## Appendix 1A

List of Class I Areas In or Impacted by

Midwest RPO States

### List of Class I Areas In or Impact ed 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 Plan ning Organization (MRPO) St ate. A variety of technical analyses were considered in developing the draft list, includ ing 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 are a located within the State and in each mandatory Class I Fed eral 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 ar eas in the e astern 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 20 0 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 PM 2.5 mass and individual PM 2.5 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 WR AP indicate that the Midwest RPO States are not important contributors to visibility impairment due to sulf ates 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 out side-WRAP contribution is generally small (on the order of 0-15%), and is likely due mostly to nearby CENRAP states.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 estimat ed the impact of 18 geo graphic sour ce regions and 6 source sectors (E GU 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.Figure 2. Source region contributions to light extinction based on MRPO PSAT modeling for

select Class I areas: Sen e y, 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 o f sulfate-driv en 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 condition s: 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.Figure 3. Percent contribution results using diffe rent 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) Missouri-Arkansas Contribution Assessment The draft Consultation Plan for the two Missouri and two Arkansas Class I areas provides

information on source re gions affect ing these Class I areas ( i .e., areas of influence) using a variety of data and analyses. (cite: “Central Cla ss 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 CEN RAP 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 t i me plots based on wind trajectory di rection 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 overla yed 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.Figure 5. Areas of Influence for Shenandoah (lef t) 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 rad ii from Class I area, red line perimeter indicate

AOI w i th residence time > 10%, and orange line perimeter indicate AOI with residence time > 5%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 W ilderness 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.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 A nalyses 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

### 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 fr om the Forest Service (FS), a joint set from the Fish and Wildlife Service (FWS) an d National Park Service (NPS), and one set

from the Environmental Pr otection Agency (EPA).

Comment: Two comments (FS and EPA) expressed a concern for how the reasonable progress goals (RPGs) will account for BAR T. The reasonable progress goals are based on modeling runs that do not reflect BART determinations in Michigan and other

states. While future haze leve ls are difficult to predict, especially due to uncertainties regarding utility control requirements and cont rol levels, the EPA will expect Michigan to establish reasonable progress goals that re flect at least an approximation of BART

control levels. There is still no statement in the State Implementat ion 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 elsew here. 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 includ e 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 sour ces 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 la ter in their letter, th ey are particularly interested in planned controls for the top co ntributing sources as illustrated in Tables

10.3.2a-d. Response: The DNRE has added information on EGU c ontrols to Section 5.3 of the

SIP document.

Comment: Two comments (FS and FWS/NPS) ques tioned how Michigan responded to the MANE-VU ask. According to the Region al Haze Rule, such consultations are not expected to result in agreement on ever ything, but the areas of agreement and disagreement that occur via consultation are to be documented in t he SIP. They found some lengthy meeting notes but no list of specific areas of agreement and disagreement between Michigan and MANE-VU. Thei r 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 identif ied in Michigan are controlled adequately? 3) What is planned for control of those stacks and of th ose 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 E PA. 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 spec ific dialogue with MANE-VU to address

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

Comment: The FWS and the NPS comm ented 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 assume s that RPGs are met, despite data showing that the cleanest days are in fact getting dirtier. (See Table 5.2b, Haze Results). Therefore, progre ss in meeting regional haze goals is not demonstrated in the plan as it is currently drafted. Response: The DNRE believes that there are seve ral reasons that could explain the cleanest days showing degradation. Modeling is not an exact science and a reasonable interpretation of the modeling is that ther e 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 assu mptions 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, indicati ng 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 t ools used, and a description of model performance establishing the level of c onfidence 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 IMPRO VE monitoring data, which illustrates the importance of sulfate, nitrate, and organic carbon to visibility impairment, and how Michigan is using these data to def ine its emission control priorities.

• Response: Over time, as the DNRE continue s to evaluate the haze problem in Michigan, we will determine whether our emission control priorities need to be

revised.

• More discussion regarding all emission in ventories, the inventory development methods, and the assumptions made with all iterations in inventory development.

• Response: The emissions inventory is thor oughly 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 r egional nature of regional haze, Michigan’s test for significance, based on wh ether a state contributes 5% of the regional haze, is too exclusive a test. Although t he EPA does not specify a particular test of significance for states to use, the alte rnative contemplated by Michigan, based on

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

whether a state has a contribut ion that warrants addressing. Response: The DNRE disagrees. As explained in Appendix 1A, the back trajectory and modeling results showed that states cont ributing 2% (or more) make up about 90 to 95% of total light extinction, whereas states contributin g 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 st ates is adequate. In future years this will be re-evaluated and a larger impacti ng group of states may be appropriate.

Comment: The EPA commented that t hey 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 pr imarily on state funding. Response: The DNRE removed this language from Se ction 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 modeli ng and other related activities. However, modeling priorities continue to focus on PM 2.5 

### and ozone.

Comment: The EPA commented that the discussion of factors to be considered in defining BART lists instead the statutory fa ctors for evaluating reasonable progress.
The Clean Air Act has a set of five factors fo r BART that differs somewhat from the four factors listed on page 7. Response: On page 7, the discussion is about reas onable progress factor s. There is

no discussion about the BART fact ors in this section.

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

the other contributi ng states shown in Table 10.2.3.a. Response: Several states contributing to Mi chigan Class I areas were planning

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

ask for additional reductions.

Comment: The FS noted that efforts spent to achieve compliance with the PM 2.5 

### and ozone ambient standards don’t preempt complianc e with other parts of the Clean Air Act (i.e., regional haze). The nona ttainment areas are generally in the opposite end of the
state from the Class I areas so the sources determined to hav e 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 PM 2.5 

### nonattainment areas. Therefore, improvements

from these sources to address the ozone and PM 2.5 

### nonattainment areas will have an effect on visibility.

Comment: The FS commented that to support Regi onal Haze SIPs, a large amount of resources were spent to produce technical info rmation 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 t he 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 w hat 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 contributi ng 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 Michi gan Class I areas were planning emission reductions in their stat es. 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. Howe ver, the DNRE is assuming that the CAIR replacement rule will still be deemed a substitu te 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 affe cted. If the Regional Haze Rule is changed to not allow this substitution, Mi chigan will re-evaluate whether additional controls on EGUs are appropriate.

Comment: The FS commented that Fi gure 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 t he proposed CATR rule that the EPA considers to be the first Phase of EPA-requi red 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 E nergy’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-c ompliant 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 pl ants 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 visibilit y. However, with the proposed CATR rule, trading is limited. The DNRE is evaluatin g the proposed CATR to determine how EGUs

will be affected. The DNRE add ed a table showing the insta lled controls for EGUs in

Section 5.3 of the SIP.

