Commonwealth of Pennsylvania

Revision to the State Implementation Plan for

Regional Haze

December 2010

Bureau of Air Quality

Pennsylvania Department of Environmental Protection

P.O. Box 8468

Harrisburg, PA 17105-8468

717-787-9495

www.dep.state.pa.us

John Hanger

Secretary

Edward G. Rendell

Governor
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TABLE OF CONTENTS

SECTION 1.0. INTRODUCTION.................................................................13

1.1. Regional Haze Background..............................................................13

1.2. History of the Federal Regional Haze Rule..........................................14

1.3. General Overview of Regional Haze SIP Requirements.........................15

SECTION 2.0. GENERAL PLANNING PROVISIONS.......................................17

SECTION 3.0. REGIONAL PLANNING........................................................17

SECTION 4.0. STATE/TRIBE AND FEDERAL LAND MANAGER

COORDINATION................................................................................................20

SECTION 5.0. ASSESSMENT OF BASELINE CONDITIONS AND ESTIMATE 

OF NATURAL CONDITIONS IN CLASS IAREAS...........................................22

SECTION 6.0. MONITORING STRATEGY...................................................26

6.1. IMPROVE Program Objectives....................................................26

6.2. MANE-VU Class I Area IMPROVE Monitors...................................27

6.3. Use of Monitoring Data in Contribution Assessment.............................42

6.4. Additional Monitoring Data.........................................................42

SECTION 7.0. EMISSIONS INVENTORY.....................................................44

7.1. Emissions Inventory Background and Requirements.............................44

7.2. Summary of 2002 Baseline Emissions Inventory...................................45

7.2.1. Summary of Inventory Methodologies....................................45

7.3. Projected Inventories....................................................................46

7.3.1. Summary of 2018 Estimated Emissions..................................46

7.3.2. Growth Projection Methodologies..........................................47

SECTION 8.0. BEST AVAILABLE RETROFIT TECHNOLOGY (BART)..............50

8.1. Overview of BART Rule.............................................................50

8.2. EGUs and CAIR.......................................................................52

8.3. BART Source Cap-Out Permits......................................................53

8.4. BART-Eligible Sources in Pennsylvania...........................................55

8.5. Sources Subject to BART............................................................56

8.5.1. Making BART Determinations for all BART-Eligible Sources...56

8.5.2. Anticipated Visibility Improvement as a Result of BART.........56

8.6. BART Determinations, Control Levels and Schedules.........................57

8.7. Reasonably Attributable Visibility Impairment..................................62
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TABLE OF CONTENTS (cont.)

SECTION 9.0. REASONABLE PROGRESS GOALS.........................................63

9.1. Consultation and Agreement With Other States’ Goals.........................63

9.1.1. The MANE-VU States....................................................................63

9.1.2. The VISTAS States.........................................................................64

9.2. Calculation of Uniform Rate of Progress..........................................66

9.3. Reasonable Progress Goals for Class I Areas in MANE-VU.....................67

9.4. The MANE-VU ‘Ask’ Statement Strategy....................................................70

SECTION 10.0. LONG TERM STRATEGY...................................................72

10.1. Consultation........................................................................72

10.2. Contribution to Visibility Impairment at Class I Areas.......................73

10.3. Technical Documentation...........................................................77

10.3.1. Basis for Emission Reduction Obligations...........................77

10.3.2. Baseline Inventory.......................................................79

10.3.3. Modeling Techniques Used.............................................79

10.3.4. Monitoring and Emissions Data.........................................81

10.4. Anthropogenic Sources of Visibility Impairment...............................81

10.4.1. The MANE-VU Reasonable Progress Strategy......................83

10.4.2. Best Available Retrofit Technology...................................89

10.4.3. Low-Sulfur Fuel Oil Strategy...........................................91

10.4.4. EGU Strategy...............................................................93

10.4.5. The VISTAS Modeling Approach...............................................98

10.5. Consideration of Factors Required by the Regional Haze Rule..............100

10.5.1. Emissions Reductions Due to Ongoing Air Pollution Programs.100

10.5.1.1. Stationary Point Sources.......................................101

10.5.1.2. Area Source Controls in MANE-VU......................106

10.5.1.3. Highway Vehicle Sources....................................106

10.5.1.4. Nonroad Sources..............................................111

10.5.2. Measures to Mitigate the Impacts of Construction Activities....111

10.5.3. Source Retirement and Replacement Schedules....................113

10.5.4. Agricultural and Forestry Smoke Management.....................113

10.5.5. Share of Emission Reductions.........................................113

10.6. Estimated Impacts of long Term Strategy on Visibility........................114

10.7. Emission Limitations and Compliance Schedules......................................120

10.8. Enforceability of Emission Limitations and Control Measures..................120

10.9. Consultation on the Long Term Strategy...........................................122

SECTION 11.0. COMPREHENSIVE PERIODIC IMPLEMENTATION

PLAN REVISIONS AND PROGRESS REPORTS...........................................126
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TABLE OF CONTENTS (cont.)

SECTION 12.0. DETERMINATION OF THE ADEQUACY OF THE

EXISTING PLAN..............................................................................................127

SECTION 13.0. PUBLIC AND FLM COMMENT PROCESS....................................128

13.1. Public Comments......................................................................................128

13.2. FLM Comments.........................................................................................128

LIST OF TABLES....................................................................................5

LIST OF FIGURES...................................................................................7

LIST OF APPENDICES..............................................................................9

LIST OF ACRONYMS.............................................................................11
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LIST OF TABLES

Table 3.0-1 MANE-VU Members..................................................................18

Table 5.0-1 IMPROVE Information for MANE-VU Class I Areas...........................23

Table 5.0-2 IMPROVE Information for Nearby Class I Areas.................................24

Table 5.0-3 Summary of Baseline Visibility and Natural Conditions for the 

20% Worst And 20% Best Visibility Days at MANE-VU Class I Areas..............24

Table 5.0-4 Summary of Baseline Visibility and Natural Conditions for the 

20% Worst And 20% Best Visibility Days at Nearby Class I Areas.....................25

Table 7.2-1 2002 Emissions In Tons Per Year.................................................................45

Table 7.3.1-1 2018 Projected Emissions...........................................................................46

Table 8.3-1 Pennsylvania Facilities Not BART-Eligible Due to Elective

Permit Restrictions..................................................................................................53

Table 8.4-1 Pennsylvania Facilities with BART-Eligible Units.......................................55

Table 8.6 BART Control Levels.......................................................................................58

Table 9.2-1 Uniform Rate of Progress for MANE-VU Class I Areas..............................67

Table 9.3-1 Reasonable Progress Goals for the 20% Worst Days...................................68

Table 9.3-2 Reasonable Progress Goals for the 20% Best Days......................................69

Table 10.2-1 Percent of Modeled Sulfate Due to Emissions from Listed States.............77

Table 10.4.1 Summary of Results From the Four Factor Analysis..................................85

Table 10.4.2 Estimated Emissions from Non-EGU BART-Eligible Facilities

Located in MANE-VU Used in Final Modeling...................................................90

Table 10.4.4-1 Pennsylvania’s EGU Stacks and Controls

Identified from the 167 Stack List.........................................................................95

Table 10.4.4-2 Pennsylvania’s Additional EGU Stacks and Controls..............................97
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LIST OF TABLES (cont.)

Table 10.4.4-3 Pennsylvania’s SO2 Baseline Emissions for 2002 and

Projected Emissions for 2018............................................................................................98

Table 10.5.5-1 SO2 Emissions Inventory in MANE-VU...............................................114

Table 10.5.5-2 SO2 Emissions Inventory from Pennsylvania Sources..........................114
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LIST OF FIGURES

Figure 3.0-1 MANE-VU Class I Areas............................................................................18

Figure 6.2-1 Acadia National Park Map...........................................................................27

Figure 6.2-2 Acadia National Park on a Clear Day Photo................................................28

Figure 6.2-3 Acadia National Park on a Hazy Day Photo................................................29

Figure 6.2-4 Edwin B. Forsythe National Wildlife Refuge Map....................................30

Figure 6.2-5 Brigantine Wilderness Area on a Clear Day Photo....................................31

Figure 6.2-6 Brigantine Wilderness Area on a Hazy Day Photo....................................31

Figure 6.2-7 Great Gulf Wilderness Area and Presidential Range/Dry River 

Wilderness Area Map..........................................................................................32

Figure 6.2-8 Great Gulf Wilderness Area on a Clear Day Photo..................................33

Figure 6.2-9 Great Gulf Wilderness Area on a Hazy Day Photo..................................33

Figure 6.2-10 Lye Brook Wilderness Area Map...........................................................34

Figure 6.2-11 Lye Brook Wilderness Area on a Clear Day Photo................................35

Figure 6.2-12 Lye Brook Wilderness Area on a Hazy Day Photo................................35

Figure 6.2-13 Moosehorn Wilderness Area Map..........................................................36

Figure 6.2-14 Moosehorn Wilderness Area on a Clear Day Photo...............................37

Figure 6.2-15 Moosehorn Wilderness Area on a Hazy Day Photo...............................38

Figure 6.2-16 Great Gulf Wilderness Area and Presidential Range/Dry River 

Wilderness Area Map.........................................................................................39

Figure 6.2-17 Presidential Range/Dry River Wilderness Area on a Clear Day Photo...40

Figure 6.2-18 Roosevelt/Campobello International Park Map.......................................41

Figure 6.2-19 Roosevelt/Campobello International Park on a Clear Day Photo............41

Figure 6.2-20 Roosevelt/Campobello International Park on a Hazy Day Photo............42
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LIST OF FIGURES (cont.)

Figure 10.2 Contributions to PM2.5 Extinction at Seven Class I Areas..........................75

Figure 10.4 167 EGU Stacks Affecting MANE-VU Class I Areas.................................82

Figure 10.4.3 Average Change in 24-hr PM2.5 Due to Low Sulfur Fuel Strategies

Relative to OTB/OTW..........................................................................................92

Figure 10.4.4 Preliminary Estimate of Average Change in 24-hr PM2.5 due to 90%

Reduction in SO2 Emissions From 167 EGU Stacks...........................................94

Figure 10.6-1 Projected Visibility Improvement at Acadia National Park 

Based on Best and Final Modeling......................................................................116

Figure 10.6-2 Projected Visibility Improvement at Brigantine National Wildlife

Refuge Based on Best and Final Modeling.........................................................117

Figure 10.6-3 Projected Visibility Improvement at Lye Brook Wilderness Area

Based on Best and Final Modeling......................................................................117

Figure 10.6-4 Projected Visibility Improvement at Great Gulf Wilderness Area

Based on Best and Final Modeling......................................................................118

Figure 10.6-5 Projected Visibility Improvement at MoosehornWilderness Area

Based on Best and Final Modeling......................................................................119
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LIST OF APPENDICES

Appendix A – MANE-VU Interim Report (May 2006)

Appendix B – Contribution Assessment for MANE-VU (NESCAUM, August 2006)

Appendix C – VISTAS, Shenandoah Group Contribution Assessment (May 2007)

Appendix D – WV and VA Emails; Agendas for FLM Conference Calls; FLM MOU

Appendix E – Baseline and Natural Background Visibility Conditions: Considerations 

and Proposed Approach to the Calculation of Baseline and Natural 

Background Visibility Conditions at MANE-VU Class I Areas (December 2006)

Appendix F – 2002 Baseline Emissions Inventory

Appendix H – 2018 Projected Emissions Inventory

Appendix I – MANE-VU CALPUFF Modeling Results for Pennsylvania BART Sources

Appendix J – Pennsylvania’s BART Analysis Review Memos

Appendix K – VISTAS Power Point Presentation of 2018 Visibility Improvement Projections, 

March 2008

Appendix L – 2018 Visibility Projections Report (NESCAUM, May 2008)

Appendix M – MANE-VU ‘Ask’ Statement Within MANE-VU (June 20, 2007)

MANE-VU ‘Ask’ Statement Outside of MANE-VU (June 20, 2007)

Appendix N – CAIR Plus Report (ICF, May 2007)

Appendix O – Reasonable Progress Report (MACTEC, July 2007)

Appendix P – Five -Factor Analysis of BART-Eligible Sources (NESCAUM, June 2007)

Appendix Q – Assessment of Control Technology Options for BART-Eligible Sources 

(NESCAUM, March 2005)

Appendix R – Nature of the Fine Particle and Regional Haze Air Quality Problems in the

MANE-VU Region (NESCAUM, November 2006)

Appendix S – MANE-VU Modeling for Reasonable Progress Goals: Model Performance

Evaluation (NESCAUM, February 2008)

Appendix T – MANE-VU Construction Activities TSD (September 2006)
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LIST OF APPENDICES (cont.)

Appendix U – MANE-VU Smoke Management TSD (September 2006)

Appendix V – Development of Emissions Projections for 2009, 2012, and 2018 

For Non-EGU Point, Area and Non-road Sources in MANE-VU

Region (MACTEC, February 2007)

Appendix W – Documentation of 2018 Emissions from EGUs (Alpine Geophysics, August 2009)

Appendix X – MANE-VU FLM Consultation Framework (May 2006)

Appendix Y – Summary Detail of MANE-VU Ask Statement Development

Appendix AA – FLM Comments/Department Responses

Appendix BB – Allegheny County Health Department (ACHD) Enforcement Order and

cover letter, BART review memo for Eastman Chemical Resins

Appendix CC – VISTAS Comments on MANE-VU Best and Final Modeling (Letter 

to Anna Garcia dated April 25, 2008)

Appendix DD – ConocoPhillips Consent Decree, Civil Action H-05-0258

Appendix EE – Sunoco Consent Decree, Civil Action 05-CV-02866
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LIST OF ACRONYMS

ACHD – Allegheny County Health Department

AMS – Philadelphia Air Management Services

AoI - Area of Influence

BART - Best Available Retrofit Technology

BRIG - Brigantine Wilderness Area, NJ

CAA - Clean Air Act

CAIR - Clean Air Interstate Rule

CAMR - Clean Air Mercury Rule

CEM - Continuous Emissions Monitoring

CERR - Consolidated Emissions Reporting Rule

CMAQ - Community Multiscale Air Quality

DOE - Department of Energy

DOSO1 - Dolly Sods Wilderness Area, WV

DV - Deciview

EAC - Early Action Compact

EGAS – Economic Growth Analysis System

EGU - Electric Generating Unit

EPA - Environmental Protection Agency

EQB – Environmental Quality Board

ESP – Electrostatic Precipitator

FAA – Federal Aviation Administration

FGD – Flue Gas Desulfurization

FLM - Federal Land Manager

Grains/dscf – grains per dry standard cubic feet

HAP - Hazardous Air Pollutant

HNO3 – Nitric Acid

IMPROVE - Interagency Monitoring of Protected Visual Environments

IPM - Integrated Planning Model

JAR1 - James River Face Wilderness Area, VA

LSD - Low Sulfur Diesel

LTS - Long-Term Strategy

MANE-VU – Mid-Atlantic/Northeast Visibility Union

MARAMA – Mid-Atlantic Regional Air Management Association

MM5 - Mesoscale Meteorological Model

NAAQS - National Ambient Air Quality Standard

NEI – National Emissions Inventory

NH3 - Ammonia

NESCAUM – Northeast States for Coordinated Air Use Management

NOx - Nitrogen Oxides

OTB/OTW - On the books/On the Way

PBL - Planetary Boundary Layer

PM - Particulate Matter

PM2.5 - Particulate Matter with a diameter of 2.5 micrometers or less (fine particles)

PM10 -Particulate Matter with a diameter of 10 micrometers or less (coarse matter)
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LIST OF ACRONYMS (cont.)

Ppmvd – Parts per Million Volume Dry

PSAT - PM Source Apportionment Technology

PSD – Prevention of Significant Deterioration

PSU/NCAR - Pennsylvania State University/National Center for Atmospheric Research

RAMS - Regional Air Modeling System

RHR - Regional Haze Rule

RPG - Reasonable Progress Goal

RPO - Regional Planning Organization

SAMI - Southern Appalachian Mountain Initiative

SCC - Source Classification Code

SCR – Selective Catalytic Reduction

SHEN1 - Shenandoah National Park, VA

SIP - State Implementation Plan

SMOKE - Sparse Matrix Operator Kernel Emissions (model)

SMP - Smoke Management Plan

SNCR – Selective Non-Catalytic Reduction

SOA - Secondary Organic Aerosols

SO2 - Sulfur Dioxide

STN - Speciated Trends Network

TDF – Tire-Derived Fuel

TDM - Travel Demand Model

TPY – Tons Per Year

UAM - Urban Airshed Model

EPA - United States Environmental Protection Agency

VIEWS – Visibility Information Exchange Web System

VISTAS - Visibility Improvement - State and Tribal Association of the Southeast

WVDEP - West Virginia Department of Environmental Protection

WVDAQ - West Virginia Division of Air Quality

VDEQ – Virginia Department of Environmental Quality

VOC - Volatile Organic Compound

VMT - Vehicle Miles Traveled
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1.0. Introduction

1.1. Regional Haze Background

Regional haze is visibility impairment caused by the cumulative effect of air pollution 

from numerous sources over a wide geographic area. Regional haze results in impaired 

visibility over a large region, affecting urban and rural areas including national parks, 

forests, and wilderness areas (federal “Class I” areas). In the eastern United States, 

average visual range has been reduced to approximately 30 kilometers or one-fifth of the 

visual range that would exist under natural conditions. In Section 169A of the Clean Air 

Act (CAA), Congress established the ultimate national goal of the regional haze program 

as follows:

Congress hereby declares 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 impairment results from man-made air 

pollution.

(See 42 U.S.C. § 7491(a)(1)

Regional haze is caused by sources and activities emitting fine particles and their 

precursors. Fine particles have a diameter smaller than 2.5 micrometers (μm) and are 

also called PM2.5. Particles affect visibility through the scattering and absorption of 

light, and PM2.5 – particles similar in size to the wavelength of light – are most efficient, 

per unit of mass, at reducing visibility. 

PM2.5 may either be emitted directly or formed from emissions of precursors, the most 

important of which are sulfur dioxides (SO2) and nitrogen oxides (NOx). Reducing 

PM2.5 in the atmosphere will reduce regional haze, resulting in improved visibility. The 

most important sources of PM2.5 and its precursors are coal-fired power plants, industrial 

boilers and other combustion sources. Other significant contributors to PM2.5 and 

visibility impairment include mobile sources, area sources, fires, and wind blown dust.

PM2.5 adversely impacts human health, especially respiratory and cardiovascular 

systems. PM2.5 also has significant environmental impacts, including acid rain and 

stream eutrophication. To protect public health and the environment, the United States 

Environmental Protection Agency (EPA) has set national ambient air quality standards 

for daily and annual levels of PM2.5. Although the goal of the regional haze program is 

a return to natural visibility in the Class I areas, actions taken to improve visibility can 

also be expected to benefit public health and reduce certain adverse effects on the 

environment. Visibility throughout the region will improve as a result of the actions 

taken to achieve the goals of the regional haze program. 
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1.2. History of the Federal Regional Haze Rule

The EPA addressed reasonably attributable visibility impairment or plume blight by 

promulgating regulations in 1980. (45 FR 80045 (Dec. 2, 1980)). The regulations 

reduced visibility impairment from specific pollution sources. However, EPA deferred 

development of regional haze regulations until better monitoring, modeling and scientific 

knowledge about regional haze were available.

When the CAA was amended in 1990, Congress added Section 169B (42 U.S.C. § 7492), 

authorizing further research and regular assessments of the progress made so far toward 

the national visibility goals. In 1993, the National Academy of Sciences concluded that 

“current scientific knowledge is adequate and control technologies are available for 

taking regulatory action to improve and protect visibility.”1

In addition to authorizing creation of visibility transport commissions and setting forth 

their duties, Section 169B(f) of the CAA mandated creation of the Grand Canyon 

Visibility Transport Commission (GCVTC) to make recommendations to EPA for the 

region affecting the visibility of the Grand Canyon National Park. The GCVTC 

submitted its report to EPA in June 1996, following four years of research and policy 

development. The GCVTC report, as well as the many research reports prepared by the 

GCVTC, contributed invaluable information to EPA in its development of the federal 

Regional Haze Rule (RHR). 

EPA provided grant funding for five Regional Planning Organizations (RPOs) throughout 

the country to assist with the multi-state coordination and cooperation needed to address 

regional haze issues. In 2001, the Mid-Atlantic and Northeast states, the District of 

Columbia, and tribes within the region formed the Mid-Atlantic/Northeast Visibility 

Union (MANE-VU)2 to coordinate regional haze planning activities for the region.

EPA’s RHR was published in the Federal Register on July 1, 1999. The RHR aims to 

achieve the national visibility goal set by the CAA by 2064. The rule addresses the 

combined visibility effects of various pollution sources over a wide geographic region. 

The RHR requires all states, even those that do not contain a Class I area, to submit a 

revision to their State Implementation Plan (SIP) containing emission reduction strategies 

to improve visibility in Class I areas that their emissions affect. Guidelines for 

implementation of the Best Available Retrofit Technology (BART) requirements of the 

federal RHR were initially proposed on July 20, 2001 (66 FR 38108). 

EPA’s RHR was subsequently revised in response to a legal challenge brought by 

industry and environmental groups. On May 24, 2002, the United States Court of 

Appeals for the District of Columbia Circuit issued a ruling vacating the RHR in part and 

sustaining it in part. The ruling vacated and remanded to EPA the BART provisions of 

 

1 Protecting Visibility in National Parks and Wilderness Areas, National Research Council (Washington, 

D.C. 1993).

2 For a description of MANE-VU and a full list of its members, see Section 3, below.
15

the rule. The Court’s ruling denied industry’s challenge to the RHR’s goal of natural 

visibility and requirement of no degradation of visibility. On May 5, 2004, EPA 

published proposed revisions to the regional haze rule and guidelines for BART 

determinations in the Federal Register (69 FR 25184). The final RHR and BART 

guidelines were published in the Federal Register on July 6, 2005 (70 FR 39104). A 

further revision to the rule was proposed August 1, 2005 (70 FR 44154) and finalized 

October 13, 2006 (71 FR 60612), pertaining to requirements for alternative trading 

programs. The regulations can be found at 40 C.F.R. Part 51, subpart P (relating to 

protection of visibility). 

1.3. General Overview of Regional Haze SIP Requirements

Section 51.308(d) of the RHR requires states to demonstrate reasonable progress toward 

meeting the national goal of a return to natural visibility conditions by 2064. As a guide 

for reasonable progress, the RHR directs states to consider what would be a “uniform rate 

of progress” toward natural conditions for each mandatory Class I Federal area within the 

State and/or for each mandatory Class I Federal area located outside the State, which may 

be affected by emissions from sources within the State. States with Class I areas are to 

establish baseline visibility conditions for 2000-2004, natural background visibility 

conditions in 2064, and the rate of uniform progress between baseline and background 

conditions. The uniform rate of progress is also known as the “glidepath.” The RHR 

stipulates that visibility targets and tracking of visibility changes over time be expressed 

in terms of the “deciview” haze metric. Deciview is an atmospheric haze index that 

expresses changes in visibility, and is a measurement of visibility impairment (see 40 

CFR § 51.301). This means that the lower the deciview value, the better the perception 

of visibility.

The RHR also requires States with Class I areas to establish reasonable progress goals 

(RPGs), expressed in deciviews, for visibility improvement at each Class I area. The 

goals must provide for reasonable progress toward achieving natural visibility conditions, 

provide for improvement in visibility for the most impaired days over the period of the 

implementation plan, and ensure no degradation in visibility for the least impaired days 

over the same period (see 40 C.F.R. § 51.308(d)(1)). 

This first set of reasonable progress goals must be met through measures contained in 

each state’s long-term strategy covering the period from the present until 2018. The 

long-term strategy includes enforceable emissions limitations, compliance schedules, and 

other measures as necessary to achieve the reasonable progress goals, including all 

controls required or expected under all federal and state regulations by 2009 and by 2018. 

During development of the long-term strategy, states are also required to consider 

specific factors, such as the abovementioned ongoing control programs, measures to 

mitigate construction activities, source retirement and replacement schedules, smoke 

management programs for agriculture and forestry, and enforceability of specific 

measures (see 40 C.F.R. § 51.308(d)(3)).
16

In addition, a specific component of each state’s first long-term strategy is dictated by the 

specific BART requirements in 40 CFR § 51.308(e) of the RHR. Section 51.308(e) of 

the RHR requires states to include a determination of BART for each BART-eligible 

source in the state that emits any air pollutant, which may reasonably be anticipated to 

cause or contribute to any impairment of visibility in any mandatory Class I area. Section 

169A(b) of the CAA defines “BART-eligible sources” as sources in 26 specific source 

categories, in operation within a 15-year period prior to enactment of the 1977 Clean Air 

Act amendments. States must determine BART according to five factors set out in 

section 169A(g)(2) of the CAA. Emission limitations representing BART and schedules 

for compliance with BART for each source subject to BART must be included in the 

long-term strategy.

The federal Clean Air Interstate Rule (CAIR) was promulgated on May 12, 2005 (70 FR 

25162). CAIR is an interstate trading program designed to mitigate the interstate 

transport of NOx and SO2 from electric generating units (EGUs). CAIR was vacated by 

the United States Court of Appeals for the District of Columbia Circuit on July 11, 2008 

and subsequently remanded on December 23, 2008, to EPA to promulgate a new rule 

consistent with the Court’s July 11, 2008 opinion. As a result of the remand and EPA 

approval of Pennsylvania’s CAIR as a SIP revision effective December 10, 2009 (74 FR 

65446), CAIR is being implemented in this Commonwealth. The owners and operators 

of EGUs in the Commonwealth must reduce nitrogen oxide (NOx) and sulfur dioxide 

(SO2) emissions according to the Department’s CAIR regulation. As a result of the 

Court’s remand of the federal CAIR to EPA, it is reasonable to expect that a replacement 

for the federal CAIR will be in place to evaluate the Commonwealth’s emissions controls 

by the time the first regional haze progress report is due.

Under the federal RHR, states are required to evaluate progress toward reasonable 

progress goals every five years to assure that installed emissions controls are on track 

with emissions reduction forecasts in the SIP. The first progress report is due 5 years 

from the submittal of the initial implementation plan. If emissions controls are not on 

track to meet SIP forecasts, then a state would need to take action to assure emissions 

controls by 2018 will be consistent with the SIP or to revise the SIP to be consistent with 

the revised emissions forecast. 
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2.0. General Planning Provisions

Pursuant to 40 CFR § 51.308(a) and (b), the Pennsylvania Department of Environmental 

Protection (Department) submits this SIP revision to meet the requirements of the CAA 

and its implementing provisions in EPA’s RHR. Elements of this SIP revision address 

the core requirements of 40 CFR § 51.308(d) and the BART components of 40 CFR 

§ 51.308(e). In addition, this SIP revision addresses regional planning and State/Tribe 

and Federal Land Manager coordination, and sets forth how Pennsylvania will address 

those requirements.

Pennsylvania is authorized under the Air Pollution Control Act and implementing 

regulations to submit this SIP revision in accordance with State laws and regulations.

3.0. Regional Planning

In 1999, EPA and affected States and Tribes agreed to create five RPOs to facilitate 

interstate coordination on Regional Haze SIPs and Tribal Implementation Plans. 

Pennsylvania is a member of the MANE-VU RPO. MANE-VU was formed by the MidAtlantic and Northeastern states, tribes, and federal agencies to coordinate regional haze 

planning activities for the region. MANE-VU was formed to encourage a coordinated 

approach to meeting the requirements of EPA’s RHR and reducing visibility impairment 

in major national parks and wilderness areas in the Northeast and Mid-Atlantic. The 

MANE-VU document, “MANE-VU Interim Report (May 2006),” outlines the MidAtlantic and Northeast region’s approach to air quality planning for regional haze and can 

be found in Appendix A.

MANE-VU provides technical assessments and assistance to its members, evaluates 

linkages to other regional air pollution issues, provides a forum for discussion, and 

encourages coordinated actions. MANE-VU also facilitates coordination with other 

regions. MANE-VU is governed by a Board of state and tribal Commissioners and 

Secretaries, and air program directors. It has two committees composed of agency 

personnel: a Technical Support Committee to assess the nature of regional haze and help 

states develop coordinated programs; and a Communications Committee to develop 

outreach messages and approaches. MANE-VU also established a Policy Advisory 

Group to facilitate coordination among members on policy issues. Members of MANEVU are listed in Table 3.0-1. The MANE-VU Class I areas are shown in Figure 3.0-1.
18

Table 3.0.-1 MANE-VU Members

Connecticut Pennsylvania

Delaware Penobscot Nation

District of Columbia Rhode Island

Maine St. Regis Mohawk Tribe

Maryland Vermont

Massachusetts U.S. Environmental Protection Agency (EPA)*

New Hampshire National Park Service (NPS)*

New Jersey U.S. Fish and Wildlife Service (FWS)*

New York U.S. Forest Service (USFS)*

* Non-voting members 

Figure 3.0.-1 MANE-VU Class I Areas

This SIP revision utilizes data analysis, modeling results and other technical support 

documents prepared for MANE-VU members. By coordinating with MANE-VU and 

other RPOs, the Department has worked to ensure that its long term strategy and BART 

determinations provide sufficient reductions to mitigate impacts of emissions from 

sources located in Pennsylvania on affected Class I areas. 

In accordance with 40 CFR § 51.308, emissions sources within Pennsylvania have or 

may have impacts on the following Class I Areas in MANE-VU: Acadia National Park, 

Maine; Brigantine Wilderness (within the Edwin B. Forsythe National Wildlife Refuge), 

New Jersey; Great Gulf Wilderness, New Hampshire; Lye Brook Wilderness, Vermont; 

Moosehorn Wilderness (within the Moosehorn National Wildlife Refuge), Maine; 

Presidential Range – Dry River Wilderness, New Hampshire; and Roosevelt Campobello 

International Park, New Brunswick. 
19

A contribution assessment analysis was completed by the Northeast States for 

Coordinated Air Use (NESCAUM), entitled Contributions to Regional Haze in the 

Northeast and Mid-Atlantic States (see the Contribution Assessment for MANE-VU, 

August 2006, Appendix B). The MANE-VU Contribution Assessment indicates that 

emission sources located in Pennsylvania may impact visibility at the following Class I 

areas outside MANE-VU: Dolly Sods Wilderness/Otter Creek Wilderness Area (the 

Dolly Sods IMPROVE monitor is also representative of Otter Creek) in West Virginia; 

and Shenandoah National Park and James River Face Wilderness Area in Virginia. The 

Department has conferred with regional haze planning staff in both Virginia and West 

Virginia. Neither of these two States intends to request that Pennsylvania make 

additional reductions at emission sources located in Pennsylvania. 

The RPO that represents West Virginia and Virginia, the Visibility Improvement State 

and Tribal Association of the Southeast (VISTAS), conducted 2018 visibility modeling to 

establish the reasonable progress goals for the Dolly Sods Wilderness Area (and the Otter 

Creek Wilderness Area because the Dolly Sods IMPROVE monitor is also representative 

of Otter Creek), and for Shenandoah National Park (VISTAS, Shenandoah Group 

Contribution Assessment, May 2007, Appendix C). This modeling shows that the 

maximum projected contribution of any single source unit from Pennsylvania to visibility 

impairment at Dolly Sods Wilderness Area, Shenandoah National Park or James River 

Face Wilderness Area is less than 1%. The West Virginia Department of Environmental 

Protection sent an email, dated September 13, 2007, to the Department stating “we are 

not going to ask PA to make any additional reductions or to consult further.” The 

Virginia Department of Environmental Quality sent an email to the Department, dated 

September 14, 2007, stating “VA is not asking PA for any additional reductions or for 

further consultation during this round of RH since our analysis shows that maximum 

normalized contribution of any PA source to Shenandoah or James River Face is <1%.” 

