 

replacement does not end up representing BART? 

Response: The DNRE is carefully reviewing the proposed CATR, the CAIR replacement rule, to determine how EGUs will be affected. If the Regional Haze Rule is 

changed to not allow this substitution, Michigan will re-evaluate whether additional 

controls on EGUs are appropriate. 

Comment: The FS commented that Figure 10.3.2b clearly shows that the uniform rate 

of progress (URP) is achievable. The EC/R concluded that additional controls on EGUs 

beyond CAIR are economically feasible. 

Response: The DNRE is currently analyzing the proposed CATR rule that the EPA 

considers to be the first Phase of EPA-required EGU controls. Additional controls on 

EGUs will be addressed by the EPA as the second phase of CATR, which the EPA will 

promulgate following the phase I rule currently proposed. 

Comment: The FS commented that Michigan states, “Some of the largest EGUs, such 

as DTE’s Monroe power plant and Consumer Energy’s Campbell plant, have installed or 

are in the process of installing CAIR-compliant controls. EGUs in other states that have 

been shown to impact Michigan’s Class I areas (see Section 10.3.2 of this document) 

also are expected to install and operate CAIR-compliant controls.” In a cap and trade 

system, how does Michigan know what level of controls constitutes a compliant system? 

A source can buy and bank allowances instead of installing controls. Also please give 

more specifics on the control plans for these and the other plants identified in 

Tables 10.3.2.a and b. 

Response: Since haze is a regional problem, cap and trade should still lower 

emissions that will result in improved visibility. However, with the proposed CATR rule, 

trading is limited. The DNRE is evaluating the proposed CATR to determine how EGUs 

will be affected. The DNRE added a table showing the installed controls for EGUs in 

Section 5.3 of the SIP. 

Comment: The FS commented that Michigan states, “Since all EGUs are subject to 

CAIR and since the Regional Haze Rule has allowed CAIR to equal BART, the DNRE 

believes that no further controls on EGUs should be considered as reasonable for 

purposes of regional haze at this time. This includes any EGUs that are not specifically 
9

BART-subject, since controls beyond BART should not be considered reasonable under 

regional haze.” It appears that under Michigan’s assumption that the new CAIR will be 

a substitute for BART, they also assume it will be a substitute for reasonable progress. 

This is incorrect. Reasonable progress is a separate requirement from BART in the 

Regional Haze Rule and requires separate analysis and justification. Reasonable 

progress must result from consideration of a four-factor analysis. The relationship 

between CAIR and BART is not part of a four factor analysis. 

Response: Section 10.3.2 was revised. The reasonable progress analysis in the Haze 

SIP document accounts for all controls currently expected to be implemented by 2018. 

We believe EGUs will be controlled via the CATR and by any additional future controls 

we determine to be necessary to meet the NAAQS. 

Comment: The FS commented that Michigan states, “The control levels evaluated by 

the LADCO contractor, EGU 1 and EGU 2, both provide more emission reductions than 

achieved by CAIR at costs that could be seen as reasonable. However, CAIR clearly is 

intended by the EPA to address reasonable controls for EGUs in terms of the Regional 

Haze SIP. To require EGU 1 and/or EGU 2 levels of control for haze reasonable 

progress goes beyond what the EPA intends, and the DNRE does not believe such 

controls are reasonable.” We are unclear what EPA intention is being referred to here. 

As stated above, reasonable progress is a separate requirement from BART. 

Response: As stated above, the reasonable progress analysis in the Haze SIP 

document accounts for all controls currently expected to be implemented by 2018. We 

believe EGUs will be controlled via the CATR and by any additional future controls we 

determine to be necessary to meet the NAAQS. However, the DNRE has removed this 

language from Section 10.3.2 of the SIP because we are evaluating the CATR controls 

to determine how EGUs will be affected. 

Comment: The FS commented that Michigan states, “The RPG is set at the visibility 

level shown to result from the application of all the elements of the DNRE’s long-term 

strategy, along with all currently known controls being applied by other states. 

However, several of these control measures include CAIR controls that currently are 

being revised by the EPA.” This is not correct since it is our understanding that the 

RPGs in the SIP do not include the affect of non-EGU BART determinations in Michigan 

and surrounding states. How and when will this deficiency be corrected? 

Response: The DNRE will redo modeling to include BART when we have definite 

emissions information based on final Lafarge controls. This data is scheduled to be 

available no later than 2016. Other BART sources in other states are expected to have 

controls in place by this date as well, allowing for revised modeling for RPG (see 

Section 5.1). 

Comment: The FS commented that Michigan states, “The control levels evaluated by 

ECR, EGU 1 and EGU 2, both provide more emission reductions than achieved by 

CAIR. However, CAIR clearly is intended by the EPA to address reasonable controls 

for EGUs in terms of the Regional Haze SIP. To require EGU 1 and/or EGU 2 levels of 

control for haze reasonable progress goes beyond what EPA intends, and the DNRE 

does not believe such controls are reasonable for this phase of the reasonable progress 
10

determination. Future determinations of reasonable progress may re-evaluate controls 

that are tighter than were addressed in the CAIR program.” Again, as stated above, 

reasonable progress is a separate requirement from BART. 

Response: As stated above, CAIR and CATR are expected to address haze. 

However, the DNRE has removed this language from Section 10.3.2 of the SIP because 

we are evaluating the CATR controls to determine how EGUs will be affected. 

Comment: The FS commented that the discussion regarding the state’s Mercury/Multipollutant Rules shows that DNRE can go beyond CAIR to require SO2 and NOx controls 

as it chose to do in this instance to encourage mercury reductions. 

Response: The DNRE allowed co-benefit mercury reductions from proposed NOx and 

SOx reductions at the choice of the EGUs. These reductions are not mandatory. 

Comment: The FS questioned how new emission sources, especially new major 

sources under New Source Review, will show they are not negatively affecting the 

RPG? 

Response: New sources with emissions impacting Seney and Isle Royale take haze 

into consideration via modeling submitted in a New Source Review permit application, 

which is reviewed by FLMs. 

Comment: The FS stated they are eager to implement the draft smoke management 

plan (SMP) and are curious to learn when it will be finalized. 

Response: The SMP is nearly completed, only requiring a few more signatures. 

BART 

Comment: The FS wanted the Q/d analysis to include all three main visibility-impairing 

pollutants, including particulate (PM10). It is unclear if their approach would make any 

difference in the number of facilities in Michigan that moved on to the next step in the 

subject to BART analysis because the Q (including PM10) of each of the sources in 

Table 1 of the Appendix 9B is not listed. 

Response: All EGUs in Michigan have particulate control either by ESP or baghouses. 

Analysis of species contributions indicated that SO2 and NOx were the primary 

pollutants contributing to visibility impairment, thus were the only pollutants modeled in 

the Q/d analysis. 

Comment: The FWS and NPS commented that DNRE must evaluate particulate 

emissions from EGUs subject to BART. While BART guidance allows states to 

conclude that reductions of sulfates and nitrates regulated under the Clean Air Interstate 

Rule (CAIR) are better than BART, this does not include particulate emissions from 

these sources. Also, for the sources for which BART determinations were performed, 

the three yearly deciviews improvements were averaged for comparisons of Pre- and 

Post-BART visibility improvements (see Table 9.3a, BART Controls and Comparison of 

Visibility-Impairing Pollutant Impacts on Class I Areas). They do not agree with 

averaging deciviews for comparison. 
11

Response: Particulate emissions were evaluated via sensitivity tests. Sensitivity tests 

showed that primary particulate emissions play only a very minor role in long-range 

transport contributing to haze, see Section 9.1 for additional detail. Regional sulfates 

and nitrates account for nearly all predicted long-range anthropogenic haze. Modeling 

guidance for determining BART applicability is very specific and does not include annual 

averaging to determine BART eligibility. However, once a facility is determined to be 

BART eligible, the states have modeling discretion on how to determine the effectiveness of control strategies. During these control sensitivity modeling runs, the averaging 

of annual results was used to provide guidance on the effectiveness of proposed 

controls. 

Comment: The EPA commented that although the regional haze rule provides for 

CAIR where applicable to satisfy the BART requirement with respect to SO2 and NOx 

from electric generating units, the EPA is reconsidering this guidance. Therefore, they 

would not necessarily agree that it is “EPA’s position” that CAIR satisfies pertinent 

BART requirements. Similarly, Michigan should avoid statements as to whether EPA 

does or doesn’t intend for CAIR to “address reasonable controls for [electric generating 

units] in... Regional Haze SIPs.” 

Response: The DNRE has removed this language from Section 10.5.2 of the SIP and 

is evaluating the CATR proposal in relation to EGUs. 

Comment: The EPA commented that Michigan must submit the documents that are to 

provide for federal enforceability of specific limits representing BART. Even if these 

limits are already federally enforceable, Michigan must submit these documents for 

inclusion in the docket for EPA’s rulemaking on Michigan’s prospective SIP submittal 

and for incorporation by reference as part of Michigan’s SIP. 

Response: The DNRE believes it has met this requirement by including appropriate 

permit language and references. For Lafarge, the BART reductions are currently 

contained in a consent order, and will be rolled into an NSR permit in the future. 

Empire Mine 

Comment: Comments from EPA and the FS were concerned that the BART-subject 

emission unit at the Empire facility is permanently shut down and reflected in an 

enforceable document. 

Response: The facility is permanently decommissioned as per Title V permit, 

Renewable Operating Permit (ROP) No. MI-ROP-B1827-2008. The decommissioned 

Kiln # 1 is not included in the Title V permit issued July 1, 2008. Kiln # 1 was included 

in NSR permit to install No 494-87B that was voided on November 6, 2000, as part of 

the Title V permit procedure for. ROP #199600365, issued November 6, 2000. It will 

require a new approved NSR permit to restart Kiln # 1. 
12

Lafarge 

Comment: The FWS/NPS commend Lafarge for its proposed BART decisions. 

Lafarge proposed BART that is generally consistent with the control equipment already 

committed to under the Lafarge Global Settlement/Consent Decree – Alpena Facility 

(Consent Decree). Lafarge proposed that BART should consist of Selective NonCatalytic Reduction (SNCR) for NOX control at all five cement kilns, along with wet flue 

gas desulfurization (FGD) for SO2 control for the two kilns in Kiln Group 6. The DNRE 

included as BART Dry Absorption Additions (DAA) for SO2 controls for the three kilns in 

Kiln Group 5 as required by the Consent Decree. They note that low NOX burners 

(LNB) are proposed for all five kilns, but this control equipment is not included in the 

definition of BART. The DNRE should consider the inclusion of LNB as BART and 

explain in the SIP the decision as to its inclusion or exclusion. 

Response: The DNRE considers that all the controls, for NOx, SO2 and PM, as stated 

in the Global settlement, are included as BART.

Comment: The FWS/NPS commented that the Consent Decree requires a 12-month 

rolling average emission limit for NOX of 4.89 lb NOX/ton of clinker, with the provision 

that a 30-day rolling average emission limit will be developed at a later date. Retrofitted 

30-day rolling average emission rates in the range of 2.0 lb NOX/ton of clinker and lower 

can be attained by using SNCR/LNB on pre-calciner kilns. The 35 to 40% removal 

efficiency using SNCR and LNB on a long dry kiln might account for the higher emission 

limit, but more discussion and calculations should be provided to justify the higher 

emission limit as is indicated will be done in the SIP. 

Response: The DNRE considers that all the controls, for NOx, SO2 and PM, as stated 

in the Global settlement, meet BART requirements. The 30-day rolling average NOx 

emission limits will be established following the installation of SNCR on the five kilns. 

These are scheduled to be operating on enforceable milestones of the Consent Decree, 

ranging from October 1, 2011 to March 1, 2012. Comparison of 30-day average 

feasible limits can then be made to the 30-day average limits set through the Global 

settlement’s requirements. 

Comment: The EPA commented that the consent decree that Michigan is relying on to 

require BART level controls specifies interim emission limits but also provides for testing 

to determine final emission limits. At that point the consent decree will be replaced by a 

permit that Michigan is expected to issue. Although the interim limit may suffice for 

current haze SIP purposes, Michigan needs to describe how it intends for the ultimate 

limit to become enforceable by the State and by EPA and to become part of the SIP, to 

replace the consent decree before the consent decree expires. If Michigan intends to 

rely on a Title V permit to provide for federal enforceability of the replacing limits, 

Michigan will need to address questions about whether it has authority to define a BART 

limit in a Title V permit rather than having the Title V permit simply compile a limit 

established elsewhere. As a general matter, Title V permits do not offer a proper 

mechanism for setting new limits. 
13

Response: The BART reductions currently contained in the consent order will be rolled 

into a NSR permit in the future. At that time the NSR permit will be submitted to EPA to 

be made part of the BART SIP. 

New Page – Escanaba Paper (NP) 

Comment: The FS said in regards to the recovery furnace, NP states they already 

have installed staged combustion but offered no data to indicate how well it is operating. 

Response: According to NP, the company is responsible for operating the recovery 

furnace in a manner that is both safe and environmentally responsible. The recovery 

furnace as an emission unit is regulated for, among other pollutants, total reduced sulfur 

(TRS) and particulate. A CEMS is installed and operated to continuously monitor TRS 

emissions. Likewise, a continuous opacity monitoring system is installed to 

continuously monitor opacity as a surrogate indicator for particulate emissions. Poor 

combustion within the furnace will yield poor char bed formation, incomplete oxidation of 

TRS, and fuming, which yields high particulate carryover out of the furnace. Each of 

these parameters, among others, is monitored to indicate adequate and proper 

combustion is occurring.

Comment: The FWS/NPS suggested that regarding the recovery furnace, lowtemperature oxidation was not considered as a NOX control alternative. It has never 

been used on a recovery furnace, but is commercially available and has been 

successfully applied to, and permitted for, industrial processes (e.g., Minnesota Steel 

PSD permit). It would be ideally suited to the relatively cool exhaust here. EPC should 

show why it is not applicable to its recovery furnace. 

Response: NP has stated that to the best of their knowledge, this technology has not 

been applied to any recovery furnace in the pulp and paper industry. The ability to 

apply low-temperature oxidation technology is likely to be extremely different on a 

recovery furnace than the type of furnace referenced in the comment. Although both 

are furnaces, they are vastly different. 

Comment: The FS, FWS/NPS, and EPA comment that there is no basis for rejecting 

control options for the boilers because “...visibility modeling does not indicate it will 

result in a significant visibility improvement (i.e., at least 0.5 deciviews).” The BART 

guidelines provide no such basis for rejecting control options. 

Response: The DNRE accepts that the information in the SIP document, submitted by 

NP, adequately supports the BART determination. 

Comment: The FS commented that in the BART guidelines EPA states that the 

threshold of perceptibility is 0.5 deciviews and not 1 as proposed by NP. The 

installation of control for one pollutant (NOx) on just one BART subject unit at NP 

improved visibility by 0.4 deciviews. NP thinks this is small, the FS sees it as very large 

in and of itself and when added to other controls at the facility would lead to an even 

more significant improvement in air quality at Seney. 
14

Response: The DNRE accepts that the information in the SIP document, submitted by 

NP, adequately supports the BART determination. 

Comment: All three commenters stated that to be consistent with other BART analyses 

the interest rate and expected equipment life for the low NOx burner (LNB) analysis for 

Boiler No. 8 should be 15 years and 7% versus 10 years and 10%. If this change is 

made the average cost-effectiveness is $2900 per ton. They also questioned what an 

employee needs to do for 0.5 hour per shift, for three 8-hour shifts per day, for an LNB? 

If that cost is removed then the average cost effectiveness is $2,100 per ton and is not 

excessive. 

Response: The DNRE accepts that the information in the SIP document, submitted by 

NP, adequately supports the BART determination. 

Comment: The FWS/NPS commented that NP proposed that no additional controls 

could be justified as BART, based on lack of technical feasibility or cost-effectiveness. 

It was claimed that serious space limitations at Boiler No. 8 would require adding fans 

and a new stack to accommodate several of the BART alternatives. Adding these costs 

to each BART alternative caused all cost estimates to be excessive, except possibly low 

NOX burners (LNB) at $3,600 per ton of NOX removed. The DNRE should confirm that 

lack of space is an issue at Boiler No. 8. 

Response: The DNRE accepts that the information in the SIP, submitted by NP, 

adequately supports the BART determination. 

Comment: Comments from the FS stated that based on current fuel prices (#6 fuel oil 

at $1.5 per gallon and natural gas at $6 per 1000 cubic feet, see: 

www.eia.doe.gov/dnav/) it is actually a cost savings to operate Boiler No. 8 on natural 

gas versus the $482,502 annual cost shown in the BART analysis. 

Response: NP cost figures are based on 2006 prices, and NP states that there is no 

guarantee that the natural gas prices will remain low in the future. The DNRE accepts 

that the information in the SIP document, submitted by NP, adequately supports the 

BART determination. 

Comment: All three commenters stated that the SNCR BART analysis for Boiler No. 9 

(a wood/natural gas fired, 250,000 pound per hour boiler) appears to be flawed. The 

MANE-VU document notes an example, “Installing SNCR to achieve 0.15 lb/MMBtu 

NOx emissions on a 300,000 pound per hour wood boiler: Capital $1.5 million; 

operating $0.1 million/yr.” NP’s total capital cost is $4.4 million and operating cost is 

$1.1 million. This large discrepancy should be explained. NP also again uses an 

expected equipment life of 10 years and an interest rate of 10%, which the commenters 

believe should be 15 years and 7%, respectively. 

Response: The DNRE accepts that the information in the SIP document, submitted by 

NP, adequately supports the BART determination. 

Comment: The FS stated the assumed fuels are important to the BART analysis. Are 

the fuels burned in the No. 9 boiler limited by an enforceable document to only bark and 

natural gas? 
15

Response: Presently only bark and natural gas are being used as fuel for the No. 9 

boiler. However, the limitation for burning wood bark, natural gas, as well as paper core 

is given in the ROP No. MI-ROP-A0884-2008. 

St. Mary’s Cement (SMC) 

Comment: All three commenters disagreed with SMC’s determination that a selective, 

non-catalytic reduction system is technically infeasible and not cost-effective. There 

does not appear to be documentation describing why SMC has insurmountable 

problems operating an SNCR system in winter. Also, four other cement plants are 

proposing SNCR as BART. These are Ash Grove Cement in Montana, CEMEX in 

Colorado, Holcim Cement in Montana, and Lafarge North America in Washington. The 

average cost-effectiveness range of $900-1200 per ton, as reported in the MANE-VU 

document for SNCR, further suggests the cost effectiveness of SNCR. In addition, the 

10% control efficiency that SMC assumed for SNCR appears too low and is among the 

lowest performing in the industry. The Lafarge BART analysis, which is planning to 

install a number of SNCR systems at its plant for year-round operation, for example, 

states the “...expected control effectiveness of SNCR (on the order of 30 to 40 percent 

based on publicly available data).” Other efficiencies are variously reported at 85%, 

80%, 47%, and 25-50%. SMC should consider an examination of its SNCR system 

seeking improvement in its operating efficiency. 

Response: The DNRE accepts that the information in the SIP document, submitted by 

SMC, adequately supports the BART determination. 

Comment: The FS, FWS/NPS, and EPA stated that the cost estimate for the SNCR 

system ($ 7,568 per ton) is too high for SMC. 

a. The MANE-VU document showed an average cost-effectiveness range of 

$900-1200 per ton. This is the same reference document SMC used for their 

sulfur dioxide control costs. Appendix F notes the average cost-effectiveness 

range down to $1,000 per ton. This report had limited data since it was from 

2004. As more SNCR systems have been applied the costs will likely have 

come down. Furthermore, other reported SNCR installation ranging from $498-

$713/ton (Lafarge, MI) to $1400-$2300/ton (Ellis County Texas Study). 

b. It is not clear which facility from Appendix F was used to arrive at a capital cost 

$1.37M, with an additional cost of $400,000 for winterization. The need for the 

winterization cost is unsupported. 

c. They didn’t believe a new SNCR system will need five cleanout events per 

year, so this cost item can be reduced or removed. 

d. The 10-year equipment life assumed is too short. Appendix F assumes 15 

years as does the EPA’s document: Alternative Control Techniques DocumentNOx Emissions from Cement Manufacturing, EPA-453/R-94-004. 

e. The very low 10% control efficiency assumption, a somewhat inflated capital 

cost, a 10-year, rather than15-year, amortization factor, along with an 

excessive assumption for the cost of annual operation, all contribute to the 

unrealistic high cost per ton. 
16

f. SMC claimed that the cold winter climate of Michigan made proper temperature 

control for SNCR difficult. SNCR has been successfully operated without 

significant efficiency impairment in many cold climates. 

g. Higher control efficiency assumptions on a new SNCR along with more realistic 

cost functions may result in a feasible retrofitted installation. 

Response: The DNRE accepts that the information in the SIP document, submitted by 

SMC, adequately supports the BART determination. 

Comment: Comments from the FWS/NPS cite The Portland Cement Association 

report1

 that a relatively inexpensive but effective NOX control technique is a “high 

pressure air injection system” (also called a mixing air system) that can be installed on 

the kiln. Mixing air systems have shown significant emissions reduction up to 48% on 

the 13 kilns operating with this technology. This should have been considered among 

the BART NOX control alternatives. 

Response: The DNRE accepts that the information in the SIP document, submitted by 

SMC, adequately supports the BART determination. 

Comment: The FWS/NPS state the proposed NOX emission limit of 6.5 lb NOX/ton of 

clinker is lenient compared to the 2.8 lb NOX/ton of clinker emission limit for pre-calciner 

kilns and the Lehigh kiln in Iowa that is subject to 2.8 lb NOX/ton of clinker. 

Response: The DNRE accepts that the information in the SIP document, submitted by 

SMC, adequately supports the BART determination. 

Comment: The FWS/NPS comment that the fifth BART factor, namely the visibility 

impact analysis of each BART alternative, was not presented, probably on the 

assumption that the high cost per ton dropped each alternative from consideration. 

After more reasonable costs are determined as discussed above, visibility impact 

analysis should be performed to assess the potential visibility improvement associated 

with each control alternative. Since the maximum impact of this facility on the Seney 

Wilderness Area is a relatively large 5.257 deciviews, this analysis becomes more 

important. 