Comment: The FS commented that Michigan states, “Since al l 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 EG Us 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 assump tion 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 separat e analysis and justification. Reasonable progress must result from consideration of a four-factor analysis. The relationship between CAIR and BART is not par t of a four factor analysis. Response: Section 10.3.2 was revised. The reas onable progress analysis in the Haze
SIP document accounts for all controls curre ntly expected to be implemented by 2018.
We believe EGUs will be controlled via the CA TR and by any additional future controls we determine to be necessary to meet the NAAQS.

Comment: The FS commented that Michigan states, “The cont rol 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 contro ls for EGUs in terms of the Regional Haze SIP. To require EG U 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 w hat EPA intention is being referred to here. As stated above, reasonable progress is a separate requirement from BART. Response: As stated above, the r easonable 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 eval uating 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 el ements of the DNRE’s long-term strategy, along with all currently known c ontrols 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 corre ct 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 wi ll this deficiency be corrected? Response: The DNRE will redo modeling to includ e 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 sour ces 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 cont rol 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 addr essed in the CAIR program.” Again, as stated above, reasonable progress is a separat e requirement from BART. Response: As stated above, CAIR and CATR are expected to address haze. However, the DNRE has removed this langu age 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 SO 2 

### and NOx controls as it chose to do in this instance to encourage mercury reductions. Response: The DNRE allowed co-benefit mercur y 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 modelin g submitted in a New Source Review permit application, which is reviewed by FLMs.

Comment: The FS stated they are eager to im plement the draf t smoke management plan (SMP) and are curious to learn when it will be finalized. Response: The SMP is nearly completed, only r equiring a few more signatures.

BART

Comment: The FS wanted the Q/d analysis to include all thr ee main visibility-impairing pollutants, includi ng particulate (PM 10 

### ). It is unclear if thei r approach would make any

difference in the number of facilities in Mi chigan that moved on to the next step in the subject to BART analysis bec ause the Q (including PM 10 

### ) of each of the sources in Table 1 of the Appendi x 9B is not listed. Response: All EGUs in Michigan have particulate control either by ESP or baghouses. Analysis of species contri butions indicated that SO 2 

### and NOx were the primary pollutants contributing to visi bility impairment, thus were the only pollutants modeled in the Q/d analysis.

Comment: The FWS and NPS comment ed that DNRE must evaluate particulate emissions from EGUs subject to BART. While BART guidance allows states to

conclude that reductions of sulfates and nitr ates 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 we re averaged for comparisons of Pre- and Post-BART visibility improv ements (see Table 9.3a, BART Controls and Comparison of Visibility-Impairing Pollut ant 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 det ail. Regional sulfates and nitrates account for nearly all predi cted long-range anthropogeni c haze. Modeling guidance for determining BART a pplicability is very specific and does not include annual averaging to determine BART eligibility. Ho wever, once a facility is determined to be BART eligible, the states hav e modeling discretion on how to determine the effectiveness of control strategies. During these cont rol sensitivity modeli ng runs, the averaging of annual results was used to provide gui dance on the effectiveness of proposed

controls.

Comment: The EPA commented that although the r egional haze rule provides for CAIR where applicable to satisfy the BART requirement with respect to SO 2 

### and NOx from electric generating units, the EPA is recons idering this guidance. Therefore, they would not necessarily agree that it is “EPA’s position” t hat 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 s ubmit 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 permi t issued July 1, 2008. Kiln # 1 was included in NSR permit to install No 494-87B that wa s voided on November 6, 2000, as part of the Title V permit procedure for. ROP #199 600365, 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 cons istent with the control equipment already committed to under the Lafarge Global Settl ement/Consent Decree – Alpena Facility (Consent Decree). Lafarge proposed that BAR T should consist of Selective NonCatalytic Reduction (SNCR) for NO X 

### control at all five cement kilns, along with wet flue gas desulfurization (FGD) for SO 2 

### control for the two kilns in Kiln Group 6. The DNRE included as BART Dry Absorp tion Additions (DAA) for SO 2 

### controls for the three kilns in Kiln Group 5 as required by the Cons ent Decree. They note that low NO X 

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

definition of BART. The DNRE should cons ider the inclusion of LNB as BART and explain in the SIP the decision as to its inclusion or exclusion. Response: The DNRE considers that a ll the controls, for NOx, SO 2 

### and PM, as stated in the Global settlement, are included as BART.

Comment: The FWS/NPS commented that the C onsent Decree requires a 12-month rolling average emission limit for NO X 

### of 4.89 lb NO X 

### /ton of clinker, with the provision that a 30-day rolling average emi ssion limit will be developed at a later date. Retrofitted 30-day rolling average emission ra tes in the range of 2.0 lb NO X 

### /ton of clinker and lower can be attained by using SNCR/LNB on pre-ca lciner 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 s hould be provided to justify the higher

emission limit as is indica ted will be done in the SIP. Response: The DNRE considers that a ll the controls, for NOx, SO 2 

### and PM, as stated in the Global settlement, meet BART require ments. 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 enforc eable milestones of t he Consent Decree, ranging from October 1, 2011 to March 1, 2012. Co mparison 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 de scribe 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 feder al enforceability of t he replacing limits, Michigan will need to address questions about whether it has authority to define a BART limit in a Title V permit rat her than having the Title V pe rmit 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 contai ned in the consent order will be rolled into a NSR permit in the futu re. 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 recove ry furnace, NP states they already have installed staged combustion but offered no dat a to indicate how well it is operating. Response: According to NP, the company is re sponsible for operating the recovery

furnace in a manner that is both safe and env ironmentally responsible. The recovery furnace as an emission unit is regulated for, among other pollutants, total reduced sulfur (TRS) and particulate. A CEMS is insta lled and operated to continuously monitor TRS emissions. Likewise, a continuous opac ity monitoring system is installed to continuously monitor opacity as a surrogate i ndicator for particulate emissions. Poor

combustion within the furnace wil l yield poor char bed formati on, incomplete oxidation of TRS, and fuming, which yields high particulate carryover out of the furnace. Each of these parameters, among other s, is monitored to indicate adequate and proper combustion is occurring.

Comment: The FWS/NPS suggested that r egarding the recovery furnace, lowtemperature oxidation wa s not considered as a NO X 

### control alternative. It has never been used on a recovery furnace, but is commercially available and has been successfully applied to, and permitted for, indus trial processes (e.g., Minnesota Steel PSD permit). It would be ideally suited to t he 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 t heir knowledge, this technology has not been applied to any recovery furnace in t he pulp and paper industry. The ability to apply low-temperature ox idation 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 “...vi sibility 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 t he BART determination.

Comment: The FS commented that in the BART guidelines EPA states that the threshold of perceptibility is 0.5 deciv iews and not 1 as proposed by NP. The installation of control for one pollutant (N Ox) on just one BART subject unit at NP improved visibility by 0.4 deciviews. NP thinks th is is small, the FS sees it as very large

in and of itself and when added to other contro ls 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 t he BART determination.