(See Appendix D for copies of the West Virginia and Virginia emails.)
20

4.0. State/Tribe and Federal Land Manager Coordination

In accordance with Section 169A(d) of the CAA, (42 U.S.C. § 169A(d), and 40 CFR 

§ 51.308(i)), coordination between States or Tribes and the Federal Land Managers 

(FLMs) is required. The Department is also required under 40 CFR § 51.308(i)(2), to 

provide the Federal Land Managers the opportunity for consultation, in person and at 

least 60 days prior to holding any public hearing on an implementation plan (or plan 

revision) for regional haze. This coordination has occurred, during both the MANE-VU 

and the Department processes. Opportunities have been provided by MANE-VU for 

FLMs to review and comment on each of the technical documents developed by MANEVU and included in this SIP revision. The Department has provided agency contacts to 

the FLMs, as required. 

Prior to beginning the mandated consultation process, the Department sent a preliminary 

draft of the regional haze SIP revision to the FLMs on August 24, 2007. Additionally, 

the Department held conference calls with the FLMs on August 31, 2007, September 14, 

2007 and October 19, 2007. The following agencies participated in some or all of the 

conference calls: U.S. EPA, U.S. Forest Service, U.S. Department of Interior, U.S. Fish 

and Wildlife Service, and the National Park Service. (See Appendix D for copies of the 

Agendas for the August 31, 2007 and September 14, 2007 conference calls with the 

FLMs.)

The Department provided the FLMs an opportunity for consultation, in person and at 

least 60 days prior to holding Pennsylvania’s public hearings on the proposed regional 

haze SIP revision. During development of this plan, the FLMs were consulted in 

accordance with 40 CFR § 51.308(i)(2). The Department sent a draft of the regional haze 

SIP revision to the FLMs on June 2, 2010, beginning the mandated 60-day consultation 

period. During the consultation process, the FLMs were given the opportunity to 

address:

• Assessment of the impairment of visibility in mandatory Class I Federal areas.

• Recommendations on the development of reasonable progress goals.

• Recommendations on the development and implementation of strategies to 

address visibility impairment.

• BART Determinations.

• Ongoing Consultation Process.

As required under 40 CFR § 51.308(i)(3), the Department received specific comments 

from the FLMs regarding the draft proposed SIP revision during the mandated 60-day 

consultation period. The FLM’s comments and the Department’s responses are included 

in Appendix AA. The Department did not receive any comments during the public 

comment period; therefore a Comment and Response document is not included in this 

final SIP revision.

The Department will continue to coordinate and consult with the FLMs on the 

implementation of the visibility protection program, in accordance with 40 CFR 
21

§ 51.308(i)(4). This process will include coordination and consultation on the 

development and review of implementation plan revisions and 5-year progress reports 

and on the implementation of other programs having the potential to contribute to 

visibility impairment in mandatory Class I areas. The following may be appropriate 

topics for future, ongoing consultations with the FLMs:

1. Implementation of emissions strategies identified in the SIP as contributing to 

achieving improvement in the worst-day visibility.

2. Summary of major new source permits issued.

3. Status of actions to complete any future assessments or rulemakings on sources 

identified as likely contributors to visibility impairment, but not directly 

addressed in the most recent SIP revision 

4. Any changes to the monitoring strategy or monitoring stations status that may 

affect tracking of reasonable progress.

5. Preparation for the 5-year review and /or 10-year SIP revision.

6. Items for FLMs to consider or provide support for in preparation for any visibility 

protection SIP revisions (based on a 5-year review or the 10-year revision 

schedule under EPA’s RHR). 

7. Summary of topics covered in ongoing communications between the Department

and the FLMs regarding implementation of the visibility program. 

The ongoing consultations will be coordinated with the designated visibility protection 

program coordinators for the National Park Service, United States Fish and Wildlife 

Service and United States Forest Service. 

In addition to the consultations required under 40 CFR § 51.308(i)), the Department, EPA 

Region 3, and the FLMs for Shenandoah National Park, James River Face Wilderness, 

Dolly Sods Wilderness, Otter Creek Wilderness and Brigantine Wilderness entered into a 

Memorandum of Understanding (MOU), effective on August 30, 2006, that established 

mutually acceptable guidelines for the effective protection of air quality related values, 

which include visibility impairment. The MOU was developed to define the framework 

for operational procedures for the review and comment on Prevention of Significant 

Deterioration (PSD) plan approval applications submitted to the Department which could 

have an impact on the above referenced Class I areas. In addition, this MOU supports the 

Department’s efforts in meeting reasonable progress. This MOU is found in Appendix 

D.
22

5.0. Assessment of Baseline Conditions and Estimate of Natural Conditions in 

 Class I Areas

Under the CAA, this regional haze SIP revision must contain measures to make 

reasonable progress toward the goal of achieving natural visibility. Each state containing 

a Class I area must determine baseline and natural visibility conditions for its Class I 

area(s) in consultation with FLMs and states identified as containing sources whose 

emissions contribute to visibility impairment in the Class I area. Comparing baseline 

conditions to natural background visibility conditions determines the uniform rate of

progress that must be considered as states set reasonable progress goals for each Class I 

area. 

In September 2003, EPA finalized guidance for the calculation of natural background and 

baseline visibility conditions. The guidance provides a default method and describes 

certain refinements that states may wish to evaluate to tailor these estimates to a specific 

Class I area if it is poorly represented by the default method. At that time, MANE-VU 

calculated estimated natural visibility for each of the MANE-VU Class I areas using the 

default method. MANE-VU calculated estimates for the 20% best and worst visibility 

days. MANE-VU evaluated options for refining the estimates. Potential refinements 

assessed included: increasing the multiplier used to calculate impairment attributed to 

carbon, adjusting the formula used to calculate the 20% best and worst visibility days, 

and accounting for visibility impairment due to sea salt at coastal sites. MANE-VU 

found that these refinements, however, did not significantly improve the accuracy of the 

estimates, and MANE-VU states desired a consistent approach. Therefore, MANE-VU 

proposed using the default estimates with the understanding that refinements would be 

reconsidered as scientific consensus on refinements develops. 

After the technical analysis was complete, MANE-VU provided an opportunity for 

federal agencies and stakeholders to comment on the analysis. The proposed approach 

was posted on the MANE-VU website on March 17, 2004, and a stakeholder briefing was 

held on the same day. Comments were received from the Electric Power Research 

Institute, the Midwest Ozone Group, the Appalachian Mountain Club, the National Parks 

Conservation Association, the National Park Service, and the United States Forest 

Service. 

Several commentators supported the proposal. Other comments addressed four main 

topics: the equation used to calculate visibility, the statistical technique used to estimate 

the 20% best and worst visibility days, the inclusion of trans-boundary effects and fires, 

and the timing of when new information should be included. All comments were 

reviewed and summarized by MANE-VU. The MANE-VU air directors were briefed on 

the comments, the proposed response options, and the implications.

After serious consideration, MANE-VU decided, at that time, to support the use of the 

default approach to calculating baseline and natural background conditions because 

national consistency in calculating estimates would allow MANE-VU to collaborate with 
23

other regions more effectively. The MANE-VU position on natural background 

conditions was issued in June 2004, and stated that, “Refinements to other aspects of the 

default method (e.g., refinements to the assumed distribution or treatment of Rayleigh 

extinction, inclusion of sea salt, and improved assumptions about the chemical 

composition of the organic fraction) may be warranted prior to submission of SIPs 

depending on the degree to which scientific consensus is formed around a specific 

approach...”

In 2006, the Interagency Monitoring of Protected Visual Environments (IMPROVE) 

Steering Committee adopted an alternative reconstructed extinction equation to address 

certain aspects of the default method. The aspects addressed are scientifically well 

understood and improve the performance of the equation at reproducing observed 

visibility at Class I sites. In 2006, MANE-VU conducted an assessment of the default 

and alternative approaches for calculation of baseline and natural background conditions 

at MANE-VU Class I areas. Based on that assessment, in December 2006, MANE-VU 

recommended adoption of the alternative reconstructed extinction equation for use in the 

December 2007 regional haze SIPs. (See the MANE-VU document, “Baseline and 

Natural Background Visibility Conditions: Considerations and Proposed Approach to the 

Calculation of Baseline and Natural Background Visibility Conditions at MANE-VU 

Class I Areas,” Appendix E.) MANE-VU will continue to participate in further research 

efforts on this topic and will reconsider the calculation methodology as scientific 

understanding evolves.

The IMPROVE program was initiated in 1985 to establish current visibility conditions, 

track changes in visibility, and help determine the causes of visibility impairment in Class 

I areas. Data from the following IMPROVE monitors (Table 5.0-1 and Table 5.0-2) are

representative of Class I Areas in and near MANE-VU.

Table 5.0-1 IMPROVE Information for MANE-VU Class I Areas

Class I Area IMPROVE Site

Location 

(latitude 

and 

longitude) State

Acadia National Park ACAD1 44.38, -68.26 Maine

Moosehorn Wilderness Area MOOS1 45.13, -67.27 Maine

Roosevelt/Campobello International 

Park MOOS1 45.13, -67.27 Maine

Great Gulf Wilderness Area GRGU1 44.31, -71.22 New Hampshire

Presidential Range/Dry River

Wilderness GRGU1 44.31, -71.22 New Hampshire

Lye Brook Wilderness Area LYBR1 43.15, -73.13 Vermont

Brigantine Wilderness Area BRIG1 39.47, -74.45 New Jersey

Source: VIEWS (http://vista.circa.colostate.edu/views/), prepared on 7/06/06
24

Table 5.0-2 IMPROVE Information for Nearby Class I Areas

Class I Area IMPROVE Site

Location 

(latitude 

and 

longitude) State

Dolly Sods Wilderness DOSO1 39.11, -79.43 West Virginia

Otter Creek Wilderness DOSO1 39.11, -79.43 West Virginia

Shenandoah National Park SHEN1 38.52, -78.43 Virginia

James River Face Wilderness JARI1 37.63, -79.51 Virginia

Source: VIEWS (http://vista.circa.colostate.edu/views/), prepared on 9/10/07

The IMPROVE program has calculated baseline (2000-2004) and natural visibility 

conditions for each IMPROVE monitoring site at MANE-VU Class I areas using EPAapproved methods. These values are posted on the Visibility Information Exchange Web 

System (VIEWS) operated by the RPOs (available online at 

http://vista.cira.colostate.edu/views/). Table 5.0-3 displays the baseline visibility for the 

20% worst and the 20% best visibility days based on the five-year average for 2000-

2004, natural background visibility for the 20% worst and the 20% best visibility days, 

and the difference between baseline and natural visibility conditions for each MANE-VU 

Class I area.

Table 5.0-3 Summary of Baseline Visibility and Natural Conditions for the 20% 

Worst and 20% Best Visibility Days at MANE-VU Class I Areas

Class I Area

2000-2004 

Baseline (dv) 

Natural 

Conditions (dv)

Difference (dv)

Worst 

20%

Best 

20%

Worst 

20%

Best 

20%

Worst 

20%

Best 

20%

Acadia National Park 22.89 8.77 12.43 4.66 10.46 4.11

Moosehorn Wilderness Area 21.72 9.15 12.01 5.01 9.71 4.14

Roosevelt/Campobello 

International Park 21.72 9.15 12.01 5.01 9.71 4.14

Great Gulf Wilderness Area 22.82 7.66 11.99 3.73 10.83 3.93

Presidential Range/Dry River 

Wilderness 22.82 7.66 11.99 3.73 10.83 3.93

Lye Brook Wilderness Area 24.45 6.36 11.73 2.79 12.72 3.57

Brigantine Wilderness Area 29.01 14.33 12.24 5.51 16.77 8.82

Source: VIEWS (http://vista.circa.colostate.edu/views/), prepared on 5/12/08.

Table 5.0-4 displays the baseline visibility for the 20% worst and the 20% best visibility 

days based on the five-year average for 2000-2004, natural background visibility for the 
25

20% worst and the 20% best visibility days, and the difference between baseline and 

natural visibility conditions for nearby Class I Areas.

Table 5.0-4 Summary of Baseline Visibility and Natural Conditions for the 20% 

Worst and 20% Best Visibility Days at Nearby Class I Areas

Class I Area

2000-2004 

Baseline (dv) 

Natural 

Conditions (dv)

Difference (dv)

Worst 

20%

Best 

20%

Worst 

20%

Best 

20%

Worst 

20%

Best 

20%

Dolly Sods Wilderness Area 29.04 12.28 10.39 3.63 18.65 8.65

Otter Creek Wilderness Area 29.04 12.28 10.39 3.63 18.65 8.65

Shenandoah National Park 29.31 10.93 11.35 3.14 17.96 7.79

James River Face Wilderness 

Area 29.12 14.21 11.13 4.39 17.99 9.82

Source: VIEWS (http://vista.circa.colostate.edu/views/), prepared on 9/10/2007

There are no Class I areas in Pennsylvania. As described in Section 3, the Department

coordinated and consulted with the MANE-VU Class I area states that are or may be 

affected by emissions from sources located in Pennsylvania as those States assessed 

baseline and natural background visibility conditions in their respective Class I areas. 

The Department also consulted with other States by participating in the MANE-VU and 

Inter-RPO regional haze planning strategies.
26

6.0. Monitoring Strategy 

Visibility conditions representative of those within the MANE-VU Class I areas are 

monitored by IMPROVE. In the mid-1980’s, the IMPROVE program was established to 

measure visibility impairment in mandatory Class I areas throughout the United States. 

The monitoring sites are operated and maintained through a formal cooperative 

relationship between the EPA, National Park Service, United States Fish and Wildlife 

Service, Bureau of Land Management, and United States Forest Service. In 1991, several 

additional organizations joined the effort: the State and Territorial Air Pollution Program 

Administrators and the Association of Local Air Pollution Control Officials, which is 

now the National Association of Clean Air Agencies (NAACA), the Western States Air 

Resources Council, the Mid-Atlantic Regional Air Management Association 

(MARAMA), and Northeast States for Coordinated Air Use Management (NESCAUM). 

6.1. IMPROVE Program Objectives 

Data collected at IMPROVE sites are used by land managers, industry planners, 

scientists, public interest groups, and air quality regulators to understand and protect the 

visual air quality resource in Class I areas. Most importantly, the IMPROVE program 

scientifically documents for American citizens the visual air quality of their wilderness 

areas and national parks. A Quality Assurance Project Plan (QAPP) for the IMPROVE 

program, dated March 2002, can be found at: 

http://vista.cira.colostate.edu/improve/Publications/QA_QC/IMPROVE_QAPP_R0.pdf 

The IMPROVE Program objectives include:

• Establish current visibility and aerosol conditions in mandatory Class I areas,

• Identify chemical species and emission sources responsible for existing 

anthropogenic visibility impairment,

• Document long-term trends for assessing progress towards the national visibility 

goals,

• Provide regional haze monitoring representing all mandatory federal Class I areas 

where practical, as required by EPA’s RHR.

Section 51.308(d)(4)(iii) of EPA’s RHR requires the inclusion of procedures by which 

monitoring data and other information are used in determining the contribution of 

emissions from within Pennsylvania to regional haze visibility impairment at the 

mandatory Class I Federal areas outside of Pennsylvania. Pennsylvania accepts the 

contribution assessment analysis completed by NESCAUM entitled, Contributions to 

Regional Haze in the Northeast and Mid-Atlantic States (see Appendix B). Methods of 

visibility and emissions data analysis used in preparing the contribution assessment 

include source apportionment analysis (see Appendix B), trajectory analysis (see Chapter 

5), emissions divided by distance (see Chapter 4), emissions times upwind probability 

(see Chapter 4), chemical transport models (see Chapter 6), and Lagrangian dispersion 

modeling (see Chapter 7). The many techniques used provided a stronger weight of 

evidence for the assessment of contribution by source types and regions.
27

Pennsylvania agrees that NESCAUM is providing quality technical information by using 

the IMPROVE program data and the VIEWS site. Information about the use of the 

default and alternative approaches to the calculation of baseline and natural background 

conditions can be found in Section 5 Assessment of Baseline and Natural Conditions of 

this SIP.

Because there are no Class I areas located in Pennsylvania, a monitoring plan is not 

required under 40 CFR § 51.308(d)(4). The Department considers the IMPROVE 

monitors located at Class I areas in MANE-VU to be representative of those Class I areas 

and the monitoring data from those monitors to be a reasonable basis for assessing 

progress toward the regional haze program goals. The Department believes that every 

effort should be made to maintain the IMPROVE monitoring network to provide the 

long-term consistency necessary to track progress toward the regional haze program 

goals. A description of the representative IMPROVE monitor for each MANE-VU Class 

I area is provided in the following section.

6.2. Monitoring Information for MANE-VU Class I Areas

Acadia National Park, Maine

The IMPROVE monitor for the Acadia National Park (indicated as ACAD1) is located at 

Acadia National Park Headquarters in Maine at an elevation of 157 meters, a latitude of 

44.38 ̊ and a longitude of -68.26 ̊. The haze data for Acadia National Park is collected by 

an IMPROVE monitor (ACAD1) that is operated and maintained by the National Park 

Service.

Figure 6.2-1 Map of Acadia National Park (source: 

http://www.maine.gov/dep/air/meteorology/images/Acadia.jpg)
28

Figure 6.2-2 Acadia National Park on a clear day (source

http://www.hazecam.net/class1/acadia.html)
29

Figure 6.2-3 Acadia National Park on a hazy day (source: 

http://www.hazecam.net/class1/acadia.html)
30

Brigantine Wilderness Area, New Jersey

The IMPROVE monitor for the Brigantine Wilderness Area (indicated as BRIG1) is 

located at the Edwin B. Forsythe National Wildlife Refuge Headquarters in Oceanville 

New Jersey at an elevation of 5 meters, a latitude of 39.47 ̊ and a longitude of -74.45 ̊. 

The haze data for Brigantine Wilderness Area is collected by an IMPROVE monitor 

(BRIG1) that is operated and maintained by the Fish & Wildlife Service. 

Figure 6.2-4 Map of Edwin B. Forsythe National Wildlife Refuge (source: 

http://www.fws.gov/northeast/forsythe/MAP.htm)
31

Figure 6.2-5 Brigantine Wilderness Area on a clear day (source: 

http://www.hazecam.net/class1/brigantine.html)

Figure 6.2-6 Brigantine Wilderness Area on a hazy day (source: 

http://www.hazecam.net/class1/brigantine.html)
32

Great Gulf Wilderness Area, New Hampshire

The IMPROVE monitor for the Great Gulf Wilderness Area (indicated as GRGU1) is 

located at Camp Dodge, White Mountain NF, South of Gorham New Hampshire, at an 

elevation of 454 meters, a latitude of 44.31 ̊ and a longitude of -71.22 ̊. This monitor also 

represents the Presidential Range/Dry River Wilderness Area in New Hampshire. The 

haze data for Great Gulf Wilderness Area is collected by an IMPROVE monitor 

(GRGU1) that is operated and maintained by the Forest Service. 

Figure 6.2-7 Map of Great Gulf Wilderness Area and Presidential Range/Dry River 

Wilderness Area (source: 

http://www.maine.gov/dep/air/meteorology/images/NHclass1.jpg)
33

Figure 6.2-8 Great Gulf Wilderness Area on a clear day (source: 

http://www.wilderness.net/)

Figure 6.2-9 Great Gulf Wilderness Area on a hazy day (source: 

http://www.wilderness.net/)
34

Lye Brook Wilderness, Vermont

The IMPROVE monitor for the Lye Brook Wilderness Area (indicated as LYBR1) is 

located on Mount Equinox at the windmills in Manchester Vermont at an elevation of 

1015 meters, a latitude of 43.15 ̊ and a longitude of -73.13 ̊. The haze data for Lye 

Brook Wilderness Area is collected by an IMPROVE monitor (LYBR1) that is operated 

and maintained by the Forest Service. 

Figure 6.2-10 Map of Lye Brook Wilderness Area (source: 

http://www.wilderness.net/index.cfm?fuse=NWPS&sec=stateView&state=NH&map=me

nhvt)
35

Figure 6.2-11 Lye Brook Wilderness Area on a clear day (source: 

http://www.hazecam.net/class1/lye.html)

Figure 6.2-12 Lye Brook Wilderness Area on a hazy day (source: 

http://www.hazecam.net/class1/lye.html)
36

Moosehorn Wilderness Area, Maine

The IMPROVE monitor for the Moosehorn Wilderness Area (indicated as MOOS1) is 

located near McConvey Road, about one mile northeast of the National Wildlife Refuge 

Baring Unit Headquarters in Maine at an elevation of 78 meters, a latitude of 45.13 ̊ and a 

longitude of -67.27 ̊. This monitor also represents the Roosevelt/Campobello 

International Park in New Brunswick, Canada. The haze data for Moosehorn Wilderness 

Area is collected by an IMPROVE monitor (MOOS1) that is operated and maintained by 

the Fish & Wildlife Service. 

Figure 6.2-13 Map of Moosehorn Wilderness Area that differentiates between the 

Wilderness Area and the Wildlife Refuge (source: Martha Webster of Maine 

Department of Environmental Protection-Bureau of Air Quality)
37

Figure 6.2-14 Moosehorn Wilderness Area on a clear day (source: NESCAUM)
38

Figure 6.2-15 Moosehorn Wilderness Area on a hazy day (source: NESCAUM)
39

Presidential Range/Dry River Wilderness Area, New Hampshire

The IMPROVE monitor for the Great Gulf Wilderness Area also represents the 

Presidential Range/Dry River Wilderness Area (indicated as GRGU1). The Presidential

Range/Dry River Wilderness Area monitor is located at Camp Dodge, White Mountain 

NF, South of Gorham New Hampshire, at an elevation of 454 meters, a latitude of 44.31 ̊ 

and a longitude of -71.22 ̊. The haze data Presidential Range/Dry River Wilderness Area 

is collected by an IMPROVE monitor (GRGU1) that is operated and maintained by the 

Forest Service. 

Figure 6.2-16 Map of Great Gulf Wilderness Area and Presidential Range/Dry 

River Wilderness Area (source: 

http://www.maine.gov/dep/air/meteorology/images/NHclass1.jpg)
40

Figure 6.2-17 Presidential Range/Dry River Wilderness Area shares a scene camera 

with Great Gulf Wilderness Area. Since the pictures would be the same for both sites, 

below is a picture of Presidential Range/Dry River Wilderness Area in autumn (source: 

http://www.wilderness.net/)
41

Roosevelt/Campobello International Park, New Brunswick, Canada

The IMPROVE monitor for the Moosehorn Wilderness Area is also the monitor for 

Roosevelt/Campobello International Park (indicated as MOOS1). The monitor is located 

near McConvey Road, about one mile northeast of the Moosehorn National Wildlife 

Refuge Baring Unit Headquarters in Maine at an elevation of 78 meters, a latitude of 

45.13 ̊ and a longitude of -67.27 ̊. The haze data for Roosevelt/Campobello International 

Park is collected by the IMPROVE monitor (MOOS1) that is operated and maintained by 

the United States Fish & Wildlife Service. 

Figure 6.2-18 Map of Roosevelt/Campobello International Park (source: 

http://www.maine.gov/dep/air/meteorology/images/rcip.jpg)

Figure 6.2-19 Roosevelt/Campobello International Park on a clear day (source: 

Chessie Johnson)
42

Figure 6.2-20 Roosevelt/Campobello International Park on a hazy day (source: 

Roosevelt Campobello International Park Commission)

6.3. Use of Monitoring Data in Contribution Assessment

Monitoring data contributes to our understanding of visibility impairment in the region. 

A review of the literature and of recent monitoring data has yielded a conceptual model 

of visibility impairment in the MANE-VU region that attributes a dominant role, on the 

worst visibility days, to the sulfate component of fine particle matter. Available 

monitoring data support and validate this conceptual model.

Given that sulfates, in particular, play a dominant role in causing visibility impairment 

throughout the Eastern United States, MANE-VU has employed multiple methods of 

apportioning the sulfate mass found in ambient air at Class I sites to contributing states 

and regions. This weight-of-evidence approach relies on several independent methods 

for assessing the contribution of different emissions sources and geographic source 

regions to regional haze in the northeastern and mid-Atlantic portions of the United 

States. These include Eulerian (grid-based) source models, Lagrangian (air pollutionbased) source dispersion models, and a variety of data analysis techniques that include 

source apportionment models, back trajectory calculations, and the use of monitoring and 

inventory data. This weight-of-evidence approach to the contribution assessment and 

pollution apportionment analysis required by the regional haze regulations is intended to 

overcome large uncertainties that would otherwise undermine confidence in the results 

obtained using any one modeling or analysis technique by itself.

6.4. Additional Monitoring Data

While the Department believes that the current IMPROVE network provides sufficient 

data to adequately measure and report progress toward the goals set for Class I areas that 

emission sources located in Pennsylvania may affect, the Department has also found 

additional monitoring information useful to assess visibility and fine particle pollution in 
43

the region. Examples of these data include results from the MANE-VU Rural Aerosol 

Intensive Network (RAIN) network, which provides continuous, speciated information 

on rural aerosol characteristics and visibility parameters; the EPA Clean Air Status and 

Trends Network (CASTNET) program, which provides complementary rural fine particle

speciation data at non-class I sites; the EPA Speciation Trends Network (STN), which 

provides speciated, urban fine particle data to help develop a comprehensive picture of

local and regional sources; state-operated rural and urban speciation sites using

IMPROVE or STN methods; and the Supersites program, which has provided 

information through special studies that generally expands our understanding of the 

processes that control fine particle formation and transport in the region. The Department

will continue to utilize these and other data -- as they are available and fiscal realities 

allow -- to improve our understanding of visibility impairment and to document progress 

toward reasonable progress goals set under the regional haze regulations for Class I areas 

that emissions sources located in Pennsylvania may affect.
44

7.0. Emissions Inventory

7.1. Emissions Inventory Background and Requirements

Section 51.308(d)(3)(iii) of EPA’s RHR requires the Department to identify the baseline 

emission inventory on which strategies are based. The EPA guidance document, 2002 

Base Year Emission Inventory SIP Planning: 8-hour Ozone, PM 2.5, and Regional Haze 

Programs, identifies 2002 as the anticipated baseline emission inventory year for regional 

haze. Consistent with this guidance, MANE-VU and the Department are using 2002 as 

the baseline emission inventory year. 

Section 51.308(d)(4)(v) of EPA’s RHR requires a statewide emission inventory of 

pollutants that are reasonably anticipated to cause or contribute to visibility impairment in 

any mandatory Class I area. As specified in the above-mentioned EPA guidance 

document, the pollutants inventoried by the Department include volatile organic 

compounds (VOC), nitrogen oxides (NOx), fine particulate (PM2.5), coarse particulate 

(PM10), ammonia (NH3), and sulfur dioxide (SO2). In addition, projections of future 

emissions have been made for the milestone year 2018. In accordance with Section 

51.308(d)(4)(v), the Department will update this inventory periodically. 

The emissions inventory as required under Section 51.308(d)(4)(v) is provided only to 

assess progress in making reductions in accordance with Section 51.308(d)(3)(iii). The 

inventory does not, in and of itself, indicate contribution to visibility impairment.

Information on emissions of VOC, NOx, PM2.5, PM10, NH3, and SO2 is compiled for:

• “Stationary sources” (or “point” sources), which refer to those sources for which 

the Department collects individual emissions-related information. Generally they 

represent major stationary sources but may be smaller.

• “Stationary area sources”, which are industrial, commercial or residential sources 

too small or too numerous to be handled individually, such as commercial and 

residential open burning, architectural and industrial maintenance coatings 

application and clean-up, consumer product use, and vehicle refueling at service 

stations. Where there is overlap between stationary point sources and stationary 

area sources, the area source values are adjusted to remove any double counting.

• “Highway vehicles”, which include passenger cars and light-duty trucks, other 

trucks, buses and motorcycles. 

• “Nonroad sources”, which cover a diverse collection of engines including outdoor 

power equipment, recreational vehicles, farm and construction machinery, lawn 

and garden equipment, industrial equipment, recreational marine, commercial 

marine vessels, locomotives, ships, aircraft and many other applications.
45

Emissions inventory data for 2002, projected emissions inventory data for 2018, and 

related technical support documents are available on the MARAMA website at: 

http://www.marama.org/visibility/EI_Projects/index.html.

A summary of the inventory follows. See Appendix F for the complete 2002 baseline 

emissions inventory for Pennsylvania.

7.2. Summary of 2002 Baseline Emissions Inventory

An emissions inventory for the base year, 2002, was developed in accordance with EPA 

guidance. Table 7.2-1 summarizes the Pennsylvania emissions for 2002. 

Table 7.2-1 Pennsylvania’s 2002 Emissions In Tons Per Year

SO2 NOx PM10 PM2.5 VOC NH3

Stationary Point Sources 995,175 297,379 40,587 20,115 37,323 1,388

Stationary Area Sources 63,679 47,591 391,897 74,925 240,785 79,911

Highway Vehicles 10,882 346,472 7,468 5,450 176,090 10,497

Nonroad Engines/Vehicles 7,915 103,824 9,738 8,440 102,331 55

TOTAL 1,077,651 795,266 449,690 108,930 556,529 91,851

7.2.1. Summary of Inventory Methodologies

The 2002 emissions were first generated by individual states in the MANE-VU area. 

MARAMA then coordinated and quality-assured the 2002 inventory data, and projected 

it for the relevant control years. The 2002 emissions from the non-MANE-VU states 

within the modeling domain were obtained from other Regional Planning Organizations

(RPOs) for their corresponding areas. These RPOs included the Visibility Improvement 

State and Tribal Association of the Southeast (VISTAS), the Midwest Regional Planning 

Organization (MRPO) and the Central Regional Air Planning Association (CenRAP). 

Version 3 of the 2002 base year emission inventory was used in the regional modeling 

exercise.

Work on Version 1 of the 2002 MANE-VU inventory began in April 2004. The 

consolidated inventory for point, area, mobile and nonroad sources was prepared starting 

with the inventories that MANE-VU state/local agencies submitted to the EPA from May 

through July of 2004 as a requirement of the Consolidated Emissions Reporting rule. 

The EPA’s format and content quality assurance (QA) programs (and other QA checks 

not included in EPA’s QA software) were run on each inventory to identify format and/or 

data content issues.3

 

3 EPA. Basic Format and Content Checker 3.0 (Formerly known as the Quality Assurance / Quality

Control Software 3.0) – March 2004. Extended Quality Control Tool – Updated May 18, 2004, United 

States Environmental Protection Agency, 2004.

A contractor, E.H. Pechan & Associates, Inc. (Pechan), worked with 
46

the MANE-VU state/local agencies and the MARAMA staff to resolve QA issues and 

augment the inventories to fill data gaps in accordance with the Quality Assurance 

Project Plan prepared for MANE-VU.4

 The final inventory and SMOKE and input files 

were finalized during January 2005.

Work on Version 2 (covering the period from April through September 2005) involved 

incorporating revisions requested by some MANE-VU state/local agencies on the point, 

area, and nonroad inventories. Work on Version 3 (covering the period from December 

2005 through April 2007) included additional revisions to the point, area, and nonroad 

inventories as requested by some states. Thus, Version 3 inventory for point, area, and 

nonroad sources was built upon Versions 1 and 2. This work also included development 

of the biogenics inventory. In Version 3, the nonroad inventory was completely redone 

because of changes that the EPA made to the NONROAD2005 model. Emissions 

inventory data files are available on the MARAMA website at: 

http://www.marama.org/visibility/EI_Projects/index.html. 