Response: The DNRE accepts that the information in the SIP document, submitted by 

SMC, adequately supports the BART determination. 

Comment: The FWS/NPS comment regarding SO2 control, wet FGD was considered 

with a cost-effectiveness estimate of $9,258 per ton and was dismissed due to the high 

cost. A wet limestone forced oxidation (LSFO) scrubber system was not considered by 

SMC. These systems demonstrate high removal efficiencies (e.g., 81 to 90%). The 

Lafarge cement plant in Michigan has proposed the LSFO as BART at a reasonable 

cost ($1,087/ton SO2). The LSFO alternative should be considered and the costs 

should be examined.

Response: The DNRE accepts that the information in the SIP document, submitted by 

SMC, adequately supports the BART determination. 

 

1

 “Summary of Control Techniques for Nitrogen Oxide” by Zephyr Environmental Corporation for the 

Portland Cement Association, 2008, p. 2. 
17

Smurfit-Stone Container Corporation 

Comment: The FWS/NPS commented that a permit or other enforceable document 

should be provided to Smurfit-Stone Container Corporation stating that all permit 

limitations for the facility are zero. 

Response: The Company is in the process of bankruptcy. However, it has been 

determined that the permits have not been voided. Therefore Smurfit has been added 

back into this SIP document. 

The DNRE has agreed that controls installed at Smurfit-Stone Container Corporation 

and planned for installation represent BART. If the company comes out of bankruptcy 

or is bought by some other company, a new NSR permit will be required to be submitted 

and approved by DNRE to make the BART controls legally enforceable at that time. 

Tilden Mining Company (TMC) 

Comment: The EPA and FS commented that the only taconite plants in the US are 

located in Minnesota and Michigan. The same company that operates Tilden operates 

facilities in Minnesota. Early on in the regional haze consultations, Michigan agreed to 

mirror what Minnesota did in their SIP with their taconite facilities to ensure consistency. 

When comparing the two SIPs they found omissions in Michigan’s SIP. The DNRE 

should thoroughly review what is contained in Minnesota’s Regional Haze SIP and 

revise the determination for Tilden to make it consistent with Minnesota. 

(http://www.pca.state.mn.us/index.php/air/air-quality-and-pollutants/general-airquality/minnesota-regional-haze-plan.html) 

Response: The DNRE accepts the company’s claim their operations are different 

enough from the facilities in Minnesota to warrant a different approach in the BART 

determination. 

Comment: The EPA and FS suggested that the control technology information in the 

Tilden BART submittal is completely out of date. In April, USS Minntac installed a lowNOx main burner firing solid fuels in its furnace. Extensive CFD work done by a number 

of companies in Minnesota has shown that burner designs that lower the flame 

temperature can reduce NOx formation in taconite furnaces. Low-NOx burners are also 

being designed for a new taconite plant, Essar Steel, to be built near Nashwauk that will 

fire natural gas. Essar was originally permitted to install LoTOx to control NOx and 

mercury. In a separate permitting action for a different taconite facility the MPCA has 

determined that LoTOx is technically and economically feasible. Babcock Power has 

made a proposal to a Minnesota taconite plant to pilot test its RSCR system to 

determine how well it will work. 

Response: The projects and technologies described above were not selected or 

proposed for BART, but rather were proposed primarily as projects to be studied, and 

were agreed to be completed as part of PSD permitting (not BART) or enforcement 

situations. None of the technologies and projects described above have been 

established for BART at taconite plants in Minnesota. 
18

Comment: The EPA and FS suggested that in regards to sulfur dioxide, the MPCA 

determined that the addition of a scrubber at the United Taconite plant that burns 

primarily coal was technically and economically feasible. In doing so, the MPCA had to 

correct the cost figures submitted by the same consultant who submitted Tilden’s BART 

analysis. They saw no evidence presented that would indicate that a similar conclusion 

is not justified for Tilden. 

Response: The DNRE accepts that the information in the SIP, submitted by TMC, 

adequately supports the BART determination. According to TMC, the facility-specific 

circumstances and evaluations completed for Tilden do not warrant further wet scrubber 

evaluations to make a BART determination. TMC’s wet scrubber (absorber) evaluation 

shows costs to be $6,000/ton of sulfur dioxide removed. TMC states that the 

implementation of a wet scrubber (absorber) would have negative environmental effects 

by increasing the sulfur constituent loading in water. 

Comment: The EPA and FS commented that other items included in the Minnesota’s 

Regional Haze SIP that are missing from the Michigan SIP include requirements to 

install NOx and SO2 CEMs by November 2008, and a pilot testing program of potential 

NOx control strategies starting in July 2011. 

a. The FS commented multiple times on Minnesota’s RH SIP that stack testing/ 

PEMS (predictive emission monitoring systems) are not appropriate for these 

sources since the taconite plants will be attempting to find methods to reduce 

emissions and in doing so need real-time emissions information. It should also 

be noted that taconite plants produce NOx emissions on the scale of utilities 

which are required to install CEMs. CEMs have been operated by a number of 

taconite plants for years and no insurmountable operating problems have been 

established. 

b. Tilden is unique among the taconite plants in the US in that it processes 

hematite and magnetite. The oxidation of magnetite produces significant heat 

versus hematite. It is this difference that led the EPA to subcategorize the 

taconite MACT standard and set a different limit for Tilden. It is also this 

difference that should compel Michigan to require CFD modeling, low-NOx 

main burner design, and pilot testing of NOx controls on this line. 

Response: The DNRE accepts that the information in the SIP, submitted by TMC, 

adequately supports the BART determination. 

Comment: The EPA and FS commented that Tilden's revised BART scenario, which 

shows that SO2 alone does not cause visibility impairment to Class I areas, is 

inconsistent with EPA policy and therefore is not an adequate basis for concluding that 

the current Title V permit limits for SO2 emissions of 28,800 lbs per day should be 

considered BART. They also disagreed that Tilden should be allowed to go back and 

model pollutant by pollutant at an individual BART-subject emission unit in an attempt to 

exempt certain pollutants from the unit, as was done for sulfur dioxide at Tilden 

Furnace 1. The EPA memo dated July 19, 2006 from Joseph Paisie that is included in 

New Page’s BART analysis states, “Because of the complexity and nonlinear nature of 

atmospheric chemistry and chemical transformation among pollutants, the EPA does 

not generally recommend that CALPUFF be used on a pollutant specific basis to 
19

determine whether a source meets the threshold test for BART.” Also it goes on to 

state, “Because the task of predicting the impacts of PM on visibility is a relatively 

straight-forward exercise, unlike predicting the impacts of SO2 and NOx, we would 

recommend the use of CALPUFF on a pollutant specific basis to model only the impact 

of PM emissions on visibility.” 

Response: There appears to be a misunderstanding of the modeling runs that were 

completed as part of the Tilden BART analysis. The Tilden modeling is consistent with 

the EPA memo cited. Multi-pollutant CALPUFF runs were performed to evaluate 

visibility impacts, not single pollutant runs as implied in the comments. Two baseline 

scenarios were evaluated reflecting the range of fuels at Tilden, natural gas (high NOx 

emissions, low SO2 emissions) and coal (low NOx emissions, high SO2 emissions). 

Further, the significantly lower impact of the coal-fueled run was only one factor that 

contributed to the BART determination for SO2. 

Comment: The FS disagreed with the assertion in Tilden’s BART analysis that, “The 

CALPUFF model is conservative, resulting in an over prediction of impacts. This 

modeled high impact from the BART eligible sources is 0.72 dV, which is below 

perceptible levels of one to two dV. Real impacts to the Class I areas from Tilden are 

expected to be even less than these modeled impacts.” The perceptibility threshold is 

not 1 to 2 deciviews it is 0.5 deciview. Also, the EPA goes into detail regarding a 

number of reasons why the CALPUFF modeling analysis may not be conservative (see 

FR Vol. 70, No. 128 p. 39119). 

Response: According to the Winter/April 1993 IMPROVE newsletter (IMPROVE Vol. 2 

No. 1), “...a 1 to 2 dV difference corresponds to a small visibility perceptible change in 

scene appearance where the assumptions used to develop the dV scale are met.” The 

BART guidelines identify the 0.5 dV as a threshold for requiring a BART determination. 

The language in question does not affect the conclusion of the analysis, that Tilden 

impacts are very small. Given the emissions assumptions (operating at maximum rates 

8,760 hours per year), “The real impacts to the Class I areas from Tilden are expected 

to be even less than these modeled impacts...” still applies even without the other 

elements of the quote. 

(The following 3 pages contain the DNRE notice of the second public comment 

period which was held in October 2008 as published in DNRE’s bi-weekly 

Calendar of events.) 
20
21
22
23

General Summary of Comments from the 2008 Public Comment Period

and DNRE Responses

Comment: Several comments addressed issues with BART for non-EGUs, such as: 

• being incomplete; 

• adjusting RPGs when BART is complete; 

• some clarifications in the current SIP for Q/d calculations; 

• a specific date when BART determinations will be made. 

Response: The BART portion of the Regional Haze SIP will not be completed until fall 

of 2009. When it is completed, the DNRE will remodel using the BART emission 

reductions to see how the Reasonable Progress Goals are affected. The SIP will also 

include additional details about the Q/d calculations. 

Comment: Several comments addressed issues with BART for EGUs such as: 

• a specific date when BART determinations will be made; 

• BART for particulate emissions; 

• SIP relies on CAIR to satisfy BART for EGUs. 

Response: With the possible CAIR vacatur, there is a great deal of uncertainty in 

dealing with EGUs. EGUs have been informed that, should CAIR be vacated they will 

be required to submit BART analyses. The SIP and all the modeling based on CAIR 

has been proceeding for several years. To completely redo the whole SIP and 

modeling based on a variety of possible EGU scenarios is not reasonable. However, 

the DNRE will be discussing control options with the EGUs, including possible BART 

controls, over the next few months. The DNRE has determined that primary 

particulates from EGUs are not significant and this is explained in greater detail in the 

SIP document. 

Comment: Comments from the FS recommended including details on current controls 

on EGUs, controls being installed, by what date and by what level of emissions 

reductions are expected. 

Response: The DNRE is working on assembling this data, considering uncertainty with 

the CAIR rule. The DNRE will include this in the BART submittal in 2009. 

Comment: Several comments indicated that the DNRE did not respond to the EC/R 

report that indicated cost effective controls for EGUs and other non-EGUs. 

Response: The DNRE addressed this issue in Part 10.5.2 of the SIP document. 

Comment: The EPA suggested that the DNRE should consider lowering the state to 

state contribution threshold to below 5%. 

Response: The DNRE disagrees. As explained in Appendix 1A to this SIP, the back 

trajectory and modeling results showed that states contributing 2% (or more) make up 

about 90-95% of total light extinction, whereas states contributing 5% (or more) make 

up only about 75-80% of total light extinction. Since this is the first planning period for 

regional haze, we believe that focusing on a 5% grouping of states is adequate. In 
24

future years this will be re-evaluated and a larger impacting group of states may be 

appropriate. 

Comment: Comments from the FS recommended including emissions summaries for 

2012 and 2018 as well as 2005. 

Response: The DNRE agrees; however, modeling was only done for 2009 and 2018. 

Therefore emission summaries for 2009 and 2018 were included in the SIP. 

Comment: Comments from the FS suggests some clarifications as well as indicating 

missing appendices. 

Response: The DNRE agrees with and has added these clarifications and included the 

missing appendices. 

Comment: Comments from the FLMs suggest that Michigan’s SIP assumes RPGs are 

met even though the 20% best days at Seney are getting worse. 

Response: The DNRE believes that this should not be an issue of concern; there are 

several reasons that could explain this including modeling or growth factors. More 

detail is included in the SIP. 

(The following 3 pages contain the DNRE notice of the first public comment 

period which was held in November 2007 as published in the DNRE’s biweekly 

Calendar of Events.) 
25
26
27
28

General Summary of Comments from the 2007 Public Comment Period

and DNRE Responses

Comment: Comments were received from several groups that supported DNRE’s 

CAIR=BART. 

Response: This comment may no longer pertain due to the possible vacatur of CAIR. 

Comment: Two comments did not support discontinuing either Class I monitors if 

federal funding was not met. 

Response: The DNRE will look at other options if federal funding is cut. 

Comment: DTE Energy encouraged the use of later year base year emissions 

inventories (2005). 

Response: The DNRE agrees and has made appropriate updates. 

Comment: Consumers Energy supports the DNRE’s Regional Haze SIP in light of the 

states current economy, the actions being taken by the 1997 PM2.5 NAACS, and the 

fundamental difference of Regional Haze to other criteria pollutants. 

Response: The DNRE appreciates the support. 

Comment: Consumers Energy suggests DNRE use the glide path diagrams in the 

body of the SIP submittal. 

Response: The DNRE agrees and has made appropriate updates. 

Comment: WE Energies supported DNRE’s Reasonable Progress approach and 

provided several references to EPA documents that support our approach. 

Response: The DNRE appreciates the support. 

Comment: The Little Traverse Bay Bands of Odawa Indians (Tribe) suggests that 

Michigan should have clearly defined milestones established and fulfilled for the next 

five decades (to 2064). 

Response: The DNRE has had difficulty predicting and setting milestones for the next 

five and ten years due to many factors beyond our control. The example, RPG in the 

SIP document shows possible milestones for the next five decades, but clearly this has 

little meaning in light of the many unknowns over that period of time. 

Comment: The Tribe wanted DNRE to discuss the issues with the location of the Isle 

Royale monitor. 

Response: This monitor is located within the boundaries of EPA regulations, but the 

DNRE did include some discussion of this issue in the SIP document. 
29

FLM Comments 

Comment: Several areas in the SIP needed more details or clarification such as: 

• Monitoring 

• Identifying sources with Q/d and PSAT (AOI) 

• No reasonable progress goals for the 20% cleanest days 

• Values used to set reasonable progress goals 

• Plans for future consultation 

• Basis for emissions reductions 

• Information analyzed in periodic reports 

• Determination of adequacy of the plan 

• Contingency measures 

• Emissions inventory 

• Information on modeling by MRPO 

• Wildland fires and smoke management plans 

Response: The DNRE has made these corrections/clarifications. 

Comment: The values for natural background conditions were incorrect. 

Response: The DNRE has made these corrections. 

Comment: Absence of information on BART analysis. 

Response: The DNRE has not completed its BART analyses, but will provide the 

FLMs a 60-day comment period when BART analyses are complete. Furthermore with 

the pending vacatur of CAIR, DNRE is uncertain of the requirements for EGUs, since 

DNRE originally determined that CAIR=BART. 

Comment: Non-health based terminology is problematic. 

Response: The Class I areas in Michigan are located in some of the cleanest areas of 

the state with annual average PM2.5 of 5 ug/m3

. This is below the 15 ug/m3 NAAQS for 

PM2.5, which the EPA considers safe. Therefore, reducing haze in the Class I areas is 

mainly to protect visibility, as the Regional Haze Rule in 40 CFR Part 51, II, states, 

“Congress adopted the visibility provisions in the CAA to protect visibility in these ‘areas 

of great scenic importance.” 

The same particles that impact haze have health effects and are of greatest concern in 

PM2.5 nonattainment areas. The Haze program is a welfare-based program, not healthbased, which is the point the DNRE was making in the earlier version of the SIP 

document. However, the CAA does not suggest that visibility is less important that 

other parts of the CAA. Therefore, the DNRE has removed any such language from the 

SIP. 
Appendix 3A 

 Midwest Regional Planning Organization, 

Principles for Regional Planning
March 9, 2001

1

Midwest Regional Planning Organization

PRINCIPLES FOR REGIONAL PLANNING

The purpose of this paper is to outline the Midwest Regional Planning Organization s

principles for regional planning to address regional haze.

Background

In 1999, the United States Environmental Protection Agency (USEPA) promulgated

regional haze regulations that, among other things, require all states to develop regional

haze rules to establish goals and emission reduction strategies for improving visibility

due to regional haze in the 156 national park and wilderness areas throughout the

United States designated as mandatory Federal Class I areas. USEPA s regional haze

regulations allow for, and encourage through deferment of deadlines, a coordinated

approach to addressing regional haze issues. As part of the implementation of the

regional haze regulations, USEPA has provided grant funds for five regional planning

organizations (RPOs) to facilitate their efforts to assess visibility impairment in the

region. Ohio has been included for this purpose with the States of Illinois, Indiana,

Michigan, and Wisconsin in the Midwest RPO.

Purpose

The Midwest RPO is a non-regulatory entity whose purpose is to provide technical

assessments for and assistance to its members on problems of air quality, and provide

a forum for its members to discuss air quality issues. In particular, the Midwest RPO

shall assess visibility impairment due to regional haze in the mandatory Federal Class I

areas located inside the borders of the States of Illinois, Indiana, Michigan, Ohio, and

Wisconsin, and the impact of emissions from the five states (including tribal lands in the

five states) on visibility impairment due to regional haze in the mandatory Federal Class

I areas located outside the borders of the five states.

Roles and Responsibilities

The regional planning process will include states, tribes, Federal Land Managers and

other Federal agencies, such as USEPA, and other interested stakeholders, including

citizen groups and industry.

The states have the primary regulatory responsibility and authority under the regional

haze regulations. Specifically, pursuant to 40 CFR Part 51, Subpart P, section 51.300,

states are required to ...develop programs to assure reasonable progress toward

meeting the national goal of preventing any future, and remedying any existing,

impairment of visibility in mandatory Class I Federal areas which impairment results
March 9, 2001

2

from manmade air pollution... . As noted in the preamble to the regional haze

regulations, states are required to ...develop SIP revisions to address regional haze, to

update the SIP every 10 years, and to continue to evaluate progress toward the national

visibility goal.  To facilitate the interaction of the states in meeting their regulatory

obligations, the five states entered into a Memorandum of Agreement on October 26,

2000 ( Memorandum of Agreement for the Midwest Regional Planning Organization to

Address Regional Haze ).

In the preamble to the regional haze regulations, USEPA noted that tribal participation

can help provide emissions inventory information to better understand the importance of

sources in Indian country to regional visibility impairment, and provide a forum for tribal

participants to alert RPO s to air quality concerns in Indian country. At this time, tribes

in the Midwest RPO states have no regulatory responsibility under the regional haze

regulations. Nevertheless, tribes shall retain a special consultation role in the regional

planning process, and shall participate at the Midwest RPO policy, planning, and

technical levels.

The Federal Government, including Federal Land Managers (FLMs) and USEPA,

should be involved in the regional planning process. As custodians of the national parks

and wilderness areas and as a source of air pollution (e.g., prescribed burns) in and

around national parks and wilderness areas, the FLMs need to participate in the

regional planning process. Furthermore, the regional haze regulations require states to

consult with FLMs before adopting and submitting their regional haze SIPs. Thus,

FLMs and USEPA will have a special consultation role in the regional planning process

and shall participate at the Midwest RPO policy, planning, and technical levels.

The Midwest RPO will attempt to operate on a consensus approach on technical and

policy matters. While the states have the primary regulatory responsibility and authority,

tribes (and appropriate Federal agencies) will be involved in the decision-making

process.

Stakeholders should be involved in both an advisory role and on technical workgroups.

All workgroup members (i.e., states, tribes, USEPA, FLMs., and stakeholders) must be

active and constructive participants, and agree to share technical information. Casual

observers are discouraged from joining the technical workgroups. 

Also, the Midwest RPO recognizes the need for interregional coordination on a wide

range of regional haze and visibility issues. To that end, the Midwest RPO will work

cooperatively with other RPOs on administrative and technical issues.
March 9, 2001

3

Organizational Structure

The Midwest RPO will be organized as follows (see attached figure):

Policy Steering Committee - The Policy Steering Committee will consist of the

Environmental Directors of the member states of the Midwest RPO, tribal

representatives, Federal Land Managers, and the Regional Administrator of USEPA,

Region 5 (or his designee). The Policy Steering Committee shall provide the overall

policy direction for the regional planning effort, and shall serve as the forum for the

resolution of disputes. The Policy Steering Committee will meet as appropriate to

oversee the progress of the effort.

Technical Steering Committee - The Technical Steering Committee will consist of the

Directors of the Air Quality offices of the member states of the Midwest RPO, tribal

representatives, Federal Land Managers, and the Director of the Air and Radiation

Division of USEPA, Region 5. The Technical Steering Committee shall be responsible

for the management of the regional planning effort, and shall meet as necessary to

carry out these duties.

Project Team - Personnel designated by the Directors of the Air Quality offices of the

member states of the Midwest RPO and by the tribal representatives shall organize a

Project Team to carry out the directions of the Technical Steering Committee and to

guide the development of the regional planning effort. In addition, the USEPA, U.S.

National Park Service, U.S. Forest Service, and U.S. Fish and Wildlife Service shall

designate representatives to participate on the Project Team. The states and tribes will

make every reasonable effort to ensure that the designated representatives receive

support for full participation in the regional planning process. The Project Team shall

prepare a long-range strategy of the regional planning process, as well as detailed

annual work plans. The Project Team will meet on a regular basis and may form

appropriate technical workgroups as necessary to address specific concerns (e.g.,

monitoring, emissions, data analysis, modeling, and public outreach).

LADCO - Subject to the availability of funding, the professional staff of LADCO shall be

available to work on the regional planning effort. LADCO staff shall support the

activities of the Policy Steering Committee, Technical Steering Committee, and the

Project Team.

Advisory Committee - The Advisory Committee will consist of representatives from

citizen groups, industry, academia, and local government located within the five states. 

These representatives are expected to provide a range of perspectives which need to

heard from in the regional planning process. Each state will designate at least four

representatives to serve on the Advisory Committee. The Advisory Committee will

meet on a regular basis.
March 9, 2001

4

Travel Policy

To promote the participation of states and tribes in the regional planning process, grant

funds can be used to pay for travel for state and tribal representatives to attend Midwest

RPO and national RPO meetings. Reimbursable expenses include costs for

transportation, lodging, and meals. (Note, it may be necessary to limit the number of

representatives from each state or tribe receiving reimbursement for a given meeting.)

Scope of Work

The regional planning process is expected to consist of three phases:

Phase I: Organization and Coordination Phase

This phase will take place during the first two years. The objective

of this phase is to develop a framework for regional planning.

Phase II: Technical Assessment Phase

This phase is expected to take place over the first five years or so. 