Comment: All three commenters stat ed that to be consistent with other BART analyses the interest rate and expected equipment lif e for the low NOx burner (LNB) analysis for Boiler No. 8 should be 15 years and 7% ve rsus 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 t he BART determination.

Comment: The FWS/NPS commented that NP propos ed that no additional controls could be justified as BART, based on lack of te chnical 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 t he BART alternatives. Adding these costs

to each BART alternative caused all cost estima tes to be excessive, except possibly low
NO X 

### burners (LNB) at $3,600 per ton of NO X 

### removed. The DNRE should confirm that lack of space is an issue at Boiler No. 8. Response: The DNRE accepts that the informati on 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 nat ural 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 bas ed on 2006 prices, and NP states that there is no guarantee that the natural gas prices will rema in low in the future. The DNRE accepts that the information in the SIP document, submitted by NP, adequ ately supports the

BART determination.

Comment: All three commenters stat ed that the SNCR BART analysis for Boiler No. 9 (a wood/natural gas fired, 250,000 pound pe r hour boiler) appears to be flawed. The

MANE-VU document notes an ex ample, “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 capita l cost is $4.4 million and operating cost is $1.1 million. This large discrepancy shoul d be explained. NP also again uses an expected equipment life of 10 years and an inte rest 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 t he BART determination.

Comment: The FS stated the assumed fuels are im portant to the BAR T 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 ar e 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 dis agreed with SMC’s determinati on that a selective, non-catalytic reduction system is technically infeasible and not cost-effective. There does not appear to be documentation de scribing why SMC has insurmountable problems operating an SNCR system in winter. Also, four other cement plants are proposing SNCR as BART. These are As h Grove Cement in Montana, CEMEX in Colorado, Holcim Cement in Montana, and Laf arge 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 assum ed for SNCR appears too low and is among the lowest performing in the industry. The Laf arge BART analysis, which is planning to install a number of SNCR syst ems at its plant for year-r ound operation, for example, states the “...expected contro l 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 consi der 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 t he 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 co sts. Appendix F notes the average cost-effectiveness range down to $1,000 per ton. This repor t had limited data since it was from 2004. As more SNCR systems have been applied the costs will likely have come down. Furthermore, other report ed SNCR installation ranging from $498- $713/ton (Lafarge, MI) to $1400-$2300/t on (Ellis County Texas Study). b. It is not clear which facility from Appendi x 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 15years 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 co ld winter climat e 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 f easible retrofitted installation. Response: The DNRE accepts that the information in the SIP document, submitted by SMC, adequately supports t he BART determination.

Comment: Comments from the FWS/NPS cite The Portland Cement Association
report 1 

### that a relatively inexpensive but effective NO X 

### control technique is a “high pressure air injection syste m” (also called a mixing air syste m) that can be installed on the kiln. Mixing air systems have shown signi ficant emissions reduction up to 48% on the 13 kilns operating with this technology. This should have been considered among
the BART NO X 

### control alternatives. Response: The DNRE accepts that the information in the SIP document, submitted by SMC, adequately supports t he BART determination.

Comment: The FWS/NPS state the proposed NO X 

### emission limit of 6.5 lb NO X 

### /ton of

clinker is lenient com pared to the 2.8 lb NO X 

### /ton of clinker emission limit for pre-calciner kilns and the Lehigh kiln in Iowa that is subject to 2.8 lb NO X 

### /ton of clinker. Response: The DNRE accepts that the information in the SIP document, submitted by SMC, adequately supports t he 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 co st per ton dropped each alternat ive from consideration.

After more reasonable costs are determined as discussed above, visibility impact analysis should be performed to assess the potent ial visibility improvement associated
with each control alternative. Since the ma ximum 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 t he BART determination.

Comment: The FWS/NPS comment regarding SO 2 

### 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 (LSF O) 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 pr oposed the LSFO as BART at a reasonable cost ($1,087/ton SO 2 

### ). 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 t he BART determination.

1 “Summary of Control Techniques for Nitrogen Oxid e” 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 Smurfi t-Stone Container Corporati on stating that all permit limitations for the facility are zero. Response: The Company is in the process of bankruptcy. Howe ver, it has been determined that the permi ts have not been voided. Therefore Smurfit has been added

back into this SIP document.

The DNRE has agreed that controls install ed 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 contro ls 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 r egional haze consultations, Michigan agreed to

mirror what Minnesota did in thei r SIP with their taconite facilities to ensure consistency. When comparing the two SIPs they found om issions in Michigan’s SIP. The DNRE should thoroughly review what is contai ned 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/ai r/air-quality-and-pollu tants/general-airquality/minnesota-regi onal-haze-plan.html) Response: The DNRE accepts the company’s clai m 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 da te. In April, USS Minntac installed a lowNOx main burner firing solid fuels in its furn ace. Extensive CFD work done by a number of companies in Minnesota has shown t hat burner designs that lower the flame temperature can reduce NOx formation in taconi te 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 pe rmitted 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 ec onomically feasible. Babcock Power has made a proposal to a Minnesota taconite pl ant to pilot test its RSCR system to

determine how well it will work. Response: The projects and technologies descr ibed above were not selected or proposed for BART, but rather were proposed pr imarily as projects to be studied, and were agreed to be completed as part of PSD permitting (not BART) or enforcement situations. None of the technologie s and projects described above have been

established for BART at tac onite plants in Minnesota.

### 18 Comment: The EPA and FS suggested that in regar ds to sulfur dioxide, the MPCA

determined that the addition of a scrubber at the United Ta conite plant that burns primarily coal was technically and economically feasible. In doing so, the MPCA had to correct the cost figures subm itted 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 informati on in the SIP, submitted by TMC, adequately supports the BART determination. A ccording 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 scr ubber (absorber) evaluation shows costs to be $6,000/ton of sulfur di oxide 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 SO 2 

### CEMs by November 2008, and a p ilot testing progr am of potential NOx control strategies starting in July 2011. a. The FS commented multiple times on Mi nnesota’s RH SIP that stack testing/ PEMS (predictive emission monitoring syst ems) 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 NO x 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 differe nce 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 Michi gan to require CFD modeling, low-NOx main burner design, and pilot testing of NOx controls on this line. Response: The DNRE accepts that the informati on in the SIP, s ubmitted by TMC, adequately supports the BART determination.