The Technical Support Document for the 2002 MANE-VU SIP Modeling Inventories, 

Version 3 (Pechan, 2006), is available on the MARAMA website at: 

http://www.marama.org/visibility/EI_Projects/index.html. This document explains the data 

sources, methods, and results for preparing this version of the 2002 baseline inventory. The 

following link summarizes the 2002 emissions inventory used by MANE-VU:

http://www.marama.org/visibility/Inventory%20Summary/2002EmissionsInventory.htm

7.3. Projected Inventories

7.3.1. Summary of 2018 Estimated Emissions

Table 7.3.1-1- summarizes the projected emissions in 2018 for Pennsylvania. These 

emissions take activity and emissions growth and/or controls from 2002 into account. 

More specific information on the 2018 projected emissions inventory for Pennsylvania is 

compiled in the Appendix H.

Table 7.3.1-1 Pennsylvania’s 2018 Projected Emissions (TONS PER YEAR)

SO2 NOx PM10 PM2.5 VOC NH3

Stationary Point Sources 266,455 162,067 60,480 39,468 46,004 3,381

Stationary Area Sources 42,072 50,829 195,467 50,842 230,011 117,400

Highway Vehicles 1,436 91,516 2,148 2,064 78,624 13,933

Nonroad Engines/Vehicles 607 55,771 6,949 5,808 69,956 73

TOTAL 310,570 360,183 265,044 98,182 424,595 134,787

 4 MANE-VU. Quality Assurance Project Plan (QAPP) for Area and Point Source Emissions Modeling 

Inventory Project, Final. (Prepared for MANE-VU by E.H. Pechan & Associates, Inc. and Carolina 

Environmental Program, August 3, 2004).
47

7.3.2. Growth Projection Methodologies

This section describes the data, methods, and assumptions utilized in developing estimates 

of emissions changes between 2002 and the milestone year 2018. Please see Appendix V 

for detailed descriptions and development of the MANE-VU projected emission 

inventories: "Development of Emission Projections for 2009, 2012, and 2018 for non-EGU 

Point, Area, and Nonroad Sources in the MANE-VU Region" (MACTEC, February 28, 

2007). Available online:

http://www.marama.org/visibility/Inventory%20Summary/FutureEmissionsInventory.htm

The mass emissions Inventory files were converted to the National Emissions Inventory 

Input Format Version 3.0. Section 10.3 (Technical Documentation) of this SIP, provides 

more information on how the modeling inventory files were processed in Sparse Matrix 

Operator Kernel Emissions/Inventory Data Analyzer (SMOKE).

The SMOKE Processing System is principally an emissions processing system, as 

opposed to a true emissions inventory preparation system, in which emissions estimates 

are simulated from “first principles.” This means that, with the exception of mobile and 

biogenic sources, its purpose is to provide an efficient, modern tool for converting 

emissions inventory data into the formatted emissions files required for a photochemical 

air quality model.

Inside the MANE-VU region, the modeling inventories were processed by the NYSDEC 

using the SMOKE (Version 2.1) processor to provide inputs for the CMAQ model. 

There are five emission source classifications in the emissions inventory as follows:

Stationary point, 

Stationary area, 

Off-road mobile,

Highway mobile, and

Biogenic. 

Stationary Point Sources. Point source emissions are emissions from large individual 

sources. Generally, point sources have permits to operate and their emissions are 

individually calculated based on source specific factors on a regular schedule. The 

largest point sources are inventoried annually. Point sources are grouped into electric 

generating unit (EGU) sources and other industrial point sources, termed as non-EGU 

point sources. The non-EGU category used annual emissions as reported for the 

Consolidated Emission Reporting Rule (CERR) for the base year 2002 (MANE-VU 

Version 3). These emissions were temporally allocated to month, day, and source 

category code (SCC) based allocation factors. The general approach for estimating future 

year emissions was to use growth and control data consistent with EPA’s CAIR analyses. 

This data was supplemented with site specific growth factors as appropriate.
48

The base year inventory for EGU sources used 2002 continuous emissions monitoring 

(CEM) data reported to the EPA in compliance with the Acid Rain program or 2002 

hourly emission data provided by stakeholders. These data provide hourly emission s 

profiles that can be used in the modeling of emissions of SO2 and NOx from these large 

sources. Emission profiles are used to estimate emissions of other pollutants (volatile 

organic compounds, carbon monoxide, ammonia, fine particles, soil) based on measured 

emissions of SO2 and NOx.

Future year inventories of EGU emissions for 2018 were developed using the Integrated 

Planning Model (IPM®) to forecast growth in electric demand and replacement of older, 

less efficient and more polluting power plants with newer, more efficient and cleaner 

units. 

The output of the IPM® model predicts that a certain number of older plants will be 

replaced by newer units to meet future electric growth and State-by-State NOx and SO2

caps, and the Department did directly rely upon the closure of the Pennsylvania Power 

and Light (PPL) Martins Creek plant’s coal-fired Units 1 and 2 in establishing the 2018 

inventory upon which the reasonable progress goals were set. This specific plant closure

is addressed in Section 10.5.3 of this SIP.

In general, the IPM® model results are not the basis upon which to reliably predict plant 

closures. Preliminary modeling was performed with unchanged IPM® 2.1.9 model 

results. However, prior to the Best and Final Modeling, future year EGU inventories 

were modified as discussed in the paragraphs below.

First, IPM® predictions were reviewed by the MANE-VU states’ permitting and 

enforcement staff. In many cases staff felt that the IPM® predictions of shutdowns were 

unlikely to occur. In particular, many oil fired EGUs in urban areas were predicted to be 

shutdown by IPM®. Similar source information was solicited from states in both 

VISTAS and MWRPO. As a result of this model validation, the IPM® modeling output 

was adjusted before Best and Final modeling to reflect staff source knowledge of specific 

plant status in MANE-VU, VISTAS and MWRPO states. Where EGUs operating status 

was contrary to what was predicted by IPM® modeling, the future year emissions 

inventory was adjusted to reflect the operation of those plants expected by state staff.

Second, as a result of inter- and intra- RPO consultations, MANE-VU agreed to pursue a 

coordinated course of action. This course of action includes pursuing the adoption and 

implementation of certain “emission management strategies”, as appropriate and 

necessary. See Section 9.3 of this SIP for a complete description of this coordinated 

course of action. For EGUs, the agreed upon approach was to reduce emissions from 167 

stacks located in MANE-VU, MWRPO and VISTAS by 90%. This control strategy is 

further described in Section 10.4 of this SIP.

Stationary Area Sources. Stationary area sources include sources whose individual 

emissions are relatively small but due to the large number of these sources, the collective 

emissions are significant. Some examples include the combustion of fuels for heating, 
49

dry cleaners, and service stations. Emissions are estimated by multiplying an emission 

factor by some known indicator of collective activity, such as fuel usage, or number of 

households or population. The general approach for estimating future year emissions was 

to use growth and control data consistent with EPA’s CAIR analyses. This data was 

supplemented with state specific growth factors as appropriate.

Highway Mobile Sources. For on-road vehicles, MOBILE6.2 was used to estimate 

emissions. For future year emissions the model considers that a certain number of the 

vehicle fleet in each State will be replaced every year by newer, less polluting 

vehicles that meet the EPA Tier II motor vehicle standards. These lower emissions 

have been built into the 2018 inventory as well as the benefits received from lower 

sulfur gasoline in on-road diesel and gasoline vehicles and the 2007 heavy-duty diesel 

standards. All new mobile source measures and standards, as well as any benefits 

from implementation of individual State Inspection and Maintenance programs, were 

used in developing the 2018 inventory.

Off-Road Mobile Sources. Non-road mobile sources are equipment that can move but 

do not use the roadways, such as construction equipment, aircraft, railroad locomotives, 

lawn and garden equipment. For the majority of the non-road mobile sources, the 

emissions for base year 2002 were estimated using the EPA’s Non-Road model. The 

Non-Road model considers that a certain number of non-road sources will be replaced 

every year by newer, less polluting vehicles that meet the new EPA standards for off-road 

sources. These lower emissions have been built into the 2018 inventory as well as the 

benefits received from lower sulfur gasoline in off-road vehicles. Aircraft engine, 

railroad locomotives and commercial marine are not included in the Non-Road model. 

For these sources growth and control data consistent with EPA’s CAIR analyses were 

used. This data was supplemented with state specific growth factors as appropriate. 

Additionally, control measures for aircraft, railroad, and commercial marine sources are 

implemented through federal rules, which are the responsibility of EPA to enforce. EPA 

estimates for these source categories were relied on.

Biogenic Emission Sources. Biogenic emissions were estimated using SMOKE-BEIS3 

(Biogenic Emission Inventory System 3 version 0.9) preprocessor. Further information 

on Biogenic emissions estimation is contained in Section 10.3 (Technical 

Documentation) of this SIP.
50

8.0. Best Available Retrofit Technology (BART)

8.1. Overview of EPA’s BART Rule

On July 1, 1999, EPA promulgated a final regional haze rule (64 FR 35714). On July 20, 

2001, EPA proposed guidelines for implementation of the BART requirements (66 FR 

38108). The BART rule and proposed guidelines outlined the method for determining if 

a facility is subject to the BART requirements, and methods for conducting a BART 

control review.

The 2001 proposed guidelines were not finalized because industry and environmental 

groups filed legal challenges to the RHR. Industry challenged the rule as it related to the 

method by which it directed states to determine the degree of visibility improvement 

resulting from application of BART controls. Under EPA’s interpretation of the rule, a 

state would have deemed sources to be subject to BART if they emitted pollutants into a 

geographic area or region that likely transports pollutants downwind into a protected 

area. In May 2002, the United States Court of Appeals for the District of Columbia

Circuit issued a ruling in American Corn Growers et al. v. EPA, 291 F.3d 1 (2002), 

which partially vacated and remanded to EPA the RHR.

On May 5, 2004, EPA proposed regional haze amendments and guidelines for BART 

determinations in the Federal Register (69 FR 25184); the final regional haze 

amendments and BART guidelines were published in the Federal Register on July 6, 

2005 (70 FR 39104). A further revision to the rule pertaining to alternative trading 

programs was proposed August 1, 2005 (70 FR 44154) and finalized October 13, 2006 

(71 FR 60612). The regulations are codified at 40 CFR Part 51, Subpart P (relating to 

protection of visibility). 

The BART provisions require states and tribes to develop an inventory of sources within 

each state or tribal jurisdiction that would be eligible for controls. The rule contains the 

following elements that:

• Outline methods to determine if a source is “reasonably anticipated to cause or 

contribute to haze”.

• Define the methodology for conducting BART control analysis.

• Provide presumptive limits for EGUs larger than 750 Megawatts.

• Provide a justification for the use of the CAIR as BART for CAIR-affected 

EGUs.

Beyond the specific elements listed above, EPA provided the states with a great deal of 

flexibility in implementing the BART program.

The BART requirements apply to sources that were in existence on August 7, 1977 but 

were not in operation before August 7, 1962 that collectively, at a facility, have the 

potential to emit more than 250 tons per year of a visibility impairing pollutant. 
51

Visibility impairing pollutants include: NOx, SO2, PM10, and PM2.5. VOC and NH3 

(ammonia) may be visibility impairing pollutants; however the Department has 

determined that modeling tools and accurate emissions inventories to assess the visibility 

impacts from VOC and NH3 adequately are not available at this time. The Department 

did not include VOCs and NH3 as part of the BART determinations for the following 

reasons:

EPA’s final rule for the “Implementation of the New Source Review Program for

Particulate Matter less than 2.5 Micrometers ( PM2.5),” (PM2.5 NSR rule), states the 

following: “Volatile organic compounds are presumed not to be precursors to PM2.5 in 

any attainment or unclassifiable area, unless the State demonstrates to the 

Administrator’s satisfaction that emissions of volatile organic compounds from 

stationary sources in a specific area are a significant contributor to that area’s ambient 

PM2.5 concentrations. However, while significant progress has been made in 

understanding the role of gaseous organic material in the formation of organic PM, this 

relationship remains complex. We recognize that further research and technical tools 

are needed to better characterize emissions inventories for specific VOC compounds, and 

to determine the extent of the contribution of specific VOC compounds to organic PM 

mass. In light of the factors discussed above, EPA proposes that States are not required 

to address VOCs as PM2.5 nonattainment plan precursors, unless the State or EPA makes 

a finding that VOCs significantly contribute to a PM2.5 nonattainment problem in the 

State or to other downwind air quality concerns. In proposing this policy, we are mindful 

of the fact that a majority of areas that have been designated as nonattainment for PM2.5 

are already designated as nonattainment for the 8-hour ozone standard. Thus, these 

areas will already be required to evaluate VOC control measures for ozone purposes. 

(The inventory of VOC as defined here, including gaseous organic compounds, is 

essentially identical to the inventory of VOC for ozone control purposes.)” (See, 73 FR 

28329, May 16, 2008)

In discussing ammonia, EPA in the preamble for the PM2.5 NSR rule states: “...In 

regard to ammonia, however, we believe there is sufficient uncertainty about emissions 

inventories and about the potential efficacy of control measures from location to location 

such that the most appropriate approach for proposal is a case-by-case approach...”. 

(See, 73 FR 28330)

The Department agrees with EPA’s rationale discussed above. Because of the lack of 

tools to estimate emissions and subsequently model VOC and ammonia, and because 

Pennsylvania is aggressively addressing VOCs through the ozone SIPs, the Department 

asserts that SO2, NOx and PM10/2.5 are the only reasonable contributing visibility 

impairing pollutants to target under BART.

The BART requirements only apply to sources in specific categories listed in the Clean 

Air Act. These categories are:

1. Fossil-fuel fired steam electric plants of more than 250 million British thermal 

units (BTU) per hour heat input,

2. Coal cleaning plants (thermal dryers),
52

3. Kraft pulp mills,

4. Portland cement plants,

5. Primary zinc smelters,

6. Iron and steel mill plants,

7. Primary aluminum ore reduction plants,

8. Primary copper smelters,

9. Municipal incinerators capable of charging more than 250 tons of refuse per day,

10. Hydrofluoric, sulfuric, and nitric acid plants,

11. Petroleum refineries,

12. Lime plants,

13. Phosphate rock processing plants,

14. Coke oven batteries,

15. Sulfur recovery plants,

16. Carbon black plants (furnace process),

17. Primary lead smelters,

18. Fuel conversion plants,

19. Sintering plants,

20. Secondary metal production facilities,

21. Chemical process plants,

22. Fossil-fuel boilers of more than 250 million BTUs per hour heat input,

23. Petroleum storage and transfer facilities with a capacity exceeding 300,000 

barrels,

24. Taconite ore processing facilities, 

25. Glass fiber processing plants, and

26. Charcoal production facilities.

The BART determination process consists of three key steps:

1. Identify all BART-eligible sources.

2. For each BART-eligible source, determine whether it “emits any pollutants which 

may reasonably be anticipated to cause or contribute to any visibility impairment” 

at a Class I area. Such sources are “subject to BART.” 

3. For each source that is “subject to BART”, determine if additional controls or 

emission limits are necessary. 

The following sections provide information regarding the BART identification and 

determination process. The Department’s BART analysis review memos for each source 

subject to BART are included in Appendix J. 

8.2. EGUs and CAIR

The BART-eligible EGUs in MANE-VU represent the largest emissions reduction 

potential among the various BART-eligible source categories. EPA has decided that 

CAIR satisfies the BART requirement for SO2 and NOx for EGUs in states participating 

in the CAIR program. EPA did not rescind that decision as a result of the court remand 

of CAIR to EPA for revisions, in State of North Carolina v. Environmental Protection 

Agency, 531 F.3d 896 (D.C. Cir. 2008). CAIR remains in place during EPA’s revisions. 
53

BART-eligible EGUs that are subject to the CAIR provisions are those in Pennsylvania, 

Delaware, Maryland, the District of Columbia, New Jersey, and New York. BARTeligible EGUs located in Connecticut and Massachusetts are also included in the CAIR 

program, but only with respect to their ozone-season NOx emissions. Because BARTeligible EGUs located in Pennsylvania are subject to the federal CAIR program for SO2 

and NOx, BART determinations were conducted for emissions of PM only. 

8.3. BART Source Cap-Out Permits

Several BART-eligible facilities in Pennsylvania are relatively small emission sources 

with potential emissions that exceed the statutory threshold of 250 tons per year or more, 

but with actual emissions of visibility impairing pollutants well below 250 tons in any 

year. The Department gave these facilities the option to accept federally enforceable 

permit limitations restricting their emissions to less than 250 tons per year. The owners 

and operators of facilities limiting their emissions in this way are no longer BARTeligible.

For completeness, facilities containing units otherwise eligible for BART that elected to 

become not BART-eligible by accepting federally enforceable permit limits to restrict 

their emissions to below the BART threshold are listed in Table 8.3-1 below. Changes at 

these sources or in their permits that would allow for an increase in emissions would

subject these sources to a BART review. The Eastman Chemical Resins Company, one 

of the sources listed in the table below, is a chemical process plant located in Allegheny 

County. Seventy-five units at the facility were determined to be BART date-eligible 

units. Eastman Chemical Resins decided to retire four of the BART units (four tanks) to 

reduce potential emissions to below 250 tons per year for all BART eligible pollutants. 

The Enforcement Order from the Allegeny County Health Department (ACHD) that 

restricts emissions to below 250 tons per year from Eastman Chemical Resins is included 

with this SIP, and is submitted to the EPA as a part of this SIP. (See Appendix BB for 

the ACHD cover letter and Order, and the ACHD review memo.)

Table 8.3-1 Pennsylvania Facilities Not BART-Eligible Due to Federally 

Enforceable Permit Restrictions

Facility Name and 

County Location

Permit # and 

Permit Issue Date

Pollutant(s) 

Restricted and PTE 

Permit Limit

PTE Permit Limit Date

and Statutory 

Authority

VICTAULIC CO 

AMER/FORKS 

FACILITY

Northampton

TV 48-00009

9/12/07

PM10 - < 250 tpy 9/12/07

25 Pa. Code §127.441

AMERICAN 

REFINING 

GR/BRADFORD

TV 42-00004

6/16/08

NOX - < 250 tpy

PM10 - < 250 tpy

SO2 - < 250 tpy

6/16/08

25 Pa. Code §127.441
54

Facility Name and 

County Location

Permit # and 

Permit Issue Date

Pollutant(s) 

Restricted and PTE 

Permit Limit

PTE Permit Limit Date

and Statutory 

Authority

McKean VOC - < 250 tpy

MERCER LIME & 

STONE 

/BRANCHTON

Butler

TV 10-00023

1/10/07

NOX – 249 tpy

SO2 – 249 tpy

1/10/07

25 Pa. Code §127.441

DUFERCO 

FARRELL 

CORP/FARRELL 

PLT

Mercer

TV 43-00310

6/16/08

NOX - < 250 tpy 6/16/08

25 Pa. Code §127.441

INMETCO/ELLWO

OD CITY

Lawrence

TV 37-00243

12/12/06

NOX – 249.5 tpy

PM10 – 249.5 tpy

12/12/06

25 Pa. Code §127.441

INDSPEC CHEM 

CORP/PETROLIA

Butler

TV 10-00021

3/9/07

VOC – 247 tpy 3/9/07

25 Pa. Code §127.441

LWB 

REFRACTORIES 

CO/W 

MANCHESTER

York

PA 67-05001D

2/13/07

SO2 – 249 tpy 2/13/07

25 Pa. Code §127.12b

EXIDE 

TECH/READING 

SMELTER

Berks

PA 06-05066E

4/3/07

SO2 - < 240 tpy 4/3/07

25 Pa. Code §127.12b

HORSEHEAD 

CORP/MONACA 

SMELTER

Beaver

TV 04-00044

10/22/07

NOX - < 249 tpy

PM10 - < 249 tpy

SO2 - < 249 tpy

VOC - < 249 tpy

10/22/07

25 Pa. Code §127.441

EASTMAN 

CHEMICAL 

RESINS INC

Allegheny5

Enforcement Order

4/24/08

VOC - < 250 tpy 5/9/08

ACHD’s Rules and 

Regulations, Article 

XXI,

§2109.03

 

5 The Department has determined that the Eastman Chemical Resins, Inc. facility is not a BART-eligible 

source since its potential to emit is below the 250 tons per year threshold. The Department makes this 

determination for the following three reasons: 1) the April 28, 2008, Allegheny County Health Department 

(ACHD) cover letter states that the tanks are out of service and incapable of storing liquid; 2) the April 28, 

2008, ACHD Order renders the tanks unusable for the storage of VOCs; and, 3) the review memo states 

that “ACHD had conducted an inspection of the tanks in November 2007, and found that one had large 

holes cut into it and the piping and instrumentation had been removed from the others, making it 

impossible for the tanks to be placed back into service without making major modifications.”
55

8.4. BART-Eligible Sources in Pennsylvania

The list of facilities in Pennsylvania that include BART-eligible units is shown in Table 

8.4-1. The BART-eligible sources were identified using the methodology in the 

Guidelines for Best Available Retrofit Technology (BART) Determinations under the 

Regional Haze Rule (40 CFR Part 51, Appendix Y.) The Department’s BART analysis 

review memos for each source subject to BART are included in Appendix J. 

Table 8.4-1 Pennsylvania Facilities with Bart-Eligible Units 

Facility County

EXELON GENERATION CO/EDDYSTONE Delaware

ISG PLATE LLC/COATESVILLE Chester

SUNOCO INC (R&M)/MARCUS HOOK REFINERY Delaware

CONOCOPHILLIPS CO/TRAINER REF Delaware

PPL MONTOUR LLC/MONTOUR SES Montour

PPL MARTINS CREEK LLC/MARTINS CREEK Northampton

RELIANT ENERGY/PORTLAND GENERATING STATION Northampton

LAFARGE CORP/WHITEHALL PLT Lehigh

KEYSTONE PORTLAND CE/EAST ALLEN Northampton

ORION POWER MIDWEST /NEW CASTLE PLT Lawrence

CEMEX INC/WAMPUM CEMENT PLT Lawrence

ESSROC/BESSEMER Lawrence

AK STEEL CORP/BUTLER WORKS Butler

UNITED REFINING CO/WARREN PLT Warren

PPL BRUNNER ISLAND LLC/BRUNNER ISLAND York

APPLETON PAPERS INC/SPRING MILL Blair

PH GLATFELTER CO/SPRING GROVE York

LEHIGH CEMENT CO /EVANSVILLE CEMENT PLT Berks

CARMEUSE LIME INC/MILLARD LIME PLT Lebanon

LEHIGH CEMENT CO/YORK OPERATIONS York

ALLEGHENY ENERGY SUPPLY/HATFIELDS FERRY POWER STA Greene

ALLEGHENY ENERGY SUPPLY/MITCHELL POWER STA Washington

EME HOMER CITY GEN LP Indiana

RELIANT ENERGY NORTHEAST/CONEMAUGH PLT Indiana

RELIANT ENERGY NORTHEAST MGMT/KEYSTONE POWER PLT Armstrong

FIRSTENERGY GEN CORP/BRUCE MANSFIELD PLT Beaver

DYNO NOBEL INC/DONORA Washington

RELIANT/CHESWICK Allegheny

US STEEL/CLAIRTON WORKS Allegheny

ALLEGHENY LUDLUM/BRACKENRIDGE Allegheny
56

Facility County

SUNOCO CHEMICALS/FRANKFORD PLANT Philadelphia

SUNOCO INC (R&M)/PHILADELPHIA REFINERY Philadelphia

TRIGEN/EDISON STATION Philadelphia

TRIGEN/SCHUYLKILL STATION Philadelphia

8.5. Sources Subject to BART

According to the Guidelines for Best Available Retrofit Technology (BART) 

Determinations, once the state has compiled its list of BART-eligible sources, it needs to 

determine whether to make BART determinations for all of the sources or to consider 

exempting some of them from BART because they may not reasonably be anticipated to 

cause or contribute to any visibility impairment in a Class I area. The Department

decided not to exempt a BART-eligible source based on a cause or contribute deciview 

threshold, and made BART determinations for all BART-eligible sources. The 

Department’s BART analysis review memos for each source subject to BART are 

included in Appendix J. 

8.5.1. Making BART Determinations for all BART-Eligible Sources

Based on the collective importance of BART sources, in June 2004, the MANE-VU 

Board decided that a BART determination would be made for each BART-eligible 

source. Consistent with the MANE-VU decision, the Department made a BART 

determination for each of these sources. 

8.5.2. Anticipated Visibility Improvement as a Result of BART

MANE-VU conducted modeling analyses of individual BART-eligible sources using 

CALPUFF – a model preferred by EPA for assessing long range transport of pollutants 

and their impacts - in order to provide a regionally consistent foundation for assessing the 

degree of visibility improvement that could result from installation of BART controls. 

Summary spreadsheets of the MANE-VU CALPUFF modeling results for the 

Pennsylvania BART sources are included in Appendix I. Affected facilities also had the 

option of conducting additional modeling to be considered in the BART determination.

The Department considered the results of the CALPUFF modeling analysis, and also any 

additional modeling conducted by individual BART sources in its determination of 

BART for each BART source. In accordance with the Guidelines for Best Available 

Retrofit Technology (BART) Determinations, in making BART determinations for the 

sources subject to BART in Pennsylvania, the Department considered the following five 

factors in identifying the best system of continuous emission control technology

available: the costs of compliance; the energy and the non-air quality environmental 

impacts of compliance; any pollution control equipment in use or in existence at the 

source; the remaining useful life of the source; and the degree of improvement in 

visibility which may reasonably be anticipated to result from the use of such technology. 
57

The CALPUFF modeling results were used in consideration of the factor of the degree of 

improvement in visibility expected from available control technology.

The Department did not establish or utilize bright line thresholds for cost or for visibility 

improvement. Instead, the Department employed an approach that considered the 

multiple BART Guideline factors. As a result, sources with a higher degree of potential 

visibility improvement from control would justify higher cost controls. Conversely, only 

low cost controls would be justified for sources with a lower degree of potential visibility 

improvement. 

8.6. BART Determinations, Control Levels and Schedules

The BART determinations for the sources subject to BART in Pennsylvania are 

summarized in the paragraphs below. BART is the emission limit for each pollutant 

based on the degree of reduction achievable through the application of the best system of 

continuous emission control technology available, taking into consideration: the costs of 

compliance, the energy and the non-air quality environmental impacts of compliance, any 

pollution control equipment in use or in existence at the source, the remaining useful life 

of the source, and the degree of improvement in visibility which may reasonably be 

anticipated to result from the use of such technology. The Department’s BART analysis 

review memos for each source subject to BART are included in Appendix J. All review 

memos are confirmed as the Department’s conclusions. The BART analyses identified 

the best system of continuous emission control technology available and include the 

consideration of these five factors: the costs of compliance, the energy and non-air 

quality environmental impacts, any existing pollution controls at the source, the 

remaining useful life of the source and the degree of improvement in visibility, the latter 

of which is determined in the Visibility Impacts portion of each review memo. The 

consideration of the degree of improvement in visibility is based on the maximum 24-

hour NESCAUM-modeled impact at the Class I area of maximum impact. However, if 

an affected BART source conducted a CALPUFF modeling analysis that used three years 

of meteorological data input, a BART determination was performed using the 98th

percentile deciview modeled impact, as allowed in the Regional Haze Regulations and 

Guidelines for Best Available Retrofit Technology (BART) Determinations, Final Rule 

(40 CFR Part 51, July 6, 2005).

The BART for each source subject to BART was determined based on the methodology 

in the Guidelines for Best Available Retrofit Technology (BART) Determinations Under 

the Regional Haze Rule (40 CFR Part 51, Appendix Y).

The Regional Haze Rule requires the control levels that are determined to be BART are 

be installed and operated no later than five years after approval of this implementation 

plan revision by EPA (40 CFR 51.308(e)(1)(iv). The Regional Haze Rule also requires 

that each source subject to BART maintain the required control equipment and establish 

procedures to ensure such equipment is properly operated and maintained (40 CFR 

51.308(e)(1)(v). The existing Title V operating permits issued by the Department contain

conditions that require any existing controls determined to be BART to be operated and 
58

maintained. The Title V permit conditions also contain reporting, monitoring, and 

recordkeeping requirements adequate to determine the source’s compliance. 

The table below summarizes the level of control determined to be BART for the 34 

BART-eligible sources in Pennsylvania, and includes the permit number and issue date of 

the current Title V permit (or applicable consent decree), and the emissions monitoring 

and reporting requirements cited in the Title V permit (or applicable consent decree) for 

each BART-eligible unit. The Department proposes to determine that existing controls 

satisfy BART for the BART sources listed below in Table 8.6. The Department’s BART 

analyses for each source subject to BART are detailed in review memos and provide a 

complete analysis of the BART control level established. The BART analysis review 

memos are in Appendix J.

Table 8.6 BART Control Levels

BART Source Name 

& Unit Id

Permit No. and

Date of Issue

Pollutant and Emission 

Limit 

Emissions Reporting 

and Monitoring

ConocoPhillips

FCCU/CO Boiler

Unit ID #C01

Consent Decree, Civil 

Action H-05-0258

(1/27/05)

Title V Permit 23-

00003 (12/22/08)

SO2: 25 ppmvd (365-day rolling 

average).

PM: 0.5 lb/1000 lb coke burn (3-

hr average).

NOx: 121.1 ppmvd (365-day)

 155.3 ppmvd (7-day).

25 Pa. Code §§ 127.441, 

127.442, 127.511, and

§§ 123, 135 and 139.

40 CFR Parts 60 and 63.

See Consent Decree, 

Appendix DD.

40 CFR Part 60 and Part 60 

Appendices A, B and F.

ConocoPhillips

Platform Feed Heater

Unit ID 738

Title V Permit 23-

00003 (12/22/08)

NOx: 0.12 lb/MMBtu.

SO2: 0.011 lb/MMBtu

(both limits are on an annual 

basis).

25 Pa. Code §§ 127.441, 

127.442, 127.511, and

§§ 123, 135 and 139.

40 CFR Parts 60 and 63.

Sunoco Inc.

Marcus Hook Refinery

FCCU/CO Boiler

Unit ID 101 and COB1

Consent Decree, Civil

Action 05-CV-02866

(6/16/05)

Title V Permit 23-

00001 (11/18/08)

SO2: 25 ppmvd (365-day rolling 

average).

NOx: 20 ppmvd (365-day 

rolling average).

PM: 1.0 lb/1000 lb coke burn.

See Consent Decree, 

Appendix EE.

40 CFR Part 60 and Part 60 

Appendices A, B and F.

Sunoco Inc.

Marcus Hook Refinery

17-2A, H-01 Heater

Title V Permit 23-

00001 (11/18/08)

NOx: 0.25 lb/MMBtu (24-hr 

basis).

SO2: 500 ppmvd.

25 Pa. Code §§ 127.441, 

127.442, 127.511, and

§§ 123, 135 and 139.

40 CFR Parts 60 and 63.

United Refining Co.

Boiler 4

Title V Permit 62-

00017 (8/20/07)

NOx: 0.173 lb/MMBtu.

SO2: 24.3 lbs/hr.

25 Pa. Code §§ 127.441, 

127.442, 127.511, and

§§ 123, 135 and 139.

40 CFR Parts 60 and 63.

United Refining Co.

Crude Heater- North

Title V Permit 62-

00017 (8/20/07)

NOx: 0.226 lb/MMBtu.

SO2: 207.7 lbs/hr.

25 Pa. Code §§ 127.441, 

127.442, 127.511, and

§§ 123, 135 and 139.

40 CFR Parts 60 and 63.

Carmeuse Lime Inc.

Kiln Number 5

Title V Permit 38-

05003 (4/27/06)

NOx: 6.0 lb/ton lime.

SO2: 500 ppmvd.

25 Pa. Code §§ 127.441, 

127.442, 127.511, and

§§ 123, 135 and 139.

40 CFR Part 64.

Lehigh Cement Co.

Evansville Plant

Title V Permit 06-

05002 (9/14/09)

NOx: 367.7 lbs/hr.