Additional details will be provided in the work plans provided with

each year s grant application. The objectives of this phase include:

(1) understanding current pollution levels; (2) identifying the

principal contributing sources; (3) determining which states or areas

contribute to another state s problem, and (4) estimating the impact

of future strategies on air quality, costs, and other factors.

Phase III: Strategy Development, Adoption, and Implementation

This phase will take place after the technical assessment phase is

completed and will be addressed in a future work plan. The

objectives of this phase include: (1) reaching consensus about the

regional strategies needed to make reasonable progress  toward

the national visibility goal in Class I areas, and (2) adopting and

implementing SIPs which reflect the regional strategy.
March 9, 2001

5
Appendix 3B 

Regional Haze in the Upper Midwest: 

Summary of Technical Information 
Regional Haze in the Upper Midwest: 

Summary of Technical Information

Voyageurs National Park

Photo Courtesy of Chris Holbeck,

Environmental Planning and Partnerships Specialist, 

Voyageurs National Park

Version 2.2

February 22, 2008

 i
ii

Scope of Document

This document provides a summary of available technical information about regional haze and 

visibility impairment in the four northern Class I areas: Boundary Waters Canoe Area 

Wilderness, Voyageurs National Park, Isle Royale National Park, and Seney Wilderness Area. 

This information includes a conceptual model of haze, the technical basis for visibility analysis, 

and the effectiveness of control measures in improving visibility. The document represents the 

technical information agreed to by the responsible states and satisfies, in part, the consultation 

requirements of the Regional Haze Rule. The document does not address policy issues and 

strategies necessary to deal with regional haze. States can use this technical information to 

highlight the relevant issues for their state policymakers. 
iii

Executive Summary

The States of Michigan and Minnesota,

along with representatives of other states, 

tribal governments, and federal

agencies1, are working to address

visibility impairment due to regional haze 

in four northern Class I areas: Boundary 

Waters Canoe Area Wilderness,

Voyageurs National Park, Isle Royale

National Park, and Seney Wilderness

Area. Pursuant to the Clean Air Act,

states are required to make reasonable

progress toward meeting a national goal

of natural conditions (i.e., visibility levels 

in the absence of manmade air pollution).

 

 Class I areas in Michigan and Minnesota2

Based on a review of technical information, several key findings should be noted:

• The chemical species which affect visibility impairment include ammonium sulfate and, 

to a lesser degree, ammonium nitrate and organic carbon.

• The pollutants and source sectors which contribute the most to visibility impairment 

include SO2 emissions from electrical generating units (EGUs) and certain non-EGUs, 

which lead to sulfate formation, and NOx emissions from a variety of source types (e.g., 

motor vehicles), which lead to nitrate formation. Ammonia emissions from livestock 

waste and fertilizer applications are also important, especially for nitrate formation. 

(Organic carbon concentrations are thought to be mostly secondary organic aerosols of 

biogenic origin and, on an occasional episodic basis, from fire activity.)

• The source regions which contribute the most to visibility impairment are the States of 

Michigan, Minnesota, and Wisconsin. Other nearby states, including Illinois, Indiana, 

Iowa, Missouri, and North Dakota, also contribute to visibility impairment.

 

1

 Representatives from the following entities are participating in the northern states Class I area 

consultation process: States of Minnesota, Michigan, Wisconsin, North Dakota, Iowa, Missouri, Illinois, 

and Indiana; Ontario Ministry of Environment; Mille Lacs, Fond du Lac, Grand Portage, and Leech Lake 

Tribes; and U.S. Forest Service, U.S. National Park Service, and U.S. EPA.

2

 Although Rainbow Lake in northern Wisconsin is also a Class I area, the visibility rule does not apply 

because the Federal Land Manager determined that visibility in is not an air quality related value there.
iv

• Current (baseline) visibility levels are well above natural conditions (see, for example, 

picture below for Boundary Waters Canoe Area).

 

Boundary Waters Canoe Area – current visibility conditions on 20% worst days (left side)

and the natural conditions goal (right side)

• Projected near-term visibility conditions based on existing (“on the books”) controls are

close to or above the uniform rate of visibility improvement line (see figure below). The 

regional haze rule calls for Class I areas to meet natural visibility conditions by the year 

2064, with an initial implementation period extending to the year 2018. To determine 

whether the model-projected 2018 values (based on existing controls) represent 

reasonable progress, states are required to consider four factors (i.e., costs of 

compliance, time necessary for compliance, energy and non-air quality environmental 

impacts, and remaining useful life).
v

10

15

20

25

2004 2010 2020 2030 2040 2050 2060 2064

10

15

20

25

2004 2010 2020 2030 2040 2050 2060 2064

Projected future year visibility levels for 20% worst visibility days in Isle Royale National 

Park (top) and Boundary Waters Canoe Area (bottom) based on existing controls

Note: symbols represent results of four modeling analyses: LADCO 2005 base year -

circle, LADCO 2002 base year – square, MPCA 2002 base year – diamond, and CENRAP 

2002 base year - triangle

• The same particles (sulfates, nitrates, organic carbon, smoke, and soil dust) which affect 

visibility, are linked to serious health effects (e.g., National Ambient Air Quality 

Standards for PM2.5) and environmental effects (e.g., ecosystem damage). Thus, actions 

to reduce levels of visibility-impairing pollutants will benefit public health and reduce 

certain adverse effects to the environment. 
vi

Table of Contents

 Title Page

Scope of Document ii

Executive Summary iii

Section 1. Regulatory Requirements 1

Section 2. Technical Questions 2

1. Conceptual model of haze 2

2. Technical basis for visibility-related analyses 6

3. Evaluation of control measure effectiveness 9

Section 3. References 23

Appendix I. Contribution Assessment for Northern Class I Areas 24
1

Section 1

Regulatory Requirements

Section 169A of the Clean Air Act sets as a national goal “the prevention of any future and the 

remedying of any existing, impairment of visibility in mandatory Class I Federal areas which 

implementation results from manmade air pollution.”

Section 169A requires states to “make reasonable progress toward meeting the national goal.” 

In determining reasonable progress, states shall consider four factors:

• costs of compliance

• time necessary for compliance

• energy and non-air quality environmental impacts of compliance

• remaining useful life of any existing source subject to such requirements

On July 1, 1999, EPA adopted a regional haze rule to implement the provisions of section 169A 

by establishing a program to address regional haze visibility impairment (USEPA, 1999). 

Pursuant to the regional haze rule, the determination of reasonable progress shall also 

consider:

• uniform rate of visibility improvement (needed to attain natural visibility conditions 

by 2064) – i.e., “the line” (see, for example, Figure 5)

EPA’s regional haze rule requires states to set reasonable progress goals for each Class I area 

which provide for an improvement in visibility for the most impaired days (i.e., 20% worst 

visibility days) and ensure no degradation in visibility for the least impaired days (i.e., 20% best 

visibility days).

The regional haze rule also requires states to develop a long-term strategy for regional haze 

which covers an initial implementation period extending to the year 2018. The haze State 

Implementation Plan (SIP) was due to EPA in December 2007. States must also submit a 

report to EPA every 5 years evaluating progress towards the reasonable progress goal, and 

submit a SIP revision by July 31, 2018 and every ten years thereafter.
2

Section 2

Technical Questions

1. Conceptual model of haze

a. What are the chemical constituents that cause visibility impairment in the northern Class 

I areas?

The most important chemical species are ammonium sulfate, ammonium nitrate, and 

organic carbon. The contribution of these species on the 20% best and 20% worst 

visibility days (based on 2000 – 2004 data) is provided in Figure 1. For the 20% worst 

visibility days, the contributions are: sulfate = 35-55%, nitrate = 25-30%, and organic 

carbon = 12-22%. It should also be noted that sulfate and nitrate contribute more to light 

extinction than to PM2.5 mass because of their hygroscopic properties.

 20% Best Days 20% Worst Days 

Figure 1. Chemical composition of light extinction for 20% best visibility days (left) and 20% 

worst visibility days (right) in terms of Mm-1

b. Which geographic areas and sources contribute to regional haze in the northern Class I

areas?

Air quality data analyses and dispersion modeling were conducted to provide information 

on source region and source sector contributions to regional haze in the northern Class I

areas (see Appendix I: Contribution Assessment for Northern Class I Areas). Based on 

this information, the most important contributing states are Michigan, Minnesota, and 

Wisconsin, as well as Illinois, Indiana, Iowa, Missouri, and North Dakota. For example, 

Figure 2 presents the results of composite back trajectories for light extinction on the 

20% worst visibility days. The orange areas are where the air is most likely to come 

from, and the green areas are where the air is least likely to come from. As can be 

seen, poor visibility days are generally associated with transport from regions located to 

the south of these Class I areas.

0

20

40

60

80

100

120

VOYA BOWA ISRO Seney VOYA BOWA ISRO Seney

sea salt

soil

elem. carbon

coarse mass

organic carbon

nitrate

sulfate
3

Figure 2. Composite back trajectories for light extinction

Note: orange is where air is most likely to come from, green is where air is least likely to come from

The most important contributing pollutants and source sectors are SO2 emissions from 

electrical generating units (EGUs) and certain non-EGUs, which lead to sulfate 

formation, and NOx emissions from a variety of source types (e.g., motor vehicles), 

which lead to nitrate formation. Ammonia emissions from livestock waste and fertilizer 

applications are also important, especially for nitrate formation. (As discussed below, 

organic carbon concentrations are thought to be mostly secondary organic aerosols of 

biogenic origin and, on an occasional episodic basis, from fire activity.)

c. What are the meteorological conditions that are associated with good visibility and poor 

visibility in the northern Class I areas? Is there a seasonal effect to visibility impairment 

in those areas?

As noted above, bad air days are generally associated with southerly transport (see 

Figure 2). Examination of the 20% worst visibility days for the northern Class I areas 

shows that these days occur throughout the year, suggesting a range of other 

meteorological parameters (see, for example, Boundary Waters data in Figure 3). This 

figure, as well as Figure 4 (which presents the monthly average light extinction values 

based on all sampling days), also show that sulfate and organic carbon concentrations 

are higher in the summer, and nitrate concentrations are higher in the winter, suggesting 

the importance of different sources and meteorological conditions at different times of 

the year.
4

Figure 3. Daily light extinction values for 20% worst days at Boundary Waters (2000 – 2004)
5

 

Figure 4. Monthly average light extinction values for northern Class I areas
6

2. Technical basis for visibility-related analyses

a. What are the present visibility conditions and how were the values calculated? How 

were the 20% worst and 20% best days determined?

Initially, the baseline (2000 – 2004) visibility condition values were derived using the 

average for the 20% worst and 20% best days for each year, as reported on the VIEWS 

website: http://vista.cira.colostate.edu/views/Web/IMPROVE/SummaryData.aspx . 

These values were calculated using the original IMPROVE equation for reconstructed 

light extinction.

Three changes were made to the baseline calculations to produce a new set of values. 

First, the reconstructed light extinction equation was revised by the IMPROVE Steering 

Committee in 2005 (DeBell, et al, 2006). The new IMPROVE equation was used to 

calculate updated baseline values. 

Second, due to sampler problems, the 2002-2004 data for Boundary Waters were 

invalid for certain chemical species. (Note, sulfate and nitrate data at Boundary Waters 

were valid.) A “substituted” data set was developed by using values from Voyageurs for 

the invalid species.

Third, LADCO identified a number of days during 2000-2004 where data capture at the 

Class I monitors was incomplete (e.g., coarse mass and soil were missing species)

(Kenski, 2007). The missing data cause the days to be excluded from the baseline 

calculations. However, the light extinction due to the remaining measured species is 

significant (i.e., above the 80th percentile). It makes sense to include these days in the 

baseline calculations, because they are largely dominated by anthropogenic sources. 

(Only one of these days is driven by high organic carbon, which might indicate nonanthropogenic aerosol from wildfires.) As seen in Table 1, inclusion of these days in the 

baseline calculation results in a small, but measurable, effect on the baseline values 

(i.e., values increase from 0.2 to 0.8 dv).

Table 1. Average of 20% Worst Days, With and Without Missing Data Days

Average 

Worst Day 

DV, per 

RHR

Average Worst Day 

DV,

with Missing Data 

Days

Difference

BOWA 19.59 19.86 0.27

ISLE 20.74 21.59 0.85

SENE 24.16 24.38 0.22

VOYA 19.27 19.48 0.21

A summary of the initial and updated baseline values for the Class I areas in northern 

Michigan and northern Minnesota are presented in Table 2. The updated baseline 

values reflect the most current, complete understanding of visibility impairing effects 

and, as such, will be used for SIP planning purposes.
7

b. What are natural conditions and how were the values calculated?

Initially, the values for the natural conditions goal for each Class I area were taken 

directly from USEPA guidance (USEPA, 2003). These values were calculated using the 

original IMPROVE equation. This equation was revised by the IMPROVE Steering 

Committee in 2005 (DeBell, et al, 2006), and the new IMPROVE equation was used to 

calculate updated natural conditions values. The updated values are reported on the 

VIEWS website (http://vista.cira.colostate.edu/views/).

.

A summary of the initial and updated natural conditions values are presented in Table 2. 

The updated natural conditions values (based on the new IMPROVE equation) will be 

used for SIP purposes. The states must establish goals that provide for reasonable 

progress towards achieving natural conditions. The reasonable progress goals must 

provide for an improvement in visibility for the 20% worst days, and no degradation in 

visibility for the 20% best days.
8

Table 2. Summary of Visibility Metrics for Northern Class I Areas in Terms of Deciviews

Old IMPROVE Equation (Cite: VIEWS, November 2005)

20% Worst Days Baseline 2018 Natural

2000 2001 2002 2003 2004 Value URI Value Conditions

Voyageurs 18.50 18.00 19.00 19.20 17.60 18.46 16.74 11.09

BWCA 19.85 19.99 19.68 19.73 17.65 19.38 17.47 11.21

Isle Royale 20.00 22.00 20.80 19.50 19.10 20.28 18.17 11.22

Seney 22.60 24.90 24.00 23.80 22.60 23.58 20.73 11.37

 

20% Best Days Baseline Natural

2000 2001 2002 2003 2004 Value Conditions

Voyageurs 6.30 6.20 6.70 7.00 5.40 6.32 3.41

BWCA 5.90 6.52 6.93 6.67 5.61 6.33 3.53

Isle Royale 5.70 6.40 6.40 6.30 5.30 6.02 3.54

Seney 5.80 6.10 7.30 7.50 5.80 6.50 3.69

 

New IMPROVE Equation (Cite: VIEWS, March 2006)

20% Worst Days Baseline 2018 Natural

2000 2001 2002 2003 2004 Value URI Value Conditions

Voyageurs 19.55 18.57 20.14 20.25 18.87 19.48 17.74 12.05

BWCA 20.20 20.04 20.76 20.13 18.18 19.86 17.94 11.61

Isle Royale 20.53 23.07 21.97 22.35 20.02 21.59 19.43 12.36

Seney 22.94 25.91 25.38 24.48 23.15 24.37 21.64 12.65

 

20% Best Days Baseline Natural

2000 2001 2002 2003 2004 Value Conditions

Voyageurs 7.01 7.12 7.53 7.68 6.37 7.14 4.26

BWCA 6.00 6.92 7.00 6.45 5.77 6.43 3.42

Isle Royale 6.49 7.16 7.07 6.99 6.12 6.77 3.72

Seney 6.50 6.78 7.82 8.01 6.58 7.14 3.73

 

Notes: (1) BWCA values for 2002 - 2004 reflect "substituted" data.

 (2) New IMPROVE equation values include Kenksi, 2007 adjustment for missing days
9

3. Evaluation of control measure effectiveness

a. What tools are available to evaluate the effectiveness of emission reductions?

USEPA’s modeling guidelines (USEPA, 2007) recommend using air quality models, 

along with complementary analyses of ambient monitoring, emissions, and 

meteorological data to determine whether a given control strategy meets the air quality 

goal. CAMx was used by LADCO (LADCO, 2006; LADCO, 2007) and the Minnesota 

Pollution Control Agency (MPCA, 2008), while both CAMx and CMAQ were used by 

CENRAP (Environ, 2007). 

Figure 5 shows the spatial coverage of the modeling domains used by CENRAP, 

LADCO, and MPCA. CENRAP used the National Inter-RPO domain with 36 km grid 

spacing, LADCO used a subset of the National Inter-RPO domain (referred to as the 

“4rpos” domain) with 36 km spacing, and MPCA used the “4rpos” domain with 36 km 

spacing and a Minnesota domain with 12 km spacing. The purpose of the Minnesota 12 

km domain was to address local source impacts on the northern Class I areas.

National Inter-RPO 36km Domain

MRPO "4rpos" 36km Domain

Minnesota 12km Nested Domain

Figure 5. Modeling domains for CENRAP (National Inter-RPO 36km Domain), LADCO (MRPO 

“4rpos” 36km Domain), and MPCA (Minnesota 12km Nested Domain)
10

Two base years were used in the modeling: 2002 and 2005. USEPA’s modeling 

guidelines recommend using 2002 as the baseline inventory year, but also allow for use 

of an alternative baseline inventory year, especially a more recent year (USEPA, 2007). 

LADCO initially conducted modeling with a 2002 base year (i.e., Base K4/Round 4

modeling). CENRAP and MPCA also used a 2002 base year in their modeling. The 

three sets of 2002 base year analyses are generally consistent, with differences 

attributable to modeling domain (i.e., CENRAP’s domain is larger), baseline values (i.e., 

CENRAP’s data do not reflect all the adjustments noted above), and emissions 

inventory data (e.g., different base year emission estimates, and growth and control 

factors). LADCO subsequently decided to conduct modeling with a 2005 base year (i.e., 

Base M/Round 5). Examination of multiple base years provides for a more complete 

technical assessment. The results from all four modeling analyses are discussed here.

The models were shown to provide reasonable estimates for sulfates and nitrates (see, 

for example, Figure 6), and can, therefore, be used to examine sulfate and nitrate

control strategies. The models are less reliable for organic carbon – note, the large 

underestimation in monthly average organic carbon concentrations in the plots below. 

To compensate for model uncertainty and to provide a more robust analysis, additional 

information should be considered as part of a weight-of-evidence demonstration.

Figure 6. Results of LADCO’s model performance for PM2.5 – monthly average mean bias and 

annual fractional bias for Base M – 2005 base year (left side) and Base K – 2002 base year

(right side)

Base M Base K
11

b. How effective will existing (“on the books”) controls be in improving visibility in the 

northern Class I areas?

Air quality modeling conducted by LADCO, MPCA, and CENRAP assessed future year 

visibility levels based on the following existing (“on the books”) controls:

On-Highway Mobile Sources

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

diesel fuel

• Inspection/Maintenance programs (nonattainment areas)

• Reformulated gasoline (nonattainment areas)

Off-Highway Mobile Sources

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

plus the evaporative Large Spark Ignition and Recreational Vehicle standards

• Heavy-duty diesel (2007) engine standard/Low sulfur fuel

• Federal railroad/locomotive standards

• Federal commercial marine vessel engine standards

Area Sources (Base M only)

• Consumer solvents

• AIM coatings

• Aerosol coatings

• Portable fuel containers

Power Plants

• Title IV (Phases I and II)

• NOx SIP Call

• Clean Air Interstate Rule

• Clean Air Mercury Rule

Other Point Sources

• MACT standards: VOC 2-, 4-, 7-, and 10-year MACT standards, combustion turbine, and 

industrial boiler/process heater/RICE MACT

• State NOx RACT rules (Illinois and Wisconsin)

The model results are provided in Table 3 and Figure 7. For the 20% worst days, “on 

the books” controls are expected to improve visibility levels, but will still result in levels 

above the uniform rate of visibility improvement line (i.e., glide path) in the Michigan and, 

perhaps, Minnesota Class I areas.

In comparing LADCO’s Round 4 and Round 5 results for the 20% worst days, one 

noticeable difference is that the Minnesota Class I areas are much closer to the glide 

path in the newer Round 5 modeling. This difference is due to more SO2 emission 

reduction in nearby states in the Round 5 modeling (i.e., -28% v. -41% - see Table 4), 

which reflects EPA’s latest (IPM3.0) EGU projections and, perhaps, differences in 

meteorology between 2002 and 2005.

For the 20% best days, “on the books” controls are expected to produce little change in 

visibility levels, but may result in a slight degradation in a few locations, including Seney. 

A preliminary review of source contributions and associated future year growth and 

control assumptions, however, suggests that these visibility levels may be overestimated 

(e.g., future year Canadian emissions do not reflect planned emission reductions).
12

Table 3. Modeling Results for Northern Class I Areas

Worst 

20% 2018 2018

 Site Model BY Baseline URI OTB

BOWA1 CENRAP 2002 19.58 17.72 18.30

MPCA 2002 19.9 17.9 18.7

LADCO 2002 19.86 17.70 18.94

LADCO 2005 19.86 17.94 17.94

 

VOYA2 CENRAP 2002 19.27 17.58 18.37

MPCA 2002 19.9 17.8 19.0

LADCO 2002 19.48 17.56 19.18

LADCO 2005 19.48 17.74 17.63

 

SENE1 CENRAP 2002 

MPCA 2002 

LADCO 2002 24.38 21.35 22.38

LADCO 2005 24.38 21.64 22.59

 

ISLE1 CENRAP 2002 20.74 18.78 19.36

MPCA 2002 

LADCO 2002 21.59 19.21 20.04

LADCO 2005 21.59 19.43 20.09

ISLE9* LADCO 2005 21.59 19.43 19.84

* = result for grid cell located on Isle Royale, 

all other results for grid cells with IMPROVE monitors

Best 

20% 2018

Site Model BY Baseline OTB

BOWA1 CENRAP 2002 6.4 6.4

MPCA 2002 6.4 6.5

LADCO 2002 6.42 6.87

LADCO 2005 6.42 6.14

 

VOYA2 CENRAP 2002 7.1 7.0

MPCA 2002 7.1 7.1

LADCO 2002 7.09 7.34

LADCO 2005 7.09 6.75

 

SENE1 CENRAP 2002 

MPCA 2002

LADCO 2002 7.14 7.23

LADCO 2005 7.14 7.71

 

ISLE1 CENRAP 2002 

MPCA 2002

LADCO 2002 6.75 6.47

LADCO 2005 6.75 6.60

ISLE9* LADCO 2005 6.75 6.52

* = result for grid cell located on Isle Royale, 

all other results for grid cells with IMPROVE monitors

Note: MPCA modeling for the Minnesota 12km domain looked at several receptors throughout the Class I areas. Results for Boundary Waters on 

the 20% worst days range from 18.3 – 19.0 dv, with an average value of 18.7 dv, which is consistent with the 36km results at the IMPROVE 

monitor location shown in the table.
13

 Voyageurs Boundary Waters

10

15

20

25

2004 2010 2020 2030 2040 2050 2060 2064

Round 5 Results Round 4 Results CENRAP Results

MPCA Results Linear ( )

10

15

20

25

2004 2010 2020 2030 2040 2050 2060 2064

Round 5 Results Round 4 Results CENRAP Results

MPCA Results Linear ( )

 Isle Royale Seney

10

15

20

25

2004 2010 2020 2030 2040 2050 2060 2064

Round 5 Results Round 4 Results CENRAP Results

10

15

20

25

2004 2010 2020 2030 2040 2050 2060 2064

Round 5 Results Round 4 Results CENRAP Results

Figure 7. Modeling results for four northern Class I areas for 20% worst visibility days
14

Table 4. EGU SO2 Emissions for States in the Upper Midwest

EGU - SO2

(Base K) 

EGU - SO2 

(Base M)

State 2002 2018 2005 2018

Minnesota 318 266 319 188

-16% -41%

Wisconsin 602 500 545 435

-17% -20%

Michigan 1,102 1,058 1,251 725

-4% -42%

Iowa 412 482 430 352

17% -18%

North Dakota 376 330 369 124

-12% -67%

Illinois 1,310 810 1,158 870

-38% -25%

Indiana 2,499 1,048 2,614 1,036

-58% -60%

Missouri 835 909 889 759

9% -15%

 

7,454 5,403 7,575 4,487

-28% -41%
15

c. What additional control measures will be effective in improving visibility in the northern 

Class I areas?