Comment: The EPA and FS commented that Tilden's revised BART scenario, which
shows that SO 2 

### 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 SO 2 

### emissions of 28,800 lbs per day should be considered BART. They also disagreed t hat Tilden should be allowed to go back and model pollutant by pollutant at an individual BART-subject emi ssion unit in an attempt to exempt certain pollutants fr om the unit, as was done for su lfur 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 trans formation among pollu tants, the EPA does not generally recommend that CALPUFF be used on a pollutant specific basis to

### 19 determine whether a source meet s the threshold test for BAR T.” Also it goes on to state, “Because the task of pr edicting the impacts of PM on visibility is a relatively straight-forward exercise, unlik e predicting the impacts of SO 2 

### and NOx, we would recommend the use of CALPUFF on a pollutant s pecific 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 analysi s. The Tilden modeling is consistent with the EPA memo cited. Multi-pollutant CA LPUFF runs were performed to evaluate visibility impacts, not single pollutant runs as implied in the co mments. Two baseline scenarios were evaluated reflecting the range of fuels at Tilden, natural gas (high NOx emissions, low SO 2 

### emissions) and coal (low NOx emissions, high SO 2 

### emissions). Further, the significantly lower impact of t he coal-fueled run was only one factor that

contributed to the BAR T determination for SO 2



### .

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 impac ts.” 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 ma y 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 differ ence corresponds to a small vi sibility 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 requi ring a BART determination. The language in question does no t affect the conclusion of the analysis, that Tilden impacts are very small. Given the emissi ons assumptions (operating at maximum rates 8,760 hours per year), “The real impacts to t he Class I areas from Tilden are expected to be even less than these modeled impact s...” 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 cu rrent 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 Progre ss Goals are affected. The SIP will also

include additional det ails 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, ther e 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. T he 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 an d this is explained in greater detail in the
SIP document.

Comment: Comments from the FS recommended incl uding 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 result s showed that states contributing 2% (or more) make up about 90-95% of total light exti nction, whereas states cont ributing 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 in cluding 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 cl arifications as well as indicating missing appendices. Response: The DNRE agrees with and has added thes e 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 incl uding 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 seve ral 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 discontin uing either Class I monitors if federal funding was not met. Response : The DNRE will look at other opt ions 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 R egional Haze SIP in light of the states current economy, the ac tions being taken by the 1997 PM 2.5 

### NAACS, and the fundamental difference of Regional Ha ze 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 O dawa Indians (Tribe) suggests that Michigan should have clearly defined milesto nes 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 t hat period of time.

Comment: The Tribe wanted DNRE to discuss the i ssues 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 sm oke 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 uncerta in of the requirements for EGUs, since DNRE originally determi ned that CAIR=BART.

Comment: Non-health based terminology is problematic. Response: The Class I areas in Michigan are loca ted in some of the cleanest areas of the state with annual average PM 2.5 

### of 5 ug/m 3 

### . This is below the 15 ug/m 3 

### NAAQS for

PM 2.5 

### , which the EPA considers safe. Therefor e, 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 provis ions in the CAA to protect visibility in these ‘areas of great scenic importance.”

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

PM 2.5 

### nonattainment areas. The Haze program is a welfare-based program, not healthbased, which is the point the DNRE was ma king in the earlier version of the SIP document. However, the CAA does not sugges t that visibility is less important that other parts of the CAA. T herefore, the DNRE has removed any such language from the
SIP.

## Appendix 3A

Midwest Regional Planning Organization, Principles for Regional PlanningMarch 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 resultsMarch 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 , 200 8

iii 

# Scope of D ocument

This document provides a summary of available technical information about regional haze and visibility impairment in the four northern Class I areas: Boundary W aters Canoe Area

Wilderness , Voyageurs National Park, Isle Royale National Park, and Se ney 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. Th e document does not address policy issues and strategies necessary

to deal with regional haze. States can use th is technical information to highlight th e relevant issues for their state policymakers.iii 

# Executive Summary

The Sta t e s of Michigan and Minnesota, along with representatives of other states, tribal governments, and federal agencies 1 , are working to address

visibil ity 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).

C lass I areas in Michigan and Minnesota 2

Based on a review of technical information, several key findings sho uld 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 reg ions which contribute the most to visibility impairment are the States of Michigan, Minnesota, and Wisconsin. Other nearby states, including Illinois, Indiana,

I owa, Missouri, and North Dakota

, also contribute to visibility impairment.

1 Representatives from the following entities are participating in the northe rn 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 Serv ice, 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 the re.iv

• Current (baseli ne) 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 (r ight 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 vis ibility conditions by the year 2064, with an initial implementation period extending to the year 2018. To determine

wh ether the model

- projected 2018 values (based on existing controls) represent reasonable progress, states are required to consider four fa ctors (i.e., costs of compliance, time necessary for compliance, energy and non

- air quality environmental impacts, and remaining usefu l 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

- tr i a ngle

• T he 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 PM 2. 5 ) and environmental effects (e.g., ecosystem damage). Thus, ac tions 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 contr ol measure effectiveness 9

Section 3. References 23

Appendix

I . Contribution Assessment for Northern Class I Areas 241 

## 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, state s 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 regi onal haze rule to implement the provisions of section 169A by establishing a program to address regional haze visibility impairment (USEPA, 1999)

. P ursuant to the regional haze rule, the determination of reasonable progress shall also

consider:

• uniform r ate 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 im provement 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) wa s due to EPA in December 2007. States must also submit a report to EPA every 5 years evaluating progress towar ds 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 a reas?

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% wor st 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 PM 2. 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

. Wh ich geographic areas and sources contribute to regional haze in t he 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 Append ix I : Contribution Assessment for Northern Class I Areas). Based on this information, the most important contributing states are Michigan, Minnesota, and

W i sconsin, as well as Illinois

, Indiana, Iowa, Missouri, and North Dakota . For example, Figure 2 pre sents the results of composite back trajectories for light extinction on the 20% worst visibility days. The o range 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, po or visibility d ays 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

sulfate3 Figure 2. Composite back trajectories for light extinction

Note: o ra nge 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 secon dary 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 n orthern Class I a reas? Is there a seasonal ef fect 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 throughou t 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 tha t sulfate and organic carbon concentrations are higher in the summer, and nitrate concentrations are higher in the winter, suggesting

th e 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 areas6

2. T echnical basis for visibility

- related analyses

a

. What are the present v isibility 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 ye ar, 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 “s ubstituted” 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 80 th percentile). It makes sense to include these days i n 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 non

anthropogenic aerosol from wildfires.) As seen in Table 1 , inclusion of these day s 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% W orst D ays, W ith and W ithout M issing D ata D ays

Average Worst Day DV, per

RHR Average Wo rst 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

V IEWS 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 n ew IMPROVE equation) will be used for SIP purposes. T he 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 d ays, and no degradation in visibility for the 20% best days.8

Table 2 . Summary of V isibility M etrics for N orthern Class I A reas in Terms of Deciviews

Old IMPROVE Equation (Cite: VIEWS, November 2005)

20% Worst Days Baseline 2018 Natural

2000 2001 2002 2003 2004 Value UR I 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

- 2 004 reflect "substituted" data. (2) New IMPROVE equation values include Kenksi, 2007 adjustment for missing days9

3

. Evaluation of control measure effectiveness

a

. What tools are available to evaluate the effectiveness of emission reductions?