SO2: 59.4 lbs/hr.

25 Pa. Code §§ 127.441, 

127.442, 127.511, and
59

BART Source Name 

& Unit Id

Permit No. and

Date of Issue

Pollutant and Emission 

Limit 

Emissions Reporting 

and Monitoring

Kiln Number 1 PM: 34.8 tons/12 month period.

PM10: 87.4 tons/12 month 

period.

§§ 123, 135 and 139.

40 CFR Part 63.

Lehigh Cement Co.

Evansville Plant

Kiln Number 2

Title V Permit 06-

05002 (9/14/09)

NOx: 367.7 lbs/hr.

SO2: 59.4 lbs/hr.

PM: 34.8 tons/12 month period.

PM10: 87.4 tons/12 month 

period.

25 Pa. Code §§ 127.441, 

127.442, 127.511, and

§§ 123, 135 and 139.

40 CFR Part 63.

Lehigh Cement Co.

York Operations

White Cement Kiln

Title V Permit 67-

05024 (2/17/06)

NOx: 8.2 lbs/ton.

SO2: 500 ppmvd.

PM: 0.02 grains/dscf.

25 Pa. Code §§ 127.441, 

127.442, 127.511, and

§§ 123, 135 and 139.

40 CFR Part 63.

Lafarge Corp.

Whitehall Plant

Kiln K-2

Title V Permit 39-

00011 (12/31/00)

NOx: 297.7 lbs/hr.

NOx: 260.5 lbs/hr (TDF).

SO2: 362 lbs/hr.

PM: 14.8 lbs/hr.

25 Pa. Code §§ 127.441, 

127.442, 127.511, and

§§ 123, 135 and 139.

40 CFR Parts 60 and 63.

Lafarge Corp.

Whitehall Plant

Kiln K-3

Title V Permit 39-

00011 (12/31/00)

NOx: 202.3 lbs/hr.

NOx: 166.0 lbs/hr (TDF).

SO2: 195.0 lbs/hr.

PM: 7.3 lbs/hr.

25 Pa. Code §§ 127.441, 

127.442, 127.511, and

§§ 123, 135 and 139.

40 CFR Parts 60 and 63.

CEMEX Inc.

Wampum Plant

Kiln No. 3

Title V Permit 37-

00013 (3/5/07)

NOx: 6.2 lbs/ton clinker

(May-Sep 6.0 lbs/ton).

SO2: 500 ppmvd.

PM: 0.02 grains/dscf.

25 Pa. Code §§ 127.441, 

127.442, 127.511, and

§§ 123, 135 and 139.

40 CFR Part 63.

ESSROC Cement

Bessemer Plant

Kiln No. 5

Title V Permit 37-

00003 (1/18/07)

NOx: 476 lbs/hr.

SO2: 500 ppmvd.

PM: 0.02 grains/dscf.

25 Pa. Code §§ 127.441, 

127.442, 127.511, and

§§ 123, 135 and 139.

40 CFR Part 63.

Keystone Cement Co.

East Allen Plant

Kiln No. 2

Title V Permit 48-

00003 (8/31/01)

NOx: 529 lbs/hr

SO2: 500 ppmvd

PM: 0.02 grains/dscf

25 Pa. Code §§ 127.441, 

127.442, 127.511, and

§§ 123 and 139.

40 CFR Part 63.

ISG Plate LLC

Coatesville Plant

Electric Arc Furnace D

Title V Permit 15-

00010 (1/7/08)

SO2: 500 ppmvd.

PM: 0.02 grains/dscf (primary 

baghouse).

PM: 0.0052 grains/dscf 

(secondary baghouses).

25 Pa. Code §§ 127.441, 

127.442, 127.511, and

§§ 123, 135 and 139.

40 CFR Part 64.

AK Steel Corp.

Butler Works

Electric Arc Furnaces:

#2, #3, and #4

Title V Permit 10-

00001 (2/13/06)

NOx: 75 lbs/hr.

SO2: 500 ppmvd.

PM: 0.0036 grains/dscf.

25 Pa. Code §§ 127.441, 

127.442, 127.511, and

§§ 135 and 139.

40 CFR Part 64.

PH Glatfelter Co.

Spring grove Plant

No. 1 Power Boiler 

Title V Permit 67-

05004 (11/8/07)

NOx: 0.66 lb/MMBtu (30-day 

rolling average).

SO2: 3.7 lb/MMBtu (30-day 

rolling average).

PM: 3.6 x Heat Input 

(lbs/MMBtu) raised to a 

negative 0.56 power.

25 Pa. Code §§ 127.441, 

127.442, 127.511, and

§§ 123, 135 and 139.

40 CFR Parts 63 and 64.

Appleton Papers Inc.

Spring Mill Plant

No. 3 Power Boiler

Title V Permit 07-

05001 (10/1/07)

NOx: 0.63 lb/MMBtu.

SO2: 4.0 lb/MMBtu (over any 1-

hr period).

PM: 3.6 x Heat Input 

25 Pa. Code §§ 127.441, 

127.442, 127.511, and

§§ 123, 135 and 139.

40 CFR Parts 63 and 64.
60

BART Source Name 

& Unit Id

Permit No. and

Date of Issue

Pollutant and Emission 

Limit 

Emissions Reporting 

and Monitoring

(lbs/MMBtu) raised to a 

negative 0.56 power.

Dyno Nobel Inc.

Donora Plant

Ammonia Oxidation Plant

Title V Permit 63-

00070 (12/31/07)

NOx: 396 tons/12-month period.

NO2: 5.5 lb/ton acid product 

(expressed as 100% HNO3).

25 Pa. Code §§ 127.441, 

127.442, 127.511, and

§§ 135 and 139.

40 CFR Parts 64 and 70.

Allegheny Energy 

Hatfields Ferry Power

Main Boilers (#1, #2, and 

#3)

Title V Permit 30-

00099F (9/12/07)

PM: 0.075 lb/MMBtu for each 

boiler.

25 Pa. Code §§ 127.441, 

127.442, 127.511, and

§§ 123, 135 and 139.

PPL Brunner Island

Brunner Island

Boilers 2 and 3

Title V Permit 67-

05005 (4/16/07)

PM: 0.1 lb/MMBtu for each 

boiler.

25 Pa. Code §§ 127.441, 

127.442, 127.511, and

§§ 123, 135 and 139.

Exelon Generation

Eddystone Plant

Boilers 3 and 4

Title V Permit 23-

00017 (12/29/04)

PM: 0.1 lb/MMBtu for each 

boiler.

25 Pa. Code §§ 127.441, 

127.442, 127.511, and

§§ 123, 135 and 139.

EME Homer City

Homer City Plant

Main Boilers (#1, #2, #3)

Title V Permit 32-

00055 (1/30/04)

PM: 0.1 lb/MMBtu for each 

boiler.

25 Pa. Code §§ 127.441, 

127.442, 127.511, and

§§ 123, 135 and 139.

PPL Montour LLC

Montour SES

Boilers 1 and 2

Title V Permit 47-

00001 (5/2/06)

PM: 0.1 lb/MMBtu for each 

boiler.

25 Pa. Code §§ 127.441, 

127.442, 127.511, and

§§ 123, 135 and 139.

Reliant Energy LLC

Portland Generating

Boiler #2

Title V Permit 48-

00006 (5/31/06)

PM: 0.1 lb/MMBtu. 25 Pa. Code §§ 127.441, 

127.442, 127.511, and

§§ 123, 135 and 139.

First Energy Corp.

Bruce Mansfield Plt

Main Boilers (#1, #2, #3)

Title V Permit 04-

00235 (11/22/02)

PM: 0.1 lb/MMBtu for each 

boiler.

25 Pa. Code §§ 127.441, 

127.442, 127.511, and

§§ 123, 135 and 139.

Allegheny Energy

Mitchell Power Station

Boiler #3

Title V Permit 63-

00016 (3/26/02)

PM: 0.1 lb/MMBtu. 25 Pa. Code §§ 127.441, 

127.442, 127.511, and

§§ 123, 135 and 139.

Orion Power Midwest

New Castle Plant

Boiler #5

Title V Permit 37-

00023 (1/23/07)

PM: 0.1 lb/MMBtu. 25 Pa. Code §§ 127.441, 

127.442, 127.511, and

§§ 123, 135 and 139.

Reliant Energy NE

Keystone Power Plant

Boilers 1 and 2

Title V Permit 03-

00027 (12/18/06)

PM: 0.1 lb/MMBtu for each 

boiler.

25 Pa. Code §§ 127.441, 

127.442, 127.511, and

§§ 123, 135 and 139.

PPL Martins Creek 

Martins Creek Plant

Boilers 3 and 4

Title V Permit 48-

00011 (4/15/08)

PM: 0.1 lb/MMBtu for each 

boiler.

25 Pa. Code §§ 127.441, 

127.442, 127.511, and

§§ 123, 135 and 139.

Reliant Energy NE

Conemaugh Plant

Boilers 1 and 2

Title V Permit 32-

00059 (3/28/08)

PM: 0.1 lb/MMBtu for each 

boiler.

25 Pa. Code §§ 127.441, 

127.442, 127.511, and

§§ 123, 135 and 139.

Trigen Edison Station

Philadelphia

Boilers 3 and 4

Title V Permit:

V06-11 (1/29/07)

NOx: 0.5 lb/MMBtu for each 

boiler.

PM: 0.1 lb/MMBtu for each 

boiler.

SO2: 0.5% sulfur (#6 fuel oil), 

0.2% sulfur (#2 oil).

25 Pa. Code §§ 127.441(c), 

(d), 127.442, 127.463(e), 

127.511(c), § 139, and 

Philadelphia County AMS 

Regulation I Sec. II and III.

Trigen Schuylkill Station

Philadelphia

Boiler # 26

Title V Permit:

V06-007 (10/12/06)

NOx: 0.36 lb/MMBtu (30-day 

rolling avg).

PM: 0.1 lb/MMBtu.

SO2: 0.5% sulfur (#6 fuel oil).

25 Pa. Code §§ 127.441(c), 

(d), 127.442, 127.463(e), 

127.511(c), § 139, and 

Philadelphia County AMS 
61

BART Source Name 

& Unit Id

Permit No. and

Date of Issue

Pollutant and Emission 

Limit 

Emissions Reporting 

and Monitoring

Regulation I Sec. II and III.

Sunoco Chemicals

Frankfort Plant

Philadelphia

Boiler No. 3

Title V Permit:

V95-047 (4/17/03)

NOx: 0.3 lbs/MMBtu.

PM: 0.1 lb/MMBtu.

SO2: 0.52 lbs/MMBtu.

25 Pa. Code §§ 127.441(c),

(d), 127.442, 127.463(e), 

127.511(c), § 139, and 

Philadelphia County AMS 

Regulation I Sec. II and III.

Sunoco Refinery, Inc

Philadelphia

FCCU/CO Boiler

Unit ID 1232

Consent Decree, Civil 

Action 05-CV-02866, 

(6/16/05)

Title V Permit: V95-

038 (1/17/02)

AMS Plan Approval:

04322 (2/28/06)

SO2: 25 ppmvd (365-day rolling 

average).

NOx: 20 ppmvd (365-day 

rolling average).

PM: 0.5 lb/1000 lb coke burn.

See Consent Decree, 

Appendix EE.

40 CFR Part 60 and Part 60 

Appendices A, B and F.

Sunoco Refinery Inc.

Philadelphia

Process Heaters

Consent Decree, Civil 

Action 05-CV-02866

(6/16/05)

Title V Permit: V95-

038 (1/17/02)

NOx: 0.020 lb/MMBtu (24-hr 

basis).

SO2: 500 ppmvd.

See Consent Decree, 

Appendix EE.

40 CFR Part 60 and Part 60 

Appendices A, B and F.

Allegheny Ludlum Corp.

Allegheny County

Basic Oxygen Furnaces

Slab Grinder

Plate Burner/Torch Cutter

Loftus Soaking Pits

Operating Permits:

0025603-000-82900

(9/29/94)

0025603-000-65304

(12/14/73)

0025603-000-1160

(12/14/73)

0025603-000-22803,

0025603-000-22804

(12/14/73)

Permitted PTE:

PM: 68 tpy

PM: 230 tpy

PM: 13 tpy

PM: 14 tpy, NOx: 194 tpy

ACHD Rules and 

RegulationsArticle XXI, Part C, 

Operating Permits (All 

Major & Minor) §2103.12.i, 

j &k, Issuance, Standard 

Conditions-Standard 

Monitoring Requirements, 

Standard Recordkeeping 

Requirements, & Standard 

Reporting Requirements.

Article XXI, Part H, 

§2108.01.e, Reports 

Required-Emissions 

Inventory Statements.

US Steel Clairton

Allegheny County

Clairton Coke Works

Desulfurization Plant

Boiler #2

R1 Boiler

T1 Boiler

Operating Permits:

7035003-010-25600

(12/14/73)

7035003-010-00800

(11/28/79)

7035003-010-01300

(5/11/77)

7035003-010-00600

(7/12/77)

Permitted PTE:

SO2: 590 tpy; NOx: 27 tpy

SO2: 1508 tpy; NOx: 1285 tpy

SO2: 796 tpy: NOx: 525 tpy

SO2: 572 tpy; NOx: 358 tpy

See above citations of 

ACHD Rules and 

Regulations.

Orion Power

Cheswick Plant

Allegheny County

Boiler No. 1

Operating Permit:

1065009-003-00100

(12/8/81)

Permitted PTE:

SO2:67,452 typ;NOx:10,840 tpy

PM10: 361 tpy

See above citations of 

ACHD Rules and 

Regulations.
62

8.7. Reasonably Attributable Visibility Impairment

Section 51.302(c) of EPA’s RHR provides for general plan requirements in cases in 

which the affected FLM has notified the state that a Reasonably Attributable Visibility 

Impairment (RAVI) source exists that affects a Class I area in the state. There are no 

Class I areas in Pennsylvania, and the Department has not been notified by any affected 

FLM that a RAVI source exists in Pennsylvania.
63

9.0. Reasonable Progress Goals

Section 51.308(d)(1) of EPA’s RHR requires each state containing a Class I area to 

establish for each Class I area within the state goals (in deciviews) that provide for 

reasonable progress toward achieving natural visibility. In addition, EPA released 

guidance on June 7, 2007 for use in setting reasonable progress goals. The goals must 

provide improvement in visibility for the most impaired days and ensure no degradation 

in visibility for the least impaired days over the SIP period. 

Under 40 CFR § 51.308(d)(1)(iv), consultation is required in developing reasonable 

progress goals. The rule states: 

In developing each reasonable progress goal, the State must consult with those 

States which may reasonably be anticipated to cause or contribute to visibility 

impairment in the mandatory Class I Federal area. In any situation in which the 

State cannot agree with another such State or group of States that a goal 

provides for reasonable progress, the State must describe in its submittal the 

actions taken to resolve the disagreement. In reviewing the State's 

implementation plan submittal, the Administrator will take this information into 

account in determining whether the State's goal for visibility improvement 

provides for reasonable progress towards natural visibility conditions.

In developing the reasonable progress goals, the Class I state must also consider four

factors specified in 40 CFR § 51.308(d)(1)(i)(A), namely, cost, time needed, energy & 

non-air quality environmental impacts and remaining useful life. The Class I state must 

also, under 40 CFR § 51.308(d)(1), show that the state considered the uniform rate of 

improvement and the emission reduction measures needed to achieve it for the period 

covered by the implementation plan, and if the state proposes a rate of progress slower 

than the uniform rate of progress, assess the number of years it would take to attain 

natural conditions if visibility improvement continues at the rate proposed. 

9.1. Consultation and Agreement With Other States’ Goals

9.1.1. The MANE-VU States

The following Class I areas are found in the MANE-VU region: Acadia National Park, 

Roosevelt/Campobello International Park, Moosehorn Wilderness Area, Presidential 

Range/Dry River Wilderness Area, Great Gulf Wilderness Area, Lye Brook Wilderness, 

Brigantine Wilderness.
64

In accordance with 40 CFR § 51.308(d)(1)(iv), the Department consulted with the 

following states in MANE-VU that have Class I areas while those states were 

establishing reasonable progress goals for their Class I areas:

• Maine

• New Hampshire

• Vermont

• New Jersey

There are no Class I areas in Pennsylvania. The MANE-VU states of New Jersey, 

Vermont and Maine sent letters to the Department in the spring of 2007 stating that, 

based on 2002 emissions, Pennsylvania contributed to visibility impairment to Class I 

areas in those states. New Jersey, Vermont and Maine have asked for Pennsylvania’s 

continued participation in further consultations with MANE-VU. Consistent with the 

RHR requirements specified in 40 CFR § 51.308(d)(3)(i), the Department consulted with 

the Class I area states that are or may be impacted by emission sources operating in 

Pennsylvania as they establish reasonable progress goals for each Class I area within their 

state. Accordingly, Pennsylvania agrees with the reasonable progress goals 

established by Maine, New Jersey, New Hampshire and Vermont.

9.1.2. The VISTAS States

In accordance with 40 CFR § 51.308(d)(3)(i), the Department consulted with the 

following states in VISTAS that have nearby Class I areas while those states were 

establishing reasonable progress goals for their Class I areas:

• West Virginia

• Virginia

Shenandoah National Park in Virginia and the Dolly Sods/Otter Creek Wilderness Area

in West Virginia are Class I areas in the VISTAS region that are impacted by emissions 

from Pennsylvania and other MANE-VU states. The Department consulted with West 

Virginia and Virginia when they were establishing their reasonable progress goals for the 

Class I areas in their states that are or may be impacted by emission sources operating in 

Pennsylvania. The 2018 visibility improvement projections that are used to establish 

reasonable progress for the Dolly Sods/Otter Creek Wilderness Area and the Shenandoah 

National Park were presented to the MANE-VU member states by VISTAS on March 18, 

2008 (Appendix K).

The Department agrees with the reasonable progress goals that were established by West 

Virginia for Dolly Sods/Otter Creek Wilderness Area. The reasonable progress goals 

established by the West Virginia DEP for the Dolly Sods/Otter Creek Wilderness Area 

are documented in West Virginia’s Regional Haze SIP posted for public comment in 

April 2008, submitted to EPA as a final SIP revision on June 18, 2008, and found on their 

website at:

http://www.wvdep.org/.
65

The Department agrees with the reasonable progress goals that were established by 

Virginia for the Shenandoah National Park. The reasonable progress goals established by 

the Virginia DEQ for the Shenandoah National Park are documented in Virginia’s 

Regional Haze SIP posted for public comment on August 18, 2010, submitted to EPA as 

a final SIP revision on October 4, 2010, and found on their website at:

http://www.deq.state.va.us/air/permitting/.

To establish reasonable progress targets for their Class I areas, West Virginia and 

Virginia used modeling that assumed implementation of CAIR for EGUs in the eastern 

United States, including the EGUs in Pennsylvania. Therefore, EGU controls in 

Pennsylvania that are consistent with CAIR are also consistent with the reasonable 

progress goals established for Dolly Sods Wilderness Area by West Virginia in their

Regional Haze SIP revision, and for the reasonable progress goals established by Virginia 

in their Regional Haze SIP revision for the Shenandoah National Park. (See Appendix K 

for the Power Point presentation given to the MANE-VU member states on March 18, 

2008, by VISTAS on VISTAS 2018 Regional Haze Best and Final Modeling 

Projections.)

Modeling conducted for VISTAS and used by West Virginia and Virginia to set their 

reasonable progress goals for the Dolly Sods Wilderness Area and the Shenandoah

National Park, respectively, projected different 2018 visibility than was predicted by the 

most recent MANE-VU modeling at those two Class I areas. MANE-VU predicted less 

visibility improvement by 2018 than VISTAS predicted at both Dolly Sods and 

Shenandoah, but only at Dolly Sods did the MANE-VU modeling project that the 

uniform rate of progress in 2018 would not be met. This is primarily because the two 

regions used different assumptions about the efficacy of CAIR in reducing emissions 

from EGUs. MANE-VU’s emissions assumptions regarding anticipated CAIR reductions 

from the EGUs are more conservative than are VISTAS’, because the MANE-VU 

emissions were not reduced as much as the VISTAS’s emissions were.

The primary reason for the different SO2 emissions inventory that MANE-VU and 

VISTAS used in their respective modeling for 2018 is that the CAIR program is a cap 

and trade program. Consultations between the RPOs (MANE-VU, VISTAS and MRPO) 

concerning an appropriate and consistent modeling approach for the CAIR EGUs yielded 

differing opinions and no enforceable mechanism to require the vast majority of the 

CAIR allowances claimed by MANE-VU’s neighboring RPOs to be retired. MANE-VU 

believed it to be appropriate to take a conservative approach and estimate the potential for 

emissions reductions under the CAIR program. Therefore, in the most recent modeling 

NESCAUM performed for MANE-VU, MANE-VU decided to keep the CAIR cap whole 

and added EGU SO2 emissions to the inventory to estimate the impact of banking and 

trading under CAIR. In the most recent modeling, NESCAUM increased the inventory 

emissions from MANE-VU states, and from the MRPO and VISTAS states subject to the 

CAIR cap and trade program. 
66

Because the MANE-VU Class I states made the decision to maintain the CAIR level of 

emissions throughout all three RPOs in the most recent modeling, NESCAUM 

determined that 516,350 tons of SO2 in total should be added back. For MANE-VU, 

75, 809 tons of SO2 were added back to the hypothetical facility controlled to meet the 

‘Ask’. The remaining 440,188 tons were allocated to VISTAS and MRPO at EGUs that 

were not among the “167 stack” list. The additional emissions correspond to an increase 

of 20.5 percent at each of these facilities, with a total of 216,685 tons added to MRPO 

and 223,504 tons added to VISTAS. The visibility projections from this modeling show 

that all MANE-VU Class I areas are projected to meet or exceed the uniform rate of 

progress goal for 2018 on the 20 percent worst days, and no area indicated an increase in 

visibility impairment on the 20 percent best days, relative to the baseline. The nearby 

Class I areas of Shenandoah and Dolly Sods also showed improvement relative to the 

baseline conditions on the 20 percent worst days. The 2018 Visibility Projections report 

on page 14 concludes: “At Dolly Sods, however, projected visibility impairment on the 

20 percent worst days exceed the level determined by the uniform rate using the MANEVU modeling approach. Apparently the net result of adding back SO2 emissions across 

the modeled domain, in order to maintain the CAIR cap, has been to increase the 

projected visibility impairment at Dolly Sods relative to previous modeled scenarios. 

This result is most evident at southern and western Class I areas where more emissions

(on an absolute basis) were added back to the EGUs.” (See pages 10-14 of Appendix L, 

2018 Visibility Projections, NESCAUM, May 13, 2008).

The most recent modeling completed by VISTAS for the Class I areas in VISTAS 

showed the uniform rate of progress in 2018 would be met at both Shenandoah and Dolly 

Sods. VISTAS did not add back SO2 emissions to their 2018 projected inventory, and 

have stated that they believe their inventory represents the best estimate of 2018 SO2 

emissions from OTB/OTW controls in that region. (See Appendix CC, VISTAS Letter 

of Comments on the MANE-VU Best and Final Modeling.)

In summary, the VISTAS modeling results indicate that the projected level of emissions 

controls for Pennsylvania’s sources by 2018 will allow the Dolly Sods Class I area to 

meet the reasonable progress goals established by West Virginia by 2018. The emissions 

control strategy for the MANE-VU Class I areas’ reasonable progress analysis is 

therefore a reasonable emissions control strategy for the reasonable progress analysis for 

the Dolly Sods Class I area. Pennsylvania is achieving a reasonable level of control by 

pursuing, as appropriate and necessary, the four goals of the MANE-VU ‘Ask’ Statement 

in order to meet the reasonable progress goals established for the Dolly Sods Class I area. 

The Commonwealth adopted a CAIR regulation on April 12, 2008, which was approved 

by the EPA as a SIP revision effective December 10, 2009 (74 FR 65446). The EGUs in 

the Commonwealth are now required to reduce NOx and SO2 emissions under 

Pennsylvania’s CAIR Program. As a result of the Court’s remand of the federal CAIR to 

EPA, it is reasonable to expect that a revised federal CAIR will be in place to evaluate the 

Commonwealth’s SO2 emissions controls on Pennsylvania’s EGUs by the time the first 

regional haze progress report is due. 

9.2. Calculation of Uniform Rate of Progress
67

As a benchmark to aid in developing reasonable progress goals, MANE-VU compared 

the baseline visibility conditions to natural visibility condition in each Class I area and 

determined the uniform rate of visibility improvement (in deciviews) that would need to 

be maintained during each implementation period in order to attain natural visibility 

condition by 2064. The uniform rate of improvement per year needed to achieve natural 

background visibility conditions is shown in Table 9.2-1 below.

Table 9.2-1 Uniform Rate of Progress for MANE-VU Class I Areas

Class I Area

Deciview 

Improvement 

Needed by 

2018

Total 

Deciview 

Improvement 

Needed by 

2064

Uniform Rate 

of 

Improvement 

Annually

Projected Year 

for Reaching 

Natural 

Visibility

Acadia National Park 2.4 10.5 0.17 2064

Moosehorn Wilderness Area 2.3 9.7 0.16 2064

Roosevelt/Campobello International

Park 2.3 9.7 0.16 2064

Great Gulf Wilderness Area 2.5 10.8 0.18 2064

Presidential Range/Dry River 

Wilderness Area 2.5 10.8 0.18 2064

Lye Brook Wilderness Area 3.0 12.8 0.21 2064

Brigantine Wilderness Area 3.9 16.8 0.28 2064

Source: VIEWS (http://vista.cira.colostate.edu/views/), prepared on 6/22/2007

In 2006, MANE-VU conducted an assessment of the default and alternative approaches 

for calculation of baseline and natural background conditions at MANE-VU Class I 

areas. Based on that assessment, in December 2006, MANE-VU recommended adoption 

of the alternative reconstructed extinction equation for use in the December 2007 regional 

haze SIPs. Both natural conditions and baseline visibility for the 5-year period from 

2000 through 2004 were calculated in conformance with an alternative method 

recommended by the IMPROVE Steering Committee.6 

As explained below, the reasonable progress goals established for the Class I areas in 

MANE-VU provide for at least as much visibility improvement by 2018 as would be 

achieved by the uniform rate of progress rate shown above.

9.3. Reasonable Progress Goals for Class I Areas in MANE-VU

 6

“Baseline and Natural Visibility Conditions, Considerations and Proposed Approach to the Calculation of 

Baseline and Natural Visibility Conditions at MANE-VU Class I Areas,” NESCAUM, December 2006, 

Appendix E.
68

This section of the regional haze SIP revision describes the reasonable progress goals 

developed by MANE-VU for each Class I area located within the MANE-VU region. A 

summary of the reasonable progress goals developed by MANE-VU is listed below in

Table 9.3-1 and Table 9.3-2.

Table 9.3-1 Reasonable Progress Goals for the 20% Worst Days

Class I Area

Baseline 

Visibility 

(deciviews) 

(20% 

Worst Days 

2000-2004)

Reasonable 

Progress Goals, 

20% worst days 

(expected 

deciview level 

by 2018)

Deciview 

improvement 

expected by 

2018

Natural Visibility 

Conditions (20% 

worst days)

Acadia National Park 22.9 19.4 3.5 12.4

Roosevelt/Campobello 

International Park

21.7 19.0 2.7 12.0

Moosehorn 

Wilderness Area

21.7 19.0 2.7 12.0

Presidential 

Range/Dry River 

Wilderness Area 

22.8 19.1 3.7 12.0

Great Gulf Wilderness 

Area

22.8 19.1 3.7 12.0

Lye Brook Wilderness 24.5 20.9 3.6 11.7

Brigantine Wilderness 29.0 25.1 3.9 12.2

Source: 2018 Visibility Projections Report, May 2008, (Appendix L).
69

Table 9.3-2 Reasonable Progress Goals for the 20% Best Days

Class I Area

Baseline 

Visibility 

(deciviews) 

(20% Best 

Days)

Reasonable 

Progress Goals, 

20% best days 

(deciviews)

(expected by 

2018)

Deciview 

improvement 

expected by 2018

Natural Visibility 

(20% best days)

(deciviews)

Acadia National Park 8.8 8.3 0.5 4.7

Roosevelt/Campobello 

International Park

9.2 8.6 0.6 5.0

Moosehorn Wilderness 

Area

9.2 8.6 0.6 5.0

Presidential Range/Dry 

River Wilderness Area 

7.7 7.2 0.5 3.7

Great Gulf Wilderness 

Area

7.7 7.2 0.5 3.7

Lye Brook Wilderness 6.4 5.5 0.9 2.8

Brigantine Wilderness 14.3 12.2 2.1 5.5

Source: 2018 Visibility Projections Report, May 2008, (Appendix L).

In 2006, MANE-VU conducted an assessment of the default and alternative approaches 

for calculation of baseline and natural background conditions at MANE-VU Class I 

areas. Based on that assessment, in December 2006, MANE-VU recommended adoption 

of the alternative reconstructed extinction equation for use in the December 2007 regional 

haze SIPs. Both natural conditions and baseline visibility for the 5-year period from 

2000 through 2004 were calculated in conformance with an alternative method 

recommended by the IMPROVE Steering Committee.7

 Progress toward the 2018 target 

will be calculated based on 5-year averages calculated in a nationally consistent manner 

consistent with EPA’s Guidance for Tracking Progress Under the Regional Haze Rule 

(EPA-454/B-03-004, September 2003), as updated by the alternative method for 

calculating regional haze recommended by the IMPROVE Steering Committee.

To determine the reasonable progress goals in deciviews, the MANE-VU Class I area 

States conducted modeling with certain control measure assumptions. The control 

measures reflected in these reasonable progress goals are summarized below in Section 

 7

“Baseline and Natural Visibility Conditions, Considerations and Proposed Approach to the Calculation of 

Baseline and Natural Visibility Conditions at MANE-VU Class I Areas,” NESCAUM, December 2006, 

Appendix E.
70

9.4 of this SIP revision. In establishing these reasonable progress goals for 2018, the 

MANE-VU Class I area states recognize that Pennsylvania and other contributing states 

have the flexibility to submit SIP revisions between now and 2018 as they are able to 

adopt control measures to implement these goals. The overall approach to reducing and 

preventing emissions that contribute to regional haze will allow each state up to 10 years 

to pursue adoption and implementation of reasonable and cost-effective NOx and SO2 

control measures, as appropriate and necessary. The Department will pursue these

measures, as appropriate and necessary, and in five years at the time of Pennsylvania’s 

first periodic SIP report expects to report on progress toward adoption of these measures 

by 2018.

9.4. The MANE-VU ‘Ask’ Statement Strategy

Section 51.308(d)(1)(vi) of EPA’s RHR requires that reasonable progress goals represent

at least the visibility improvement expected from implementation of other CAA programs 

during the applicable planning period. As documented in the emissions inventory and 

long term strategy sections of this SIP, the modeling that formed the basis for 

determining the reasonable progress goals for the MANE-VU Class I areas included an 

estimate of all of the other programs required by the CAA. (See Sections 7 and 10 of this 

SIP revision.)