LADCO’s air quality modeling (Round 4) examined several additional control measures, 

as summarized below.

Sulfate Control Strategies: Reductions in SO2 emissions will decrease sulfate 

concentrations. Because most the SO2 emissions in the upper Midwest are from EGUs, 

additional EGU SO2 control measures were examined. In particular, the following SO2 

emission targets were modeled (MRPO, 2005):

 SO2 (lb/MMBTU) NOx (lb/MMBTU)

 EGU1 0.15 0.10

 EGU2 0.10 0.07

The modeling shows that additional EGU control will improve visibility in the northern 

Class I areas (see Table 5). Increasing the spatial extent of this additional control 

produces greater visibility improvement (i.e., 12-state control program provides more 

benefit than 5-state control program).

Table 5. LADCO Round 4 Modeling Results for EGU Control Strategy

2018 2018 2018 2018

20% Worst 

Days Baseline URI OTB EGU2 (5 state region)

EGU2 

(12 state region)

BOWA1 19.86 17.70 18.94 18.40 17.72

VOYA2 19.48 17.56 19.18 18.94 18.38

SENE1 24.38 21.35 22.38 21.26 20.63

ISLE1 21.59 19.21 20.04 19.09 18.64

Nitrate Control Strategies: Reductions in NOx emissions will decrease nitrate 

concentrations. NOx emissions in the upper Midwest are from a variety of sources, 

principally, mobile sources (on-road and off-road) and stationary sources (EGUs and 

non-EGUs). The modeling for EGU1 and EGU2 reflects lower SO2 and NOx emission 

targets. No additional NOx-specific strategies were modeled by LADCO to address 

regional haze.

To determine whether additional SO2 and NOx control measures satisfy the requirement 

for reasonable progress, an assessment of the five factors was performed (ECR, 

2007a). Specifically, ECR examined reductions in SO2 and NOx emissions from EGUs

and industrial, commercial, and institutional (ICI) boilers; NOx emissions from mobile 

sources and reciprocating engines and turbines; and ammonia emissions from 

agricultural operations. The impacts of “on the books” controls were also examined to 

provide a frame of reference for assessing the impacts of the additional control 

measures.
16

The results of ECR’s analysis of the reasonable progress factors are summarized below:

Factor 1 (Cost of Compliance): The average cost effectiveness values (in terms 

of $ per ton are provided in Table 6. For comparison, cost-effectiveness 

estimates previously provided for “on the books” controls include:

CAIR SO2: $700 - $1,200, NOx: $1,400 – $2.600 ($/T)

BART SO2: $300 - $963, NOx: $248 - $1,770

MACT SO2: $1,500, NOx: $7,600

Most of the cost-effectiveness values for the additional controls are within the 

range of cost-effectiveness values for “on the books” controls.

Factor 2 (Time Necessary for Compliance): All of the control measures can be 

implemented by 2018. Thus, this factor can be easily addressed.

Factor 3 (Energy and Non-Air Quality Environmental Impacts): The energy and 

other environmental impacts are believed to be manageable. For example, the 

increased energy demand from add-on control equipment is less than 1% of the 

total electricity and steam production in the region, and solid waste disposal and 

wastewater treatment costs are less than 5% of the total operating costs of the 

pollution control equipment. It should also be noted that the SO2 and NOx 

controls would have beneficial environmental impacts (e.g., reduced acid 

deposition and nitrogen deposition).

Factor 4 (Remaining Useful Life): The additional control measures are intended 

to be market-based strategies applied over a broad geographic region. It is not 

expected that the control requirements will be applied to units that will be retired 

prior to the amortization period for the control equipment. Thus, this factor can 

be easily addressed.

Factor 5 (Visibility Impacts): The estimated incremental improvement in 2018 

visibility levels for the additional measures is shown in Figure 8, along with the 

cost-effectiveness expressed in $M per deciview improvement). These results 

show that although EGU and ICI boiler controls have higher cost-per-deciview 

values (compared to some of the other measures), their visibility impacts are 

larger.
17

Table 6. Estimated Cost Effectiveness for Potential Control Measures

Average Cost effectiveness ($/ton)

Emission category Control strategy Region SO2 NOX NH3

EGU EGU1 3-State 1,540 2,037 

9-State 1,743 1,782 

EGU2 3-State 1,775 3,016 

 9-State 1,952 2,984 

ICI boilers ICI1 3-State 2,992 2,537 

9-State 2,275 1,899 

ICI Workgroup 3-State 2,731 3,814 

 9-State 2,743 2,311 

3-State 538 

Reciprocating engines 

emitting 100 tons/year or 

more 9-State 506 

Reciprocating engines 

and turbines

3-State 754 Turbines emitting 100 

tons/year or more 9-State 754 

3-State 1,286 Reciprocating engines 

emitting 10 tons/year or more 9-State 1,023 

3-State 800 

 

Turbines emitting 10 

tons/year or more 9-State 819 

10% reduction 3-State 31 - 2,700 Agricultural sources

9-State 31 - 2,700

15% reduction 3-State 31 - 2,700

 9-State 31 - 2,700

Mobile sources Low-NOX Reflash 3-State 241 

9-State 241 

MCDI 3-State 10,697 

9-State 2,408 

Anti-Idling 3-State (430) - 1,700 

9-State (430) - 1,700 

Cetane Additive Program 3-State 4,119 

 9-State 4,119 

Cement Plants Process Modification Michigan - 

Conversion to dry kiln Michigan 9,848 

 LoToxTM Michigan 1,399 

Glass Manufacturing LNB Wisconsin 1,041 

Oxy-firing Wisconsin 2,833 

Electric boost Wisconsin 3,426 

SCR Wisconsin 1,054 

 SNCR Wisconsin 1,094 

Lime Manufacturing Mid-kiln firing Wisconsin 688 

LNB Wisconsin 837 

SNCR Wisconsin 1,210 

SCR Wisconsin 5,037 

 FGD Wisconsin 128 - 4,828 

Oil Refinery LNB Wisconsin 3,288 

SNCR Wisconsin 4,260 

SCR Wisconsin 17,997 

LNB+FGR Wisconsin 4,768 

ULNB Wisconsin 2,242 

 FGD Wisconsin 1,078 
18

Visibility Improvement (dv)

0.00

0.25

0.50

0.75

1.00

SO2NOx NH3 SO2NOx NH3 SO2 NOx NH3 SO2 NOx NH3 SO2NOx NH3

Strategy 1 Strategy 2

EGUs ICI Boilers Rec.Eng. Mobile Ag

Cost Effectiveness ($M/dv)

0

1000

2000

3000

4000

5000

6000

SO2 NOx NH3 SO2NOx NH3 SO2 NOx NH3 SO2 NOxNH3 SO2 NOx NH3

Strategy 1 Strategy 2

EGUs ICI Boilers Rec.Eng. Mobile Ag

Figure 8. Results of ECR analysis of reasonable progress factors – visibility improvement (Factor 

5) is on top, and cost effectiveness (Factor 1) is on bottom
19

Organic Carbon Strategies: Although organic carbon is also an important contributor to

visibility impairment, no organic carbon control strategies were considered for the 

following reasons. 

First, a special study was performed in Seney to identify sources of organic carbon 

(Sheesley, et al, 2004). As seen in Figure 9, the highest PM2.5 concentrations occurred 

during the summer, with organic carbon being the dominant species. The higher 

summer organic carbon concentrations were attributed mostly to secondary organic 

aerosols of biogenic origin, because of the lack of primary emission markers in the 

summer3, and concentrations of known biogenic-related species (e.g., pinonic acid) were 

also higher during the summer. 

Second, to assess further whether fire activity is a significant contributor to visibility 

impairment in the northern Class I areas, the PM2.5 chemical speciation data were 

examined for days with high organic and elemental carbon concentrations, which are 

indicative of biomass burning impacts. A handful of such days were identified:

Table 7. Days with High OC/EC Concentrations in Northern Class I Areas

Site 2000 2001 2002 2003 2004

Voyageurs --- --- Jun 1 Aug 25 Jul 17

 Jun 28 

 Jul 19 

Boundary Waters --- --- Jun 28 Aug 25 Jul 17

 Jul 19 

Isle Royale --- --- Jun 1 Aug 25 ---

 Jun 28 

Seney --- --- Jun 28 --- ---

Back trajectories on these days point mostly to wildfires in Canada. Elimination of these 

high organic carbon concentration days has a small effect in lowering the baseline 

visibility levels in the northern Class I areas (i.e., Minnesota Class I areas change by 

about 0.3 deciviews, and Michigan Class I areas change by less than 0.2 deciviews).

This suggests that fire activity, although significant on a few days, is on average a 

relatively small contributor to visibility impairment in the northern Class I areas. 

In summary, these two analyses indicate that organic carbon in the northern Class I 

areas is largely uncontrollable.

Finally, the modeling results are presented in Figure 10 in terms of chemical species. In 

comparison to the 2000-2004 baseline and 2018 projected visibility level, the 2064 

natural conditions level reflects comparable organic carbon concentrations, but much 

lower sulfate and nitrate concentrations. This suggests the need for additional sulfate 

and nitrate concentration reduction to achieve natural conditions.

 

3 Analysis of primary source emission markers and chemical mass balance modeling of the Seney data 

showed that the impact of primary emission sources (e.g., biomass burning, motor vehicles, and road 

dust) was fairly low. Biomass burning, in particular, contributed less than 1% on an annual average 

basis, although episodic impacts were found (e.g., see high organic carbon days in Figure 3).
20

 

Figure 9. Monthly concentrations of PM2.5 species (top) and biogenic-related organic carbon

species in Seney (bottom)
21

Figure 10. Comparison of 2002 base yea, 2018 future year, and 2064 natural condition levels for 

the four northern Class I areas (LADCO Round 4 modeling)
22

d. Should we consider control measures for ammonia?

Technical analyses have shown

that PM2.5 concentrations will

respond to reductions in sulfate, 

nitrate (nitric acid), and ammonia –

see, for example, Figure 11 based 

on data from the Great River

Bluffs, MN site in the Midwest

regional ammonia network

(Blanchard, 2005). The plot shows

PM2.5 concentrations as a function 

of ammonia (NH3) and nitric acid 

(HNO3). Reductions in ammonia 

(i.e., movement to left of the

baseline value (represented by the 

red star), as well as reductions in 

nitric acid (i.e., movement

downward from the baseline

value) result in lower PM2.5

concentrations. Thus, ammonia 

emission reductions will lower

PM2.5 concentrations and improve 

visibility levels in the northern

Class I areas. Figure 11. Predicted PM2.5 mass levels at 

 Great River Bluffs, MN as functions of 

 changes in ammonia and nitric acid

Current regional inventories show most ammonia emissions come from livestock waste 

and fertilizer applications. A white paper on candidate control measures for agricultural 

ammonia emissions was prepared by a contractor (ECR, 2007b). ECR examined

several measures which would mitigate air emissions, and water pollution from livestock 

waste management and synthetic fertilizer usage. Information on emission reductions 

(and other impacts), cost effectiveness, and geographic and seasonal applicability are 

considered in the white paper.

Further analyses (and discussions with stakeholders) are necessary before deciding 

whether to pursue control measures for ammonia. Key issues which need to be 

addressed include technical uncertainties, such as reliability of emission estimates, 

treatment of ammonia by current photochemical modeling systems, and lack of ambient 

measurements. It is worth noting, however, that LADCO and CENRAP have attempted 

to address these uncertainties by supporting development of a new process-based 

emissions model, conducting model sensitivity studies of ammonia deposition, and 

collecting ambient ammonia data as part of the Midwest regional ammonia network. 

Another issue was noted by USEPA in its final CAIR rulemaking: “reductions in ammonia 

emissions alone would also tend to increase the acidity of PM2.5 and precipitation.... this 

might have untoward environmental or health consequences.” (70 FR 25182)
23

Section 3

References

Blanchard, C.L., and S. Tanenbaum, 2005, “Analysis of Data from the Midwest Ammonia 

Monitoring Project”, Draft Final Technical Memorandum, March 31, 2005.

DeBell, L.J., K. Gebhart, J. Hand, W. Malm, M. Pitchford, B. Schichtel, and W. White, 2006, 

“Spatial and Seasonal Patterns and Temporal Variability of Haze and its Constituents in the 

United States, Report IV”, Cooperative Institute for Research in the Atmosphere, November 

2006

EC/R, Incorporated, 2007a, “Reasonable Progress for Class I Areas in the Northern Midwest –

Factor Analysis”, Draft Final Technical Memorandum, July 18, 2007.

EC/R, Incorporated, 2007b, “Source Category: Agricultural Emissions of Ammonia”, Draft White 

Paper, November 15, 2007.

Environ, 2007, “Draft Report Technical Support Document for CENRAP Emissions and Air 

Quality Modeling to Support Regional Haze State Implementation Plans”, Prepared by 

ENVIRON and UC-Riverside for CENRAP, September 12, 2007

Kenski, D.M., 2007, “Impact of Missing Data on Worst Days at Midwest Northern Class 1 

Areas”, Donna Kenski, Lake Michigan Air Directors Consortium, March 12, 2007 (revised 

6/19/07).

LADCO, 2006, “Base K/Round 4 Modeling: Summary”, August 31, 2006.

LADCO, 2007, “Base M/Round 5 Modeling: Summary (DRAFT), October 10, 2007

MPCA, 2008, “Draft Regional Haze SIP, Chapter 8. Modeling”, February 2008

http://www.pca.state.mn.us/air/regionalhaze.html#sip

MRPO, 2005, “Interim White Paper – Midwest RPO Candidate Control Measures: Electric 

Generating Units”, MACTEC prepared for Midwest RPO, Deceber 9, 2005

Sheesley, R.J., J.J. Schauer, E. Bean, and D. Kenski, Trends in Secondary Organic Aerosol at 

a Remote Site in Michigan’s Upper Peninsula, Env. Sci. and Tech. 38(24); 6491-6500 (October

2004).

USEPA, 1999, Regional Haze Regulations, 64 FR 35714, July 1, 1999

USEPA, 2003, “Guidance for Estimating Natural Visibility Conditions Under the Regional Haze 

Program”, EPA-454/B-03-005, September 2003.

USEPA, 2007, "Guidance for on the Use of Models and Other Analyses for Demonstrating 

Attainment of Air Quality Goals for Ozone, PM2.5, and Regional Haze”, EPA-454/B07-002, April 

2007

Web Sites:

http://vista.cira.colostate.edu/views/
24

APPENDIX I

Contribution Assessment for Northern Class I Areas

Air quality data analyses involving back trajectories, dispersion modeling, and emissions 

inventories were examined to provide information on source region and source sector 

contributions to regional haze in the northern Class I areas. Based on this information, the 

following key findings should be noted:

• The most important contributing states are Michigan, Minnesota, and Wisconsin, as well 

as Illinois, Indiana, Iowa, Missouri, and North Dakota.

• The most important contributing pollutants and source sectors are SO2 emissions from 

electrical generating units (EGUs), which lead to sulfate formation, and NOx emissions 

from a variety of source types (e.g., motor vehicles), which lead to nitrate formation. 

Ammonia emissions from livestock waste and fertilizer applications are also important, 

especially for nitrate formation.

LADCO Back Trajectory Analysis (1997-2001 Data)

Back trajectories were prepared by LADCO using data for 1997-2001 (all sampling days), a start 

height of 200 m, and a 72-hour (3-day) trajectory period (Kenski, 2004). By combining trajectory 

frequencies with concentration information, the average contribution to PM2.5 mass and 

individual PM2.5 species was estimated (which, in turn, was used to estimate the average 

contribution to light extinction). The results for three northern Class I areas are provided in 

Table I-1 for the 20% best days, all days, and 20% worst days. The table shows that the most 

important contributing states are Michigan, Minnesota, and Wisconsin, and, to a lesser degree 

North Dakota, South Dakota, Missouri, Iowa, Illinois, Ontario, and Manitoba.

LADCO Back Trajectory Analysis (2000-2003 Data)

Back trajectories were prepared by LADCO using data for 2000-2003 (20% worst and 20% best

days), a start height of 200m4, and a 120-hour (5-day) trajectory period (Kenski, 2005). 

Composite back trajectory plots were prepared for light extinction, sulfate, and nitrate (see 

Figure I-1). For the high light extinction (poor visibility) and high sulfate and nitrate 

concentration days, the orange areas are where the air is most likely to come from, and the 

green areas are where the air is least likely to come from. As can be seen, bad air days are 

generally associated with transport from Michigan, Minnesota, and Wisconsin, as well as North 

Dakota, South Dakota, Missouri, Iowa, Illinois, and Indiana. On the other hand, the good air 

days (low extinction) are generally associated with transport from Canada. 

 

4 A sensitivity analysis was performed to determine the effect of start height. Increasing westerly 

influence was seen as start height increases. 200 m was assumed to be an appropriate compromise to 

represent the mixed boundary layer, but not unduly influenced by surface features.
25

Table I-1. Estimated Contributions to Visibility (Light Extinction) – Percentages

 Boundary Waters Extinction Voyageurs Extinction Seney Extinction

 Best All Days Worst Best All Days Worst Best All Days Worst

US Alabama 0.03 0.20 0.39

Arkansas 0.30 0.40 0.10 0.19 1.54 2.93

Florida 0.09 0.17

Georgia 0.21 0.39

Illinois 1.68 2.74 0.50 1.22 4.99 7.43

Indiana 0.57 1.18 1.67 2.17

Iowa 5.14 7.44 6.12 10.24 5.27 5.66

Kentucky 1.14 2.18

Louisiana 0.12 0.23 0.03 0.06 0.78 1.23

Michigan 0.78 1.17 0.66 0.27 1.22 1.57 14.51 13.68 14.68

Minnesota 22.04 34.75 37.63 20.96 34.60 36.88 1.46 5.41 3.79

Mississippi 0.06 0.62 1.04

Missouri 2.17 3.26 1.02 0.30 2.42 3.17

New Hampshire 0.02 

New York 0.07 0.10

North Carolina 0.09 0.19 0.36

North Dakota 1.21 5.13 5.91 1.59 6.51 7.11 1.26 0.64

Ohio 0.19 0.23 0.07 1.61 2.80

Pennsylvania 0.49 0.15 0.26

South Carolina 0.21 0.39

South Dakota 0.45 3.06 4.38 4.08 6.93 1.13 1.12

Tennessee 0.01 0.47 0.85

Vermont 0.02 

Virginia 0.03 0.17 0.33

West Virginia 0.05 0.54 1.02

Wisconsin 1.31 7.86 10.06 5.50 9.66 0.26 10.63 8.44

Western States 1.10 4.31 5.74 7.05 9.53 5.80 5.90

Canada Manitoba 9.95 7.45 3.71 17.65 10.35 6.04 3.77 2.37 0.77

Ontario 47.52 15.96 8.92 49.56 13.59 4.98 50.97 12.86 7.66

Quebec 1.77 0.15 0.21 0.01 0.97 0.93 0.41

Other Provinces 2.27 3.73 2.46 6.05 6.29 2.35 0.86 1.72 2.28

Other (over water, etc.) 11.61 6.02 5.05 3.72 3.05 2.94 26.65 21.86 21.44

Total 100.00 100.00 100.00 100.00 100.00 100.00 100.00 100.00 100.00

Note: Because Seney is more surrounded by water (the Great Lakes) than the other monitoring sites, the analysis shows greater impacts associated with the Other (over water) 

category. Actually, most of the Other (over water) impacts at Seney are from nearby (over land) emission sources, not over water emission sources.
26

 

 High extinction days 

 

 High sulfate concentration days High nitrate concentration days

Figure I-1. Composite back trajectories for light extinction, sulfates, and nitrates

Note: orange is where air is most likely to come from, green is where air is least likely to come from
27

LADCO Back Trajectory Analysis (2000 – 2005 Data)

LADCO’s back trajectory study (based on 2000-2003 data) was updated using data for 2000-

2005 (Kenski, 2007). Composite back trajectory plots were prepared for each Class I area (see 

Figures I-2 and I-3). In each plot, the orange areas are where the air is most likely to come 

from, and the green areas are where the air is least likely to come from. As can be seen, bad 

air days are generally associated with transport from Michigan, Minnesota, and Wisconsin, as 

well as North Dakota, South Dakota, Missouri, Iowa, Illinois, and Indiana. On the other hand, 

the good air days are generally associated with transport from Canada.