U SEPA’s modeling guidelines (USEPA, 2007) recommend using air qu a lity 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 use d 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. CE NRAP 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 12k m Nested Domain)10

Two base years were used in the modeling: 2002 and 2005. USEPA’s modeling guid elines recommend using 2002 as the baseline inventory year, but also allow for use of an alternative baseline inventory year, especially a more recent year (USE PA, 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 a re generally consistent, with differences

att ributable 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 mo dels 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

undere stimation in monthly average organic carbon concentrations in the plots below

. T o compensate for model uncertainty and to provide a more robust analysis , additional information should be considered as part of a weight

- o f

- evidence demonstration.

Figure 6

. Results of LADCO ’s model performance for PM 2. 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 K

Base M11

b. How effective will existing (“on the bo oks”) controls be in improving visibility in the

northern Class I areas?

Air quality modeling conducted by LADCO , MPCA, and CENRAP assess ed future year visibility levels based on the following existing ( “on the books” ) controls:

On

- Highway Mobile Source s

• 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 in corporated 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 s tandards: VOC 2

- , 4

- , 7

- , and 10

- year MACT standards , combustion turbine, and

i ndustrial 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 Ro und 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 mode ling ( 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

visibilit y 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 overestimat ed (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 UR I 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 R oyale, 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* LADC O 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

. M odeling results for four northern Class I areas for 20 % worst visibility days14 Table 4

. EGU SO2 E missions for S tates in the U pper 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 mod eling (Rou n d 4) exam ined several additional control measures,

as summarized below.

Sulfate Control Strategies: Reductions in SO2 emissions will decrease sulfate

concentrations. Because m ost 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 vi sibility in the northern

Class I area s (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 R ound 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 u pper Midwest are from a variety of sources, principally, mobile sources (on

- road and off

- roa d) and stationary sources (EGUs and

non

- EGUs). The modeling for EGU1 and EGU2 reflect s lower SO2 and NOx emission targets

. No additional NOx

- specific strategies were modeled by LADCO to ad dress regional haze

.

To determine whether additional S O 2 and NOx control measures satisfy the requirement for reasonable progress, an assessment of the f ive factors was performed (ECR,

2007a ). Specifically, ECR examined reductions in S O 2 and NO x emissions from EGUs

and i ndustrial, commercial

, and institutional (ICI) bo ilers ; NO x emissions from mobile

sources and reciprocating engines and turbines ; and a mmonia 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, c ost

- 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 f or 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 prod uction 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 impac ts (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 requireme nts 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 improvem ent in 2018 visibility levels for th e additional measures is shown in Figure 8 , along with the

cost

- effectiveness expressed in $M per deciview improvement). These results

show that a lthough EG U and ICI boiler controls have higher cost

- per

- deciview values (compared to some of the other meas ures), 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

e mitting 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

MCD I 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 9,8 48

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 1,07818 

## Visibility Improvement (dv)

0.00 0.25 0.50 0.75 1.00

SO2 NOx NH3 SO2 NOx NH3 SO2 NOx NH3 SO2 NOx NH3 SO2 NOx 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 SO2 NOx NH3 SO2 NOx NH3 SO2 NOx NH3 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 bottom19

Organic Carbon Strategies: Although organic carbon is also an important contributor to visibility impairment, no organic carbon control strateg ies were considered for the following reason s

.

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 PM 2.5 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 mar kers in the

summer 3 , 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 Clas s I areas, the PM 2.5 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 H igh OC/EC Co ncentra tions in N orthern Class I A reas

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 2 8

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 t o 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.

Finall y, the modeling results are presented in Figure 10 in terms of chemical spe cies. 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 addition al 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 PM 2.5 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 m odeling)22

d

. Should we consider control measures for ammonia?

Technical analyses have shown

that PM 2.5 concentrations will respond to reductions in s ulfate, 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 show s PM 2.5 concentrations as a function of ammonia (NH3) and ni tric 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 PM 2.5 concentrations

. Thus, ammoni a emission reductions will lower

PM 2.5 concentrations and improve visibility levels in the northern
Class I areas. Figure 11 . Predicted PM 2.5 mass levels at
Great R iver Bluffs, MN as functions of changes in ammonia and nitric acid

C urre nt regional inventories show most a mmonia emissions come from livestock waste and fertilizer applic ations. A white paper on candidate control measures for agricultural

ammonia emissions was prepared by a contractor (ECR, 2007b). ECR examined

several meas ures 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

consider ed in the white paper.

Further analyses (and discussions with stakeholders) are necessary before de ciding whether to pursue control measures for ammonia . Key issues which need to be

addressed include t echnical uncertainties, such as r eliability of emissi on 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

- bas ed emissions model, conducting model sensitivity studies of ammonia deposition, and collecting ambient ammonia data as part of the Midwest regional ammonia network.

Another issue wa s noted by USEPA in its final CAIR rulemaking : “reductions in ammonia

emis sions alone would also tend to increase the acidity of PM 2. 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 Midwes t 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 Constituen ts in the United States, Report IV”, Cooperative Institute for Research in the Atmosphere, November

2006

EC/R, Incorporated, 2007 a , “Reasonable Progress for Class I Areas in the Northern Midwest

– Factor Analysis”, Draft Final Technical Memorandum, July 1 8, 2007.

EC/R, Incorporated, 2007 b , “ 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 (Oct ober 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 Qualit y Goals for Ozone, PM 2. 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 quali ty 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, t he 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 SO 2 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 applicati ons are also important, especially for nitrate formation.

LA D CO Back Trajectory Analysis (1997

- 2001 Data)

B ack 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 per iod ( Kenski, 2004 ). By combining trajectory frequencies with concentration information, the average contribution to PM 2. 5 mass and

individual PM 2. 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.