The reasonable progress goals shown above in Tables 9.3-1 and 9.3-2 represent 

implementation of the regional course of action set forth by MANE-VU on June 20, 2007 

and entitled, “Statement of the Mid-Atlantic/Northeast Visibility Union (MANE-VU) 

Concerning a Course of Action Within MANE-VU toward Assuring Reasonable 

Progress”, (Appendix M), also known as the “Ask” Statement. As such, these goals are 

intended to reflect the pursuit by MANE-VU States, including Pennsylvania, of a course 

of action, including pursuing the adoption and implementation of the following “emission 

management” strategies, as appropriate and necessary:

• “Timely implementation of BART requirements; and

• “A low sulfur fuel oil strategy in the inner zone states (New Jersey, New York, 

Delaware, and Pennsylvania, or portions thereof) to reduce the sulfur content of: 

o Distillate oil to 0.05% sulfur by weight (500 ppm) by no later than 2012,

o #4 residual oil to 0.25% sulfur by weight by no later than 2012,

o #6 oil to 0.3 – 0.5% sulfur by weight by no later than 2012, and

o Further reduce the sulfur content of distillate oil to 15 ppm by 2016; and

• “A low sulfur fuel oil strategy in the outer zone states (the remainder of the 

MANE-VU region) to reduce the sulfur content of: 

o Distillate oil to 0.05% sulfur by weight (500 ppm) by no later than 2014,

o #4 residual oil to 0.25%-0.50% sulfur by weight by no later than 2018,

o #6 oil to no greater than 0.5% sulfur by weight by no later than 2018, and

o Further reduce the sulfur content of distillate oil to 15 ppm by 2018; and
71

• “A 90% or greater reduction in sulfur dioxide (SO2) emissions from each of the 

electric generating unit (EGU) stacks identified by MANE-VU (Attachment 1-

comprising a total of 167 stacks, dated June 20, 2007) as reasonably anticipated to 

cause or contribute to impairment of visibility in each mandatory Class I Federal 

area in the MANE-VU region. If it is infeasible to achieve that level of reduction 

from a unit, alternative measures will be pursued in such State; and

• “Continued evaluation of other control measures including energy efficiency, 

alternative clean fuels, and other measures to reduce SO2 and nitrogen oxide 

(NOx) emissions from all coal-burning facilities by 2018 and new source 

performance standards for wood combustion. These measures and other measures 

identified will be evaluated during the consultation process to determine if they 

are reasonable and cost-effective.”

The Long Term Strategy portion of this SIP (Section 10) provides a detailed technical 

description of how these regional strategies were modeled to estimate the visibility 

impact of the MANE-VU Statement’s emission management strategies described above. 

These measures and other measures identified were evaluated by Pennsylvania and other 

MANE-VU States prior to and during the consultation process, and the above course of 

action was determined to be reasonable. Assumptions about the implementation of these 

measures are represented by the emissions and modeling assumptions described in 

Section 10. As stated above, this long-term strategy to reduce and prevent regional haze 

will allow the MANE-VU States, including Pennsylvania, up to 10 years to pursue 

adoption and implementation of reasonable and cost-effective NOx and SO2 emissions 

reduction measures, as appropriate and necessary. The Department will pursue these

measures, as appropriate and necessary, and in five years at the time of Pennsylvania’s 

first periodic SIP report expects to report on progress toward adoption of these measures 

by 2018.

In conclusion, the reasonable measures proposed by the MANE-VU States, including

Pennsylvania, are found to be consistent with the stated national goals of preventing 

further visibility degradation while making measurable progress toward achieving natural 

visibility conditions in wilderness areas by 2064.
72

10.0. Long-Term Strategy

Section 51.308(d)(3) of EPA’s RHR requires Pennsylvania to submit a long-term strategy 

that addresses regional haze visibility impairment for each Class I area outside 

Pennsylvania that may be affected by emissions from within Pennsylvania. The longterm strategy must include enforceable emissions limitations, compliance schedules and 

other measures necessary to achieve the reasonable progress goals established by states or 

tribes where the Class I areas are located. This section describes how the Department

meets the long-term strategy requirements.

The Department will continue to evaluate all measures included in the long term strategy 

to determine whether they remain reasonable for Pennsylvania to pursue implementation 

of by 2018. Pennsylvania will formalize that determination in the first regional haze SIP 

progress report, which is due five years from the date of the initial submittal of the 

regional haze SIP. In developing this long-term strategy, the Department considered the 

requirements of Section 110(a)(2)(D)(i) of the CAA pertaining to the requirement that 

SIPS contain adequate provisions to prohibit any source or activity from emitting air 

pollutants in amounts that would interfere with another state’s ability to protect visibility. 

The measures described in the Commonwealth’s long-term strategy are designed to meet 

the reasonable progress goals contained in the SIPs of states with Class I areas that may 

be affected by emissions from the Commonwealth, as required by 40 CFR § 51.308

(d)(3). These measures thereby constitute adequate protection against interference with 

another state’s ability to protect visibility.

10.1. Consultation 

Section 51.308(d)(3)(i) of the RHR requires the Department to consult with other states 

and tribes to develop coordinated emission strategies. This requirement applies where 

emissions from Pennsylvania are reasonably anticipated to contribute to visibility 

impairment in Class I areas outside Pennsylvania.

The Department consulted with states with mandatory Class I areas that Pennsylvania 

sources may cause or contribute to visibility impairment in by participation in the 

MANE-VU and inter-RPO processes, through which technical information necessary for 

development of coordinated strategies was developed. The Department also coordinated 

with MANE-VU and other RPOs to develop the MANE-VU Contribution Assessment 

(Appendix B) that was used to develop the Department’s long-term strategy. Strategy 

development considered the impacts of Pennsylvania’s emissions on Class I areas outside 

Pennsylvania. The Department has held discussions with staff in both Virginia and West 

Virginia. Neither of these two states intends on requesting that Pennsylvania make 

additional reductions at emission sources located in Pennsylvania. The 2018 visibility 

modeling conducted for VISTAS and used by West Virginia and Virginia to establish the 

reasonable progress goals for the Dolly Sods Wilderness Area and for Shenandoah 

National Park (VISTAS, Shenandoah Group Contribution Assessment, May 2007, 

Appendix C) shows that the maximum projected contribution of any single source unit 
73

from Pennsylvania to visibility impairment at Dolly Sods Wilderness Area, Shenandoah 

National Park or James River Face Wilderness Area is less than 1%. The West Virginia 

Department of Environmental Protection sent an email, dated September 13, 2007, to the 

Department stating, “we are not going to ask PA to make any additional reductions or to 

consult further.” The Virginia Department of Environmental Quality sent an email to the 

Department, dated September 14, 2007, stating, “VA is not asking PA for any additional 

reductions or for further consultation during this round of RH since our analysis shows 

that maximum normalized contribution of any PA source to Shenandoah or James River 

Face is <1%.” (See Appendix D for copies of the West Virginia and Virginia emails.)

As a participant in MANE-VU, Pennsylvania supported a regional approach toward

deciding which control measures to pursue for regional haze that was based on technical 

analyses documented in the following reports:

• Contributions to Regional Haze in the Northeast and Mid-Atlantic United 

States (called the Contribution Assessment, Appendix B), 

• Comparison of CAIR and CAIR Plus Proposal using the Integrated Planning 

Model® (called the CAIR+ Report, Appendix N), 

• Assessment of Reasonable Progress for Regional Haze in MANE-VU Class I 

Areas (called the Reasonable Progress Report, Appendix O), 

• Five-Factor Analysis of BART-Eligible Sources: Survey of Options for 

Conducting BART Determinations, Appendix P, and

• Assessment of Control Technology Options for BART-Eligible Sources: 

Steam Electric Boilers, Industrial Boilers, Cement Plants and Paper and Pulp 

Facilities, Appendix Q. 

The regional strategy development process identified reasonable measures that would 

reduce emissions contributing to visibility impairment at Class I areas affected by 

emissions from within the MANE-VU region by 2018 or earlier. Section 10.9 provides a 

detailed description of the consultation process the Department was a part of with 

MANE-VU that developed the technical information necessary for developing the 

coordinated long-term strategies.

The Department’s coordination with FLMs on long-term strategy development is 

described in Section 4.0 State/Tribe and Federal Land Manager Coordination.

10.2. Contribution to Visibility Impairment at Class I Areas

Pursuant to 40 CFR § 51.308(d)(3)(iv), each state must identify all anthropogenic sources 

of visibility impairment considered by the state in developing its long-term strategy. 

EPA’s Guidance for Setting Reasonable Progress Goals Under the Regional Haze 

Program (June, 2007) notes that this process begins with the identification of key 

pollutants and source categories that contribute to visibility impairment at the Class I 

area(s) affected by emissions from the state.
74

Finalized in August 2006, the MANE-VU Contribution Assessment reflects a conceptual 

model in which sulfate emerges as the most important single constituent of haze-forming 

fine particle pollution and the principle cause of visibility impairment across the region. 

Sulfate alone accounts for approximately one-half to two-thirds of total fine particle mass 

on the 20 percent haziest days at MANE-VU Class I sites. Organic carbon was shown to 

be the second largest contributor to haze. Its contribution typically ranges from 20 to 30 

percent of total fine particle mass on the haziest days. The Contribution Assessment for 

MANE-VU (Appendix B) provides this information concerning organic carbon:

“The term organic carbon encompasses a large number and variety of chemical 

compounds that may come directly from emission sources as a part of primary PM or 

may form in the atmosphere as secondary pollutants. The conceptual models that explain 

elevated regional PM2.5 peak concentrations in the summer differ significantly from 

models that explain the largely urban peaks observed during winter. On average, 

summertime concentrations of sulfate in the northeastern United States are more than 

twice that of the next most important fine particle constituent, OC, and more than four 

times the combined concentration of nitrate and black carbon (BC) constituents 

(NARSTO, 2003). Episodes of high summertime sulfate concentrations are consistent 

with stagnant meteorological flow conditions and the accumulation of airborne sulfate 

(via atmospheric oxidation of SO2) through long-range transport of sulfur emissions from 

industrialized areas within and outside the region. The organic carbon present at Class I 

locations almost certainly includes a mix of species, including pollutants originating from 

anthropogenic (manmade) sources as well as biogenic hydrocarbons emitted from 

vegetation. The inorganic constituents of fine particles (sulfates and nitrates) are the 

dominant contributors to visibility impairment, accounting for about 80 percent of total 

particle extinction. 

“Within the MANE-VU sites, the relative split between these two components is about 

eight to one sulfate to nitrate (at Shenandoah, the average 20 percent worst day 

contribution of sulfates is even more dominant). Carbonaceous components account for 

the bulk of the remaining particle extinction, ranging from 12 to nearly 20 percent, 

mostly in the form of organic carbon. Almost all particle sulfate originates from sulfur 

dioxide (SO2) oxidation and typically associates with ammonium (NH4) in the form of 

ammonium sulfate ((NH4)2SO4), 95 percent of SO2 emissions are from anthropogenic 

sources (primarily from fossil fuel combustion), while the majority of ammonium comes 

from agricultural activities and, to a lesser extent, from transportation sources in some 

areas (NARSTO, 2003). The fact that the contribution from organic carbon can be as 

high as 40 percent at the more rural sites on the 20 percent clearest days is likely 

indicative of the role played by organic emissions from vegetation (so-called ‘biogenic 

hydrocarbons’ (HC)). Relative contributions to overall fine particle mass from nitrate 

(NO3), elemental carbon, and fine soil are all smaller (typically under 10 percent), but the 

relative ordering among the three species varies with location. Nitrate plays a noticeably 

more important role at urban sites compared to northeastern and mid-Atlantic Class I 

locations, perhaps reflecting a greater contribution from vehicles and other urban

pollution sources (NESCAUM, 2001).
75

“For urban areas of the northeastern and southeastern United States, an effective

emissions management approach may be to combine regional SO2 control efforts aimed

at reducing summertime PM2.5 concentrations with local SO2 and OC control efforts.

Local SO2 reductions would help reduce wintertime PM concentrations, while OC

reductions can help reduce overall PM concentrations year-round. Long-range pollutant 

transport and local pollutant emissions are important, especially along the eastern 

seaboard, so one must also look beyond the achievement of further sulfate reductions. 

Given the dominant role of sulfate and nitrate, however, and the difficulty in obtaining 

reductions in some of the other categories such as soil or course mass, sulfate- and 

nitrate-based control programs are likely to offer more reasonable emission reduction 

opportunities. Recent efforts to reduce manmade organic carbon emissions have been 

undertaken primarily to address summertime ozone formation in urban areas. Future 

efforts to further reduce organic carbon emissions may be driven by programs that 

address fine particles and visibility.”

As a result of the dominant role of sulfate in the formation of regional haze in the 

Northeast and Mid-Atlantic region, MANE-VU concluded that an effective emissions 

management approach would rely heavily on broad-based regional SO2 control efforts in 

the eastern United States. The Department agrees with this approach.

The following Figure 10.2 shows the dominance of sulfate in the extinction calculated 

from the 2000-2004 baseline data.

Figure 10.2 Contributions to PM2.5 Extinction at Seven Class I Areas

#

#

#

#

#

#

#

Contributions to PM2.5 Extinction at 7 Sites

20% Worst Visibility Days (2000-2004)

Soil

Sea Salt

OC

EC

Nitrate

Sulfate

0

20

40

60

80

100

120

140

160

180

1

1

1

1

1

Extinction (Mm-1)

Dolly Sods

Shenandoah

Brigantine

Lye Brook

Great Gulf

Acadia

Moosehorn
76

The MANE-VU Contribution Assessment used various modeling techniques, air quality 

data analysis, and emissions inventory analysis to identify source categories and states 

that contribute to visibility impairment in MANE-VU Class I areas. With respect to 

sulfate, based on estimates from four different techniques, the Contribution Assessment 

estimated emissions from within MANE-VU in 2002 were responsible for about 25-30 

percent of the sulfate at MANE-VU and nearby Class I areas. (See Chapter 8 of the 

Contribution Assessment, Appendix B.) Emissions from other regions, Canada, and 

outside the modeling domain were also important. For more details about the methods 

used to identify contributing states and regions, please see the Contribution Assessment 

document. 

MANE-VU considered modeling results documented in the Contribution Assessment to 

determine which states should be consulted in developing the long-term strategy for 

improving visibility in MANE-VU Class I areas. Because sulfate was the primary 

pollutant of concern, and the Modeling System for Aerosols and Deposition (REMSAD,

SAI, 2002) model results quantified sulfate impacts, three methods of evaluating states’ 

impacts using REMSAD results were considered: 

1. States/regions that contributed 0.1 ug/m3 sulfate or greater on the 20 percent worst 

visibility days in the base year (2002).

2. States/regions that contributed at least 2 percent of total sulfate observed on 20 

percent worst visibility days in 2002.

3. The top ten contributing states on the 20 percent worst visibility days in 2002.

For purposes of deciding how broadly to consult, the MANE-VU States decided to use 

method 2, including states that contributed at least 2 percent of total sulfate observed on 

the 20 percent worst visibility days in 2002. Based on the MANE-VU Contribution 

Assessment, emissions from Pennsylvania contribute to visibility degradation in the 

following Class I Areas: Acadia National Park, Brigantine Wilderness, Dolly Sods 

Wilderness, Great Gulf Wilderness, Lye Brook Wilderness, Presidential Range/Dry River 

Wilderness, Moosehorn Wilderness, Roosevelt/Campobello International Park, 

Shenandoah National Park.

Table 10.2-1 below shows the results of the REMSAD model of assessing state-by-state 

contributions to sulfate impacts at Class I areas within MANE-VU and nearby the 

MANE-VU region (See Table 8-1 of Appendix B). Shenandoah and Dolly Sods are 

Class I areas in the VISTAS region that are impacted by emissions from MANE-VU 

states. The Dolly Sods IMPROVE monitor is also representative of the Otter Creek 

Wilderness Area in West Virginia. The other five Class I areas are in MANE-VU. The 

IMPROVE monitor at Great Gulf also represents the Presidential Range/Dry River 

Wilderness. The IMPROVE monitor at Moosehorn also represents Roosevelt 

Campobello International Park. This table highlights the importance of emissions from 

outside the MANE-VU region.
77

Table 10.2-1 Percent of Modeled Sulfate Due to Emissions from Listed States8

Contributing 

States or Areas

Acadia, 

Maine

(%)

Brigantine, 

New Jersey

(%)

Dolly 

Sods, 

Otter 

Creek, 

West 

Virginia

(%)

Great Gulf 

and 

Presidential 

Range Dry 

River, New 

Hampshire

(%)

Lye 

Brook, 

Vermont

(%)

Moosehorn

and 

Roosevelt 

Campobello

,Maine

(%)

Shenandoah, 

Virginia

(%)

Connecticut 0.76 0.53 0.04 0.48 0.55 0.56 0.08

Delaware 0.96 3.20 0.30 0.63 0.93 0.71 0.61

District of 

Columbia 0.01 0.04 0.01 0.01 0.02 0.01 0.04

Maine 6.54 0.16 0.01 2.33 0.31 8.01 0.02

Maryland 2.20 4.98 2.39 1.92 2.66 1.60 4.84

Massachusetts 10.11 2.73 0.18 3.11 2.45 6.78 0.35

New 

Hampshire 2.25 0.60 0.04 3.95 1.68 1.74 0.08

New Jersey 1.40 4.04 0.27 0.89 1.44 1.03 0.48

New York 4.74 5.57 1.32 5.68 9.00 3.83 2.03

Pennsylvania 6.81 12.84 10.239 8.30 11.72 5.53 12.0510

Rhode Island 0.28 0.10 0.01 0.11 0.06 0.19 0.01

Vermont 0.13 0.06 0.00 0.41 0.95 0.09 0.01

MANE-VU 36.17 34.83 14.81 27.83 31.78 30.08 20.59

Midwest RPO 11.98 18.16 30.26 20.10 21.48 10.40 26.84

VISTAS 8.49 21.99 36.75 12.04 13.65 6.69 33.86

Other 33.79 16.78 12.70 23.54 18.99 44.17 12.48

10.3. Technical documentation

10.3.1. Basis for Emission Reduction Obligations

Section 51.308(d)(3)(iii) of EPA’s RHR requires the Department to document the 

technical basis for Pennsylvania’s apportionment of emission reductions necessary to 

meet reasonable progress in each Class I area affected by Pennsylvania’s emissions. 

 8 Percentages based on 2002 annual average sulfate impact estimated with REMSAD model as described in 

MANE-VU Contribution Assessment Chapter 4 and summarized on page 8-2 of the Contribution 

Assessment.

9 The percent contribution of the sulfate impact at Dolly Sods due to Pennsylvania sources modeled by the 

West Virginia RPO (VISTAS) is 5.26%. (See Appendix C).

10 The percent contribution of the sulfate impact at Shenandoah due to Pennsylvania sources modeled by 

the Virginia RPO (VISTAS) is 6.11%. (See Appendix C).
78

The Department relied on technical analyses developed by MANE-VU to demonstrate 

that Pennsylvania’s emission reductions, when coordinated with those of other states and 

tribes, are sufficient to achieve the reasonable progress goals in Class I areas affected by 

Pennsylvania’s emissions.

The emission reductions relied upon to meet reasonable progress goals in Class I areas 

affected by Pennsylvania are described in the following documents:

• Baseline and Natural Background Visibility Conditions—Considerations and 

Proposed Approach to the Calculation of Baseline and Natural Background 

Visibility Conditions at MANE-VU Class I Areas (NESCAUM, December 

2006) (Appendix E).

• The Nature of the Fine Particle and Regional Haze Air Quality Problems in 

the MANE-VU Region: A Conceptual Description (NESCAUM, November 

2006) (Appendix R).

• Contributions to Regional Haze in the Northeast and Mid-Atlantic United 

States (NESCAUM, August 2006)(called the Contribution Assessment) 

(Appendix B.)

• Comparison of CAIR and CAIR Plus Proposal using the Integrated Planning 

Model® (called the CAIR+ Report) (ICF, May 2007) (Appendix N).

• Assessment of Reasonable Progress for Regional haze in MANE-VU Class I 

Areas (MACTEC, July 2007)(called the Reasonable Progress Report) 

(Appendix O).

• Five-Factor Analysis of BART-Eligible Sources: Survey of Options for 

Conducting BART Determinations (June, 2007) (Appendix P).

• Assessment of Control Technology Options for BART-Eligible Sources: 

Steam Electric Boilers, Industrial Boilers, Cement Plants and Paper and Pulp 

Facilities (NESCAUM, March 2005) (Appendix Q).

• MANE-VU Modeling for Reasonable Progress Goals: Model Performance 

Evaluation, Pollution Apportionment, and Control Measure Benefits 

(NESCAUM, February 2008) (Appendix S).

• 2018 Visibility Projections (NESCAUM, March 2008) (Appendix L).

In addition, MANE-VU relied on analysis conducted by neighboring RPOs, including the 

following documents, which are available upon request but are not incorporated into this 

SIP:

• VISTAS Reasonable Progress Analysis Plan by VISTAS, dated September 

18, 2006.

• Reasonable Progress for Class I Areas in the Northern Midwest-Factor 

Analysis, by EC/R, dated July 18, 2007.
79

10.3.2. Baseline inventory 

Section 51.308(d)(3)(iii) of EPA’s RHR requires the Department to identify the baseline 

emissions inventory on which the long-term strategy is based. 

• For the MANE-VU region, the Department used the 2002 MANE-VU 

Emissions Inventory Version 3.0 as its baseline inventory. The inventory is 

documented in Section 7 of this SIP.

• For other regions, MANE-VU used emissions inventories developed by the 

RPOs for those regions, including VISTAS Base G2, MRPO’s Base K, and 

CenRAP’s emissions inventory.

More specific information about the baseline emissions inventory data used may be found 

in Section 7 of this SIP.

The Department used the 2002 MANE-VU Emissions Inventory Version 3.0 as its 

baseline inventory. (The inventory is documented in Section 7 Emissions Inventory, of

this SIP) 

10.3.3. Modeling Techniques Used

The following documents describe preliminary and final modeling runs conducted by 

MANE-VU and used in developing this long term-strategy:

• Contributions to Regional Haze in the Northeast and Mid-Atlantic United 

States (NESCAUM, August 2006)(called the Contribution Assessment) 

(Appendix B).

• MANE-VU Modeling for Reasonable Progress Goals: Model Performance 

Evaluation, Pollution Apportionment, and Control Measure Benefits 

(NESCAUM, February 2008) (Appendix S).

• 2018 Visibility Projections (NESCAUM, March 2008) (Appendix L).

As documented in the MANE-VU Contribution Assessment, two regional-scale air 

quality models were used to perform air quality simulations for MANE-VU. These are 

the Community Multi-scale Air Quality modeling system (CMAQ; Byun and Ching, 

1999) and the REMSAD model. CMAQ was developed by EPA, while REMSAD was 

developed by ICF Consulting/Systems Applications International (ICF/SAI) with EPA 

support. CMAQ provides one-atmosphere results for multiple pollutants while the 

REMSAD model was used primarily for attribution of sulfate species in the eastern 

United States via the species-tagging scheme included in Version 7.10 and newer 

versions of the model.

Three rounds of modeling were conducted:
80

o CMAQ was run for a complete set of baseline simulations including 2002, 2009 

and 2018. Preliminary runs are described in greater detail in Appendix C of the 

MANE-VU Contribution Assessment, (Appendix B). 

o Runs assessing impacts of potential control measures are described in the Modeling 

for Reasonable Progress Goals report (NESCAUM, 2008) (Appendix S).

o Final modeling to help develop reasonable progress goals is described in the 2018 

Visibility Projections report (NESCAUM, 2008) (Appendix L).

The modeling tools utilized for these analyses include MM5, SMOKE, CMAQ and 

REMSAD, and incorporate tagging features that allow for the tracking of individual 

source regions or measures.

A significant feature of the REMSAD work used to evaluate regional contributions is that 

NESCAUM reprocessed the SO2 emission data from each state to take advantage of 

REMSAD’s tagging capabilities. Thus, all SO2 emissions included in the model for the 

eastern half of the country were tagged according to state of origin, and emissions from 

Canada and the boundary conditions were also tagged. This allowed for a rough 

estimation of the total contribution from elevated point sources in each state to simulated 

sulfate concentrations at eastern receptor sites. Using identical emission and 

meteorological inputs to those prepared for the Integrated SIP (CMAQ) platform, 

REMSAD was used to simulate the annual average impact of each state’s SO2 emission 

sources on the sulfate fraction of PM2.5 over the northeastern United States. For more 

information see Appendix C of the MANE-VU Contribution Assessment (Appendix B). 

In addition to the REMSAD run with tagging, NESCAUM and its modeling partners at 

the University of Maryland and Rutgers University performed a sensitivity run with the 

CMAQ Particle and Precursor Tagging Methodology (CMAQ-PPTM) system. This run 

was used to assess the impacts of potential control measures under consideration. This 

work is described in the Modeling for Reasonable Progress Goals report (Appendix S).

The modeling platform is further described in the reports Modeling for Reasonable 

Progress Goals and 2018 Visibility Protections (Appendix L). MANE-VU used the 

Inter-RPO modeling domain. The 36-km gridded domain covers the continental US, 

southern Canada, and northern Mexico. The 12-km gridded inner domain covers the 

northeastern, central, and southeastern United States, as well as southeastern Canada.

Meteorological inputs for CMAQ, provided by Dalin Zhang’s group at the University of 

Maryland, were derived from the Fifth-Generation Pennsylvania State 

University/National Center for Atmospheric Research (NCAR) Mesoscale Model 

(MM5). A detailed description of the meteorological inputs can be found in the 

Modeling for Reasonable Progress Goals report.

The evaluation of model performance is also described in Section 2 of the report 

Modeling for Reasonable Progress Goals (Appendix S). Section 2.2 Model Evaluation 

of the report Modeling for Reasonable Progress Goals states: “predicted PM2.5 sulfate an 

measure sulfate are in a good 1:1 linear relationship.... PM2.5 nitrate also has close to a 1:1 
81

linear relationship between the model and observations.” The modeling tools were 

evaluated and found to perform adequately relative to USEPA modeling guidance. The 

modeling results were used in a relative sense by calculating the relative reduction factor 

(RRF) relative to the 2002 base case and then applying those factors to the baseline 

observations to estimate future projections. U.S. EPA guidance documents spell the 

process out in great detail. This guidance is the same for ozone, PM2.5 and regional haze 

and can be found at: http://www.epa.gov/scram001/guidance_sip.htm.

10.3.4. Monitoring and Emissions Data

Chapters 4 and 5 of the MANE-VU Contribution Assessment (Appendix B) document 

the techniques for analyzing air monitoring data and emissions data used by MANE-VU 

to assess the contribution of various states, regions, and source categories to visibility 

impairment at MANE-VU Class I areas. 

10.4. Anthropogenic Sources of Visibility Impairment

Section 51.308(d)(3)(iv) of EPA’s RHR requires the Department to identify all 

anthropogenic sources of visibility impairment considered by it in developing its longterm strategy, including major and minor stationary sources, mobile sources, and areas 

sources. The contribution assessment analysis completed by NESCAUM entitled, 

Contributions to Regional Haze in the Northeast and Mid-Atlantic States, (Appendix B) 

identifies the anthropogenic sources of visibility impairment considered by the 

Department.

The MANE-VU Contribution Assessment (Appendix B) and the MANE-VU Conceptual 

Model for Fine Particles and Regional Haze Air Quality Problems (Appendix R) identify 

sulfate as the largest contributor to visibility impairment in the Mid-Atlantic and 

Northeastern Class I areas. Organic carbon was shown to be the second largest 

contributor to haze in the MANE-VU region. 

Chapter 4 of the MANE-VU Contribution Assessment summarizes an analysis of hazeassociated pollutant emissions. Chapter 5 of the same document describes the results of 

numerous source apportionment analyses, which are further explained in Appendix B of 

the Contribution Assessment. Together, these studies identify the major source 

categories affecting Class I areas in and near MANE-VU. 

As a result of the dominant role of sulfate in the formation of regional haze in the 

Northeast and Mid-Atlantic region, MANE-VU concluded that an effective emissions 

management approach would rely heavily on broad-based regional SO2 control efforts in 

the eastern United States. Roughly 70 percent of the 2.3 million tons of SO2 emission in 

the 2002 MANE-VU emissions inventory Version 3.0 were from EGUs, making them the 

largest SO2 source category in terms of visibility impairing emissions. MANE-VU found 

through modeling analysis documented in the Contribution Assessment that emissions 

from specific EGUs were important contributors to visibility impairment in MANE-VU 

Class I areas in 2002. The Figure 10.4 below shows the locations of 167 EGU stacks that 
82

impair visibility at one or more MANE-VU Class I area. Some of the stacks identified as 

important were outside the states identified as contributing at least 2 percent of the sulfate 

at MANE-VU Class I areas; therefore they were dropped from the list. 

Figure 10.4 167 EGU Stacks Affecting MANE-VU Class I Areas

The largest source categories of sulfur dioxide in the MANE-VU region are EGUs, 

industrial, commercial, and institutional (ICI) boilers, cement kilns, lime kilns, and 

distillate-oil fired heating units. 

To assist with the assessment of potential control strategies for these important source 

categories, MANE-VU contracted with engineering and consulting company MACTEC. 

The project produced a technical support document that summarizes MANE-VU’s 

assessment of pollutants and associated source categories affecting visibility in Class I 

areas in and near MANE-VU, lists possible control measures, and compiles data on each 

control measure necessary to determine whether the control measure is reasonable to 

pursue. The final report, Assessment of Reasonable Progress for Regional Haze in 
83

MANE-VU Class I Areas Final Report (called the Reasonable Progress Report), is found 

in Appendix O.

Pennsylvania worked with other members of the Ozone Transport Commission (OTC) 

and MANE-VU to consider a wide variety of potential emission reduction strategies 

covering a wide range of sources of SO2

• Coal and oil-fired EGUs;

and other pollutants contributing to regional 

haze. Based on available information about emissions and potential impacts, the MANEVU Reasonable Progress Workgroup selected the following source categories for detailed 

analysis of the four factors the CAA establishes as the basis for determining how much 

progress in visibility improvement is reasonable:

• Point and area source industrial, commercial and institutional (ICI) boilers;

• Cement kilns;

• Lime kilns;

• The use of heating oil, and,

• Residential wood combustion and open burning.

Coal and oil-fired EGUs in Pennsylvania are subject to the Department’s CAIR

regulation (see page 100 of this SIP revision). The Department’s recently adopted 

cement kiln regulation is described on page 105 in this SIP revision. The rulemaking 

status of the Department’s low-sulfur fuel oil regulation is described on page 120 of this 

SIP revision. ICI boilers and lime kilns are source categories included in the 

Department’s developing Reasonably Available Control Technology (RACT) regulation 

to address the eight-hour ozone standard. New indoor wood stoves in Pennsylvania are 

regulated by EPA’s Residential Woodstoves NSPS. The NSPS for residential 

woodstoves was part of the area source inventory developed by MANE-VU to model the 

2018 inventory for area sources (see page 106 of this SIP revision). The final outdoor 

wood boiler (OWB) regulation was published in the Pennsylvania Bulletin on October 2, 

2010 (40 Pa.B. 5571). The Department’s final regulation will require EPA’s Phase 2 

emission standards, including the particulate matter standard of 0.32 lb/MMBtu, for all 

new OWBs in the Commonwealth by May 1, 2011.