Figures I-4 and I-5 compare the transport patterns for the two base years: 2002 and 2005. 

Figure I-4 shows strong similarities in the transport patterns for the two years. Additional detail 

on the transport patterns for the two base years is provided in Figure I-5 for Seney and 

Voyageurs. The dots are plotted in graduated colors, by day, so that it is easier to distinguish 

one day from another. It is worth noting that even though a few of the worst-day trajectories 

originate in Canada, many of these trajectories actually spend significant time in the U.S. and 

should not be thought of as strictly Canadian influences.
28

Figure I-2. Composite back trajectories for Seney (top) and Isle Royale (bottom) 

Note: orange is where air is most likely to come from, green is where air is least likely to come from

 Seney, 2000-2005 

 Best Days Worst Days

 Isle Royale, 2000-2005 

 Best Days Worst Days
29

Figure I-3. Composite back trajectories for Boundary Waters (top) and Voyageurs (bottom) 

Note: orange is where air is most likely to come from, green is where air is least likely to come from

 Boundary Waters, 2000-2005 

 Best Days Worst Days

 Voyageurs, 2000-2005 

 Best Days Worst Days
30

Figure I-4. Composite back trajectories for 2002 (top) and 2005 (bottom) 

Note: orange is where air is most likely to come from, green is where air is least likely to come from

 4 Northern Class 1 Sites, 2002 

 Best Days Worst Days

 4 Northern Class 1 Sites, 2005 

 Best Days Worst Days
31

Figure I-5a. Composite back trajectories for Seney

Seney NWR

2002 best

2005 worst

2005 best

2002 worst
32

 

Figure I-5b. Composite back trajectories for Voyageurs

Voyageurs

2002 best

2005 

worst

2002 

worst

2005 best
33

CENRAP Areas of Influence Assessment Using Back Trajectories and Other Tools

Areas of Influence (AOI) were developed using several back trajectory analyses, including 

Residence Time Difference Plots, the Probability of Regional Source Contribution to Haze plots, 

and Tagged Species Source Apportionment Results (Alpine Geophysics, 2006). AOIs were 

constructed for 10 Class I areas in the CENRAP region, including Boundary Waters/Voyageurs 

(see Figure I-6). Green contours represent AOIs for nitrates, and red contours represent AOIs 

for sulfates. Similar to LADCO’s composite trajectory plots in Figure I-1, nitrate impacts are 

associated with more westerly transport, while sulfate impacts are associated with more 

southerly transport.

Figure I-6. AOIs for nitrates (green) and sulfates (right) for Boundary Waters/Voyageurs

CENRAP Emissions Inventory Potential Analysis

Back trajectories were combined with emissions inventory data to estimate the Emissions 

Impact Potential (CENRAP, 2006). This approach weights emissions at a particular location by 

the probability of transport from that location to a given receptor under days of high sulfate or 

nitrate concentrations. The EIP results for SO2 and NOx for Voyageurs, which are provided in 

Figure I-7, show that contributions are greatest from source regions in northeastern Minnesota 

and the Twin Cities urban area.

 

Figure I-7. EIP for SO2 (left) and NOx (right) as calculated for Voyageurs
34

Receptor Modeling Study

Ambient monitoring data for the period 1991 – 2002 were analyzed to identify sources impacting 

PM2.5 levels in several Class I areas, including Boundary Waters (DRI, 2005). Using statistical 

tools (i.e., receptor models), the relative contributions associated with various primary and 

secondary emissions were estimated. The results from three receptor models (CMB, PMF, and 

UNMIX) for Boundary Waters are presented in Figure I-8. Because most of the fine particle 

mass is secondary in nature, the tools were unable to provide much definition - e.g., over 80% 

of the impacts on the 20% worst visibility days at Boundary Waters was due to a combination of 

secondary sulfate, secondary nitrate, and (mostly secondary) organic carbon. Back trajectory 

analysis of these sources showed the largest impacts are associated with transport from the 

following directions: (1) sulfate – south and southeast, (2) nitrate – west and southwest, and (3) 

organics – west and south.

 CMB PMF CMB

nitrate

13%

sulfate

39%

organics + veg. 

burning

32%

industrial

4%

highway

4%

dust

8%

nitrate

18%

sulfate

38%

organics + veg. 

burning

26%

dust

8%

industrial

3%

highway

7%

 

 UNMIX

nitrate

20%

sulfate

14%

organics + veg. 

burning

25%

dust

11%

highway

14%

industrial

16%

Figure I-8. Source apportionment results from three receptor models for Boundary Waters
35

Dispersion Modeling Studies: MPCA, CENRAP, and LADCO

Dispersion models were used to estimate source region and source sector contributions for the 

northern Class I areas. Source contribution information based on the particle source 

apportionment tool (PSAT) in CAMx is available from several modeling studies: (1) MPCA 

modeling 2002 and 2018 (MPCA, 2008), (2) CENRAP modeling for 2018 (Environ, 2007), (3) 

LADCO modeling for 2018 (LADCO, 2006 and LADCO, 2007). MPCA’s analyses included 19 

source regions, LADCO’s included 18, and CENRAP’s included 30 (see Figure I-9). All the

analyses considered similar source groups: EGU point, non-EGU point, on-road, nonroad, area, 

and ammonia. 

 

Figure I-9. Source regions in PSAT analyses: MPCA (left), LADCO (center), and CENRAP 

(right). Contiguous areas of the same color represent a source region.

The contributions to light extinction on the 20% worst visibility days at each of the four Class I

areas are shown in Figures I-10 thru I-13. A few comments on these results should be noted:

• Source apportionment differs from source response. The source apportionment 

results represent how much a given source sector and source region contribute to 

light extinction, whereas the source response is how much light extinction changes 

due to changes in emissions from a given source sector and source region. 

• The source sector and source region contributions are similar for the base years 

(2002, 2005) and future year (2018).

• Sulfate impacts are dominated by point source (EGU and non-EGU) SO2 emissions. 

Nitrate impacts are due to a variety of source sectors.

• The contributions in the two Minnesota Class I areas are dominated by emissions 

from Minnesota, while the contributions in the two Michigan Class I areas come from 

several northern and midwestern states.

• CENRAP’s modeling shows a higher Canadian contribution compared to LADCO’s 

and MPCA’s modeling. This is due to the larger spatial extent of the CENRAP 

modeling domain, and differences in the Canadian emissions inventory.

Table II-2 provides a summary of the estimated state-level culpabilities based on the LADCO 

back trajectory analysis and the PSAT analyses for 2018. 
36

Boundary Waters, Minnesota

 2002 (MPCA) 2005 (LADCO Round 5)

 2018 (CENRAP) 2018 (LADCO Round 5)

Figure I-10a. Model-based source apportionment for 20% worst days – Boundary Waters
37

Boundary Waters, Minnesota

 2002 (MPCA) 2005 (LADCO Round 5)

 2018 (CENRAP) 2018 (LADCO Round 5)

Figure I-10b. Model-based source apportionment on 20% worst days – Boundary Waters
38

Voyageurs, Minnesota

 2002 (MPCA) 2005 (LADCO Round 5)

 

 2018 (CENRAP) 2018 (LADCO Round 5)

 
39

Figure I-11a. Model-based source apportionment for 20% worst days – Voyageurs

Voyageurs, Minnesota

 2002 (MPCA) 2005 (LADCO Round 5)

 

 2018 (CENRAP) 2018 (LADCO Round 5)
40

Figure I-11b. Model-based source apportionment for 20% worst days – Voyageurs

 Seney, Michigan

 2002 (MPCA) 2005 (LADCO Round 5)

 2018 (LADCO Round 5)
41

 

Figure I-12a. Model-based source apportionment for 20% worst days – Seney

Seney, Michigan

 2002 (MPCA) 2005 (LADCO Round 5)
42

 2018 (LADCO Round 5)

 

Figure I-12b. Model-based source apportionment for 20% worst days – Seney
43

Isle Royale, Michigan

 2002 (MPCA) 2005 (LADCO Round 5)

 2018 (LADCO Round 5)

 

Figure I-13a. Model-based source apportionment for 20% worst days – Isle Royale
44

Isle Royale, Michigan

 2002 (MPCA) 2005 (LADCO Round 5)

 2018 (LADCO Round 5)

 

Figure I-13b. Model-based source apportionment for 20% worst days – Isle Royale 
45

Table II-2. State Culpabilities Based on PSAT Modeling and Trajectory Analyses

Boundary Waters Seney

LADCO - 

Round 4 

PSAT

LADCO - 

Round 5 

PSAT

MPCAPSATCENRAP - 

PSAT

LADCO - 

Traj. Analysis

LADCO - 

Round 4 

PSAT

LADCO - 

Round 5 

PSAT

CENRAP - 

PSAT

LADCO - 

Traj. Analysis

Michigan 3.4% 4.8% 3.0% 1.9% 0.7% 13.8% 18.1% 14.7%

Minnesota 30.5% 23.5% 28.0% 30.6% 37.6% 4.8% 1.6% 3.8%

Wisconsin 10.4% 10.9% 10.0% 6.4% 10.6% 12.6% 10.9% 8.4%

Illinois 5.2% 5.1% 6.0% 3.5% 2.7% 13.0% 14.3% 7.4%

Indiana 2.9% 3.9% 3.0% 1.8% 1.2% 9.6% 11.6% 2.2%

Iowa 7.6% 8.3% 8.0% 2.5% 7.4% 6.2% 3.8% 5.7%

Missouri 5.2% 3.4% 6.0% 2.1% 3.3% 6.5% 4.8% 3.2%

N. Dakota 5.7% 1.1% 6.0% 4.6% 5.9% 1.5% 0.1% 0.6%

Canada 1.9% 2.7% 3.0% 12.5% 15.1% 2.1% 1.2% 11.1%

CENRAP-WRAP 10.9% 13.5% 4.2% 10.1% 13.1% 10.0% 7.0%

83.6% 77.2% 73.0% 70.2% 94.6% 83.3% 76.4% 64.1%

 

Voyageurs Isle Royale

LADCO - 

Round 4 

PSAT

LADCO - 

Round 5 

PSAT

MPCAPSATCENRAP - 

PSAT

LADCO - 

Traj. Analysis

LADCO - 

Round 4 

PSAT

LADCO - 

Round 5 

PSAT

CENRAP - 

PSAT

LADCO - 

Traj. Analysis

Michigan 2.0% 4.9% 2.0% 1.0% 1.6% 12.7% 13.4%

Minnesota 35.0% 20.2% 31.0% 31.5% 36.9% 14.1% 9.5%

Wisconsin 6.3% 7.9% 6.0% 3.7% 9.7% 16.3% 14.7%

Illinois 3.0% 7.1% 3.0% 1.8% 1.2% 7.0% 8.7%

Indiana 1.6% 4.6% 2.0% 0.8% 5.6% 5.2%

Iowa 7.4% 7.1% 7.0% 2.4% 10.2% 6.9% 8.3%

Missouri 4.3% 4.0% 4.0% 1.6% 0.3% 3.9% 4.6%

N. Dakota 10.3% 1.7% 13.0% 6.1% 7.1% 3.6% 0.3%

Canada 2.7% 3.3% 5.0% 17.2% 13.3% 2.2% 1.7%

CENRAP-WRAP 10.2% 13.7% 6.1% 16.5% 12.5% 12.6%

82.7% 74.5% 73.0% 72.2% 96.8% 84.9% 79.0%
46

LADCO Emissions Inventory Comparison

Emissions inventories were examined for the northern states which have the greatest impact on 

the northern Class I areas: Michigan, Wisconsin, and Minnesota. The sector-level emissions for 

the base years (2002, 2005) and future years of interest (2009, 2012, and 2018) are presented 

in Figure I-13 (LADCO, 2006, and LADCO, 2007).

5

 The future year SO2 emissions are 

dominated by EGUs, suggesting that an SO2 emission reduction strategy, which is needed to 

reduce sulfate concentrations, should focus on control measures for EGUs. The future year 

NOx emissions come from a variety of sources, suggesting that a NOx emission reduction 

strategy, which is needed to reduce nitrate concentrations, may need to consider control 

measures for a variety of source sectors.

Table I-3 provides a summary of the EGU SO2 and NOx emissions for the 2001-2003 period, as 

well as several 2018 projections (i.e., IPM2.1.9, which was used in the CENRAP modeling and 

LADCO’s Base K/Round 4 modeling, and IPM3.0, which was used in LADCO’s Base M/Round 

5 modeling). 

 

 

5

It is worth noting that the base year (2002) NOx and SO2 emissions for the adjacent Canadian province 

(Ontario) are considerably less than the combined NOx and SO2 emissions for the three northern states.
47

Michigan

0

500

1000

1500

2000

2002 2005 2009 2012 2018 2002 2005 2009 2012 2018

Area

On-road 

Nonroad

NonEGU

EGU

Minnesota

0

500

1000

1500

2000

2002 2005 2009 2012 2018 2002 2005 2009 2012 2018

Area

On-road 

Nonroad

NonEGU

EGU

Wisconsin

0

500

1000

1500

2000

2002 2005 2009 2012 2018 2002 2005 2009 2012 2018

Area

On-road 

Nonroad

NonEGU

EGU

Figure I-13. Emissions for Michigan (top), Minnesota (middle), and Wisconsin (bottom) for NOx 

(left side) and SO2 (right side)
48

Table I-3: EGU SO2 and NOx Emissions

Heat Input (MMBTU/year) Scenario

SO2 

(tons/year)

SO2 

(lb/MMBTU)

NOx 

(tons/year)

NOx 

(lb/MMBTU)

IL 980,197,198 2001 - 2003 (average) 362,417 0.74 173,296 0.35

IPM 2.1.9 241,000 73,000

1,310,188,544 IPM3.0 (base) 277,337 0.423 70,378 0.107

IPM3.0 - will do 140,296 0.214 62,990 0.096

IPM3.0 - may do 140,296 0.214 62,990 0.096

IN 1,266,957,401 2001 - 2003 (average) 793,067 1.25 285,848 0.45

IPM 2.1.9 377,000 95,000

1,509,616,931 IPM3.0 (base) 361,835 0.479 90,913 0.120

IPM3.0 - will do 628,286 0.832 128,625 0.170

IPM3.0 - may do 621,539 0.823 127,937 0.169

IA 390,791,671 2001 - 2003 (average) 131,080 0.67 77,935 0.40

IPM 2.1.9 147,000 51,000

534,824,314 IPM3.0 (base) 115,938 0.434 59,994 0.224

IPM3.0 - will do 115,938 0.434 59,994 0.224

IPM3.0 - may do 100,762 0.377 58,748 0.220

MI 756,148,700 2001 - 2003 (average) 346,959 0.92 132,995 0.35

IPM 2.1.9 399,000 100,000

1,009,140,047 IPM3.0 (base) 244,151 0.484 79,962 0.158

IPM3.0 - will do 244,151 0.484 79,962 0.158

IPM3.0 - may do 244,151 0.484 79,962 0.158

MN 401,344,495 2001 - 2003 (average) 101,605 0.50 85,955 0.42

IPM 2.1.9 86,000 42,000

447,645,758 IPM3.0 (base) 61,739 0.276 41,550 0.186

IPM3.0 - will do 54,315 0.243 49,488 0.221

IPM3.0 - may do 51,290 0.229 39,085 0.175

MO 759,902,542 2001 - 2003 (average) 241,375 0.63 143,116 0.37

IPM 2.1.9 281,000 78,000

893,454,905 IPM3.0 (base) 243,684 0.545 72,950 0.163

IPM3.0 - will do 237,600 0.532 72,950 0.163

IPM3.0 - may do 237,600 0.532 72,950 0.163

ND 339,952,821 2001 - 2003 (average) 145,096 0.85 76,788 0.45

IPM 2.1.9 109,000 72,000

342,685,501 IPM3.0 (base) 41,149 0.240 44,164 0.258

IPM3.0 - will do 56,175 0.328 58,850 0.343

IPM3.0 - may do 56,175 0.328 58,850 0.343

SD 39,768,357 2001 - 2003 (average) 12,545 0.63 15,852 0.80

IPM 2.1.9 12,000 15,000

44,856,223 IPM3.0 (base) 4,464 0.199 2,548 0.114

IPM3.0 - will do 4,464 0.199 2,548 0.114

IPM3.0 - may do 4,464 0.199 2,548 0.114

WI 495,475,007 2001 - 2003 (average) 191,137 0.77 90,703 0.36

IPM 2.1.9 155,000 46,000

675,863,447 IPM3.0 (base) 127,930 0.379 56,526 0.167

IPM3.0 - will do 150,340 0.445 55,019 0.163

IPM3.0 - may do 62,439 0.185 46,154 0.137
49

Other Issues: Transboundary Impacts

In a Technical Brief, EPRI proposed an alternative method for calculating future year visibility 

impacts in the northern Class I areas (EPRI, 2007). This method subtracts the transboundary 

impact from the 2018 future year visibility estimate and compares this adjusted future year value 

to the uniform rate of improvement value.

In a letter to EPRI dated July 20, 2007, LADCO cited two major concerns with EPRI’s analysis 

(i.e., transboundary impact is flawed because it is based on VISTAS’ modeling which relied on a 

bad version of the Canadian emissions inventory, and adjustment of only the 2018 visibility 

value is inconsistent). In addition, LADCO noted that technical analyses (e.g., LADCO’s back 

trajectory analyses using 2000-2005 data) show that visibility impairment on the 20% worst 

visibility days is dominated by emissions from sources in the U.S., and are not greatly affected 

by transboundary impacts. 

In a follow-up letter dated July 31, 2007, EPRI stated its belief that the emissions inventory 

problems may actually understate (not overstate) the Canadian contribution, and that its 

approach to only adjust 2018 values was a “reasonable way to examine the influence of 

transboundary pollution”.

Putting aside the EPRI analysis and its criticisms, the fundamental issue is to what degree 

Canadian emissions are impacting visibility on the 20% worst visibility days in the northern 

Class areas6. There appear to be two principle pieces of information which address this issue:

• Back Trajectory Analyses: The contoured trajectories (Figures I-1 through I-4) 

show that, generally, bad air days are associated with transport from the south, 

and good air days with transport from Canada. As noted above, however, the 

detailed trajectories (Figure I-5 and I-6) show that a few of the worst-day 

trajectories originate in Canada. Nevertheless, many of these trajectories 

actually spend significant time in the U.S. and should not be thought of as strictly 

Canadian influences.

• PSAT Analyses: There are two fundamental differences between the 

MPCA/LADCO and CENRAP PSAT analyses: (1) extent of modeling domain

(see Figure I-8), and (2) version of the Canadian emissions inventory. On the 

first point, the CENRAP domain is better, given that it includes much of the 

southern Canadian provinces, whereas the MPCA/LADCO domain only includes 

portions of some of these provinces (i.e., Saskatchewan and provinces to the 

east). On the second point, LADCO’s Base M/Round 5 analysis is better, given 

that it reflects the most current version of the Canadian emissions inventory 

(including stack parameters). (Note, however, LADCO’s modeling may overstate 

the 2018 Canadian contribution, because it assumed 2018 and 2005 emissions 

are the same.)

 

6

In a guidance memo, USEPA has stated that “States should not directly consider the effects of 

international emissions when calculating their uniform rates of progress by either adding the effects of 

international emissions to their estimates of natural conditions, or by subtracting international emissions 

from current conditions. Either of these approaches conflicts with the basic definitions of "current 

conditions" (baseline conditions for the first SIP) and "natural conditions," as described in the 1999 RHR. 

64 Fed. Reg. 35728, (July 1, 1999).” (USEPA, 2006)
50

In conclusion, while the back trajectory analyses suggest the impact from Canadian sources in 

the northern Class I areas is small, there is sufficient uncertainty with the available modeling 

analyses that it is not possible to estimate, with any confidence, their impact. Further analyses 

may be warranted to quantify the Canadian contribution. In particular, an analysis should be 

conducted using the most current version of the Canadian emissions inventory (with up-to-date 

stack parameters) and an expanded CENRAP-like modeling domain. 
51

References

Alpine Geophysics, 2006, “CENRAP Regional Haze Control Strategy Analysis Plan”, May 9, 

2006, Alpine Geophysics. 

CENRAP, 2006, Voyageurs Emissions Impact Potential, slides included in “CenRAP RHaze 

North Class I 08-10-06.ppt”, prepared by Bret Anderson for CENRAP, August 10, 2006.

DRI, 2005, “Source Apportionment Analysis of Air Quality Monitoring Data: Phase II”, Prepared 

by Desert Research Institute for MANE-VU and Midwest RPO, March 2005.

Environ, 2007, “Draft Report Technical Support Document for CENRAP Emissions and Air 

Quality Modeling to Support Regional Haze State Implementation Plans”, Prepared by 

ENVIRON and UC-Riverside for CENRAP, September 12, 2007

EPRI, 2007, “Effect of Transboundary Pollution on Visibility: A Case Study for Northern Class I 

Areas”, Electric Power Research Institute.

Kenski, 2004, Quantifying Transboundary Transport of PM2.5: A GIS Analysis, Proc. AWMA 97th 

Annual Conf., Indianapolis, June 2004.

Kenski, 2005, “Sensitivity Analysis of Various Trajectory Parameters”, June 2005, LADCO

Kenski, 2007, PowerPoint Presentation (“northern.class.1.trajectories1.ppt”) - updated

trajectories, September 27, 2007

LADCO, 2006, “Base K/Round 4 Strategy Modeling” Emissions”, May 16, 2006.

LADCO, 2007 “Base M Strategy Modeling: Emissions (Revised)”, October 10, 2007

USEPA, 2006, “Additional Regional Haze Questions”, August 3, 2006.

MPCA, 2008, “Technical Support Document for the Minnesota State Implementation Plan for 

Regional Haze”, Rough Draft v1, January 30, 2008.
Appendix 3C 

MANE-VU Consultation Notes
August 6 2007 MANE-VU/MRPO Consultation Summary (DRAFT) 

MANE-VU Class I States’ Consultation 

Open Technical Call Summary 

July 19, 2007 

Introduction & Purpose of Call (A. Garcia, MANE-VU)

 Anna Garcia opened the call at 10 am (EDT) with a welcome and roll call by all 3 RPOs 

(see attached list of participants). She then reviewed the purpose of today’s call, including: 

 After asking for general questions about the agenda and call purpose, the MANE- VU 

representatives began the substance of the call with an overview of the technical work to be 

discussed as organized in the MANE-VU briefing books provided for the call. 