LA D CO 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 200m 4 , and a 120

- hou r (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 o r ange 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

Da kota, 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 D akota 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 State s 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) t han 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 source s , 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: o ra nge is where air is most likely to come from , green is where air is least likely to come from27

LADCO Back Trajectory Analysis (2000

– 2005 Data) LADCO’s back trajectory study (based on 2000

- 2003 data) was updated u sing 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 o range 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 i s easier to distinguish one day from another. It is worth noting that even though a few of the worst

- day trajectories originate in Canada, ma ny of these trajectories ac tually 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 R oyale (bottom)

Note: o ra nge 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 Da ys



## Isle Royale, 2000

- 2005 Best Days Worst Days29

Figure I

- 3 . Composite back trajectories for Boundary Waters (top) and Voyageu rs (bottom)

Note: o ra nge 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 Days30 Figure I

- 4 . Composite back trajectories for 2002 (top) and 2005 (bottom)

Note: o ra nge 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 No rthern Class 1 Sites, 2005 Best Days Worst Days31 Figure I

- 5a . Composite back trajectories for Seney



## Seney NWR 2002 best

2005 worst

2005 best 2002 worst32 Figure I

- 5b . Composite back trajectories for Voyageurs



## Voyageurs 2002 best

2005

worst 2002

worst

2005 best33

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 Contr ibution 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 nit rates, and red contours represent AOIs for sulfates. Similar to LADCO’s compos ite 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 ap proach 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 Voyageurs34

Rece ptor Modeling Study

A mbient monitoring data for the period 1991

– 2002 were analyzed to identify sources impacting

PM 2. 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 pr imary 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 nat ure, 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 (mostl y secondary) organic carbon. Back traject ory 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 Waters35

Dispersion Modeling Studies: MPCA , CENRAP, and LADCO

D ispersion model s were used to estimate source region and source sector contributions for the

northern Class I ar eas. Source contribution information based on the p article 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 )

LA DCO modeling for 2018 (LADCO, 2006 and LADCO, 2007) . M PCA’ s analys e s 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 p oint, on

- road, nonroad, area,

and a mmonia.

Figure I

- 9 . Source regions in PSAT analyses: M PCA (left)

, LADCO (center), and CENRAP (right) . Contiguous areas of the same c olor represent a source region

.

The contributions to light e xtinction 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 repres ent 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 r egion 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 M innesota Class I areas are dominated by emissions from Minnesota, while the contributions in the two Michigan Class I areas come from

several northern and midwest ern states.

• CENRAP’s modeling shows a higher Canadian contribution compared to LADCO’s

and MP CA’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 analys is 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 d ays

– Boundary Waters37 Boundary Wat ers, Minnesota 2002 (MPCA) 2005 (LADCO Round 5)

2018 (CENRAP) 2018 (LADCO Round 5)

Figure I

- 10 b . Model

- based source apportionment on 20% worst days

– Boundary Waters38 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 d ays

– Voyageurs

Voyageurs, Minnesota 2002 (MPCA) 2005 (LADCO Round 5)

2018 (CENRAP) 2018 ( LADCO Round 5)40 Figure I

- 1 1b . Model

- based source apportionment for 20% worst d ays

– Voyageurs

Seney, Michigan

2002 (MPCA) 2005 (LADCO Round 5)

20 18 (LADCO Round 5)41 Figure I

- 12a . Model

- based source apportio nment for 20% worst d ays

– Seney

Seney, Michigan

2002 (MPCA) 2005 (LADCO Round 5)42 2018 (LADCO Round 5)

Figure I

- 1 2b . Model

- based source apportionment for 20% worst d ays

– Seney43 Isle Royale, Michigan

200 2 (MPCA) 2005 (LADCO Round 5)

2018 (LADCO Round 5)

Figure I

- 13a . Model

- based source apportionment for 20% worst d ays

– Isle Royale44 Isle Royale, Michigan

2002 (MPCA) 2005 (LADCO Round 5)

2018 (LADCO Round 5)

Figure I

- 13 b . Model

- based source apportionment for 20% worst d ays

– Isle Royale45 Table II

- 2. State Culpabilities Based on PSAT Modeling and Trajectory Analyses

Boundary Waters Seney

LADCO

- Round 4
PSAT LADCO

-

Round 5
PSAT MPCA

PSAT CENRAP

-

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 MPCA

PSAT CENRAP

-

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%

Minnesot a 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 Co mparison

E missions 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 se ctors.

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 LA DCO’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

IP M3.0

- 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

- ma y 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

- 200 3 (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 0.13749

Other Issues: Transboundary Impacts

In a Technical Brief, EPRI proposed an alternativ e 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 ra te 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 inv entory, 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 d ominated 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 Can adian 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 areas 6 . 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 Ca nada. Nevertheless, many of these trajectories

ac tually 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 inclu des 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 pa rameters). (Note, however, LADCO’s modeling may overstate the 2018 Canadian contribution, because it assumed 2018 and 2005 emissions

a re the same .)

6 In a guidance memo, USEPA has stated that “States should not directly consider the effects of

international emissions when calculatin g 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 defi nitions 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. F urther 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 Strate gy 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 H aze 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 PM 2. 5 : A GIS Analysis, Proc. AWMA 97 th 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”)

- u pdate d

t rajectories, 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 Regi onal 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 Cons ultation 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 que stions about the agenda and call purpose, the MANE- VU representatives began the substanc e 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 Assessm ent (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 Ta bs 4 & 5 of briefing book).

Discussion :

• M. Koerber (MRPO): Requested documenta tion of 2018 projections – MANE-VU work seems consistent with MRPO analyses. Also, it looks as if the North east 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. Al so, VISTAS new emissi on inventory with GA

reductions is not in the MANE-VU modeli ng. 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 ta ke 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 or ganic 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? MR PO will be interested in what our control measures analysis says for organic carbon.

• G. Kleiman (NESCAUM): There is some uncerta inty 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 extin ction. Organic carbon doe s not contribute as much to extinction as sulfate in the MANE-VU region.

• P. Brewer (VISTAS): After discussion with Gary at MA RAMA 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?

### August 6 2007 MANE-VU/MRPO Cons ultation 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 m odel runs. Liz, took a quick look at 3.0 and same SO 4 

### increases that look problematical.

MANE-VU Reasonable Progress Proj ect 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 refl ected in 1999 dollars. If converted to 2006 dollars the cost figures would be highe r – 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 be lieve are needed based on the technical work we have done. In the consultations these requ ests 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 cons ultation 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 visibil ity is not one of the 4 factor s and so is not applicable.

• M. Koerber (MRPO): Isn’t there a 5 th 

### factor in guidan ce - $/deciview ?

• S.Wierman (MARAMA) – EPA expects that we will look at visibility improvement, but still not a factor regard ing reasonableness. MANE-VU is planning on looking at visibility improvement of the control measur se we initially looke d 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 m echanism for different control measures.

• S. Holman (NC): In NC, 11 of 12 EGUs will ha ve scrubbers - need to reflect units that

have scrubbers on in VISTAS base G.

MANE-VU Long-Term Strategy/Statements

### August 6 2007 MANE-VU/MRPO Cons ultation Summary (DRAFT)

As discussions proceeded after the reasonabl e progress overview, participants began to ask questions about the MANE-VU resolution a nd 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 sector s that MANE-VU believes are needed for its Class I areas, as a starting point fo r consultation discussions.