10.4.1. The MANE-VU Reasonable Progress Strategy

As required under 40 CFR § 51.308(d)(1)(i)(A), the MANE-VU states applied a fourfactor analysis to potential control measures for the purpose of establishing reasonable 

progress goals. The MANE-VU states also identified additional control measures found 

to be reasonable, and these were included in the modeling used to establish the 

reasonable progress goals. All of the control measures, including the additional measures 

(described below), comprise the long-term strategy for improving visibility at MANEVU Class I areas. The reasonable progress goals adopted by the MANE-VU Class I 

States represent implementation of the regional course of action set forth by MANE-VU 

on June 20, 2007 and entitled, “Statement of the Mid-Atlantic/Northeast Visibility Union 

(MANE-VU) Concerning a Course of Action within MANE-VU toward Assuring 

Reasonable Progress”, (Appendix M), also known as the ‘Ask’ Statement. As such, these 
84

reasonable progress goals, also described below, are intended to reflect the pursuit by 

Pennsylvania and the other MANE-VU States of a course of action including pursuing 

the adoption and implementation of the following “emission management” strategies, as 

appropriate and necessary:

• “Timely implementation of BART requirements; and

• “A low sulfur fuel oil strategy in the inner zone states (New Jersey, New York, 

Delaware, and Pennsylvania, or portions thereof) to reduce the sulfur content of: 

o Distillate oil to 0.05 percent sulfur by weight (500 ppm) by no later than 

2012,

o #4 residual oil to 0.25 percent sulfur by weight by no later than 2012,

o #6 residual oil to 0.3 – 0.5 percent sulfur by weight by no later than 2012, 

and

o Further reduce the sulfur content of distillate oil to 15 ppm by 2016; and

• “A low sulfur fuel oil strategy in the outer zone states (the remainder of the 

MANE-VU region) to reduce the sulfur content of: 

o Distillate oil to 0.05 percent sulfur by weight (500 ppm) by no later than 

2014,

o #4 residual oil to 0.25 percent-0.50 percent sulfur by weight by no later 

than 2018,

o #6 residual oil to no greater than 0.5 percent sulfur by weight by no later 

than 2018, and

o Further reduce the sulfur content of distillate oil to 15 ppm by 2018 

depending on supply and availability; and

• “A 90 percent or greater reduction in sulfur dioxide (SO2) emissions from each of 

the electric generating unit (EGU) stacks identified by MANE-VU (Attachment 1-

comprising a total of 167 stacks, dated June 20, 2007) as reasonably anticipated to 

cause or contribute to impairment of visibility in each mandatory Class I Federal 

area in the MANE-VU region. If it is infeasible to achieve that level of reduction 

from a unit, alternative measures will be pursued in such State; and

• “Continued evaluation of other control measures including energy efficiency, 

alternative clean fuels, and other measures to reduce SO2 and nitrogen oxide 

(NOx) emissions from all coal-burning facilities by 2018 and new source 

performance standards for wood combustion.” 

As stated above, this long-term strategy to reduce and prevent regional haze will allow 

each state up to 10 years to pursue adoption and implementation of reasonable and costeffective NOx and SO2 control measures as appropriate and necessary. The Department

will pursue these measures, as appropriate and necessary, and in five years at the time of 

Pennsylvania’s first periodic SIP report expects to report on progress toward adoption of 

these measures by 2018.
85

The MANE-VU states, including Pennsylvania, agreed on the additional reasonable 

strategies listed above after consideration of an analysis of the four factors that the CAA

requires to be considered in determining whether controls are reasonable.

The Department relied on analysis developed for MANE-VU in applying the four factors 

to a series of emission control measures. This analysis is described in detail in the 

Reasonable Progress Report (Appendix O). The Reasonable Progress Report

summarizes MANE-VU’s assessment of pollutants and associated source categories 

affecting visibility in Class I areas in and near MANE-VU, lists possible control 

measures for those pollutants and source categories, and develops the requisite four factor 

analysis. Table 10.4.1 below presents a summary of the four factor analysis for the 

source categories analyzed in the Reasonable Progress Report11. 

Table 10.4.1: Summary of Results from the Four Factor Analysis

Source 

Category

Primary 

Regional 

Haze 

Pollutant

Control 

Measure(s)

Average 

Cost in 

2006 

dollars 

(per ton of 

pollutant 

reduction)

Compliance 

Timeframe

Energy and 

Non-Air 

Quality 

Environmental 

Impacts

Remaining 

Useful Life

Electric 

Generating 

Units 

SO2 Switch to a 

low sulfur coal 

(generally <1% 

sulfur),

switch to 

natural gas 

(virtually 0% 

sulfur), coal 

cleaning, 

Flue Gas 

Desulfurization 

(FGD)-Wet, -

Spray Dry, or -

Dry.

IPM®* 

v.2.1.9 

predicts 

$775-

$1,690. 

$170-

$5,700 

based on 

available 

literature

2-3 years 

following 

SIP 

submittal

Fuel supply 

issues, potential 

permitting 

issues, 

reduction in 

electricity 

production 

capacity, 

wastewater 

issues

50 years or 

more

Industrial, 

Commercial, 

Institutional 

Boilers

SO2 Switch to a 

low sulfur coal 

(generally <1% 

sulfur), 

switch to 

natural gas 

(virtually 0% 

sulfur), switch 

to a lower 

sulfur oil, coal 

cleaning, 

combustion 

control, Flue 

Gas 

$130-

$11,000 

based on 

available 

literature. 

Depends on 

size.

2-3 years 

following 

SIP 

submittal

Fuel supply 

issues, potential 

permitting 

issues, control 

device energy 

requirements, 

wastewater 

issues

10-30 years

 11 Assessment of Reasonable Progress for Regional Haze in MANE-VU Class I Areas by MACTEC
86

Desulfurization 

(FGD)- Wet, -

Spray Dry, or -

Dry.

*Integrated Planning Model®
87

Table 10.4.1 (cont.): Summary of Results from the Four Factor Analysis

Source 

Category

Primary 

Regional 

Haze 

Pollutant

Control 

Measure(s)

Average 

Cost in 

2006 

dollars 

(per ton of 

pollutant 

reduction)

Compliance 

Timeframe

Energy and 

Non-Air 

Quality 

Environmental 

Impacts

Remaining 

Useful 

Life

Cement and 

Lime Kilns

SO2 Fuel switching, 

Dry Flue Gas 

DesulfurizationSpray Dryer 

Absorption 

(FGD), Wet 

Flue Gas 

Desulfurization 

(FGD), 

Advanced Flue 

Gas 

Desulfurization 

(FGD).

$1,900-

$73,000 

based on 

available 

literature. 

Depends 

on size.

2-3 years 

following SIP 

submittal

Control device 

energy 

requirements, 

wastewater 

issues

10-30 

years

Heating Oil SO2 Lower the 

sulfur content in 

the fuel. 

Depends on the 

state.

$550-$750 

based on 

available 

literature. 

There is a 

high 

uncertainty 

associated 

with this 

cost 

estimate.

Currently 

feasible. 

Capacity issues 

may influence 

timeframe for 

implementation 

of new fuel 

standards

Increases in 

furnace/boiler 

efficiency, 

Decreased 

furnace/boiler 

maintenance 

requirements

18-25 

years

Residential 

Wood 

Combustion

PM State 

implementation 

of NSPS, Ban 

on resale of 

uncertified 

devices, 

installer 

training 

certification or 

inspection 

program, pellet 

stoves, EPA 

Phase II 

certified RWC 

devices, retrofit 

requirement, 

accelerated 

changeover 

requirement, 

accelerated 

changeover 

inducement.

$0-

$10,000 

based on 

available 

literature

Several years -

dependent on 

mechanism for 

emission 

reduction 

Reduce 

greenhouse gas 

emissions, 

increase 

efficiency of 

combustion 

device

10-15 

years
88

Guided by this analysis, MANE-VU arrived at a suite of suggested control measures that 

the MANE-VU states agreed to pursue as a region, including Pennsylvania. The 

corollary was that the MANE-VU Class I states (Maine, New Hampshire, Vermont, and 

New Jersey) also asked states outside of MANE-VU that also contribute to visibility 

impairment to pursue similar strategies for reducing sulfate emissions from source 

sectors, or equivalent sulfate reductions if not from the source sectors that MANE-VU 

has identified for its own sulfate reductions. The request was documented in “Statement 

of the Mid-Atlantic/Northeast Visibility Union (MANE-VU) Concerning a Request for a 

Course of Action by States Outside of MANE-VU toward Assuring Reasonable 

Progress”, and is found in Appendix M of this SIP. The states outside MANE-VU to 

whom this request was addressed were identified in the MANE-VU Contribution 

Assessment as those states contributing at least 2 percent of the sulfates at MANE-VU 

Class I areas in 2002. The following states outside MANE-VU were identified: Georgia, 

Illinois, Indiana, Kentucky, Michigan, North Carolina, Ohio, South Carolina, Tennessee, 

Virginia, and West Virginia.12

This MANE-VU June 20, 2007 ‘Ask’ Statement requested that the above-listed States 

outside of MANE-VU pursue the adoption and implementation of the following control 

strategies, as appropriate and necessary:

• “Timely implementation of BART requirements; and

• “A 90 percent or greater reduction in sulfur dioxide (SO2) emissions from each of 

the electric generating unit (EGU) stacks identified by MANE-VU (Attachment 1-

comprising a total of 167 stacks, dated June 20, 2007) as reasonably anticipated to 

cause or contribute to impairment of visibility in each mandatory Class I Federal 

area in the MANE-VU region. If it is infeasible to achieve that level of reduction 

from a unit, alternative measures will be pursued in such State; and

• “The application of reasonable controls on non-EGU sources resulting in a 28 

percent reduction in non-EGU SO2 emissions relative to on-the-books, on-theway 2018 projections used in regional haze planning, by 2018, which is 

equivalent to the projected reductions MANE-VU will achieve through its low 

sulfur fuel oil strategy; and

• “Continued evaluation of other measures including measures to reduce SO2 and 

NOx emissions from all coal-burning facilities by 2018 and promulgation of new 

source performance standards for wood combustion. These measures and other 

measures identified will be evaluated during the consultation process to determine 

if they are reasonable.”

These measures and other measures were evaluated prior to and during the consultation 

process and the above course of action was determined to be reasonable. Assumptions 

 12 In addition, the State of Vermont identified at least one source in the State of Wisconsin as a significant 

contributor to visibility impairment at the Lye Brook Wilderness Class I Area.
89

about the implementation of these measures are represented by the inventory and 

modeling assumptions described below in sections 10.4.2 through 10.4.4.

As stated above, this long-term strategy to reduce and prevent regional haze will allow 

each state up to 10 years to pursue adoption and implementation of reasonable and costeffective NOx and SO2 control measures, as appropriate and necessary. The Department

will pursue these measures, as appropriate and necessary, and in five years at the time of 

Pennsylvania’s first periodic SIP report expects to report on progress toward adoption of 

these measures by 2018.

In addition to the above controls in the United States, the MANE-VU Class I states 

determined that it was reasonable to include anticipated emissions reductions in Canada 

in the modeling used to set reasonable progress goals. Six coal-burning EGUs in Canada 

totaling 6500 megawatts (MW) are scheduled to be shut down and replaced with nine 

natural gas turbine units with SCR before 2018. 

Preliminary modeling was conducted to estimate the impact of various elements of the 

MANE-VU ‘Ask’ Statement. This modeling is described in NESCAUM’s report 

entitled, MANE-VU Modeling for Reasonable Progress Goals (February 2008, Appendix 

S). NESCAUM also conducted additional revised modeling to assess combined impacts. 

This modeling is described in NESCAUM’s report entitled 2018 Visibility Projections 

(March 2008, Appendix L). The information in the following sections (10.4.2 through 

10.4.4) is taken from those reports and describes the effects of the specific strategies. 

These sections (10.4.2 through 10.4.4) explain the assumptions used to model the impact 

of potential control strategies, and describe the combined potential visibility benefits of 

all the strategies based on CMAQ modeling. As with all modeling, emissions estimates 

and modeling results for 2018 entail uncertainty, and further evaluation may be 

conducted as part of the SIP report required in five years under 40 CFR § 51.308(g). 

NESCAUM evaluated the visibility benefits of the potential control strategies described 

above that go beyond the “on the books/on the way” (OTB/OTW) controls that are 

already required by actions to implement other requirements of the CAA. 

10.4.2. The Best Available Retrofit Technology Modeling Strategy

BART controls are among the reasonable strategies included in this SIP revision. The 

BART control determinations for sources in Pennsylvania are identified in Section 8 of 

this SIP revision. 

EPA determined that CAIR fulfills the BART requirement for EGUs for SO2 and NOx

for EGUs in states participating in the CAIR program. In 2009, EPA did not rescind that 

decision as a result of the court remand of CAIR to EPA for revisions, in State of North 

Carolina v. Environmental Protection Agency, 531 F.3d 896 (D.C. Cir. 2008). CAIR 

remains in effect pending the promulgation of a rule to replace the CAIR. To assess the 

impacts of MANE-VU states’ implementation of the BART provisions of the Regional 

Haze Rule for other facilities, NESCAUM included estimated reductions anticipated for 

BART-eligible facilities in the MANE-VU region in the final 2018 CMAQ modeling 
90

analysis. Table 10.4.2 lists affected facilities and emissions assumptions used in the 

modeling.

Additional visibility benefits are likely to result from installation of controls at other nonCAIR BART-eligible facilities located in adjacent RPOs. These benefits were not 

accounted for in the MANE-VU modeling, since information about final BART 

determinations was not available. None of the eight facilities listed in Table 10.4.2 are 

located in Pennsylvania.

Table 10.4.2 Estimated Emissions from Non-EGU BART-Eligible Facilities Located 

in MANE-VU Used in Final Modeling

Facility Name Unit 

Name

SCC 

Code

Plant ID 

(from the 

MANE-VU 

Inventory)

Point ID 

(from the 

MANEVU 

Inventory)

Facility 

Type

Fuel 2002 

Emissions 

(tons)

2018 

Emissions 

(tons)

MD

EASTALCO 

ALUMINUM 28 30300101 021-0005 28

Metal 

Production 1506 1356

MD

EASTALCO 

ALUMINUM 29 30300101 021-0005 29

Metal 

Production 1506 1356

MD

LEHIGH 

PORTLAND 

CEMENT 39 30500606 013-0012 39

Portland 

Cement 9 8

MD

LEHIGH 

PORTLAND 

CEMENT 16 30500915 021-0003 16

Portland 

Cement 1321 1,189

MD

LEHIGH 

PORTLAND 

CEMENT 17 30500915 021-0003 17

Portland 

Cement 976 878

MD

WESTVACO 

FINE PAPERS 2 10200212 001-0011 2

Paper and 

Pulp 8923 1338

ME Wyman Station

Boiler 

3 10100401 2300500135 004 EGU Oil 616 308

ME SAPPI Somerset

Power 

Boiler 

#1 10200799 2302500027 001

Paper and 

Pulp

Oil/Wood 

Bark/Process 

Gas 2884 1442

ME IP Jay

Power 

Boiler 

#2 10200401 2300700021 002

Paper and 

Pulp Oil 3086 1543

ME IP Jay

Power 

Boiler 

#1 10200401 2300700021 001

Paper and 

Pulp Oil 2964 1482

NY

KODAK PARK 

DIVISION U00015 10200203 8261400205 U00015

Chemical 

Manufacturer 23798 14216

NY

LAFARGE 

BUILDING 

MATERIALS 

INC 41000 30500706 4012400001 041000

Portland 

Cement 14800 4440
91

10.4.3. The Low-Sulfur Fuel Oil Modeling Strategy

The MANE-VU states agreed through consultations to pursue a low sulfur fuel strategy 

within the region, as appropriate and necessary. Although this phased strategy would be 

implemented in two steps, both components of the strategy would be fully implemented 

by 2018. NESCAUM initially analyzed both steps of the program as separate strategies, 

but it is the combined benefit of implementing the program that is relevant to the question 

of program benefits in 2018.

To estimate the total 2018 emissions reductions from this strategy, 2018 OTB/OTW SO2 

emissions were reduced from all MANE-VU non-EGU sources burning #1, #2, #4, #5, or 

#6 oil. Emissions reductions reflected lowering the sulfur content in fuel from its original 

level to 0.015 percent for #1 and #2 oil; to 0.25 percent for #4 oil; and to 0.5 percent for 

#5 and #6 oil. 

The first phase of the MANE-VU low sulfur fuel strategy calls for the lowering of fuelsulfur content in distillate (No. 2 oil) from current levels that range between 2,000 and 

2,300 ppm down to 500 ppm by weight. It also calls for restricting the sale of heavier 

blends of residual oil (No. 4 fuel oil and No. 6 bunker fuels) that have sulfur content 

greater than 0.25 percent sulfur and 0.5 percent sulfur by weight, respectively. The 

second phase of the strategy calls for further reducing the fuel-sulfur content of the 

distillate fraction to 15 ppm sulfur by weight.

The two phases of the MANE-VU low sulfur fuel strategy are designed to be 

implemented in sequence with slightly different timing for inner zone states (New Jersey, 

New York, Delaware and Pennsylvania, or portions thereof) and the outer zone states (the 

remainder of the MANE-VU region). All states, however, have agreed to pursue 

reductions that would take place no later than 2018. 

Based on the fuel sulfur limits within the first phase of the strategy, MANE-VU 

estimated a decrease of 140,000 tons of SO2 emitted from distillate combustion and a 

decrease of 40,000 tons of SO2 from residual combustion in MANE-VU. 

The second phase of the MANE-VU low sulfur fuel strategy calls for reducing the sulfur

content of distillate from 500 ppm to 15 ppm while keeping the sulfur limits on residual 

oils to 0.25 percent and 0.5 percent for No. 4 and No. 6 oils, respectively. By states 

lowering the distillate fuel sulfur limit from 500 ppm to 15 ppm, MANE-VU estimated

an additional reduction of 27,000 tons of SO2 emissions in MANE-VU from distillate 

combustion in 2018.

Figure 10.4.3 shows the full benefit of the MANE-VU fuel strategies being considered 

relative to the OTB/OTW baseline. NESCAUM used the concentration changes 

illustrated in Figure 10.4.3 to estimate the visibility benefits for this strategy. Because 

the fuel sulfur program only affects sources within MANE-VU, that region sees the 

largest PM2.5 reduction and the greatest visibility benefits.
92

Figure 10.4.3 Average Change in 24-hr PM2.5 Due to Low Sulfur Fuel

Strategies Relative to OTB/OTW (μg/m3

)

The assumption underlying the MANE-VU low-sulfur fuel oil strategy is that refiners 

can, by 2018, produce home heating and fuel oils that contain 50 percent less sulfur for 

the heavier grades (#4 and #6 residual), and a minimum of 75 percent and maximum of 

99.25 percent less sulfur in #2 fuel oil (also known as home heating oil, distillate, or 

diesel fuel), at an acceptably small increase in price to the end user. As much as 75 

percent of the total sulfur reductions that may be achieved by this strategy come from 

using the low-sulfur #2 distillate for space heating in the residential and commercial 

sectors. While costs for these emissions reductions are somewhat uncertain, they appear 

reasonable in comparison to costs of controlling other sectors, as documented in the 

MANE-VU Reasonable Progress Report, estimated at $550 to $750 per ton.

The MANE-VU states agreed to pursue the adoption and implementation of a low-sulfur 

oil strategy, as appropriate and necessary. The Department will pursue this measure, as 

appropriate and necessary, and in five years at the time of Pennsylvania’s first periodic 

SIP report expects to report on progress toward adoption for the Commonwealth or 

portions thereof by 2018. As is described in the MANE-VU ‘Ask’ Statement, June 20, 
93

2007, if the inner zone strategy cannot be implemented statewide, the Department will 

pursue the outer zone strategy by 2018. The inner zone strategy states: “A low sulfur fuel 

oil strategy in the inner zone states (New Jersey, New York, Delaware, and Pennsylvania, 

or portions thereof) to reduce the sulfur content of: 

o Distillate oil to 0.05 percent sulfur by weight (500 ppm) by no later than 

2012,

o #4 residual oil to 0.25 percent sulfur by weight by no later than 2012,

o #6 residual oil to 0.3 – 0.5 percent sulfur by weight by no later than 2012, 

and

o Further reduce the sulfur content of distillate oil to 15 ppm by 2016.”

Should any portion of Pennsylvania fall into the outer zone, the Department will pursue, 

as appropriate and necessary, the outer zone strategy for those portions. The outer zone 

strategy states: “A low sulfur fuel oil strategy in the outer zone states (the remainder of 

the MANE-VU region) to reduce the sulfur content of: 

o Distillate oil to 0.05 percent sulfur by weight (500 ppm) by no later than 

2014,

o #4 residual oil to 0.25 percent-0.50 percent sulfur by weight by no later 

than 2018, and

o #6 residual oil to no greater than 0.5 percent sulfur by weight by no later 

than 2018, and to further reduce the sulfur content of distillate oil to 15 

ppm by 2018 depending on supply and availability.”

MANE-VU adopted the two-zone low sulfur fuel oil strategy because of concerns about 

supply, and anticipated that New Jersey, New York and Pennsylvania would evaluate 

supply concerns in the adoption of compliance dates. Pennsylvania intends to pursue, as 

appropriate and necessary, a single strategy for the state. Based on supply concerns, 

Pennsylvania will pursue a strategy that will not be less stringent than the outer zone 

strategy and would meet the sulfur content emission limits listed above by 2018.

10.4.4. The EGU Modeling Strategy

SO2 emissions from power plants are the single largest sector contributing to the 

visibility impairment experienced in the Northeast’s Class I areas. The SO2 emissions 

from power plants continue to dominate the inventory. Sulfate formed through 

atmospheric processes from SO2 emissions are responsible for over half the mass and 

approximately 70-80 percent of the extinction on the worst visibility days (NESCAUM’s 

Contribution Assessment, Appendix B). 

In order to ensure that EGU controls are targeted at those EGUs with the greatest impact 

on visibility in MANE-VU, a modeling analysis was conducted to determine which 

sources those were. A list of 167 EGU stacks was developed that includes the 100 largest 

impacts at each MANE-VU Class I site during 2002. MANE-VU requested 90 percent 

control on all units emitting from those stacks by 2018 as part of consultations within 

MANE-VU and with other RPOs.
94

Preliminary modeling showed that requiring SO2 emissions from these 167 EGU stacks 

to be reduced by 90 percent could reduce 24-hour PM2.5 concentrations. NESCAUM 

modeled 2018 emissions for the 167 EGU stacks in the Northeast, Southeast, and 

Midwest at levels equal to 10 percent of their 2002 emissions. NESCAUM used CMAQ 

to model the sulfate concentrations in 2018, after implementation of this EGU control 

strategy, and converted sulfate concentrations to PM2.5 concentrations. Figure 10.4.4

displays the average change in 24-hr PM2.5.

Figure 10.4.4 Preliminary Modeled Estimate of Average Change in 24-hr PM2.5 Due 

to 90% Reduction in SO2 Emissions from 167 EGU Stacks Affecting MANE-VU

Figure 10.4.4 shows that significant reductions of PM2.5 were predicted for the MANEVU region as well as for portions of the VISTAS and Midwest RPO regions as a result of 

reducing SO2 emissions by 90 percent from 167 EGU stacks affecting MANE-VU. 

While the anticipated SO2 emissions reductions are significant, based on consultations 

with affected states, MANE-VU determined that it may be unrealistic to expect the full 

90 percent emissions reductions would be achieved by 2018. Therefore, further modeling 

was conducted to assess a more realistic scenario. The final EGU modeling inventory is 

described fully in the report entitled, Documentation of 2018 Emissions from Electric 

Generating Units (Alpine, 2008, Appendix W).

MANE-VU’s most recent modeling is documented in the report 2018 Visibility 

Projections (NESCAUM 2008, Appendix L). This modeling estimated composite 

visibility benefits of all strategies within and outside MANE-VU rather than the benefits 
95

of individual strategies. These modeling results and the estimated composite visibility 

benefits projected by 2018 are described in Section 10.6.

MANE-VU identified emissions from 167 stacks at EGU facilities as having visibility 

impacts in MANE-VU Class I areas that make controlling emissions from those stacks 

crucial to improving visibility at MANE-VU Class I areas. MANE-VU’s agreed regional 

approach for this source sector is to pursue a 90 percent control level on SO2 emissions 

from these 167 stacks by 2018 as appropriate and necessary. MANE-VU has concluded 

that pursuing this level of sulfur reduction is both reasonable and cost-effective. Table 

10.4.4-1 below lists the EGU stacks in Pennsylvania identified on the list of 167 stacks in 

all of MANE-VU, (including for reference purposes and where applicable, the BART 

facility identification number associated with the stack modeled in the MANE-VU Class 

I area deciview impact spreadsheets contained in Appendix I) with their current and 

anticipated controls, the permit status of the SO2 controls, and the anticipated SO2 

emissions reductions achieved by 2018: 

Table 10.4.4-1 EGU Stacks in Pennsylvania and Controls Identified from the 

MANE-VU 167 Stack List

Facility 

Name & 

Stack ID in 

Appendix I

Facility 

ID 

ORISPL

Unit 

ID

Unit 

Type

PF ID Facility 

ID 

Identified 

Stacks

Current 

Controls

Anticipated 

Controls &

Permit

Status

Anticipated 

Reduction 

in SO2 

Emissions

Armstrong 3178 2 Coal 

Steam

251515 43086 D031782 LNB, / CS 

ESP 90% *

Brunner 

Island

PA_26

3140 2 Coal 

Steam

473196 45820 D03140C12 LNB, SOFA 

/ CS ESP

Wet Scrubber 

in 2009

Plan Approval 

No. 67-

05005D

95%

Brunner 

Island

3140 3 Coal 

Steam

473196 45821 D031403 LNB, SOFA 

/ CS ESP

Wet Scrubber 

in 2009

Plan Approval 

No. 67-

05005D

95%

Cheswick

AC_04

8226 1 Coal 

Steam

D082261 SCR / CS 

ESP

Wet Scrubber 

in 2010

95%

Hatfields 

Ferry

PA_35

3179 2 Coal 

Steam

280920 43072 D03179C01 LNCB, Gas 

Reburn, 

SNCR in 

2006 / CS 

ESP

Wet Scrubber 

in 2009

Plan Approval 

No. 30-

00099F

95%

Homer City

PA_37

3122 1 Coal 

Steam

262713 49780 D031221 SCR / CS 

ESP

95% **

Homer City

PA_37

3122 2 Coal 

Steam

262713 49781 D031222 SCR / CS 

ESP

95%**

Keystone

PA_39

3136 1 Coal 

Steam

275229 49769 D031361 SCR / CS 

ESP

Wet Scrubber 

in 2009

Plan Approval 

No. 03-

00027B

95%

Keystone

PA_39

3136 2 Coal 

Steam

275229 49770 D031362 SCR / CS 

ESP

Wet Scrubber 

in 2010

Plan Approval 

No. 03-

00027B

95%
96

Martins Creek

PA_08

3148 2 Coal 

Steam

252187 45859 D03148C12 Permanent 

Shutdown 

9/07

N/A

Montour

PA_07

3149 1 Coal 

Steam

254018 45872 D031491 SCR / CS 

ESP

Wet Scrubber 

in operation.

Plan Approval 

No.:47-

00001B

95%

Montour

PA_07

3149 2 Coal 

Steam

254018 45873 D031492 SCR / CS 

ESP

Wet Scrubber 

in operation.

Plan Approval 

No.:47-

00001B

95%

Portland

PA_09

3113 1 Coal 

Steam

549766 45735 D031131 LNB-SOFA

Portland 3113 2 Coal 

Steam

549766 45736 D031132 LNB-SOFA

Shawville 3131 1 Coal 

Steam

249235 49763 D03131CS1 SNCR / CS 

ESP

* The Department is currently in litigation with Allegheny Energy, owner of Armstrong, to require SO2

controls as part of NSR and PSD alleged violations by the Department.

** In June 2008, May and November 2010, EPA issued notices of violation to EME Homer City 

Generating Facility to require SO2 controls as part of NSR alleged violations under the Clean Air Act. In 

addition, the Department, together with New York State in July 2010, filed a 60-day notice of intent to sue 

related to these violations.

In addition to these measures (BART controls within MANE-VU, low sulfur fuel within 

MANE-VU, and controls on specific EGUs), MANE-VU asked neighboring RPOs to 

consider further non-EGU emissions reductions comparable to those achieved through 

MANE-VU’s low sulfur fuel strategies, which are expected to achieve a greater than 28 

percent reduction in non-EGU SO2

In order to model the impact of this strategy on visibility at MANE-VU Class I areas, the 

following reductions were made to emissions in the VISTAS and MRPO regions:

emissions in 2018. After consultation with other 

states and consideration of comments received, the MANE-VU Class I States decided 

that MANE-VU’s most recent modeling would include implementation of these 

additional emissions reductions.

For both Southeast and Midwest States:

Coal-Fired ICI Boilers: emissions were reduced by 60 percent.

Oil-Fired ICI boilers: emissions were reduced by 75 percent.

ICI Boilers lacking fuel specification: emissions were reduced by 50

percent.

Additional controls in the Southeastern States:

Emissions from Other Area Oil-Combustion sources were reduced by 75

percent. (Used the same SCCs identified in MANE-VU Oil strategies 

list.)

As requested by the MANE-VU Class I States for the most recent modeling, NESCAUM

also removed SO2 emissions from 6500 MW of six coal-burning EGUs in Canada that are 
97

scheduled to be shut down.

13 It is expected that these units will be replaced with nine 

natural gas turbine units with SCR controls. NESCAUM based estimated emission rates 

for modeled pollutants on a combination of factors, including recommendations from the 

State of New Hampshire, a New York State Energy Research and Development 

Authority (NYSERDA) study, and AP-42 (Air Pollution emission factors compilation) 

ratios among pollutants. Emissions were reduced by more than 144,000 tons per year as 

a result of this measure.

The Department intends to re-evaluate the projections of SO2 reductions due to CAIR at 

the time of Pennsylvania’s first periodic report to determine whether the predicted 

reductions are realized. The Department’s CAIR was approved by the EPA as a SIP 

revision effective December 10, 2009 (74 FR 65446). The EGUs in the Commonwealth 

are now required to reduce NOx and SO2 emissions under Pennsylvania’s CAIR 

Program. As a result of the Court’s remand of the federal CAIR to EPA for revision, it is 

reasonable to expect that a revised CAIR will be in place to evaluate the 

Commonwealth’s SO2 emissions controls on Pennsylvania’s EGUs by the time the first 

progress report is due. Based on the controls proposed, constructed and under 

construction in Pennsylvania, the Department has concluded that at this time, the 

Department’s CAIR regulation constitutes a reasonable measure for EGUs in 

Pennsylvania. Therefore, consistent with the MANE-VU ‘Ask’ Statement, the 

Department projects a 94.5% reduction in SO2 emissions from the EGUs listed above in 

Table 10.4.4-1 (or from alternative measures, as appropriate and necessary). Because of 

the SO2 controls installed in 2009 and 2010 (as shown in Table 10.4.4-1), no additional 

measures will be needed to meet the reasonable progress goals. Additionally, several 

EGU stacks in Pennsylvania not identified on the 167 stack list that are expected to be 

controlled as a result of the Department’s CAIR regulation are listed in the following

Table 10.4.4-2:

Table 10.4.4-2 Additional EGU Stacks and Controls in Pennsylvania

Facility 

Name

Facility 

ID 

ORISPL

Unit 

ID

Unit 

Type

PF ID Facility 

ID 

Identified 

Stacks

Current 

Controls

Anticipated 

Controls &

Permit

Status

Anticipated 

Reduction 

in SO2 

Emissions

WPS Res.

Sunbury

Six Boilers 

(Units 1-4)

3152 1-4 Coal 

Steam

4612 D03152CS2

D03152CS3

D03152CS4

LNB, 

Baghouse, 

Multiclone,

ESPs.

Wet Scrubber 

in 2010 with a 

new stack that 

will exhaust all 

six boilers.

Plan Approval 

No. 55-

00001C

95%

 13 NESCAUM’s 2018 Visibility Projections report cited a November 2006 paper by the Ontario Power 

Authority, “Ontario’s Integrated power System Plan Discussion Paper 7: Integrating the Elements—A 

Preliminary Plan.” See 

http://www.powerauthority.on.ca/ipsp/Storage/32/2734_DP7_IntegratingTheElements.pdf
98

Reliant 

Shawville

Units 3 & 4

3131 3

4

Coal 

Steam

249235 49765

49766

D03131CS2 SNCR / CS 

ESP

FGD - Dry 

Scrubber 

(spray dryer 

absorber) in 

2010.