MANE-VU Contribution Assessment (G. Kleiman, NESCAUM)

 Gary Kleiman provided a brief summary of the contribution assessment work that 

MANE-VU conducted to help them determine which states the Class I states would request be 

involved in consultation (see Tabs 4 & 5 of briefing book). 

Discussion: 

• M. Koerber (MRPO): Requested documentation of 2018 projections – MANE-VU work 

seems consistent with MRPO analyses. Also, it looks as if the Northeast states will be 

below the glide path for uniform progress by 2018. 

• G. Kleiman (NESCAUM): There seems to be pretty good consistency across all the 

RPOs in terms of their modeling work. Also, VISTAS new emission inventory with GA 

reductions is not in the MANE-VU modeling. It also includes MANE-VU’s 500 ppm low 

sulfur fuel strategy, but not the 15 ppm level. 

• R. Papalski (NJ): So the modeling does take into account 500 ppm sulfur fuel oil? 

• G. Kleiman (NESCAUM): Yes, and that is significant (not including VT or DE). 

• M. Koerber (MRPO): I notice that in 2018 organic carbon is more significant, and may 

be as significant as sulfate. This issue is very complex, especially in urban areas. Where 

is MANE-VU’s organic carbon coming from? MRPO will be interested in what our 

control measures analysis says for organic carbon. 

• G. Kleiman (NESCAUM): There is some uncertainty with regard to what the modeling is 

indicating about organic carbon in 2018 – that is why MANE-VU is focusing on sulfate 

now. 

• P. Wishinski (VT): Sulfate dominates extinction. Organic carbon does not contribute as 

much to extinction as sulfate in the MANE-VU region. 

• P. Brewer (VISTAS): After discussion with Gary at MARAMA Science Meeting, our 

approach was more understandable. 

• B. Lopez (WI): This work was based on IPM 2.1.9 – what is expected if put in context of 

EPA’s IPM 3.0 runs? 

1
August 6 2007 MANE-VU/MRPO Consultation Summary (DRAFT) 

• S. Wierman (MARAMA): IPM 3.0 results were not available at the time this analysis 

was done, so we used 2.1.9 with updated gas curves. 

• L. Nixon (NH): On state by state basis sulfur levels from EPA 3.0 model runs. Liz, took 

a quick look at 3.0 and same SO4 increases that look problematical. 

MANE-VU Reasonable Progress Project Summary (S. Wierman, MARAMA)

 Susan Wierman provided a brief summary of the reasonable progress work that MANEVU conducted to help them develop long-term strategies and control measures for the 2018 state 

implementation plans(see Tab 7 – A, B and C - of briefing book). 

Discussion: 

• J. Hornback (SESARM): Are costs in 1999 dollars? If so, how do they compare in 

current dollars? 

• S. Wierman (MARAMA): Yes, these are reflected in 1999 dollars. If converted to 2006 

dollars the cost figures would be higher – multiply 1999 by 1.186 to go from 1999 $ to 

2006 $. 

• D. MacLeod (VA): Regarding the MANE-VU statement, how would disagreements 

between a Class I State and a non MANE-VU state be handled in the SIP? 

• A. Garcia (MANE-VU): The statements that MANE-VU issued are the request for the 

kinds of measures that our Class I states believe are needed based on the technical work 

we have done. In the consultations these requests are a starting point for discussion, and 

provide a basis for looking at the work the other RPOs have done in comparison to our 

work to determine what may be needed and is reasonable. According to the rule, the 

consultations are not expected to result in agreement on everything, but the areas of 

agreement and disagreement that occur via consultation are to be documented in the SIP. 

• J. Johnson (GA): Regarding EGUs, is there a relationship between what is on pages 68-

78 and CAIR+? And does MANE-VU have any idea of what level of reductions would 

result from CAIR+? 

• S. Wierman (MARAMA): We have not done an analysis of CAIR+ and its impact on 

visibility. Impact on visibility is not one of the 4 factors and so is not applicable. 

• M. Koerber (MRPO): Isn’t there a 5th factor in guidance - $/deciview ? 

• S.Wierman (MARAMA) – EPA expects that we will look at visibility improvement, but 

still not a factor regarding reasonableness. MANE-VU is planning on looking at 

visibility improvement of the control measurse we initially looked at as reasonable. 

• S. Holman (NC): Modeling on visibility – are you doing CMAQ modeling for 2018? Or 

CALPUFF? 

• G. Kleiman (NESCAUM): We are doing a CMAQ sensitivity run –not a full annual run, 

but for select periods, with tagging mechanism for different control measures. 

• S. Holman (NC): In NC, 11 of 12 EGUs will have scrubbers - need to reflect units that 

have scrubbers on in VISTAS base G. 

MANE-VU Long-Term Strategy/Statements

2
August 6 2007 MANE-VU/MRPO Consultation Summary (DRAFT) 

 As discussions proceeded after the reasonable progress overview, participants began to 

ask questions about the MANE-VU resolution and statements (see Tab 3 of briefing book). 

These documents outline how MANE-VU is approaching the consultation process and a request 

that states pursue strategies in various sectors that MANE-VU believes are needed for its Class I 

areas, as a starting point for consultation discussions. 

Discussion: 

• F. Durham (WV): Regarding the low sulfur fuel strategy, will regulatory impact analyses 

for this measure be done on state or regional basis? 

• G.Kleiman (NESCAUM), S.Wierman (MARAMA) & Ray Papalski (NJ): That will be 

done on state basis, but with coordination across the MANE-VU states. NJ will be doing 

an analysis, but there is also a federal role in terms of any national rulemakings that may 

happen on low sulfur fuel. 

• J. Johnston (GA): What is the basis for saying that the low sulfur fuel strategy is 

reasonable for States outside MANE-VU? 

• G. Kleiman (NESCAUM), S. Wierman (MARAMA), A.Garcia (MANE-VU): Actually 

the Class I states are looking for equivalent reductions to what they are doing in the low 

sulfur fuel strategy – not necessarily expecting that MRPO and VISTAS states will 

pursue a low sulfur fuel strategy. We are asking you to look at what is reasonable in 

terms of making equivalent reductions, which is the point of having the consultations. 

We know the MRPO and VISTAS states are looking at reasonable measures for your 

own Class I areas. During the consultation we anticipate comparing what you are looking 

at as reasonable with what we are requesting as a starting point for what is “potentially” 

reasonable. 

• J. Johnston (GA): Is there flexibility to get more reductions from EGUs and fewer 

reductions from non-EGUs? What if, for example, we get more sulfate reductions from 

EGU sources equivalent to the amount of non-EGU MANE-VU reductions? 

• P.Wishinski (VT), A. Garcia (MANE-VU): VT would support that kind of alternative. 

MANE-VU does envision that flexibility in our consultation discussions. 

• M. Koerber (MRPO): An issue they have been looking at is actually setting a reasonable 

progress goal - what is MANE-VU’s process for that? 

• G. Kleiman (NESCAUM), A. Garcia (MANE-VU): A deciview number will come out of 

our CMAQ sensitivity runs, and agreed-to reductions after consultations, with full 

CMAC run. There may still be some overlap between what may and may not be agreed 

to and what the Class I states want to include as reasonable in CMAQ final run. 

• M. Koerber (MRPO): There are very different EGU predictions between IPM 2.1.9, IPM 

3.0, and what his states say will actually happen. Will it be possible to have further 

discussions after August 6th and August 20th consultations to refine and sync up EGU 

reductions and possible modeling run inputs? 

• G. Kleiman (NESCAUM), A. Garcia (MANE-VU): It would be helpful for MRPO and 

VISTAS to share with us their information on their EGU inventory, so we can make sure 

our modeling for reasonable progress reflects their work and so that our states can 

understand what they will be doing. The in-person meetings are not the end of the 

consultation process. Our states are interested in having a continued dialogue, beyond the 

August in-person meetings. 

3
August 6 2007 MANE-VU/MRPO Consultation Summary (DRAFT) 

• M. Koerber (MRPO): On page 61, is WI in or out? (in VT letter due to its CALPUFF 

runs) 

• P. Wishinski (VT): VT CALPUFF modeling indicated that WI contributed >2% of 

emissions, so VT wants to include WI in consultation process, even though there are no 

WI EGUs on 167 list 

• L. Bruss (WI): Please give him or Kevin Kessler a call (608) 266-0603 

• D. Valentinetti (VT): We agree with Mike that this is an ongoing process for best science 

• D. Andrews (KY): The two EGU modeling runs in the table of 167 stacks do not show 

much correlation – why? 

• S. Wierman (MARAMA): Because the modeling for each of the different runs is based 

on different days, there were different meteorological inputs to each model and 

variability in wind fields (shows importance of meteorology). 

MWRPO Overview (M. Koerber, LADCO) 

• The MRPO states have moved ahead with some of their own state rules (consumer 

products, AIM, etc.). They also have PM SIPS to do. 

• We updated our modeling to use 2005 as base year and made changes to IPM 3.0 based 

on what we know will actually happen – will be quite a bit different from 2.1.9 (not ready 

by Aug. 6th) 

• Would hope modeling would form basis for a collaborative on future control strategies 

• MRPO internal consultation process for the Northern Class I states has been ongoing for 

once a year – completed a great deal of technical work. 

• Their reasonable progress project by EC/R is finished- provides a new metric - 

$/deciview. Looked at “5th Factor” for on-the-books controls as context for candidate 

measures. Examined similar strategies as those that MACTEC did for MARAMA 

analysis. Now completing report on “5th Factor” - will send out later. 

• Requirement to address regional haze Class I areas in state and outside state. Have done 

more work on who is contributing. Will provide MRPO states with a list of who they 

impact. 

Discussion: 

• A. Garcia (MANE-VU): Will MRPO states be looking for any national measures? 

• M. Koerber (MRPO): Our Class I areas are still above the glidepath, so may need some 

regional/national reductions. We are looking at that – may have something as develop, 

but will not have it by Aug. 6th. Note that MANE-VU sites are at uniform progress with 

control measures but MRPO states are above uniform line. 

• D. Littell (ME): How much of the contribution at their Class I sites is coming from 

Canada? 

• M. Koerber (MRPO): On the 20% worst days, the contributions are mainly from the 

south. 

• A. Garcia (MANE-VU): Would it be possible to include Canada (primarily Ontario) at 

the August 6th consultation? They have expressed an interest, and our northern Class I 

states would like to invite them to hear our discussions. 

• M.Koerber (MRPO): That would be ok. 

4
August 6 2007 MANE-VU/MRPO Consultation Summary (DRAFT) 

VISTAS Overview (Pat Brewer, VISTAS) 

• In VISTAS we the focus is on sulfate as well. 

• Started with IPM 2.1.9 – in Base G, took account of results supplied by utilities – created 

hybrid between 2.1.9 and ground – truthing in summer 2006 (somewhere between 

versions 2.1.9 and 3.0) – pretty close to MV CAIR+ results. Base G2 has some changes 

in GA & FL 

• See improvements at Southwest and Appalachian sites – mountain sites below the 

uniform progress line; less improvement at coastal sites – very close to uniform progress. 

Smaller reductions in units affecting relative reductions over whole year. GA and FL are 

working closely together on those sites. 

• Distributed reasonable progress approach to stakeholders - looked at areas of influence. 

• Reasonable progress analysis based on area of influence approach shows sulfate from 

EGUs and other sources dominated – most responses from sulfate reductions. When 

looking at areas of influence, we looked at their sulfate sources 

• In modeling we included Brigatime and other sites 

• Look at cost of controls, what are sulfate emissions after implementing the on-the-way 

controls. After 2018, EGUs still contribute 40% of emissions. Coal burning ICI boilers 

are the next largest at 20-30% of emissions, also a small percent from glass, pulp and 

paper, etc. Know by SEC code what kind of sources and costs of typical measures 

(AirControl.net). Will be using MARAMA 4- Factor analysis to inform their process. 

• Delivered lists of sources in areas of influence in November. VISTAS states consultation 

occurred in December 2006 - agreed on approach to take on 4- Factor analysis. Got back 

together in May and repeated our process. Some states sent letters asking them to look at 

certain kinds of sources -- “tell us what you decide when you do your analysis of these 

sources on your Class I areas.” Provided schedules on next steps of SIP process. 

• VISTAS has interstate consultations going on in southern states - May 2007 consultation, 

too, plus June FLM/EPA meeting, intrastate consultations . Now consultation has started 

with MANE-VU 

• FLM/EPA feedback is commitment to good mid-course review in 2012 to see where 

EGU reductions are actually occurring . 

Discussion: 

• S. Wierman (MARAMA): Please elaborate on your comment that IPM run with Base G 

are “close to” MANE-VU CAIR+ run? 

• P. Brewer (VISTAS): There are similarities with MACTEC top 30 for VISTAS EGUs 

• A. Garcia (MANE-VU): We/ MANE-VU received similar look-back comments from our 

FLMs 

• J. Hornback (SESARM): Everyone should look at emissions reductions that are already 

in place. Substantial reductions have occurred already, not just what’s going to occur in 

2018. Benefits from additional controls for upcoming NAAQS will help regional haze, 

too – substantial reductions in the southeast. 

• T. Allen (FWS): CAIR uncertainly can be addressed by communicating with EGUs and 

can include in SIP instead of waiting for look-back 

• G. Kleiman (NESCAUM): IPM projections a moving target, but info on controls on 167 

stacks important to bring to consultation – we may not be very far apart. Any information 

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August 6 2007 MANE-VU/MRPO Consultation Summary (DRAFT) 

that the RPOs and states can provide about controls on 167 Stacks would be very 

valuable. We also recognize that states are looking at their own measures. Any info on 

control measure decisions that you have made for your own sources may show we are 

closer - by August 6th and August 20th meeting. 

• R. Papalski (NJ) Is the material from the VISTAS June meeting available? 

• P. Brewer (VISTAS): Yes, all presentations from the June meeting are posted on 

VISTAS’ website. 

• J. Hornback (SESARM): More on 28% reduction – ICI sulfur goes up from 10% to 24% 

nationwide and could be possible national rule John H – 16% of sulfur from ICI boilers in 

2002 up to 24% after CAIR. As we move into next round of fine particle work – ask 

whether we have enough info re ICI boilers. Impact, concern and what control 

options/cost are – talk to EPA? Uncontrolled/inadequately controlled sources 

• A. Garcia (MANE-VU): Our states have done some work on ICI boilers and have some 

information developed already. We would be glad to work with MRPO and VISTAS on 

this issue. 

• S. Wierman (MARAMA): It may be possible to include something on ICI boilers as a 

potential amendment to MANE-VU National ask statement. Might be possible for it to 

come out of consultations. 

• J. Hornback (SESARM): We should continue to collect data and be ready to move 

forward. 

• S. Wierman (MARAMA): We would appreciate feedback at the consultation on joining 

MANE-VU on its request for a Phase 3 CAIR 

Comments from FLMs 

• Pay attention to mid course review – look at where you will be in 2012 compared to 

where you expected to be. 

• Regarding the 2012 look back – discussions of source can be helpful and included in this 

SIP, with recognition of uncertainty. 

EPA 

• John Summerhays (EPA Region 5) and Michelle Notariani (EPA/OAQPS), expressed 

their appreciation for being invited to participate on the call and on future consultations. 

Outcomes & Next Steps 

• R. Papalski (NJ): Asked that all RPOs bring a list of the 167 EGUs and any planned 

controls on those units to the August meeting. 

• P. Wishinski (VT): To confirm, VT will be asking WI to participate in the August 6th

meeting – will be calling WI to ask them to attend. 

• A. Garcia (MANE-VU): Gave a brief overview of the upcoming consultation meetings 

on August 6th and 20th – asked for any further comments/changes to the agendas to be 

sent to her next week. 

• T.Aburn (MD): Opportunity to work with EPA on CAIR “Phase 3” for 2018/2020 would 

be a great outcome of consultations – Ann, Strengthen numbers – Tad, can we talk about 

PM? Mike, very relevant and need to look ahead 

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August 6 2007 MANE-VU/MRPO Consultation Summary (DRAFT) 

Adjournment 

Anna Garcia thanked everyone for their participation and promised to circulate a draft 

summary of the call for comment – asked that each RPO share their attendance lists for the 

open call all around via email. Information on this and other MANE-VU consultations will 

be posted on the consultation page of the MANE-VU website, www.manevu.org. 

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August 6 2007 MANE-VU/MRPO Consultation Summary (DRAFT) 

 

Attendees 

MANE-VU 

Affiliation Name 

Connecticut Wendy Jacobs 

Delaware Jack Sipple 

Maine David Littell 

Maine Jeff Crawford 

Maine Tom Downs 

Maryland Tad Aburn 

Maryland Andy Hiltebridle 

Massachusetts Eileen Hiney 

New Hampshire Bob Scott 

New Hampshire Jeff Underhill 

New Jersey Chris Salmi 

New Jersey Ray Papalski 

New Jersey Sandy Krietzman 

New York Matt Reis 

New York Diana Rivenburgh 

Penobscot Tribe Bill Thompson 

Vermont Dick Valentinetti 

Vermont Paul Wishinski 

MARAMA Julie McDill 

MARAMA Susan Wierman 

NESCAUM Gary Kleiman 

OTC Doug Austin 

OTC Anna Garcia 

EPA Region 1 Anne Arnold 

EPA Region 1 Anne McWilliams 

EPA Region 2 Bob Kelly 

EPA Region 3 Ellen Wentworth 

EPA Region 3 LaKeshia Robertson 

FLM-NPS Bruce Polkowsky 

FLM-NPS Holly Salazer 

FLM-FWS Tim Allen 

FLM-FS Ann Mebane 

 

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August 6 2007 MANE-VU/MRPO Consultation Summary (DRAFT) 

 

VISTAS 

Georgia Heather Abrams

Georgia Jimmy Johnston 

Kentucky John Lyons 

Kentucky Diana Andrews 

Kentucky Lona Brewer 

Kentucky Martin Luther 

North Carolina Keith Overcash 

North Carolina Sheila Holman 

North Carolina Laura Booth 

North Carolina George Bridgers 

South Carolina Renee Shealy 

South Carolina John Glass 

South Carolina Maeve Mason 

South Carolina Stacey Gardner 

Tennessee Barry Stephens 

Tennessee Quincy Styke 

Tennessee Julie Aslinger 

Virginia Tom Ballou 

Virginia Doris MacLeod 

Virginia Mike Kiss 

West Virginia Fred Durham 

West Virginia Bob Betterton 

West Virginia Laura Crowder 

EPA Region 4 Brenda Johnson 

EPA OAQPS Michele Notarianni 

Metro 4/SESARM John Hornback 

VISTAS Pat Brewer 

 

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August 6 2007 MANE-VU/MRPO Consultation Summary (DRAFT) 

 

MANE-VU/MRPO Consultation Meeting 

August 6, 2007 

Rosemont, IL 

 On Monday, August 6, 2007, the Mid-Atlantic/Northeast Visibility Union (MANE-VU) 

Class I states (Maine,Vermont, New Hampshire, and New Jersey) held a consultation with 

several of the Midwest Regional Planning Organization (MRPO) states (Illinois, Indiana, Ohio, 

Michigan and Wisconsin). The following summary documents the discussions that took place 

during the consultation. 

Summary of Today’s Consultation Agreements

1. Define next steps for multi-pollutant approach to reduce regional haze, PM 2.5, and 

ozone 

2. Discuss crafting a revised national ask among interested MANE-VU and MRPO 

states regarding needs for national action on EGUs, including potential multipollutant control levels for CAIR Phase III with emission rates and output-based 

options; 

3. Pursue discussions on options for reducing SO2 (and NOx) emissions from ICI 

boilers, including: 

• Reconvening the MANE-VU/MRPO ICI boiler workgroup to re-examine the 

workgroup’s January 2007 straw proposal; 

• Developing a process for sharing information on SO2 RACT for ICI boilers, and 

examining potential SO2 control measures; 

• Contacting NACAA regarding expansion of the Boiler MACT model rule work to 

address SO2 and NOx; and 

• Discuss crafting a national ask among interested MANE-VU and MRPO states 

regarding national action on ICI boilers. 

4. Discuss crafting a national ask regarding low sulfur fuel for all off-road sources, and 

share information on biodiesel. 

5. Continue to share modeling assumptions and analyses, and continue dialogue 

between MANE-VU and MRPO states regarding SIP submittals. 

6. Define next steps to gather information on controls for locomotives and ocean-going 

vessels. 

7. Develop list of controls for units that will be scrubbed, not just MANE-VU’s list of 

167 stacks. 

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August 6 2007 MANE-VU/MRPO Consultation Summary (DRAFT) 

 

Attendees

States and Tribes FLMs and EPA

Maine – Dave Littell, Jeff Crawford National Park Service – Bruce Polkowsky 

New Hampshire – Tom Burack, Bob Scott Forest Service – Anne Mebane, Chuck Sams, 

Rich Fisher 

New Jersey – Chris Salmi Fish and Wildlife Service – Tim Allen 

Vermont –Justin Johnson, Dick Valentinetti, 

Paul Wishinski 

EPA Region I – Anne Arnold 

Illinois – Laurel Kroack, Scott Leopold EPA Region II – Bob Kelly

Indiana – Tom Easterly, Ken Ritter EPA Region III (by phone) – Ellen Wentworth, 

Neil Bigioni 

Ohio – Bob Hodanbosi EPA Region V – John Summerhays 

Michigan – Vince Hellwig, Cindy Hodges, 

Bob Irvine 

EPA – OAQPS (by phone) – Todd Hawes, 

Michelle Notarianni

Wisconsin – Larry Bruss 

MRPO – Mike Koerber 

MANE-VU – Anna Garcia, Doug Austin 

MARAMA – Susan Wierman, Julie McDill 

NESCAUM – Gary Kleiman 

Consultation Meeting Presentations and Discussions

Welcome and Introductions – Goals for Today’s Meeting - David Littell, Maine DEP 

• Presented goals for today’s consultation: 

- Review requirements, resources and critical timing issues to ensure all share a 

common understanding; 

- Discuss options for control measures to identify what is reasonable for joint work 

between regions; 

- Identify impediments to implementing control measures and discuss how to address 

them; 

- Identify links between haze and PM that help define what is reasonable; 

- Examine reasonable progress for MRPO and MANE-VU Class I areas in terms of 

control measure options; and 

- Summarize points of agreement and identify issues for follow-up consultation 

• Compare our request for what we need in terms of reductions to improve visibility at our 

Class I areas with what the MRPO states have done to address their own Class I areas and 

regional haze/PM issues 

• Find out how close we are, what gaps may still remain, and discuss how we may address 

them together. 