Discussion :

• F. Durham (WV): Regarding the low sulfur fu el strategy, will regul atory 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 ac ross 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 sa ying that the low sulf ur 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 re ductions to what they are doing in the low sulfur fuel strategy – not necessarily exp ecting that MRPO and VISTAS states will pursue a low sulfur fuel strategy. We are as king you to look at what is reasonable in terms of making equivalent re ductions, 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 compari ng what you are looking

at as reasonable with what we are requesting as a starting po int 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 am ount of non-EGU MANE-VU reductions?

• P.Wishinski (VT), A. Garcia (MANE-VU): VT would support th at 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 M ANE-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 cons ultations, 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 diffe rent 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 6 th 

### and August 20 th 

### 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 interest ed in having a continued dialogue, beyond the August in-person meetings.

### August 6 2007 MANE-VU/MRPO Cons ultation 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 c onsultation process, ev en 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 wi th Mike that this is an ongoing process for best science

• D. Andrews (KY): The two EGU modeling r uns in the table of 167 stacks do not show much correlation – why?

• S. Wierman (MARAMA): Because the modeling fo r each of the different runs is based on different days, there were different meteorological inputs to each model and variability in wind fields (s hows 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. 6 th 

### )

• Would hope modeling would form basis for a co llaborative 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 “5 th 

### Factor” for on-the-books contro ls as context for candidate measures. Examined similar strategies as those that MACTEC did for MARAMA analysis. Now completing report on “5 th 

### Factor” - will send out later.

• Requirement to address regional haze Class I ar eas 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 st ill 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. 6 th 

### . Note that MANE-VU sites are at uniform progress with

control measures but MRPO st ates 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 6 th 

### 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.

### August 6 2007 MANE-VU/MRPO Cons ultation 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 Appal achian sites – mountain sites below the uniform progress line; less improvement at coas tal sites – very close to uniform progress. Smaller reductions in units affecting relativ e reductions over whole year. GA and FL are working closely together on those sites.

• Distributed reasonable progress ap proach to stakeholders - look ed at areas of influence.

• Reasonable progress analysis based on area of influence approach shows sulfate from

EGUs and other sources domi nated – 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, wh at 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 influe nce 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 as king 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 recei ved 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 ju st 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 c onsultation – we may not be very far apart. Any information

### August 6 2007 MANE-VU/MRPO Cons ultation Summary (DRAFT)

that the RPOs and states can provide a bout 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 ma de for your own sources may show we are closer - by August 6th and August 20 th 

### meeting.

• R. Papalski (NJ) Is the material from the VISTAS June meeting available?

• P. Brewer (VISTAS): Yes, all presenta tions from the June meeting are posted on

VISTAS’ website.

• J. Hornback (SESARM): More on 28% reducti on – 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 bo ilers. Impact, concern and what control options/cost are – talk to EPA? Uncont rolled/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 as k 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 Miche lle Notariani (EPA/O AQPS), expressed their appreciation for being invited to partic ipate on the call and on future consultations.

Outcomes & Next Steps

• R. Papalski (NJ): Asked that all RPOs br ing 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 partic ipate in the August 6 th



### meeting – will be calling WI to ask them to attend.

• A. Garcia (MANE-VU): Gave a brief overvie w of the upcoming consultation meetings on August 6 th 

### and 20 th 

### – 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

### August 6 2007 MANE-VU/MRPO Cons ultation Summary (DRAFT)

Adjournment Anna Garcia thanked everyone for their partic ipation 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

.

### August 6 2007 MANE-VU/MRPO Cons ultation 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

### August 6 2007 MANE-VU/MRPO Cons ultation 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

### August 6 2007 MANE-VU/MRPO Cons ultation 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 Organiza tion (MRPO) states (Illinois, Indiana, Ohio, Michigan and Wisconsin). Th e following summary documents th e discussions that took place during the consultation.



## Summary of Today’s Consultation Agreements

1. Define next steps for multi- pollutant approach to reduc e regional haze, PM 2.5, and

ozone

2. Discuss crafting a revised national as k among interested MANE-VU and MRPO states regarding needs for national acti on on EGUs, including potential multipollutant control levels fo r CAIR Phase III with emi ssion rates and output-based options;

3. Pursue discussions on options for redu cing 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 inform ation 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 in terested MANE-VU and MRPO states regarding national act ion 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 stat es 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.

### August 6 2007 MANE-VU/MRPO Cons ultation 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 Pres entations and Discussions

Welcome and Introductions – Goals for Today’s Meeting - David Littell, Maine DEP

• Presented goals for today’s consultation:

- Review requirements, resources and critic al timing issues to ensure all share a common understanding;

- Discuss options for control measures to id entify 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 a nd MANE-VU Class I areas in terms of control measure options; and

- Summarize points of agreement and iden tify 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 thei r 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.

### August 6 2007 MANE-VU/MRPO Cons ultation 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 documen tation of the Open Call and of today’s
discussions, and will circulate the drafts fo r comment and make the final documentation

available to all states for use in th eir state implementation plans (SIPs).

Summary of Reasonable Progress Work and De velopment 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 sulf ate 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 visibi lity 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 fr om 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 visibi lity impairment in MANE-VU Class I areas;

- A low sulfur fuel oil strategy with differen t implementation timeframes for inner zone
states versus outer zone states, that re sults 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 ot her 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 strategi es are reasonable;

- Open a dialogue with the USEPA con cerning a possible Ph ase 3 of CAIR;

- Define strategies to incl ude in the final modeling;

- Determine goals based on the final modeling;

- SIPs are due 12/17/07;

- Adopt enforceable emissions limits & compliance schedules; and

### August 6 2007 MANE-VU/MRPO Cons ultation 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 ex emption 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 th e MANE-VU numbers?

- Answer (Gary Kleiman, NESCAUM) : They are from MARAMA’s inventory work.

National ask for EGU sector based on IP M results and increasing the SO2 ratios.

• Comment (Mike Koerber, MRPO) : The MANE-VU numbers are cl ose to his, but we need to sync them up.

• Comment (Tom Easterly, Indiana) : Companies make economic analyses for installation of controls and we keep ch anging 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 Progre ss Work for MRPO Class I Areas – Mike Koerber, MRPO

Presentation:

• MRPO results consistent with MANE-VU analyses.

• MRPO states still looking at st rategies for their 4 northern Cla ss I areas, nitrates a bigger share of visibility impairment, visibility impacts mostly from southerly transport.

• With OTB measures, we are above glid e path in 2018 for all 4 Class I areas.

• Review of MRPO 5-Factor An alysis (including degree of visibility improvement) for reasonable progress.