Plan Approval 

No. 17-

00001D

95%

The EGU SO2 emission reductions that the Department agreed to pursue are consistent 

with the assumptions used in the MANE-VU final modeling used to establish reasonable 

progress goals for MANE-VU Class I areas. Table 10.4.4-3 below shows the reductions 

in SO2 emissions anticipated from 2002 to 2018 for all Pennsylvania source sectors:

Table 10.4.4-3 Pennsylvania’s SO2 Baseline Emissions for 2002 and Projected 

Emissions for 2018 (tons per year)

0

200,000

400,000

600,000

800,000

1,000,000

1,200,000

Baseline 2002 2018 (w ith additional

measures for RPG)

Area

Non-EGU Point

EGU Point

Onroad Mobile

Non-Road Mobile

10.4.5. The VISTAS Modeling Approach

In addressing emissions from EGUs, the Department has also considered impacts on 

Class I areas outside MANE-VU where visibility may be affected by emissions from 

within Pennsylvania.

As described more fully in Section 9.1.2 of this SIP revision, to establish reasonable 

progress targets for their Class I areas, West Virginia and Virginia used modeling that 

assumed implementation of CAIR for EGUs in the eastern United States, including the 

EGUs in Pennsylvania. Therefore, EGU controls in Pennsylvania that are consistent with 

CAIR are also consistent with the reasonable progress goals established for Dolly Sods 

Wilderness Area by West Virginia in their Regional Haze SIP revision, and for the 

reasonable progress goals established by Virginia in their Regional Haze SIP revision for
99

the Shenandoah National Park. (See Appendix K for the Power Point presentation given 

to the MANE-VU member states on March 18, 2008, by VISTAS on VISTAS 2018 

Regional Haze Best and Final Modeling Projections.)

Modeling conducted for VISTAS and used by West Virginia and Virginia to set their 

reasonable progress goals for the Dolly Sods Wilderness Area and the Shenandoah

National Park, respectively, projected different 2018 visibility than was predicted by the 

most recent MANE-VU modeling at those two Class I areas. MANE-VU predicted less 

visibility improvement by 2018 than VISTAS predicted at both Dolly Sods and 

Shenandoah, but only at Dolly Sods did the MANE-VU modeling project that the 

uniform rate of progress in 2018 would not be met. This is primarily because the two 

regions used different assumptions about the efficacy of CAIR in reducing emissions 

from EGUs. MANE-VU’s emissions assumptions regarding anticipated CAIR reductions 

from the EGUs are more conservative than are VISTAS’, because the MANE-VU

emissions were not reduced as much as the VISTAS’s emissions were. MANE-VU 

decided to keep the CAIR cap whole and added EGU SO2 emissions to the inventory to 

estimate the impact of banking and trading under CAIR. In the most recent modeling, 

NESCAUM increased the inventory emissions from MANE-VU states, and from the 

MRPO and VISTAS states subject to the CAIR cap and trade program. 

The most recent modeling completed by VISTAS for the Class I areas in VISTAS 

showed the uniform rate of progress in 2018 would be met at both Shenandoah and Dolly 

Sods. VISTAS did not add back SO2 emissions to their 2018 projected inventory, and

have stated that they believe their inventory represents the best estimate of 2018 SO2 

emissions from OTB/OTW controls in that region. (See Appendix CC, VISTAS Letter 

of Comments on the MANE-VU Best and Final Modeling.)

In summary, the VISTAS modeling results indicate that the projected level of emissions 

controls for Pennsylvania’s sources by 2018 will allow the Dolly Sods Class I area to 

meet the reasonable progress goals established by West Virginia by 2018. The emissions 

control strategy for the MANE-VU Class I areas’ reasonable progress analysis is 

therefore a reasonable emissions control strategy for the reasonable progress analysis for 

the Dolly Sods Class I area. Pennsylvania is achieving a reasonable level of control by 

pursuing, as appropriate and necessary, the four goals of the MANE-VU ‘Ask’ Statement 

in order to meet the reasonable progress goals established for the Dolly Sods Class I area. 

The Commonwealth adopted a CAIR regulation on April 12, 2008, which was approved 

by the EPA as a SIP revision effective December 10, 2009 (74 FR 65446). The EGUs in 

the Commonwealth are now required to reduce NOx and SO2 emissions under 

Pennsylvania’s CAIR Program. As a result of the Court’s remand of the federal CAIR to 

EPA, it is reasonable to expect that a revised federal CAIR will be in place to evaluate the 

Commonwealth’s SO2 emissions controls on Pennsylvania’s EGUs by the time the first 

regional haze progress report is due. 
100

10.5. Consideration of Factors Required by the Regional Haze Rule

Section 51.308(d)(3)(v) of EPA’s RHR requires the Department to consider several 

factors in developing its long-term strategy. These are discussed below.

10.5.1. Emission Reductions Due to Ongoing Air Pollution Programs

Section 51.308(d)(3)(v)(A) requires that emission reductions from ongoing pollution 

control programs be considered. The Department, and MANE-VU, considered emission 

control programs being implemented between the baseline period and 2018, as discussed 

below. Significant emissions control programs are being implemented between the 

baseline period and 2018. These programs are described in more detail below.

MANE-VU’s 2018 “beyond on the way” (BOTW) emissions inventory accounts for 

emission controls already in place as well as emission controls that are not yet finalized 

but are likely to achieve additional reductions by 2018. The BOTW inventory was 

developed based on the MANE-VU 2002 Version 3.0 inventory and the MANE-VU 2018 

OTB/OTW inventory. Inventories used for other RPOs also reflect anticipated emissions 

controls that will be in place by 2018. The inventory is termed “beyond on the way” 

because it includes control measures that were developed for ozone SIPs which were not 

yet on the books in some states. For some states, BOTW also included controls that were 

under consideration for regional haze SIPs that have not yet been adopted. More 

information may be found in the following documents:

• Development of Emissions Projections for 2009, 2012, and 2018 for NonEGU Point, Area, and Non-road Sources in the MANE-VU Region

(MACTEC, February 2007)(Appendix V).

• Documentation of 2018 Emissions from Electric Generationg Units in the 

Eastern U.S. for MANE-VU’s Regional Haze Modeling (Alpine Geophysics, 

March 2008)(Appendix W).

• MANE-VU Modeling for Reasonable Progress Goals: Model Performance 

Evaluation, Pollution Apportionment, and Control Measure Benefits, 

(NESCAUM, February 2008)(Appendix S).

• 2018 Visibility Projections, NESCAUM (March 2008)(Appendix L).

For other regions, MANE-VU used inventories developed by the RPOs for those regions, 

including VISTAS Base G2, MRPO’s Base K, and CenRAP’s emissions inventory. 

(Emissions for CenRAP states in the MANE-VU modeling domain were taken from the 

VISTAS Base G2 inventory.)

The following suite of measures is part of the Department’s strategy for reducing 

emissions as part of its long-term strategy to reduce emissions: 
101

10.5.1.1. Stationary Point Sources

Clean Air Interstate Rule (CAIR). This major federal CAIR (70 FR 25162, May 12, 

2005), as amended, and the CAIR FIPs (71 FR 25328, April 28, 2006) provided a 

transition from the NOx SIP Call EGU regulations in 2009 and were designed to continue 

to ensure that large EGUs within and upwind of the area would maintain background 

emissions at or below 2002 levels, while any new large EGUs locating within the area 

would be required to obtain both offsets and allowances. Pennsylvania and other nearby 

states were required to adopt a regulation implementing the requirements of the CAIR or 

an equivalent program. On April 28, 2006, EPA promulgated FIPs to reduce the 

interstate transport of NOx and SO2 that contribute significantly to nonattainment and

maintenance of the 8-hour ozone and PM2.5 NAAQS. This major federal rule imposed 

permanent emissions caps on NOx and SO2 in the eastern United States by 2015. When 

fully effective, CAIR would have reduced SO2 emissions in the CAIR region by up to 70 

percent. However, the federal CAIR was vacated by the United States Court of Appeals

for the District of Columbia Circuit on July 11, 2008, in State of North Carolina v. 

Environmental Protection Agency, 531 F.3d 896 (D.C. Cir. 2008), and subsequently 

remanded to EPA on December 23, 2008. The final replacement rule for CAIR, expected 

in 2011, must be consistent with the Court’s July 11, 2008, decision. In the meantime, as 

a result of the remand and EPA approval of Pennsylvania’s CAIR as a SIP revision 

effective December 10, 2009 (74 FR 65446), Pennsylvania’s CAIR is being implemented 

in this Commonwealth. The IPM® model was used to predict future emissions from 

EGUs after implementation of CAIR.14 Modifications to the output of IPM® made to 

better represent anticipated controls are described in the report Documentation of 2018 

Emissions from Electric Generating Units (Alpine Geophysics, 2008) (Appendix W).

Pennsylvania CAIR Program. The Department’s CAIR SIP revision was approved by 

the EPA on December 10, 2009 (74 FR 65446). The EGU owners and operators in the 

Commonwealth are now required to reduce emissions according to the Department’s 

CAIR regulation. The annual SO2 budget for EGUs is 275,990 tons per year for the 

years 2010-2015.

Interstate Pollution Transport Reduction. In response to the Federal NOx SIP call 

rule, Pennsylvania and other covered states adopted NOx control regulations for large 

industrial boilers and internal combustion engines, EGUs, and cement plants. The 

regulation covering industrial boilers and electric generators required emission reductions 

to commence May 1, 2003, while the regulation covering large internal combustion 

engines and cement plants required emission reductions to commence May 1, 2005. EPA 

 14 Although the IPM® model runs also anticipated the implementation of EPA’s Clean Air Mercury Rule 

(CAMR), that rule has since been vacated by the courts. However, it is anticipated the adjustments to the 

predicted SO2 emissions from electric generating units (EGUs) used in the air quality modeling, which 

were based on state-specific comments on the amount of SO2 controls that will actually be installed due to 

state specific regulations and the EPA’s CAIR rule, will have more of an impact on the air quality modeling 

analysis conducted for this SIP than the vacature of the CAMR rule. MANE-VU believes the adjustments 

based on state-specific comments improved the reliability of the inventory and made the modeling results 

more dependable.
102

approved this regulation, found in 25 Pa. Code Chapter 145, on September 29, 2006 (71 

FR 57428). 

Small Sources of NOx, Cement Kilns, and Large Stationary Internal Combustion 

Engines. The Department established additional ozone season requirements for small 

sources of NOx in the counties of Bucks, Chester, Delaware, Montgomery, and 

Philadelphia in regulations that were adopted December 11, 2004. The rules (25 Pa. 

Code Chapter 129) apply to owners and operators of certain boilers, turbines, and 

stationary internal combustion units located in Bucks, Chester, Delaware, Montgomery, 

and Philadelphia Counties. The emission limits are differentiated by fuel type and allow 

alternative compliance mechanisms. By November 1st of each year, owners and 

operators of these sources must surrender NOx allowances if actual emissions exceed 

allowable emissions. The amendments required the NOx emission limits to be 

implemented by May 1, 2005. EPA approved this program on September 29, 2006 (71 

FR 57428). 

Refinery Consent Decrees. EPA’s national petroleum refinery initiative has produced 

19 multi-facility settlements with United States petroleum refining companies. These 

settlements require significant reductions of NOx, SO2, VOC, PM, and toxics. Three 

refinery facilities in Pennsylvania have negotiated settlements: Sunoco/Marcus Hook 

Refinery, Sunoco/Philadelphia Refinery, and ConocoPhillips/Trainer Refinery. These 

three consent decree settlements are described below:

United States et al v Sunoco USA, Inc.:

On June 16, 2005, the United State Department of Justice, acting at the request 

and on behalf of the EPA, simultaneously filed a Complaint and lodged a Consent Decree 

in the United States District Court for the Eastern District of Pennsylvania against 

Sunoco, Inc. (“Sunoco”) for alleged environmental violations at Sunoco’s four petroleum 

refineries located in Marcus Hook, Pennsylvania; Philadelphia, Pennsylvania; Toledo, 

Ohio; and Tulsa, Oklahoma. The Plaintiff/Intervenors include the States of Ohio, 

Oklahoma, and the City of Philadelphia. This consent decree is found in Appendix EE of 

this SIP revision.

Sunoco/Marcus Hook and Sunoco/Philadelphia Refineries. This federallyenforceable consent decree requires Sunoco, Inc., to install certain controls that are 

estimated to yield reduction of emissions from the Marcus Hook refinery of 

approximately 1500 tons of NOx, 4000 tons of SO2, and 200 tons of PM from the 2002 

baseline inventory and a reduction of emissions from the Philadelphia Refinery of 

approximately 1200 tons of NOx and 3000 tons of SO2 from the 2002 baseline inventory.

At the Marcus Hook Refinery, the consent decree requires installation of a wet 

scrubber to reduce SO2 and PM emissions and SCR or equivalent to reduce NOx 

emissions from the Fluidized Catalytic Cracking (FCC) Unit. The consent decree also 

mandates that the FCC unit meet the New Source Performance Standard (NSPS) PM 

limit of 1 lb/1000 lb coke or lower. The consent decree mandates that Sunoco agree to do 
103

one of the following by June 30, 2013: Continue to operate its existing ESP, install a 

new ESP, or accept a PM limit of 0.5 lb/1000 lb coke or lower.

At Sunoco’s Philadelphia Refinery, the consent decree requires installation of a 

wet gas scrubber to reduce SO2 and PM emissions and SCR or equivalent to reduce NOx 

emissions from the 1232 FCC Unit. The consent decree also mandates that the 1232 FCC 

Unit wet gas scrubber meets a PM limit of 0.5 lb/1000 lb coke or lower. The consent 

decree mandates that the 1232 FCC Unit and the 868 FCC Unit with CO Boiler meet the 

NSPS requirements for SO2, PM, CO, and opacity.

In addition to addressing requirements related to the FCC unit, Sunoco was 

required to submit a NOx control plan for their combustion units. At the Marcus Hook 

Refinery, Sunoco is complying by shutting down four boilers and one process heater. At 

the Philadelphia Refinery, Sunoco will comply by installing ULNB on 4 boilers and 2 

process heaters. 

United States et al v. ConocoPhillips Company:

On January 27, 2005, the United States Department of Justice, acting at the 

request and on behalf of the EPA, simultaneously filed a Complaint and lodged a Consent 

Decree in the United States District Court for the Southern District of Texas. The States 

of Illinois, Louisiana, New Jersey and Pennsylvania, and the Northwest Clean Air 

Agency were Plaintiff/Intervenors in the matter. This consent decree is found in 

Appendix DD of this SIP revision. The consent decree requires ConocoPhillips, the 

defendant, to install certain controls that are estimated to yield reduction of emissions 

from the ConocoPhillips Trainer Refinery of approximately 1100 tons of NOx, 2100 tons 

of SO2, and 100 tons of PM from the 2002 baseline inventory. 

ConocoPhillips/Trainer Refinery. 

The consent decree requires installation of a wet scrubber (installed in 2006) to 

reduce SO2 and PM emissions and enhanced SNCR (also installed in 2006) to reduce 

NOx emissions from the FCC unit/CO Boiler. EPA proposed final NOx limits for the 

Trainer FCC unit pursuant to paragraphs 50 and 51 of the referenced consent decree on 

January 5, 2010. Subsequently, ConocoPhillips accepted EPA’s limits on August 5, 

2010. Based on ConocoPhillips’s acceptance of the NOx limits on August 5, 2010, 

ConocoPhillips will act to incorporate the limits into a federally enforceable permit 

pursuant to paragraph 257 of the referenced consent decree by November 2010. The 

final FCC NOx limits are: 121.1 ppmvd (365-day) and 155.3 ppmvd (7-day). The 

consent decree also mandates that the emissions of Particulate matter from the FCC 

unit/CO Boiler meet a limit of 0.5 lb/1000 lb coke or lower.

In addition to requirements related to the FCC unit/CO Boiler, the consent decree 

requires ConocoPhillips to submit a NOx control plan for their combustion units. 

ConocoPhillips’ NOx control plan includes shutdown of three boilers and the FCC unit 

feed heater by 2006 and installation of ULNB on certain heaters.
104

New Source Review and PSD Programs. The federal new source review (NSR) 

programs are preconstruction review and permitting programs applicable to new or 

modified major stationary sources subject to Title I, Parts C and D of the federal the 

CAA. The programs consists of the PSD program requirements, which are applicable in 

areas attaining the national ambient air quality standards (NAAQS), and the 

nonattainment NSR program requirements that apply in geographic areas which are not 

attaining and maintaining the NAAQS. 

Pennsylvania's PSD program, codified in 25 Pa.Code Chapter 127, Subchapter D, was 

approved by EPA on August 21, 1984 (49 FR 33128) and codified at codified at 40 CFR 

§ 52.2058. The federal PSD regulations codifed in 40 CFR Part 52 are incorporated by 

reference in their entirety in 25 Pa. Code § 127.83 (relating to adoption by reference). 

The PSD program requires any new source to implement Best Available Control 

Technology (BACT) and limits a new source's allowable impact on the environment. As 

part of additional impact analyses under the PSD program, pursuant to 40 CFR § 52.21 

(p), new or modified sources are required to demonstrate that their proposed emissions 

will not adversely impact any air quality related values (AQRV), including visibility, in 

Federal Class I areas.

These federally enforceable programs, incoporated in the Commonwealth’s State 

Implementation Plan, will also reduce emissions to provide continued improvements in 

visiblility in mandatory Class I Federal areas.

Additional Point Source Controls in MANE-VU Expected by 2018:

Control factors were applied to the 2018 MANE-VU inventory to represent the following 

national, regional, or state control measures:

• NOx SIP Call Phase I (NOx Budget Trading Program)

• NOx SIP Call Phase II 

• NOx RACT in 1-hour Ozone SIPs

• NOx OTC 2001 Model Rule for ICI Boilers

• 2-, 4-, 7-, and 10-year MACT Standards 

• Combustion Turbine and Rotating Internal Combustion Engine (RICE)

MACT 

• Industrial Boiler/Process Heater MACT15

• EPA’s Refinery Enforcement Initiative

In addition, states provided specific control measure information about specific sources 

or regulatory programs in their state. MANE-VU used the state-specific data to the 

extent it was available in the BOTW 2018 MANE-VU inventory.

 15 The inventory was prepared before the MACT for Industrial Boilers and Process Heaters was vacated. 

Control efficiency was assumed to be at 4 percent for SO2 and 40 percent for PM.
105

For the specific states identified, the measures included in this analysis reduced emissions 

for the following pollutants and non-EGU point source categories due to strategies 

developed for purposes of reducing ozone in the Ozone Transport Region (OTR): 

• NOx measures: 

o asphalt production plants in CT, DC, NJ, and NY; 

o cement kilns in ME, MD, NY, PA; 

o glass and fiberglass furnaces in ME, MD, NY, PA; 

• VOC measure: adhesives and sealants application (all MANE-VU states 

except NJ and VT). 

The Final Rulemaking for Cement Kilns: The Commonwealth adopted a regulation to 

lower the ozone season NOx emission limits for cement kilns based on the type of kiln. 

The regulation became effective on June 19, 2010, when it was published in the 

Pennsylvania Bulletin (40 Pa.B. 3346). The current ozone season NOx limit for cement 

kilns is one rate regardless of kiln type. The revised regulation for cement kilns further 

reduces NOx emissions in Pennsylvania by lowering the allowable emission limit. This 

regulation has a compliance date of May 1, 2011.

The Final Rulemaking for Glass Furnaces: The Commonwealth adopted a regulation

to reduce the ozone season NOx emissions from glass melting furnaces, based on the type 

of product the glass furnace makes. The regulation became effective on June 19, 2010, 

when it was published in the Pennsylvania Bulletin (40 Pa.B. 3328). The glass furnaces

regulation will further reduce NOx emissions in Pennsylvania by reducing the allowable 

emission limit from the furnaces. This regulation has a compliance date of January 1, 

2012.

Pennsylvania’s Energy Initiatives:

The Department intends to pursue a proposed rulemaking to address NOx and fine 

particulate emissions reductions during high electric demand days at electric generating 

sources.

The Commonwealth’s Alternative Energy Investment Act (73 P.S. §§ 1649.101-

1649.711) provides for a $650 million energy initiative program. 

The Alternative Energy Portfolio Standards (AEPS) Act (73 P.S. §§ 1648.1-1648.8) 

provides for the acquisition and sale of electricity generated from renewable and 

environmentally beneficial sources. Under the AEPS, by February 28, 2007 (two years 

after the effective date), at least 1.5% of the electric energy sold by an electric 

distribution company or electric generation supplier to retail customers in this 

Commonwealth was required to be generated by Tier I alternative energy sources. Three 
106

years after the effective date of the AEPS (February 28, 2008), it was required to be 

3.0%. The percentage increases by at least 0.5% each year until at least 8% of the 

electric energy sold by an electric distribution company or electric generation supplier to 

retail customers in this Commonwealth is generated by Tier I alternative energy sources 

by February 28, 2020 (15 years after the effective date of the AEPS).

Phase 1 of Act 129 of 2008 (the act of October 15, 2008 (P.L.1592, No. 129)) (Act 129) 

imposes an obligation on the Pennsylvania Public Utility Commission to adopt an energy 

efficiency and conservation (EE&C) program by January 15, 2009. Act 129 requires 

utilities to adopt and implement cost-effective plans to cut electricity use 1% by 2011 and 

3% by 2013. Utilities must also implement plans by 2013 to cut energy use 4.5% during 

peak electric demand periods when electricity prices are highest - typically the hottest 

days of summer and the coldest days of winter.

10.5.1.2. Area Source Controls in MANE-VU 

For area sources within MANE-VU, the 2018 inventory for area sources was developed 

by applying growth and control factors to the 2002 Version 3.0 inventory. Area source 

control factors were developed for the following national or regional control measures:

• OTC VOC Model Rules.

• Federal On-board Vapor Recovery.

• New Jersey Post-2002 Area Source Controls.

• Residential Woodstove NSPS.

10.5.1.3. Highway Vehicle Sources

Even with increases in VMT that occur from 2002 through 2009, highway vehicle 

emissions of both VOC and NOx will continue to decrease. As more vehicles subject to 

cleaner new car standards replace older vehicles subject to less stringent new vehicle 

standards, the fleet as a whole emits fewer emissions, compensating for the increase in 

vehicle miles traveled. These decreases can be attributed to the programs described 

below. 

Federal Motor Vehicle Control Programs (FMVCP) and Pennsylvania Clean 

Vehicles Program for passenger vehicles and light-duty trucks and cleaner gasoline

Tier 1 tailpipe standards established by the CAA amendments of 1990 include NOx and 

VOC limits for light-duty gasoline vehicles (LDGVs) and light-duty gasoline trucks 

(LDGTs). These standards began to be phased in starting in 1994. Evaporative VOC 

emissions were also reduced in gasoline-powered cars starting with model year (MY) 

1998.

In 1998, under the authority of section 177 of the CAA, the Department adopted the 

Pennsylvania Clean Vehicles Program. (28 Pa. B. 5873, Dec. 5, 1998.) The 
107

Pennsylvania Clean Vehicles Program incorporates certain California Low Emission 

Vehicle emission standards for passenger cars and light-duty trucks by reference. As 

required under Section 177 of the CAA, these provisions are identical to the low emission 

standards adopted by California, except that the regulation does not incorporate by 

reference the California zero emissions vehicle (ZEV) or emissions control warranty 

systems statement provisions.

In the same rulemaking, the Department adopted the National Low Emission Vehicle 

(NLEV) program as a compliance alternative to the Pennsylvania Clean Vehicles 

Program. The NLEV program became effective in the Ozone Transport Region in 1999. 

Pennsylvania’s New Motor Vehicle Emissions Control Program regulations (25 Pa. Code

Subchapter 126.401-126.441) allowed automobile manufacturers to comply with NLEV 

instead of the California Low Emission Vehicle (CA LEV) program through model year 

2005. These regulations affected vehicles 6,000 pounds and less and were the regulations 

in effect for new motor vehicles in the baseline year, 2002. 

In 1999, EPA promulgated regulations more stringent than NLEV (Tier 2), starting with 

MY 2004. In order to participate in NLEV, the Department had been required to adopt 

language that extended its “commitment” to NLEV until MY 2006. In practical terms, 

the NLEV program was replaced for MY 2004 and later by the more stringent Federal 

“Tier 2” vehicle emissions regulations, 65 F.R. 6698 (Feb. 10, 2000), and vehicle 

manufacturers operating under the NLEV program became subject to the Tier 2 

requirements. 

The Department amended the former New Motor Vehicle Control Program (which 

includes the Pennsylvania Clean Vehicles Program) in 2006. The Clean Vehicles 

Program continues to incorporate the California Low Emission Vehicle Program (CA 

LEV II) by reference. As amended, the program affects MY 2008 and newer passenger 

cars and light-duty trucks vehicles. 36 Pa B. 7424 (December 9, 2006). 

Emissions for milestone years were estimated based on compliance with the 

Pennsylvania Clean Vehicles Program according to the methodology described in section 

7.4.1 of the “Technical Guidance on the Use of MOBILE6.2 for Emissions Inventory 

Preparation” published by EPA’s Office of Transportation and Air Quality (OTAQ) in 

January 2002. The Department is assuming in its MOBILE modeling that the federal 

Tier 2 program applies to subject vehicles sold in Pennsylvania from MY 2004 through 

MY 2007 and the Pennsylvania Clean Vehicles Program applies to subject vehicles sold 

in model year 2008 and beyond.

Heavy-Duty Diesel Control Programs. EPA promulgated more stringent national 

regulations for heavy-duty engines and vehicles (vehicles over 14,000 pounds) starting 

with MY 2004. In addition, consent decrees with seven of the largest heavy-duty engine 

manufacturers required, among other terms, that diesel engines made by these companies 

comply with these 2004 standards two model years early, in MY 2002. The Department

includes these programs as provided in the MOBILE model. 
108

In 2002, the Department adopted the Heavy-Duty Diesel Emissions Control Program for 

model years starting after May 2004. The program incorporates California standards by 

reference and requires MY 2005 and subsequent new heavy-duty diesel highway engines 

to be those certified by California. California standards are more stringent than federal 

standards for the two model years between expiration of the consent decrees discussed 

above and the implementation of more stringent federal standards affecting MY 2007 and

beyond. However, EPA’s MOBILE model already assumes that the engines would 

comply with consent decree standards, even without an enforcement mechanism. The 

Department has used MOBILE defaults to calculate emissions from MY 2005 and 2006 

highway engines.

EPA adopted new emission standards for heavy-duty engines and vehicles for MY 2007 

and subsequent. For diesel engines, the standards will be phased in from 2007 to 2010 

for NOx and VOCs. For gasoline engines, the standards will be phased in during MY 

2008 and MY 2009. Federal and California standards are virtually identical for MY 

2007. For MY 2008, California adopted requirements for anti-idling engine 

programming which will be required in Pennsylvania by virtue of the Department’s 

incorporation by reference. However, there is no EPA-approved methodology to 

estimate emission reductions from this requirement. Therefore, the emission estimates 

use assumptions of the federal rule for these years.

Because the new engine standards are adversely affected by sulfur in fuel, EPA also 

required most highway diesel fuel to contain no more than 15 parts per million (ppm) of 

sulfur, as of the fall of 2006. There is a temporary compliance option allowing refiners to 

continue to produce up to 20 percent of their highway diesel fuel at 500 ppm fuel until 

2010. The Department uses MOBILE defaults to estimate the effects of the phase-in 

provision.

Vehicle Emission Inspection/Maintenance Programs in Pennsylvania.

Philadelphia region (Bucks, Chester, Delaware, Montgomery, Philadelphia):

In early 2004, the Department implemented its revised Vehicle Emission 

Inspection/Maintenance (I/M) Program in the Philadelphia Area. The program applies to 

gasoline-powered vehicles 9,000 pounds and under, MY 1975 and newer. For vehicles 

1996 and newer, the program consists of an annual on-board diagnostics test and a gas 

cap pressure test. For most subject vehicles MY 1995 and older, the program consists of 

a tailpipe test, visual inspection of pollution control devices to ensure they are present, 

connected and the proper type for the vehicle and a gas cap pressure test. For vehicles 

older than 25 years, the program is a visual inspection and gas cap test. These regulations 

can be found in 67 Pa. Code Chapter 177. The Department submitted the revised 

emissions program as a SIP revision on December 1, 2003. EPA approved the SIP 

revision on October 6, 2005.
109

Pittsburgh Region (Allegheny, Beaver, Washington, Westmoreland):

In early 2004, the Department implemented its revised I/M Program in the four 

applicable counties (Allegheny, Beaver, Washington and Westmoreland) in the 

Pittsburgh Area. The program applies to gasoline-powered vehicles 9,000 pounds and 

under, MY 1975 and newer. For vehicles 1996 and newer, the program consists of an 

annual on-board diagnostics test and a gas cap pressure test. For subject vehicles MY 

1995 and older, the program consists of an annual two-speed idle test, visual inspection 

of pollution control devices to ensure they are present, connected and the proper type for 

the vehicle and a gas cap pressure test. For vehicles older than 25 years, the program is a 

visual inspection and gas cap test. These regulations can be found in 67 Pa. Code Chapter 

177. The Department submitted the revised emissions program as a SIP revision on 

December 1, 2003. EPA approved the SIP revision on October 6, 2005.

South Central Region (Berks, Cumberland, Dauphin, Lancaster, Lebanon, Lehigh, 

Northampton, York):

In early 2004, the Department expanded its I/M Program into Berks County. The 

program applies to gasoline-powered vehicles 9,000 pounds and under, MY 1975 and 

newer. For vehicles 1996 and newer, the program consists of an annual on-board 

diagnostics test and a gas cap pressure test. For subject vehicles MY 1995 and older, the 

program consists of an annual visual inspection of pollution control devices to ensure 

they are present, connected and the proper type for the vehicle and a gas cap pressure test. 

These regulations can be found in 67 Pa. Code Chapter 177. The Department submitted 

the expanded emissions program as a SIP revision on December 1, 2003. EPA approved 

the SIP revision on October 6, 2005.

Northern Region (Blair, Cambria, Centre, Erie, Lackawanna, Luzerne, Lycoming, 

Mercer):

In early 2004, the Department expanded its I/M Program into these counties. The 

program applies to gasoline-powered vehicles 9,000 pounds and under, MY 1975 and 

newer. The program consists of an annual visual inspection of pollution control devices 

to ensure they are present, connected and the proper type for the vehicle and a gas cap 

pressure test. These regulations can be found in 67 Pa. Code Chapter 177. The 

Department submitted the expanded vehicle emissions inspection program as a SIP 

revision on December 1, 2003. EPA approved the SIP revision on October 6, 2005 (70 

FR 58313).

All other counties:

In December 2003, the Department amended its vehicle safety inspection program to 

include a visual inspection of certain pollution control components in the 42 counties for 

which a separate vehicle emissions inspection program is not required. These regulations 

can be found in 67 Pa. Code Chapter 175. The Department submitted that portion of the 
110

amended safety inspection program as a revision to its State Implementation Plan on 

December 1, 2003. EPA approved the SIP revision on October 6, 2005 (70 FR 58313).

Low sulfur gasoline. Simultaneously with publication of the Tier 2 program, EPA 

published a regulation requiring the reduction of sulfur in gasoline beginning in 2004, 

with full implementation in 2006. Sulfur levels are capped at 80 parts per million (ppm) 

per gallon and annual refinery averages must be no more than 30 ppm. This analysis uses 

the default assumptions provided in MOBILE6 to account for the implementation of the 

federal sulfur standard rule in an area in which reformulated gasoline is required. 