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August 6 2007 MANE-VU/MRPO Consultation Summary (DRAFT) 

 

Overview of Open Technical Call & Consultation Briefing Book – Anna Garcia, MANE-VU 

• Open Technical Call discussions provided a good technical basis for today’s meeting. 

• MANE-VU staff is developing draft documentation of the Open Call and of today’s 

discussions, and will circulate the drafts for comment and make the final documentation 

available to all states for use in their state implementation plans (SIPs). 

Summary of Reasonable Progress Work and Development of “Asks” for MANE-VU Class 

I Areas – Chris Salmi, New Jersey DEP 

Presentation: 

• Provided a review of MANE-VU Class I states’ Resolution on Principles; 

• Showed focus for MANE-VU is on sulfate reductions for the 2018 milestone; 

• Gave an overview of MANE-VU’s four factor analysis; 

• Outlined how MANE-VU Class I states developed the “asks” for the MANE-VU and 

MPRO regions; 

• Provided a comparative analysis of the MANE-VU region “ask” with that of the MRPO 

“ask”; 

• Outlined the specifics of each of the asks, including for MRPO: 

- Timely implementation of BART requirements; 

- A focused strategy for the electricity generating units (EGUs) comprising a 90% 

reduction of sulfate emissions from 2002 levels from 167 stacks that modeling 

indicates affect visibility impairment in MANE-VU Class I areas; 

- A 28% reduction from non-EGU sector emissions based on 2002 levels; and 

- Continued evaluation of other measures, including measures to reduce SO2 and 

nitrogen oxide (NOx) emissions from coal-burning facilities by 2018. 

• Within MANE-VU, the Class I states have the following commitment: 

- Timely implementation of BART requirements; 

- A focused strategy for the electricity generating units (EGUs) comprising a 90% 

reduction of sulfate emissions from 2002 levels from 167 stacks that modeling 

indicates affect visibility impairment in MANE-VU Class I areas; 

- A low sulfur fuel oil strategy with different implementation timeframes for inner zone 

states versus outer zone states, that results in a 38% reduction from non-EGU sector 

emissions in the MANE-VU region; and 

- Continued evaluation of other measures, including measures including energy 

efficiency, alternative clean fuels and other measures to reduce SO2 and nitrogen 

oxide (NOx) emissions by 2018. 

• Also outlined the national “ask” MANE-VU plans to make of the US EPA, for a Phase 3 

of CAIR that reduces SO2 by at least an additional 18%. 

• From presentation, next steps are: 

- Consult within and outside MANE-VU about which control strategies are reasonable; 

- Open a dialogue with the USEPA concerning a possible Phase 3 of CAIR; 

- Define strategies to include in the final modeling; 

- Determine goals based on the final modeling; 

- SIPs are due 12/17/07; 

- Adopt enforceable emissions limits & compliance schedules; and 

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August 6 2007 MANE-VU/MRPO Consultation Summary (DRAFT) 

- Progress evaluation due in 5 years. 

Discussion: 

• Question (Tom Easterly, Indiana): Are there emission rate targets instead of a flat 90% 

reduction? 

- Answer (Chris Salmi, New Jersey): No, and no net reductions. 

• Question (Tom Easterly, Indiana): Where do the emissions go? 

• Answer (Gary Kleiman, NESCAUM): MANE-VU EGU reduction on the order of 

68,000 TPY would be “rearranged.” They are spread out between all EGUs 

proportionately, except for those in the 167 stacks, to maintain the cap.Question (Tom 

Easterly, Indiana): Did MANE-VU use the 0.5dV exemption threshold for BART 

sources? 

- Answer (Gary Kleiman, NESCAUM): MANE-VU did not exempt any BART sources 

from the BART determination process. 

• Question (Mike Koerber, MRPO): What is the source of the MANE-VU numbers? 

- Answer (Gary Kleiman, NESCAUM): They are from MARAMA’s inventory work. 

National ask for EGU sector based on IPM results and increasing the SO2 ratios. 

• Comment (Mike Koerber, MRPO): The MANE-VU numbers are close to his, but we need 

to sync them up. 

• Comment (Tom Easterly, Indiana): Companies make economic analyses for installation 

of controls and we keep changing the rules on them. 

- Answer (Gary Kleiman, NESCAUM): They are spread out between all EGUs 

proportionately, except for those in the 167 stacks, to maintain the cap. 

Summary of Reasonable Progress Work for MRPO Class I Areas – Mike Koerber, MRPO 

Presentation:

• MRPO results consistent with MANE-VU analyses. 

• MRPO states still looking at strategies for their 4 northern Class I areas, nitrates a bigger 

share of visibility impairment, visibility impacts mostly from southerly transport. 

• With OTB measures, we are above glide path in 2018 for all 4 Class I areas. 

• Review of MRPO 5-Factor Analysis (including degree of visibility improvement) for 

reasonable progress. 

• Review of new visibility metric of $/dV improvement, additional control measures 

comparable in costs to existing OTB controls, most visibility improvement obtained from 

MRPO’s EGU1 (0.3dV) and EGU2 (0.4dV) strategies. 

• MRPO analysis regional in nature, not a focused EGU strategy like MANE-VU due to 

different source / receptor relationships. 

• Review of projected visibility levels, Seney above glide path in 2018, a lot more SO2 will 

need to be “squeezed” out of the system to achieve 2064 natural conditions. 

• Review of MRPO source apportionment analysis, MRPO contributes 10-15% of visibility 

impairment at Lye Brook in Vermont. 

• Conclusions and key findings from MRPO analyses: 

- Many Class I areas in the eastern half of U.S. expected to be below the glide path in 

2018 (with existing controls), including those in the Northeast; 

- Contribution analyses show closer states have larger impacts; and 

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August 6 2007 MANE-VU/MRPO Consultation Summary (DRAFT) 

- Regional emission reductions (in 2013-2018 timeframe), such as those identified in 

MANE-VU’s June 2007 resolutions, may be necessary to meet reasonable progress 

goals in the MRPO Class I areas and provide for attainment of new tighter PM2.5 and 

possibly tighter ozone standards in the MRPO states. 

Discussion:

• Question (Tom Easterly, Indiana): How do we deal with ammonia? 

- Answer (Mike Koerber, MRPO): EPA won’t touch it and ammonia is included in the 

analyses for completeness. 

• Question (Jeff Crawford, Maine): Are mobile measures included? 

• - Answer (Mike Koerber, MRPO): Only bundled measures including chip reflash and 

diesel retrofits where the states are not preempted from doing such measures. 

• Question (Tom Easterly, Indiana): Would a monthly electric bill of $150 be doubled? 

- Answer (Mike Koerber, MRPO): Yes, at least doubled. 

• Question (Dave Littell, Maine): Are ammonia controls from the agricultural sector 

assumed? 

- Answer (Mike Koerber, MRPO): Yes, assumes 10% ammonia reductions from best 

practices. 

• Question (Jeff Crawford, Maine): How much of the ammonia comes from CAFOs versus 

fertilizer application? 

 - Answer (Mike Koerber, MRPO): Two-thirds to three-quarters comes from CAFOs, but 

 urban ammonia sources are also important. 

• Question (Tim Allen, F&W Service): How much benefit is there from ammonia controls? 

- Answer (Mike Koerber, MRPO): The analysis shows that a 10% ammonia decrease 

that may be cost-effective will result in greater than a 0.10dV improvement. 

• Comment (Bruce Polkowsky, NPS): 10% is a lot. 

• Comment (Larry Bruss, Wisconsin): There is a lot of uncertainty when it comes to the 

effects of ammonia reductions. 

• Question (Doug Austin, MANE-VU): Is the $/dV analysis based on three states or nine? 

- Answer (Mike Koerber, MRPO): It is based on three states, and a nine-state analysis 

would be higher 

• Comment (Gary Kleiman, NESCAUM): MANE-VU saw almost identical MRPO 

contributions in the 10-15% range. 

• Comment (Chris Salmi, New Jersey): New Jersey is looking at performance standards for 

the 24-hour PM2.5 standard and a potentially tighter ozone standard. 

• Comment (Laurel Kroack, Illinois): Illinois would be interested if New Jersey could share 

that information. 

EPA and FLM Perspectives on RPGs and Reasonable Measures Work – Bruce Polkowsky, 

NPS; Chuck Sams, Forest Service; John Summerhays, EPA Region V; Todd Hawes, EPA - 

OAQPS 

Bruce Polkowsky, National Park Service

• Tomorrow is the 30th anniversary of the passage of the 1977 Clean Air Act Amendments 

that enacted section 169A and established the regional haze program. 

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August 6 2007 MANE-VU/MRPO Consultation Summary (DRAFT) 

• The uniform progress line is “useful,” but the 4-Factor analses are most important from 

FLM perspective. 

• Don’t forget the 20% clean days reasonable progress goal (VISTAS getting 1 dv 

improvement). 

• Are states being overly optimistic in their CAIR controls scenarios? Information coming 

in from states seems to be pointing to predicting a higher level of controls than what 

CAIR predicts. 

• The location of controls is important for visibility as seen in the MANE-VU 167 stack 

analysis. 

• The 2013 progress report is key, and it is important to know about new sources, too. 

• PM 2.5, ozone and regional haze issues are all coming together in the 2013-2018 

timeframe. The PM2.5 SIPs should take into account what the regional haze measures 

will achieve. Strategies should be coordinated to maximize their effectiveness for both 

regional haze, PM2.5, and ozone SIPs. 

• The FLMs encourage states to be as detailed as possible in their regional haze SIPs, 

including dates, for control measure development. It is up to EPA through the approval 

and disapproval process as to how they will react to state promises to pursue control 

measures in the regional haze SIPs. 

Chuck Sams, Forest Service

• There should be one hard copy of the regional haze SIP per FLM reviewer. 

• The FLM goal is for comments back to the states 30 days before their public hearings. 

• The FLMs need need the SIPs as soon as possible for their 60-day review. 

• The FLMs would would appreciate a summary sheet that provides a cross-reference as to 

when the specific items on their checklist can be found in the SIP. 

• There is an FLM expectation for ongoing consultation. 

John Summerhays, EPA Region V

• There are three main requirements of the Regional Haze Rule: 

- (1) Reasonable Progress – lots of questions about what conclusions and questions 

about what EPA will have as a requirement to the different scenarios; 

- (2) BART – haven’t seen much control taken on BART. EPA is thinking about how 

to ensure consistency in BART determinations by different states. EPA asks the RPOs 

to try to insure consistency across their states; and 

- (3) Consultations - RPOs have done valuable work in technical analyses and 

facilitating consultations. 

• EPA appreciates being part of the current process and continuing that participation into 

the future. 

Todd Hawes, EPA – OAQPS

• While EPA is not in a position to initiate consultations as required by the Regional Haze 

Rule, today’s meeting is a good representation of what they envisioned the consultation 

process would be. 

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August 6 2007 MANE-VU/MRPO Consultation Summary (DRAFT) 

• EPA is getting lots of questions from states about the regional haze SIPs. Some states are 

saying they are not going to set reasonable progress goals, while some say they are only 

going to do BART, use it for their reasonable progress goal with no analysis. 

• EPA is legally bound and expecting full SIPs on 12/17/2007 that include all of the 

required elements. It is not acceptable for states to say they do not have the time or 

resources, or that the SIP cannot be done by December 17. 

• The EPA lawyers are working on “what if” scenarios. 

Discussion:

• Question to FLMs and EPA (Dick Valentinetti): Will the Federal agencies comment on 

the extent of agreement and disagreement on strategies? 

- Answer (Bruce Polkowsky, NPS): Yes, they will. 

• Comment (Tim Allen, F&W Service): They will also be looking for regional consistency 

and that the various emission reductions for meeting the Class I reasonable progress goals 

are proportional between the states. They may comment more on any disagreements 

between RPOs. 

• Comment (Bruce Polkowsky, NPS): The continuing consultation requirement is in 

308(i)(4). The MANE-VU states have provided input on format and frequency. The 

monitoring aspects are crucial and especially important to consult about. 

• Question to EPA (Bruce Polkowsky, NPS): The long-term strategy is a 10-year strategy 

from rule adoption, but are promises to look at reductions approvable? 

- Answer (Todd Hawes, EPA): Realistically, we have to see what comes in December. 

They realize that they will not get 100% approvable SIPS in December 2007 and will 

have to see then what they will do about it. 

• Comment (Bruce Polkowsky, NPS): FLMs would rather have a SIP later that has all 

elements rather than one that is on time that does not. 

• Question to EPA (Susan Wierman, MARAMA): Can EPA process the BART SIPs first to 

start BART clock? 

- Answer (Todd Hawes, EPA): Yes, they are discussing BART severability, and it 

would be easier to consider BART first if they get a complete SIP. 

• Comment (Susan Wierman, MARAMA): Holding up BART approvals due to 

incompleteness of the rest of SIP would be unfortunate. Glad to hear EPA discussing this 

issue. 

• Comment (Todd Hawes, EPA): They have 6 months to deem complete. 

• Question to MANE-VU (John Summerhays, EPA): How are BART compliance dates set 

in M-V? 

- Answer (Susan Wierman, MARAMA): Some states are setting the date to be “as 

expeditiously as practicable.” The states need to be doing their best to get BART 

controls in place as we do not want a repeat of the NOx SIP call delays. The BART 

requirement is one of the best ways in the Clean Air Act for getting old facilities 

controlled. 

• Question to MRPO (Todd Hawes, EPA): Can I get clarification on the $/dV metric 

developed by MRPO? Is there any cost-effectiveness breakpoint? 

- Answer (Mike Koerber, MRPO): It is a reference point. 

• Question to EPA (Chris Salmi, New Jersey): How will EPA react to inconsistencies 

between state SIPs? 

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August 6 2007 MANE-VU/MRPO Consultation Summary (DRAFT) 

- Answer (Todd Hawes, EPA): The rule says EPA is the arbiter of any disagreement and 

there is little guidance beyond that. EPA would lean heavily on consultation 

documentation, but EPA will ultimately have to decide. 

• Comment to EPA and FLMs (Chris Salmi, New Jersey): It is one of the MANE-VU 

Class I States principles that the FLMs will help identify and EPA will act upon any 

inconsistencies. 

Roundtable Discussion on Reasonable Progress Goals and Reasonable Measures

 States continued the consultation with a roundtable discussion open on all issues raised 

during the Open Technical Call and this consultation meeting. Most of the discussion focused on 

the substance of the MANE-VU statements, or “asks” from the MRPO states and from the U.S. 

EPA. 

ICI Boilers, MACT and NOx/SO2 RACT

 During the Open Technical Call it was suggested that there may be an opportunity to 

examine the scope of the ICI boiler sector and potential emission reductions from that source 

category. Several states brought up the recent vacatur of the Boiler MACT in terms of the 

possibility for states to work together on this sector. NACAA is discussing with its members and 

the Ozone Transport Commission and Northeast States for Coordinated Air Use Management an 

effort to develop a Boiler MACT model rule. While for Boiler MACT this effort would focus on 

hazardous air pollutants (HAPs), including volatile organic compounds (VOCs), it may be 

possible to include in that project a parallel process to gather information on NOx and SO2 

emissions from the boiler sector and develop options for control strategies, separate from the 

MACT levels. 

 MANE-VU states also inquired about what MRPO states are doing for PM 2.5 

attainment. Many of the MRPO states are focusing on local sources for urban excess, and it 

appears that EPA is discouraging a focus on regional strategies. Illinois informed the group that 

it has a multi-pollutant agreement including scrubbers. Illinois also has a statewide NOx RACT 

proposal with stringent levels and is working on SO2 RACT, such as low sulfur diesel for nonroad and refinery SO2 reductions. These RACT proposals are working their way through 

Illinois’ regulatory processes, so they are not yet included in SIPs and are not reflected in 

MRPO’s modeling. Michigan may also look at statewide RACT under the new PM2.5 standard. 

 In addition to the work done by the ICI boiler workgroup, OTC has completed some 

regional inventory work on its ICI boilers and NESCAUM is completing a study on ICI boilers 

that was sponsored by EPA. All of this work can be included in the review of this sector. 

Follow up items from this discussion include:

• Reconvene MANE-VU/MRPO ICI Workgroup that was initiated under the State 

Collaborative to re-examine ICI boiler work and define next steps; 

• Contact NACAA about possible addition to Boiler MACT model rule work to examine 

potential for NOx and SO2 reductions and identify strategies; and 

17
August 6 2007 MANE-VU/MRPO Consultation Summary (DRAFT) 

• Look at pursuing SO2 RACT regionally, as well as asking EPA again for an ICI national 

rule. 

Low Sulfur Fuels 

In addition to the low sulfur fuel measures that MANE-VU is pursuing, the states 

discussed other areas of opportunity for low-sulfur fuels, including nonroad low-sulfur diesel. 

Illinois indicated that they will be talking to their four refineries about non-road low-sulfur diesel 

Michigan indicated that they are looking at a possible executive order mandating low-sulfur nonroad diesel for state contracts. MRPO states also expressed interest in low-sulfur fuel for 

locomotives. 

 New Hampshire inquired as to whether the cost for biodiesel is similar to low-sulfur 

diesel, and suggested that we share information on biodiesel as an option. New Jersey expressed 

interest in ocean-going vessels as a source sector for low-sulfur fuel opportunities. The National 

Park Service folks indicated that there is a recent World Trade Organization agreement that 

could be of use in this regard, and that this is a sector that the VISTAS and WRAP states are also 

looking into. 

Follow up items from this discussion include:

• Look at federal rules that are in the works for non-road, locomotive and marine engines 

to see if there are gaps or opportunities that MANE-VU and MRPO could explore 

together; and 

• Share information on biodiesel as a low-sulfur fuel option. 

State/Regional EGU Strategy 

 States discussed the EGU strategy proposed by the MANE-VU Class I areas, regarding a 

focus to pursue reductions of 90% or greater from the 167 stacks identified on the MANE-VU 

list. The MANE-VU states have agreed to pursue 90% EGU reductions and a low-sulfur fuel oil 

strategy. MRPO states will continue to examine what the potential for reductions are at these 

units, and provide information about which sources in their states are putting controls on, to 

better inform the process and our modeling. According to the information MRPO has at this 

time, over 70% of the emissions from the 167 stacks on the list will be scrubbed. The question 

remains whether that will be enough, or whether MRPO will still need to address the remaining 

30% even if it has a very low impact. Another issue was raised regarding whether it would be 

acceptable for MRPO states to substitute reductions from the non-EGU sector that go beyond the 

28% level for reductions that may not be obtainable in the EGU sector. MANE-VU states 

indicated that this would likely be acceptable, depending on the location and type of non-EGU 

source. 

 MANE-VU states raised the question as to whether the 70/30 split is the same for the rest 

of the EGUs, i.e. those in the MRPO region that are not part of the 167 stacks on the list. MRPO 

responded that they can get that information and provide it to MANE-VU. For example, IPM 

indicates that Rockport will be getting controls, while MRPO’s information from the source is 

18
August 6 2007 MANE-VU/MRPO Consultation Summary (DRAFT) 

that they will not. There is also a concern that cumulatively, the controls that the EGU sources 

say are going on will be larger than what is required by CAIR, i.e., it will not reflect reductions 

that will be “sold” on the trading market, or what units they will be sold to, to keep emissions at 

the CAIR budget level. 

 Another concern was raised regarding the addition of controls to older EGUs and how 

they can be permitted given NSR issues for increases in other emissions. Some states responded 

that it has been possible to add scrubbers to older units and address increases in other emissions 

by fine-tuning the control systems. 

 Generally, while the concept is feasible, MRPO states anticipate needing more assistance 

and information from the MANE-VU Class I areas to understand the justification for controls on 

these units. In addition, it will be helpful to look at ways to incentivize the retirement/closing of 

old units and their replacement with cleaner technology, such as through output-based standards. 

We will also need to work together to craft language that will work in our SIPs to reflect the 

approach that MANE-VU is requesting that will be acceptable to EPA. 

Follow up items from this discussion include:

• Continue to share specific information about what MANE-VU and MRPO sources are 

anticipating as controls on EGUs as compared to what is indicated in IPM modeling; 

• Update our inventories and databases accordingly so that our information is “synched”; 

and 

• Continue dialogue on approaches for addressing this sector to meet the 90% reduction 

target for the 167 stacks and on equivalent alternatives. 

National “Ask” for CAIR Phase III 

 There is interest from some MRPO states in joining MANE-VU in its “ask” for a Phase 

III of CAIR. All of the MRPO states will review and consider the option as we continue our 

consultation process. For many MRPO states the real concern is obtaining PM 2.5 reductions; 

regional haze is not their primary concern. As we continue to discuss the national “ask” we need 

to develop control levels that will help all of our states with attainment for ozone, PM and 

regional haze. MANE-VU based its request on the recent IPM modeling work done on the levels 

that came out of the state collaborative work. Those levels are not as stringent as those that are in 

the original OTC multi-pollutant position, and we are iin the process of reviewing them. 

Follow up items from this discussion include:

• MANE-VU to revisit its multi-pollutant strategy; 

• MRPO and MANE-VU to have discussions on potential multi-pollutant control levels for 

a CAIR Phase III; and 

• Craft a revised national “ask” to reflect revised levels, as appropriate. 

NEXT STEPS 

In addition to the agreements reached during the discussions (listed at the beginning and 

in the roundtable discussion sections of this document) the MANE-VU Class I states and the 

19
August 6 2007 MANE-VU/MRPO Consultation Summary (DRAFT) 

MRPO states agreed to continue the consultation dialogue on the upcoming State Collaborative 

call, scheduled for 10:00 am CDT, 11:00 am EDT on Thursday, August 16th. The states will 

continue discussions from today’s meeting, bring forth additional issues as necessary, and have a 

first opportunity to review and discuss the draft documentation of the consultation. 