• Review of new visibility me tric 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, Sene y 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), incl uding those in the Northeast;

- Contribution analyses show closer st ates have larger impacts; and

### August 6 2007 MANE-VU/MRPO Cons ultation Summary (DRAFT)

- Regional emission reductions (in 2013-2018 timeframe), such as those identified in MANE-VU’s June 2007 resolutions, may be n ecessary to meet reasonable progress goals in the MRPO Class I areas and provide for attainment of new tighter PM2.5 and possibly tighter ozone standa rds 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 a mmonia 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 no t 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 pote ntially 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 Su mmerhays, EPA Region V; Todd Hawes, EPA - OAQPS

Bruce Polkowsky, National Park Service

• Tomorrow is the 30 th 

### anniversary of the passage of the 1977 Clean Air Act Amendments

that enacted section 169A and esta blished the regional haze program.

### August 6 2007 MANE-VU/MRPO Cons ultation Summary (DRAFT)

• The uniform progress line is “u seful,” 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 CA IR controls scenarios? Information coming in from states seems to be pointing to pred icting a higher level of controls than what CAIR predicts.

• The location of controls is important for vi sibility as seen in the MANE-VU 167 stack analysis.

• The 2013 progress report is key, and it is im portant 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 coordinate d to maximize their effectiveness for both regional haze, PM2.5, and ozone SIPs.

• The FLMs encourage states to be as detail ed as possible in their regional haze SIPs, including dates, for control measure developm ent. 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 st ates 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 ch ecklist can be found in the SIP.

• There is an FLM expecta tion 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 mu ch control taken on BART. EPA is thinking about how to ensure consistency in BART determinati ons by different states. EPA asks the RPOs to try to insure consistency across their states; and

- (3) Consultations - RPOs have done valu able work in technical analyses and facilitating consultations.

• EPA appreciates being part of the current pr ocess 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.

### August 6 2007 MANE-VU/MRPO Cons ultation 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 reasona ble progress goal with no analysis.

• EPA is legally bound and expecting full SI Ps on 12/17/2007 that include all of the required elements. It is not acceptable for st ates to say they do not have the time or
resources, or that the SIP ca nnot 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 look ing 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 provi ded input on format and frequency. The monitoring aspects are crucial and esp ecially 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 fi rst 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 repe at of the NOx SIP call delays. The BART requirement is one of the best ways in th e 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 a ny 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?

### August 6 2007 MANE-VU/MRPO Cons ultation Summary (DRAFT)

- Answer (Todd Hawes, EPA) : The rule says EPA is the arbiter of any disagreement and there is little guidance beyond that. EP A 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 a nd EPA will act upon any

inconsistencies.

Roundtable Discussion on Reasonable Progress Goals and Reasonable Measures

States continued the consultation with a r oundtable 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 sugge sted that there may be an opportunity to examine the scope of the ICI boiler sector and potential emission reducti ons from that source category. Several states brought up the recent va catur 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. Wh ile for Boiler MACT this effort would focus on hazardous air pollutants (HAPs), including vol atile organic compounds (VOCs), it may be possible to include in that pr oject a parallel process to ga ther information on NOx and SO2 emissions from the boiler sector and develop opti ons 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 focu sing on local sources for urban excess, and it appears that EPA is discouraging a focus on regi onal strategies. Illinois informed the group that it has a multi-pollutant agreement including scrubbe rs. 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 RA CT proposals are working their way through Illinois’ regulatory processes, so they are not yet included in SIPs a nd 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 co mpleting a study on ICI boilers that was sponsored by EPA. All of this work can be included in the re view 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-exami ne ICI boiler work and define next steps;

• Contact NACAA about possible addition to Boil er MACT model rule work to examine potential for NOx and SO2 reductions and identify strategies; and

### August 6 2007 MANE-VU/MRPO Cons ultation 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 measur es that MANE-VU is pursuing, the states discussed other areas of opportunity for low-sulf ur 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 execu tive order mandating low-sulfur nonroad diesel for state contracts. MRPO states al so expressed interest in low-sulfur fuel for

locomotives.

New Hampshire inquired as to whether the co st for biodiesel is similar to low-sulfur diesel, and suggested that we sh are 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, a nd 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 work s 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 st acks 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. Acco rding to the information MRPO has at this
time, over 70% of the emissions from the 167 stack s 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 reducti ons from the non-EGU sector that go beyond the 28% level for reductions that may not be obtai nable 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 wh ether the 70/30 split is the same for the rest
of the EGUs, i.e. those in the MR PO region that are not part of the 167 stacks on the list. MRPO responded that they can get that information a nd provide it to MANE-VU. For example, IPM indicates that Rockport will be ge tting controls, while MRPO’s information from the source is

### August 6 2007 MANE-VU/MRPO Cons ultation 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 requ ired 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 increa ses in other emissions. Some states responded that it has been possible to add scrubbers to olde r units and address increas es 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 justific ation 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 la nguage that will work in our SIPs to reflect the approach that MANE-VU is requesti ng 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 compar ed 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 addressi ng 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 st ates will review and consider the option as we continue our consultation process. For many MRPO states th e real concern is obtaining PM 2.5 reductions; regional haze is not their primary concern. As we continue to discuss th e 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 th e 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 di scussions on potential multi-pollutant control levels for
a CAIR Phase III; and

• Craft a revised national “ask” to refl ect revised levels, as appropriate.



## NEXT STEPS

In addition to the agreements reached during the discussions (listed at the beginning and

in the roundtable discussion sect ions of this document) the M ANE-VU Class I states and the

### August 6 2007 MANE-VU/MRPO Cons ultation Summary (DRAFT)

MRPO states agreed to conti nue the consultation dialogue on the upcoming State Collaborative call, scheduled for 10:00 am CDT, 11:00 am EDT on Thursday, August 16 th 

### . 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 documen tation of the consultation.

## Appendix 3D

EPA Ask LettersSeptember 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 separat e 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 asPage 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 i dentified 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 signif icance 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 (SO 2 ) 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 SO 2 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 SO 2 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 SO 2 (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 SO 2 (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 SO 2 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 SO 2 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 fordetermining 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 IslandPage 6 of 6 

### ______________________ ______________________ Vermont Virginia

______________________ WisconsinPerformance 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)

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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 provide2. In th

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nOTC appreciates the efforts put forth by EPA to work with all interested stakeholders in developing a CAIR replacem ent 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 oper able 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 approachcombines state and regional caps with phased-in performance standards to costeffectively reduce nitrogen oxide (NOx) and sulfur dioxide (SO 2 ) 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 SO 2 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 PM 2.5 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 achi evable. 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-cataly tic 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 SO 2

.

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 SO 2 , 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 im plemented as early as possible and set at a level that will drive deeper regional NOx and SO 2 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 SO 2 , 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 regi onal 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 incent ives (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 stat es, 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 SO 2 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 rema in accountable to address contributions

to downwind areas’ nonattainment of both the ozone and PM 2.5 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 inPage 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