20
Appendix 3D 

EPA Ask Letters 
September 2, 2009 

The Honorable Lisa P. Jackson, Administrator 

U.S. Environmental Protection Agency 

Ariel Rios Building 

1200 Pennsylvania Avenue, NW 

Mail Code 1101A 

Washington, DC 20460 

Dear Administrator Jackson: 

On behalf of 17 states in the eastern half of the U.S., we wish to provide the following 

recommendations to the Environmental Protection Agency (EPA) to consider as it 

develops a replacement rule for the Clean Air Interstate Rule (CAIR), in light of the 

December 23, 2008, remand by the U.S. Court of Appeals for the D.C. Circuit. 

The recommendations follow through on the commitment we made in the March 9, 2009, 

Framework Document to work together to address the transport requirements of Section 

110(a)(2)(D) of the Clean Air Act (CAA), and to attain the ozone and PM2.5 National 

Ambient Air Quality Standards (NAAQS). Please understand that in preparing these 

recommendations our fundamental air quality objective is to achieve attainment and 

ensure maintenance of the NAAQS as expeditiously as practicable. 

As the result of our collaboration, we recommend for your consideration a framework, 

which is based on in-depth technical evaluations and a sincere and concerted effort by 

all states to reach common ground on an overall approach to addressing transport. This 

comprehensive framework comprises national rules involving significantly contributing 

states that combine statewide emissions caps and complementary regional trading 

programs with a state-led planning process to address transport in a multi-pronged and 

layered approach. While the undersigned states have reached consensus on this 

suggested framework, there are some regional differences concerning the timing and 

stringency of electric generating unit (EGU) reductions, and the criteria for determining 

which states are included in the state-led planning process. In addition, the states differ 

in their perspectives on whether performance based standards should be part of the 

strategy. 

The Lake Michigan Air Directors Consortium (LADCO) and the Ozone Transport 

Commission (OTC) will be submitting separate letters to explain their perspectives on 

these areas of regional differences on implementation of the framework. 

Many areas in the eastern U.S. are designated as nonattainment for the current ozone 

and PM2.5 standards (1997 version), and it is expected that even more areas will not be 

in compliance with 2008 ozone and 2006 PM2.5 standards. Numerous data analysis and 

modeling studies have shown that some (not all) of these nonattainment problems are 

strongly influenced by inter-state transport. 

Additional regional emission reductions will be necessary to help states meet the new air 

quality standards. A timely and robust federal program that requires substantial regional 

emission reductions from mobile sources, area sources and large point sources such as 
Page 2 of 6

EGUs is an essential component of any strategy to reduce interstate transport of air 

pollution. These reductions are necessary to attain and maintain compliance with the 

NAAQS. 

The undersigned states recommend a 3-step approach, as further discussed below, to 

establish a framework from which to address the requirements of CAA section 

110(a)(2)(D): 

1. Identifying areas of interest (i.e., those not meeting the standards and those 

struggling to maintain the standards); 

2. Identifying, based on specific criteria, upwind states which contribute to 

nonattainment or interfere with maintenance in these areas of interest; and 

3. Implementing a multi-sector remedy to meet CAA requirements. 

Step 1 - Identifying Areas of Interest 

A. While the requirements of Section 110(a)(2)(D) apply to all areas, most attention 

should be given to those areas not meeting or struggling to maintain the NAAQS. 

These "areas of interest" should be identified using monitoring and modeling 

data. 

B. Specifically, areas with both base monitored design values and future modeled 

design values above the applicable NAAQS should be designated as areas of 

interest. The monitored design values are based on the maximum design value 

from the periods 2003-2005 through the most recent three-year period, and the 

future modeled values are based on future year modeling which reflects legally 

enforceable control measures and a conservative model attainment test - i.e., 

use of maximum design values rather than average design values. 

1. The use of maximum design values and a conservative model attainment test 

are intended to account for historic variability, which is necessary to ensure 

maintenance. An alternative means of accounting for historic variability is to 

conduct a statistical analysis of the year-to-year variation in meteorology. 

2. Requiring a more conservative model attainment test will necessitate a 

change in EPA's modeling guidance. EPA should also establish performance 

criteria to insure that the modeling is capturing transport appropriately. 

3. EPA's approach in CAIR also reflects a "monitored and modeled" test to 

identify areas of interest. 

Step 2 - Identifying Upwind States that Significantly Contribute to Nonattainment 

or Interfere with Maintenance 

A. An upwind state significantly contributes to nonattainment or interferes with 

maintenance in a downwind area of interest if its total impact from all source 

sectors equals or exceeds 1% of the applicable NAAQS. 
Page 3 of 6

B. Individual state contributions should be determined through a weight-of-evidence 

approach, including source apportionment modeling. 

C. Use of 1% of the NAAQS as the significance threshold is consistent with EPA's 

approach in CAIR. 

Step 3 - Implementing a Multi-Sector Remedy to Meet Clean Air Act Requirements 

A two-part process is recommended consisting of: (A) a national/regional control 

program adopted by EPA for EGUs and additional federal control measures for 

other sectors, and (B) state-led efforts to develop, adopt, and implement federally 

enforceable plans for each area of interest that is not expected to attain the 

standards even after implementation of the national/regional program. 

A. National/Regional Control Program

A significantly contributing state (i.e., a state which contributes at least 1% to a 

downwind area of interest) must comply with the national/regional control 

program described below. 

1. EGU point source strategy (applicable to units > 25 MW) 

In adopting a CAIR replacement rule EPA should: 

(a) make federally enforceable through appropriate mechanisms all 

nitrogen oxide (NOx) and sulfur dioxide (SO2) controls to comply 

with the original CAIR Phase I program; 

(b) make federally enforceable through appropriate mechanisms 

optimization by no later than early 2014 of existing NOx and SO2

controls; 

(c) make federally enforceable through appropriate mechanisms 

application by 2015 of low capital cost NOx controls; 

(d) establish statewide emission caps by no later than 2017 for all 

fossil fuel-fired units ≥25MW. The caps should reflect an analysis 

of NOx and SO2 controls on coal-fired units ≥ 100 MW which, in 

combination with the three measures above, will achieve rates 

that are not expected to exceed 0.25 lb/MMBTU for SO2 (annual 

average for all units ≥25 MW) and 0.11 lb/MMBTU for NOx (ozone 

seasonal and annual average for all units ≥25 MW) and which will 

result in lower rates in some states. Previously banked emissions 

under the Title IV or CAIR programs shall not be used to comply 

with the state-wide emission caps; and 

(e) to the fullest extent allowed under the Clean Air Act, EPA should 

work with the states to establish regional emissions caps with full 

emissions trading to replace the caps currently applicable under 

CAIR. 
Page 4 of 6

Again, there are regional differences on some elements of the EGU point 

source strategy, including mechanisms for achieving reductions prior to 

2017. Further recommendations will be provided in separate letters by 

LADCO and OTC. 

2. Non-EGU point source strategy 

a. EPA should identify and prioritize other categories of point 

sources with major emissions of NOx and/or SO2 (e.g., cement 

plants) based on a review of available emissions inventories and 

other information, such as source apportionment studies. 

b. For the non-EGU point sources, EPA should identify and evaluate 

control options for reducing NOx and/or SO2 emissions. The 

evaluation should consider the technological, engineering, and 

economic feasibility of each control option. 

c. At a minimum, EPA should evaluate the technological, 

engineering, and implementation feasibility, and cost-effectiveness 

of controlling SO2 and NOx emissions from industrial, commercial, 

and institutional boilers > 100 MMBTU/hour. 

3. Mobile source strategy, such as new engine standards for on-highway 

and off-highway vehicles and equipment, and a single consistent 

environmentally-sensitive formulated fuel. 

4. Area source strategy, such as new federal standards for consumer 

products and architectural, industrial and maintenance coatings as 

originally promised by EPA in 2007 

B. State- Led Attainment Planning 

The undersigned states recommend the use of a state-led attainment planning 

process concurrent with developing the transport SIP to address areas of interest 

that are not expected to attain after implementation of the national/regional 

control program. The state-led planning effort should involve a key subset of 

significantly contributing states to develop, adopt, and implement an appropriate 

attainment strategy. EPA should work with the states to establish criteria for 

determining which significantly contributing states should be involved in the stateled planning process. Additionally EPA should work with the states to determine 

the appropriate criteria for each state to satisfy CAA section 110(a)(2)(D). The 

advantages of this state-led planning effort include: 

• A one-size-fits-all federal solution cannot provide the most appropriate 

and cost-effective solution for each area; 

• Attainment planning is more effective and more likely to succeed if it is 

done on a non-attainment area basis with a key subset of contributing 

states; 

• Additional controls are identified where they are needed; and 

• States maintain their responsibility under the Clean Air Act to establish 

state implementation plans. 
Page 5 of 6

Further recommendations on this issue will be provided in separate letters by 

LADCO and OTC. 

The comprehensive framework outlined above represents the culmination of our 

collaborative work over the past six months. We look forward to working with you further 

as EPA develops its CAIR replacement rule. 

Sincerely, 

______________________ _______________________ 

Connecticut District of Columbia 

______________________ ________________________ 

Illinois Indiana 

_______________________ _______________________ 

Maine Maryland 

 

______________________ ______________________ 

Massachusetts Michigan 

______________________ _______________________ 

New Hampshire New Jersey 

______________________ ______________________ 

New York Ohio 

______________________ _______________________ 

Pennsylvania Rhode Island 
Page 6 of 6

______________________ ______________________ 

Vermont Virginia 

______________________ 

Wisconsin 

Performance Standards: We understand that EPA is considering a hybrid approach in its 

CAIR replacement rule involving regional emissions trading and unit-specific performance 

standards (cite: July 9, 2009, testimony by Regina McCarthy before the Subcommittee on 

Clean Air and Nuclear Safety, Committee on Environment and Public Works, U.S. Senate). 

As discussed in the September 2, 2009, joint letter, we strongly support and encourage EPA 

to include regional emissions trading to the fullest extent allowed under the Clean Air Act. 

We believe, however, that unit-specific performance standards go beyond the requirements 

of section 110 and the scope of a CAIR replacement rule; inhibit trading; and that 

performance standards with a near-term compliance timeframe, such as 2017, are not 

practical for all EGUs. Although we firmly believe that it is not appropriate to include 

performance standards in a CAIR replacement rule, if EPA decides to consider including 

performance standards, then EPA should work with the states to take into account the basis 

and timing of the requirements identified in the September 2, 2009, joint letter, cost 

effectiveness, site specific factors (such as space limitations) and the pollution control 

equipment already in place on the existing fleet of EGUs. Specifically, on this last point, we 

believe that EPA should not require replacement or repowering of units or control systems 

that are sound technology and operating at a reasonable effectiveness. 

LADCO Recommendation 2 

B. State- Led Attainment Planning 

We recommend the use of a state-led attainment planning process concurrent with developing 

the transport SIP to address areas of interest that are not expected to attain after 

implementation of the national/regional control program. The advantages of this state-led 

planning effort include: 

 A one-size-fits-all federal solution cannot provide the most appropriate and cost-effective 

solution for each area; 

 Attainment planning is more effective and more likely to succeed if it is done on a nonattainment area basis with a limited number of states; 

 Additional controls are identified where they are needed; and 

 States maintain their responsibility under the Clean Air Act to establish state 

implementation plans. 

A major contributing state (i.e., a state which contributes at least 4% to a downwind area of 

interest that is not expected to attain after implementation of the national/regional program) 

must also either: 

1. In conjunction with other major contributing states, develop, adopt, and implement an 

appropriate attainment strategy for the area of interest, as follows:

a. An upwind state’s responsibility for achieving air quality benefits in a downwind area 

should be commensurate with the magnitude of the upwind state’s contribution to the 

downwind air quality problem. 

b. To facilitate flexibility in developing control programs and reduce control costs, state 

planning efforts should accommodate interstate emissions trading to the fullest extent 

allowed by the Clean Air Act. 

c. Photochemical modeling, performed in accordance with EPA modeling guidance, 

should be conducted to determine the amount of emission reduction needed to provide 
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OTC appreciates the efforts put forth by EPA to work with all interested 

stakeholders in developing a CAIR replacement rule based on sound science. OTC 

further acknowledges that air pollutant transport within the OTC region is a significant 

issue that EPA should also address. The CAIR replacement rule should also recognize 

that our planning processes continue to evolve in the face of ever-tightening standards 

and newly uncovered air quality concerns, such as the impact of peaking unit emissions 

on high electricity demand days (HEDD). As such, OTC recommends that EPA propose 

measures to address HEDD emissions in the CAIR replacement rule. 

Our recommendations are provided below in three parts. OTC considers these 

recommendations feasible, practicable and operable within the framework of the existing 

Clean Air Act, all of which facilitate a rapid adoption process as directed by the D.C. 

Circuit Court of Appeals in remanding CAIR. The CAIR replacement rule offers an 

opportunity for transformational change over incremental improvement. Providing 

regulatory certainty to America’s electric generating sector promotes transformational 

change through business decisions that support our air quality goals. A summary of the 

technical analyses conducted by the OTC States and provided as support 

documentation for the recommendations provided in this letter and the September 2, 

2009 letter is attached to support these recommendations. 

A. Achievable EGU Limitations

The OTC States recommend that EPA consider a comprehensive, multi-layered, 

hybrid approach for obtaining further reductions from EGUs. This hybrid approach 

combines state and regional caps with phased-in performance standards to costeffectively reduce nitrogen oxide (NOx) and sulfur dioxide (SO2) emissions. The 

components of this strategy (enforceable conditions, state-by-state reductions, regional 

trading caps/program and phased performance standards), should coordinate with each 

other and other EGU control initiatives such as federal MACT standards and greenhouse 

gas reduction programs. 

A national strategy for EGUs should be implemented in phases. The first phase 

should combine federally enforceable NOx and SO2 reductions from each state with a 

regional trading program. A later phase should include performance standards to 

achieve continuing reductions from the EGU sector over the course of the regulatory 

time frame for implementation of the 2008 ozone and 2006 PM2.5 NAAQS. 

Timing is essential to meet attainment obligations. Three years of data are 

needed to demonstrate attainment; therefore reductions are needed three years prior to 

the attainment deadline. While we recognize that full implementation of all controls may 

not be achieved in that time frame, it is essential that enforceable mechanisms be 

provided to lock in controls that are achievable. The OTC-LADCO submission reflects 

the participating states’ agreement on state-specific caps that would be applicable no 

later than 2017. Years prior to 2017 may be critical for many states to demonstrate 

attainment with the applicable NAAQS. The OTC States seek to work with EPA to 

develop mechanisms for achieving interim reductions in the 2012-16 time period, 

including the possibility of interim state-specific caps in addition to a regional cap-andtrade program. 
Page 3 of 6

Since CAIR was not sufficient for attaining and maintaining the 1997 ozone 

NAAQS, EPA will need to make the limits in the CAIR replacement rule stricter to enable 

compliance with the recently revised ozone and PM NAAQS and any tighter standards 

that EPA enacts after reconsideration of those standards. The state caps are also 

necessary to ensure that each State contributes fully to the needed reductions. 

Specifically, the OTC States propose that EPA include phased state-by-state 

reductions, complementary regional emission trading caps as early as possible (but no 

later than 2014), and performance standards as follows: 

1. State-by-State Reductions 

The September 2, 2009 letter recommends the implementation of state 

caps by no later than 2017 that reflect the emission rates that would be achieved 

through installation of SCR and FGD controls on all coal-fired EGUs of 100 MW 

or larger in all significantly contributing states. In addition, the participating states 

recommend in that letter a number of interim measures including operation and 

optimization of all controls currently in place or being installed to meet other 

requirements, and installation and operation of all feasible, low capital cost NOx 

controls such as selective non-catalytic reduction (SNCR) and low NOx burners 

(LNB) not currently installed or in use on existing EGUs on a unit basis by 2015. 

 

The OTC States recommend that EPA analyze and determine the stateby-state reductions needed prior to 2017 in order to address CAA Section 

110(a)(2)(D) requirements to address interstate transport from EGUs within the 

NAAQS timeframe. The OTC States see interim state-by-state reductions prior 

to 2017 as a key part of addressing the Court of Appeals concerns over what is 

needed to satisfy the requirements of CAA Section 110(a)(2)(D). 

2. Regional Trading Programs for NOx and SO2.

As explained in the September 2, 2009 submission, the second key 

element of the OTC-LADCO agreed framework for a CAIR replacement rule is 

the implementation of regional trading programs for both NOx and SO2, to 

complement the state-by-state caps described above. The OTC States 

recommend that EPA consider the following in developing the regional caps: 

• The new regional caps should be implemented as early as possible 

and set at a level that will drive deeper regional NOx and SO2

reductions than the regional reductions that would result from the 

implementation of the state-by-state caps by themselves. This pairing 

of state-by-state caps with an aggressive regional trading program will 

guarantee specific reductions in each state while also using market 

forces to further reduce regional emissions at lowest cost. 

• OTC’s analysis (attached) and the analysis that EPA recently 

prepared for Senator Carper show that stringent regional trading caps 

for NOx and SO2, implemented as early as possible (but no later than 

2014), would provide significant public health benefits that 

substantially outweigh the costs. 

• Banking and inter-state trading would continue to be allowed in the 

regional trading program. 
Page 4 of 6

• To be creditable under Section 110(a)(2)(D), controls installed in 

response to the regional trading program should be made federally 

enforceable through an appropriate mechanism. 

3. Performance Standards

We understand that EPA is also considering a hybrid approach in its 

CAIR replacement rule involving regional emissions trading and unit-specific 

performance standards (cite: July 9, 2009, testimony by R. McCarthy before the 

Subcommittee on Clean Air and Nuclear Safety, Committee on Environment and 

Public Works, U.S. Senate). 

The OTC States request that EPA work with the states to develop and 

phase in unit-specific performance standards that owners of fossil fuel-fired units 

should comply with between 2017 and 2025, or earlier if EPA’s technical analysis 

demonstrates that an earlier date is reasonable. Performance standards should 

either be output-based or transition to output-based standards to reward 

efficiency. Such performance standards will give regulatory certainty to EGU 

owners and encourage transformational change in the energy market. In 

developing these performance standards: 

• EPA should consider fuels, types and sizes of EGUs, the timing of 

other requirements included in this and the September 2, 2009 letter, 

cost-effectiveness and the pollution control equipment already in 

place on the existing fleet of EGUs. 

• EPA should phase-in the performance standards to maximize 

efficiency and minimize costs to affected sources. For example: 

o The performance standards for coal-fired units greater than 

100 MW should be coordinated with the state-by-state caps 

that are recommended for no later than 2017. 

o The performance standards for units subject to the upcoming 

federal MACT requirements should be coordinated with the 

MACT requirements. 

• In later phases (2020 to 2025), the performance standards should be 

coordinated with greenhouse gas reduction programs and other 

energy efficiency initiatives and be output-based. 

• OTC’s analysis (attached) shows that performance standards on 

larger fossil-fuel fired EGUs (based on a 30-day rolling average) are 

feasible and should be implemented on an aggressive timeframe (as 

early as 2017). 

• EPA should consider including incentives (e.g., alternative compliance 

schedules not to exceed three years), to promote the repowering or 

replacement of existing units. 

• After the adoption and implementation of performance standards, 

EPA should evaluate the feasibility of eliminating the state-by-state 

caps. 
Page 5 of 6

B. State-led Planning Process 

The OTC States recommend that the state-led planning effort include all 

significantly contributing states (i.e., 1% of the NAAQS or greater impact) unless each 

state in the affected nonattainment area chooses to reduce the number of states 

involved. 

• The OTC believes that this is the most appropriate way to identify 

those states that are required to participate in the state-led planning 

process as model performance (related to long-range transport) varies 

from one nonattainment area to another and the meteorology that 

affects some nonattainment areas is very complex. 

• The states in the nonattainment area would use monitoring data, 

modeling and other information on ozone transport, meteorology, 

emissions, control programs, geography and chemistry to decide 

which significantly contributing states, if any, should be excused from 

the state-led planning process. 

• Two scenarios are outlined below: 

o If the states in a nonattainment area have technical data that 

show that the state-led planning process for that area should 

be limited to just three or four states, that would be 

appropriate. 

o If the states in a nonattainment area are subject to highly 

complex transport patterns, it is most likely necessary to 

include all significantly contributing states in the state-led 

planning process. 

• The OTC believes that the most appropriate way to address transport 

is through a suite of aggressive national programs to reduce NOx, 

VOC and SO2 emissions from EGUs, other stationary sources, area 

sources and off-road and on-road mobile sources and that the role of 

the state-led planning process should be secondary. 

• The OTC continues to have serious concerns over model 

performance related to long-range, aloft transport. It is critical for EPA 

to establish and implement performance criteria related to aloft 

transport to ensure that the process for identifying significantly 

contributing states is credible. 

• As indicated in the September 2, 2009 joint letter, additional controls 

may be required where needed. 

C. Eliminating Significant Contribution 

The OTC States recommend that under the state-led attainment planning 

process, both the upwind states and EPA remain accountable to address contributions 

to downwind areas’ nonattainment of both the ozone and PM2.5 NAAQS by the relevant 

attainment dates, without designing any new “off-ramp” that avoids direct and timely 

action to reduce emissions that are in violation of CAA Section 110(a)(2)(D). 

 In addition to a program of controls for EGUs, OTC also urges EPA to address 

interstate transport through the development and implementation of national rules in 
Page 6 of 6

2012 or as early as feasible for additional controls on non-EGU sources, as supported in 

prior statements of the OTC to EPA. (See, e.g., Statement on the Need for National 

Rulemaking and Implementation of Ozone Control Measures, November 14, 2007). 

 

In acting on these recommendations, EPA can use the CAIR replacement rule to 

provide regulatory certainty to the EGU sector, which will enable business decisions that 

will move us many steps toward improved air quality and a more efficient electricity 

generating sector. We look forward to talking with you further about our 

recommendations for the CAIR replacement rule, and working with your staff as you 

expeditiously develop this important air quality and public health program. 

Sincerely, 

______________________ _______________________ 

Connecticut District of Columbia 

_______________________ _______________________ 

Maine Maryland 

 

______________________ ______________________ 

Massachusetts New Hampshire

______________________ _______________________ 

New Jersey New York

 

______________________ _______________________ 

Pennsylvania Rhode Island 

______________________ 

Vermont 

Enclosures