Additional programs related to motor vehicles. The Department’s Stage II 

requirements were adopted in February 1992. The Stage II requirements apply to five

counties in the Philadelphia area (Bucks, Chester, Delaware, Montgomery and 

Philadelphia counties) and seven counties in the Pittsburgh-Beaver Valley area

(Allegheny, Armstrong, Beaver, Butler, Fayette, Washington, and Westmoreland

counties). This program requires vapor recovery nozzles on gasoline pumps that ensure 

that the gasoline vapors from the filling of motor vehicle gasoline tanks are collected and 

returned to the service station’s storage tanks. Emission reductions from this strategy 

primarily come from vehicles without the federally required on-board vapor recovery 

controls phased in between 1998 and 2000 model years, although the requirement 

provides some additional reductions from the newer vehicles as well. 

Gasoline sold in the Philadelphia Area is required by the CAA to be the cleaner-burning 

reformulated gasoline meeting standards established in Section 211 of the CAA. This 

federally enforced program has been in place since January 1995. 

Gasoline sold in the seven county Pittsburgh-Beaver Valley area from May 1 through 

September 15 of each year must be no greater than 7.8 psi Reid Vapor Pressure. This 

state-enforced regulation was adopted in October 1997 and amended in October 1999.

The Diesel-Powered Motor Vehicle Idling Act, Act 124 of 2008

On October 9, 2008, Act 124 (also called the Diesel-Powered Motor Vehicle Idling Act), 

was signed into law in Pennsylvania. The act became effective February 6, 2009. The 

purpose of Act 124 is to reduce unnecessary idling of the main propulsion engine in 

diesel-powered motor vehicles. The Act applies to drivers or owners of a diesel-powered 

motor vehicle engaged in commerce with a gross weight of 10,001 pounds or more and 

an owner or operator of a location where the aforementioned subject vehicles load or 

unload, or a location that supplies 15 or more parking spaces. Act 124 requires that all 

diesel-powered motor vehicles that weigh 10,001 pounds or more, engaged in commerce, 

limit idling to no more than five minutes in any continuous 60-minute period (with some 

exceptions). Reducing main engine idling in diesel vehicles will lead to significant 

reductions in particulate pollution and other air pollutants all across Pennsylvania.
111

10.5.1.4. Nonroad Sources

EPA has adopted a series of regulations affecting new diesel-powered (“compression 

ignition”) and gasoline-powered (“spark ignition”) nonroad engines of various sizes 

(horsepower) and applications. Information on these federal rules, including their 

implementation dates, can be found at www.epa.gov/nonroad. The Department used the 

assumptions built into the nonroad model (NONROAD2005) to estimate emissions for all 

milestone years.

No new national or international regulations are expected to be applicable to aircraft by 

the ozone season of 2009. While EPA has published a notice of proposed rulemaking for 

more stringent standards for locomotives and large commercial marine diesel engines, the 

agency has not finalized any new standards.

EPA will also require diesel fuel used in most nonroad applications to contain less sulfur. 

The sulfur will prevent damage to the more advanced emission control systems needed to 

meet the engine standards; it will also reduce fine particulate emissions from diesel 

engines. In 2007, fuel sulfur levels were limited to 500 parts per million (ppm) for 

nonroad applications other than ocean-going marine vessels. In 2010, fuel sulfur levels 

will be reduced to the same sulfur concentration as in highway fuel, 15 ppm; this 

requirement applies in 2012 to locomotive and marine diesel fuel.

10.5.2. Measures to Mitigate the Impacts of Construction Activities

Section 51.308(d)(3)(v)(B) of EPA’s RHR requires the Department to consider measures 

to mitigate the impacts of construction activities. According to the EPA, construction 

activities are sources of fugitive dust and air pollutants from the use of diesel powered 

equipment. A description of MANE-VU’s consideration of measures to mitigate the 

impacts of construction can be found in the MANE-VU Construction Activities 

Technical Support Document (TSD) entitled, Technical Support Document on Measures 

to Mitigate the Visibility Impacts of Construction Activities in the MANE-VU Region, 

October 2006, Appendix T.

The MANE-VU Construction Activities TSD reports that “small dust particles, especially 

particles smaller than 10 micrograms (PM10) can persist in the atmosphere, possibly 

contributing to diminished visibility.” The Construction Activities TSD also reports 

“dust from construction activities is unlikely a large component of PM2.5 concentrations 

measured in MANE-VU Class I areas.” The Conclusion on page 13 in the Construction 

Activities TSD provided the following information:

“The following statements summarize the main points of this technical support document.

• Although a temporary source, fugitive dust and diesel emissions from 

construction activities can have an effect on local air quality. 
112

• While construction activities are responsible for a relatively large fraction of 

direct PM2.5 and PM10 emissions in the Region, the impact on visibility is less 

because dust settles out of the air relatively close to the sources. 

• Ambient air quality data shows that soil dust makes up only a minor fraction of 

the PM2.5 measured in MANE-VU Class I Areas, and impacts of diesel emissions 

in these rural areas are also a small part of total PM2.5. 

• The use of measures such as clean fuels, retrofit technology, best available 

technology, specialized permits, and truck staging areas (to limit the adverse 

impacts of idling) can help decrease the effects of diesel emissions on local air 

quality.

• MANE-VU States have rules in place to mitigate potential impacts of 

construction on visibility in Class I Areas.”

The Department’s existing regulations in 25 Pa. Code, Section 123.1 (relating to 

prohibition of certain fugitive emissions) state that persons responsible for construction

activities “shall take all reasonable actions to prevent particulate matter from becoming 

airborne.” Section 123.2 (relating to fugitive particulate matter), states that persons 

responsible for construction activities “may not permit fugitive particulate matter to be 

emitted into the outdoor atmosphere...if the emissions are visible at the point the 

emissions pass outside the person’s property.” These regulations are SIP-approved as 

follows: Section 123.1 (a) through (c) was approved by EPA on December 17, 1979 (44 

FR 73031), and Section 123.2 was approved by EPA on July 27, 1984 (49 FR 30183).

The Department does not have regulations to control emissions from diesel equipment at 

construction sites. However, permits are required for the operation of diesel and nonroad 

engines. Section 2 of both the General Plan Approval and/or General Operating Permit 

(BAQ-GPA/GP 9) and the General Plan Approval and/or General Operating Permit 

(BAQ-GPA/GP 11), states that nonroad and diesel engines must have the best available 

technology (BAT) installed and in operation so that the engine is in compliance with 

regulated emissions standards; these general permits are federally enforceable. Both 

general permits require the permittee to maintain accurate records of the amount of time 

the engine is in operation per month and the amount of fuel used. The Department’s 

BAT requirement in these general permits is authorized under the Pennsylvania Air 

Pollution Control Act, Section 6.6, 35 P.S. Section 4006.6 and under 25 Pa. Code, 

Sections 127.1 and 127.12(a)(5). The Department also requires a General Plan Approval 

and/or General Operating Permit (BAQ-GPA/GP – 5) for natural gas, coal bed methane 

or gob gas production or recovery facilities. This General Permit authorizes construction 

and/or operation of a natural gas, coal bed methane or gob gas production or recovery 

facility. This permit authorizes the construction of internal combustion engine(s); 

dehydrator(s) and associated equipment that meet the best available technology (BAT) 

required under 25 Pa. Code §§ 127.1 and 127.12(a)(5). Once authorization to use GP – 5

is granted, construction of the natural gas, coal bed methane or gob gas production or 

recovery facility designated in the application may proceed.
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10.5.3. Source Retirement and Replacement Schedules

Section 51.308(d)(3)(v)(D) of EPA’s RHR requires the Department to consider source 

retirement and replacement schedules in developing its long-term strategy. Retirement 

and replacement will be managed in conformance with existing SIP requirements 

pertaining to PSD and NSR.

A federally-enforceable settlement agreement signed October 10, 2003, and filed with the 

Commonwealth of Pennsylvania Environmental Hearing Board between New Jersey 

Department of Environmental Protection, Appellant, on the one hand, and

Commonwealth of Pennsylvania, Department of Environmental Protection, Appellee, and 

Lower Mount Bethel Energy, Permittee, on the other hand, required PPL Martins Creek 

to permanently cease operations of the boilers serving Units 1 and 2 by September 15, 

2007. In 2002, Units 1 and 2 combined emitted 17,100 tons of SO2 and 2800 tons of 

NOx.

10.5.4. Agricultural and Forestry Smoke Management

Section 51.308(d)(3)(v)(E) of EPA’s RHR requires the Department to consider smoke 

management techniques for the purposes of agricultural and forestry management in 

developing its long-term strategy.

A description of MANE-VU’s analysis of smoke management in the context of regional 

haze SIPs can be found in the MANE-VU Smoke Management TSD entitled, Technical 

Support Document on Agricultural and Forestry Smoke Management in the MANE-VU 

Region in Appendix U. The TSD comes to the following conclusion:

“Smoke Management Programs are only required when smoke impacts from fires 

managed for resource benefits contribute significantly to regional haze. The results of the 

emissions inventory indicate that emissions from agricultural, managed, and prescribed 

burning are very minor source categories. Although source apportionment results show 

that wood smoke is a moderate contributor to visibility impairment at some Class I Areas 

in the MANE-VU Region, most of the wood smoke is attributable to residential wood 

combustion. It is unlikely that fires for agricultural or forestry management cause large 

impacts on visibility in any of the Class I Areas in the MANE-VU Region. On rare 

occasions, smoke from major fires degrades the air quality and visibility in the MANEVU Area. However, these fires are generally unwanted wildfires that are not subject to 

Smoke Management Programs.”

Fires in Pennsylvania do not significantly contribute to visibility impairment in Class I 

areas. Therefore, the Department has not implemented a smoke management program.

10.5.5. Share of Emission Reductions

Section 51.308(d)(3)(ii) of the RHR requires the Department to demonstrate that its 

implementation plan includes all measures necessary to obtain Pennsylvania’s share of 

emission reductions needed to meet reasonable progress goals for the area. 
114

The visibility modeling for 2018 that is described in Section 10.3 demonstrated that the 

Department’s long-term strategy, when coordinated with other state and tribes’ strategies,

is sufficient to meet or exceed the reasonable progress goals for affected Class I Areas. 

The ‘Ask’ Statement agreed to by MANE-VU on June 20, 2007, (Appendix M), provided 

that each state will have up to 10 years to pursue adoption and implementation of 

reasonable and cost-effective NOx and SO2 control measures, as appropriate and 

necessary. The Department will pursue these measures, as appropriate and necessary, 

and in five years at the time of Pennsylvania’s first periodic SIP report expects to report 

on progress toward adoption of these measures by 2018.

Table 10.5.5-1 below shows that the average SO2 emissions totals from the 2002 baseline 

year to the 2018 projected year from all of the MANE-VU states are reduced by 73.5

percent. Table 10.5.5-2 shows that the SO2 emissions reduction from Pennsylvania’s

sources from the 2002 baseline year to the 2018 projected year is 71 percent. Table 

10.5.5-2 also shows that all source categories in Pennsylvania meet or exceed the 

projected average SO2 reduction of 73.5 percent for all of MANE-VU, with the 

exception of the stationary area source category.

Table 10.5.5-1 SO2 Emissions Inventory in MANE-VU (tons/year)

Source Category Baseline 2002

2018 (with additional 

measures for RPG) Percent Reduction

Area 286,921 129,656

Non-EGU Point 264,377 91,438

EGU Point 1,643,257 368,717

On-Road Mobile 40,090 8,757

Non-Road Mobile 57,257 8,643

TOTAL 2,291,902 607,211 73.5%

Table 10.5.5-2 SO2 Emissions Inventory from Pennsylvania Sources

(Tons Per Year)

Source Category 2002 Baseline 2018 Projected Reduction

Stationary Point Sources 995,175 266,455 73.3%

Stationary Area Sources 63,679 42,072 33.9%

Highway Mobile Sources 10,882 1,436 86.8%

Nonroad Mobile Sources 7,915 607 92.4%

TOTAL 1,077,651 310,570 71.2%

10.6. Estimated Impacts of Long Term Strategy on Visibility

In accordance with 40 CFR § 51.308(d)(3)(v)(G), the Department must address the net 

effect on visibility resulting from changes projected in point, area and mobile source 

emissions by 2018. The emissions inventory for Pennsylvania projects changes to point, 
115

area and mobile source inventories by the end of the first implementation period resulting 

from population growth; industrial, energy and natural resources development; land 

management; and air pollution control. NESCAUM has conducted modeling for MANEVU to document the impacts of the long-term strategy on visibility at affected Class I 

areas. (See 2018 Visibility Projections, NESCAUM, March 2008, Appendix L.) 

Additional detailed information is provided in the following reports:

Development of Emissions Projections for 2009, 2012, and 2018 for Non-EGU 

Point, Area, and Non-road Sources in the MANE-VU Region (MACTEC, 

February 2007) (Appendix V), and

Documentation of 2018 Emissions from Electric Generationg Units in the 

Eastern U.S. for MANE-VU’s Regional Haze Modeling (Alpine Geophysics, 

March 2008) (Appendix W).

The Class I states affected by emissions from within Pennsylvania have established or are 

expected to establish reasonable progress goals for each of their Class I areas. The 

control measures included in this SIP revision represent the reasonable efforts of 

Pennsylvania, in conjunction with the efforts of the other MANE-VU states, toward 

achieving the reasonable progress goals established by the Class I states by 2018.

The starting point for indicating progress achieved by measures included in this SIP and 

other MANE-VU-member SIPs is the 2000-2004 baseline visibility at affected Class I 

areas. To calculate the baseline visibility for affected Class I areas, using 2000-2004 

IMPROVE monitoring data, the deciview value for the 20 percent best days in each year 

were averaged together, producing a single average deciview value for the best days. 

Similarly, the deciview values for the 20 percent worst days in each year were averaged 

together, producing a single average deciview value for the worst days.

Initial modeling to assess the impact of potential control measures is documented in 

MANE-VU Modeling for Reasonable Progress Goals: Model Performance Evaluation, 

Pollution Apportionment, and Control Measure Benefits, (NESCAUM, February 2008, 

Appendix S). Results of the reasonable progress modeling showed that sulfate aerosol –

the dominant contributor to visibility impairment in the Northeast’s Class I areas on the 

20 percent worst visibility days – has significant contributions from states throughout the 

eastern United States that are projected to continue in future years from all three of the 

eastern RPOs. An assessment of potential control measures identified a number of 

promising strategies that would yield significant visibility benefits beyond the uniform 

rate of progress and, in fact, significantly beyond the projected visibility conditions that 

would result from OTB/OTW air quality protection programs. These additional measures 

include the adoption of low sulfur heating oil, implementation of BART requirements, 

and additional EGU controls on select sources. 

Final modeling was conducted after consultation with states in and outside of MANEVU. Final modeling is documented in 2018 Visibility Projections (NESCAUM, March 

2008, Appendix L). Emissions inventory adjustments were made for this modeling in 
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order to better represent the likely outcome of efforts to pursue the BART, low sulfur 

fuel, and EGU control measures included in the MANE-VU June 20, 2007, ‘Ask’

Statement and described above in Section 10.4.1.

Figure 10.6-1 through Figure 10.6-5 illustrates the predicted visibility improvement by 

2018 resulting from the implementation of the MANE-VU regional long-term strategy. 

The visibility improvements will result, in part, from the efforts identified in this SIP 

revision to reduce emissions from sources in Pennsylvania. This improvement is 

compared to the uniform rate of progress for affected Class I areas. All Class I Areas in 

MANE-VU are projected to meet or exceed the uniform rate of progress goal for 2018. 

In addition, no site anticipates increases in best day visibility relative to the baseline.

Figure 10.6-1 Projected Visibility Improvement at Acadia National Park Based on 

Final Modeling

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Figure 10.6-2 Projected Visibility Improvement at Brigantine National Wildlife 

Refuge Based on Final Modeling

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Figure 10.6-3 Projected Visibility Improvement at Lye Brook Wilderness Area 

Based on Final Modeling

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Figure 10.6-4 Projected Visibility Improvement at Great Gulf Wilderness Area 

Based on Final Modeling16

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 16 The estimate for Great Gulf Wilderness Area also serves to provide an estimate for the Presidential 

Range/Dry River Wilderness Area.
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Figure 10.6-5 Projected Visibility Improvement at Moosehorn Wilderness Area 

Based on Final Modeling 17

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 17 The estimate for Moosehorn Wilderness Area also serves to provide an estimate for 

Roosevelt/Campobello International Park.
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10.7. Emission Limitations and Compliance Schedules

Pursuant to 40 CFR § 51.308(d)(3)(v)(C), the Department is required to consider, in 

development of its long term strategy, emissions limitations and schedules for 

compliance to achieve the reasonable progress goals. Emission limitations and 

compliance schedules are in place for the Department’s control measures listed in 

subsections 10.5.1.1-10.5.1.3 of this section. For the additional reasonable control 

measures described in subsections 10.4.1-10.4.4 of this section, certain emission 

limitations and compliance schedules may need to be established in Pennsylvania’s air 

pollution control regulations. These additional measures include:

1. Low-sulfur fuel oil requirements,

2. Emission reductions from specific EGUs,

3. Additional measures determined to be reasonable after consultation with other

 MANE-VU states.

On September 25, 2010, the Pennsylvania Environmental Quality Board (EQB) proposed the 

Commonwealth’s statewide low-sulfur heating and distillate oil regulation, in response to the 

MANE-VU ‘Ask’ low-sulfur fuel oil strategy. The proposed rulemaking amends 

§ 123.22 (relating to combustion units) to lower the allowable sulfur content of commercial 

fuel oil for use in combustion units and replace the existing area-specific sulfur content limits 

for commercial fuel oils with statewide sulfur limits (40 Pa.B 5456, September 25, 2010). 

The public comment period closed on November 29, 2010. The proposed regulation would 

reduce the allowable sulfur content limits of commercial fuel oil to 15 parts per million 

(ppm) for Number (No.) 2 and lighter commercial fuel oils and to 0.25% sulfur content by 

weight for No. 4 commercial fuel oil, and 0.5% sulfur content by weight for No. 5, 6 and 

heavier commercial fuel oils beginning May 1, 2012. Certain commentators oppose the 

stringency of the proposed rulemaking and compliance dates. Consideration of the finalform regulation will proceed in accordance with applicable provisions of the Pennsylvania 

Regulatory Review Act, the APCA and procedures established by the EQB and the 

Department.

The Department will continue to evaluate additional measures to ascertain whether they 

are reasonable for Pennsylvania to implement by 2018 and will formalize that 

determination in the first regional haze SIP progress report. Pennsylvania intends to 

pursue all reasonable control measures as expeditiously as practicable, in a manner 

consistent with state law, so that they may be in place by the end of the ten-year planning 

period.

10.8. Enforceability of Emission Limitations and Control Measures

40 CFR § 51.308(d)(3)(v)(F) requires the Department to consider, in development of its 

long term strategy, the enforceability of emissions limitations and control measures. Any 

control measures incorporated into law or codified in rules will be enforceable. Any 

facility subject to state or federal permit requirements, including BART-eligible and Title 
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V facilities, will be required to comply with the specific permit conditions that reference 

the applicable provisions of those laws and rules. 

The Pennsylvania rules provide for enforceable emission control measures and 

compliance schedules to meet the applicable requirements of the CAA and rules 

promulgated by the EPA. In Pennsylvania, the authority to create rules, issue permits and 

enforce laws related to regional haze are established in the Pennsylvania Air Pollution 

Control Act (APCA) and in the provisions of the Pennsylvania Code Title 25, 

Environmental Protection, Article III, Chapters 121-145 (25 Pa. Code Chapters 121-145). 

Section 4(1) of the APCA, 35 P.S. § 4004(1), gives the Department the authority and 

duty to implement the provisions of the CAA in this Commonwealth. Section 12 of the

APCA authorizes only two local air pollution control programs in the Commonwealth, 

which are administered by the Philadelphia AMS and the ACHD. Authority for AMS is 

provided by Title 3, Air Management Code and for ACHD by Article XXI and County 

Ordinance 16782. The regulations in the Pennsylvania Code are duly adopted by the 

Environmental Quality Board. The regulations adopted by the two local air agencies, 

namely ACHD and Philadelphia AMS, are duly adopted by the county Board of Health, 

enacted by the County Council and approved by the Chief Executive and the Air 

Pollution Control Board, respectively, pursuant to section 12 of the APCA (35 P.S. § 

4012).

The Pennsylvania rules that define the permit program and the fee structure for stationary 

sources, and that are of relevance to this regional haze SIP revision are as follows:

The Commonwealth’s enforceable emission limitations and other control measures are 

covered in the APCA and applicable provisions in 25 Pa. Code Chapters 121-145 and 

Title 67, Chapters 175-177 that are incorporated in the SIP codified in 40 CFR § 

52.2020(c)(1); those provisions of ACHD Regulations, Parts A through I to Articles XX 

and XXI that are listed in 40 CFR § 52.2020(c)(2); those provisions of Philadelphia Title 

3 Air Management Code and Philadelphia AMS Regulations I, II, III, IV, V, VII, VIII, 

XI, and XIII that are listed in 40 CFR § 52.2020(c)(3); and source specific provisions 

codified at 40 CFR § 52.2020(d)(1). 

The Commonwealth has an EPA-approved air permitting program for both major and 

minor facilities, which ensures that all applicable requirements are included in the permit. 

Sections 4 and 8 of the APCA, 35 P.S. §§ 4004 and 4008, provide adequate authority for 

the Department to enforce appropriate limitations and other control measures. Section 

6.1(k) of the APCA, 35 P.S. § 4006.1(k), provides that the Department shall require 

revisions to any permit to incorporate applicable standards and regulations promulgated 

under the CAA after issuance of a Title V permit. Section 9.1 of the APCA, 35 P.S. § 

4009.1, provides that the Department may assess civil penalties for violations of the 

APCA, regulations adopted under the APCA, Department orders or terms, and conditions 

of plan approvals and operating permits. Additionally, Section 7.1 of the APCA, 35 P.S. 

§ 4007.1, authorizes the Department to withhold plan approvals, state operating permits, 

or Title V permits where an applicant or related party has shown a lack of ability or 

intention to comply with the APCA.
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Section 6.3 of the APCA (35 P.S. § 4006.3) authorizes the Department to establish fees 

sufficient to cover the indirect and direct costs of administering the plan approval and 

operating permit program including Title V and costs of administering certain 

committees. The implementing regulations in 25 Pa. Code § 127.701 impose fees to 

cover the direct and indirect costs of administering the air pollution control planning 

process, implement and operate the permit program, enforce the terms and conditions of 

any such permit, certain committee operations and to support the air pollution control 

program authorized by state statute. 

10.9. Consultation on the Long-Term Strategy

In accordance with 40 CFR § 51.308(d)(3)(i), the Department consulted with other States

and tribes by participation in the MANE-VU and inter-RPO processes that developed 

technical information necessary for development of coordinated strategies. 

On May 10, 2006, MANE-VU adopted the Inter-RPO State/Tribal and FLM Consultation 

Framework (See Appendix X). That document set forth the following principles:

1) All State, Tribal, RPO, and Federal participants are committed to continuing 

dialogue and information sharing in order to create understanding of the 

respective concerns and needs of the parties. 

2) Continuous documentation of all communications is necessary to develop a 

record for inclusion in the SIP submittal to EPA. 

3) States alone have the authority to undertake specific measures under their SIP. 

This inter-RPO framework is designed solely to facilitate needed 

communication, coordination and cooperation among jurisdictions but does 

not establish binding obligation on the part of participating agencies. 

4) There are two areas which require State-to-State and/or State-to-Tribal 

consultations (“formal” consultations): (i) development of the reasonable 

progress goal for a Class I area, and (ii) development of long-term strategies. 

While it is anticipated that the formal consultation will cover the technical 

components that make up each of these policy decision areas, there may be a 

need for the RPOs, in coordination with their State and Tribal members, to 

have informal consultations on these technical considerations. 

5) During both the formal and informal inter-RPO consultations, it is anticipated 

that the States and Tribes will work collectively to facilitate the consultation 

process through their respective RPOs, when feasible. 

6) Technical analyses will be transparent, when possible, and will reflect the 

most up-to-date information and best scientific methods for the decision 

needed within the resources available. 

7) The State with the Class I area retains the responsibility to establish 

reasonable progress goals. The RPOs will make reasonable efforts to facilitate 

the development of a consensus between the State with a Class I area and 
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other States affecting that area. In instances where the State with the Class I 

area can not agree with such other States that the goal provides for reasonable 

progress, actions taken to resolve the disagreement must be included in the 

State’s regional haze implementation plan (or plan revisions) submitted to the 

EPA Administrator as required under 40 CFR § 51.308(d)(1)(iv). 

8) All States whose emissions are reasonably anticipated to contribute to 

visibility impairment in a Class I area, must provide the Federal Land 

Manager (“FLM”) agency for that Class I area with an opportunity for 

consultation, in person, on their regional haze implementation plans. The 

States/Tribes will pursue the development of a memorandum of understanding 

to expedite the submission and consideration of the FLM’s comments on the 

reasonable progress goals and related implementation plans. As required 

under 40 CFR Section 51.308(i)(3), the plan or plan revision must include a 

description of how the State addressed any FLM comments. 

9) States/Tribes will consult with the affected FLMs to protect the air resources 

of the State/Tribe and Class I areas in accordance with the FLM coordination 

requirements specified in 40 CFR Section 51.308(i) and other consultation 

procedures developed by consensus.

10) The consultation process is designed to share information, define and 

document issues, develop a range of options, solicit feedback on options, 

develop consensus advice if possible, and facilitate informed decisions by the 

Class I States. 

11) The collaborators, including States, Tribes and affected FLMs, will promptly 

respond to other RPO’s/States’/Tribes’ requests for comments.

The document also describes a process primarily applicable to formal consultation with 

states in other RPOs concerning regional haze SIP elements. Although other RPOs did 

not formally adopt the same process, in general, the process was followed and provided 

significant opportunities for consultation with other states concerning the long term 

strategy as well as reasonable progress goals.

MANE-VU consultation meetings and conference calls included those held on the 

following dates:

• MANE-VU Intra-Regional Consultation, March 1, 2007

o At this meeting, MANE-VU members reviewed the requirements for 

regional haze plans, preliminary modeling results, the work being done to 

prepare the MANE-VU report on reasonable progress factors, and control 

strategy options under review.

• MANE-VU Intra-State Consultation, June 7, 2007

o At this meeting, the MANE-VU Class I states adopted a statement of 

principles, and all MANE-VU members discussed draft statements 

concerning reasonable controls within and outside of MANE-VU. Federal 
124

Land Managers also attended the meeting, which was open to 

stakeholders.

• MANE-VU Conference Call, June 20, 2007

o On this call, the MANE-VU states concluded discussions of statements 

concerning reasonable controls within and outside MANE-VU and agreed 

on the statements called the MANE-VU “Ask,” including a statement 

concerning controls within MANE-VU, a statement concerning controls 

outside MANE-VU, and a statement requesting a course of action by the 

U.S. EPA. Federal Land Managers also participated in the call. The 

“Ask” statement concerning controls within MANE-VU list “emission 

management” strategies, as appropriate and necessary, that the MANE-VU 

states agreed to pursue. Upon approval, all statements as well as the 

statement of principles adopted on June 7 were posted and publicly 

available on the MANE-VU web site.

• MANE-VU Class I States’ Consultation Open Technical Call, July 19, 2007

o On this call, the MANE-VU “Ask” was presented to states in other RPOs,

RPO staff, and Federal Land Managers, and an opportunity was provided 

to request further information. This call was intended to provide 

information to facilitate informed discussion at follow-up meetings.

• MANE-VU Consultation Meeting with MRPO, August 6, 2007

o This meeting was held at LADCO offices in Chicago, Illinois and was 

attended by representatives of both MANE-VU and MRPO states as well 

as staff. The meeting provided an opportunity to formally present the 

MANE-VU “Ask” to MRPO states and to consult with them regarding the 

reasonableness of the requested controls. Federal Land Manager agencies 

also attended the meeting.

• MANE-VU Consultation Meeting with VISTAS, August 20, 2007

o This meeting was held at State of Georgia offices in Atlanta and was 

attended by representatives of both MANE-VU and VISTAS states as well 

as staff. The meeting provided an opportunity to formally present the 

MANE-VU “Ask” to VISTAS states and to consult with them regarding 

the reasonableness of the requested controls. Federal Land Manager 

agencies also attended the meeting.

• MANE-VU – Midwest RPO Consultation Conference Call, September 13, 2007

o This call was a follow-up to the meeting held on August 6 in Chicago and 

provided an opportunity to further clarify what was being asked of the 

MRPO states. The flexibility in the Ask was explained. Both MRPO and 

MANE-VU staff agreed to work together to facilitate discussion of further 

controls on ICI boilers and EGUs.

• MANE-VU Air Directors’ Consultation Conference Call, September 26, 2007

o This call allowed MANE-VU members to clarify their understanding of 

the “Ask” and to provide direction to modeling staff as to how to interpret 
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the “Ask” for purposes of estimating visibility impacts of the requested 

controls.

• MANE-VU Air Directors’ Conference Call, March 31, 2008

o On this call, NESCAUM presented the results of the final 2018 modeling 

and described the methods used to represent the impacts of the measures 

agreed to by the Class I States. The Class I area states on the call 

confirmed they would rely on the modeling results to set their reasonable 

progress goals. Federal Land Manager agencies also attended this call.

Appendix Y of this SIP revision contains detailed summaries of the key meetings and 

calls the MANE-VU states conducted to develop and accept the final MANE-VU 'Ask' 

resolution and statements (Appendix M), as well as some follow up calls regarding 

modeling and determining the reasonable progress goals.
126

11.0. Comprehensive Periodic Implementation Plan Revisions and Progress Reports

Section 51.308(f) of EPA’s RHR requires the Department to revise its regional haze 

implementation plan and submit a plan revision to EPA by July 31, 2018 and every ten 

years thereafter. In accordance with the requirements listed in Section 51.308(f) of 

EPA’s RHR, the Department will revise its regional haze implementation plan and 

submit the SIP revision by July 31, 2018 and every ten years thereafter.

In addition, Section 51.308(g) requires periodic reports evaluating progress towards the 

reasonable progress goals established for each Class I area. In accordance with the 

requirements listed in Section 51.308(g) of the RHR, the Department will submit a report 

on reasonable progress to EPA every five years following the initial submittal of the SIP

revision. The report will be submitted to EPA in the form of a SIP revision. The 

reasonable progress report will evaluate the progress made toward the reasonable 

progress goal for each Class I area located outside Pennsylvania that may be affected by 

emissions from within Pennsylvania. All requirements listed in Section 51.308(g) shall 

be addressed in the SIP revision for reasonable progress. The reasonable progress report 

will include a summary of the emissions reductions achieved throughout Pennsylvania 

through implementation of measures, including the Department’s CAIR regulation. The 

Department’s CAIR regulation was approved by the EPA as a SIP revision effective 

December 10, 2009 (74 FR 65446). The EGUs in the Commonwealth are now required 

to reduce emissions according to the Department’s CAIR regulation. As a result of the 

Court’s remand of the federal CAIR to EPA, it is reasonable to expect that a revised 

CAIR will be in place to evaluate the Commonwealth’s emissions controls by the time 

the first regional haze progress report is due. By the due date of the first periodic 

reasonable progress report, in 2015, the first phase of the Department’s CAIR regulation

for EGUs should be fully implemented and the Department can assess the adequacy of 

the 2018 projections of emissions reductions.
127

12.0. Determination of the Adequacy of the Existing Plan

At the same time the Department submits a five-year progress report, the Department will 

make a determination of the adequacy of the existing implementation plan. 

Based on the findings of the five-year progress report, the Department will take one of 

the following appropriate actions in accordance with the requirements in 40 CFR 

§ 51.308(h):

1) If the Department in its five-year progress report determines that the existing SIP 

requires no further substantive revision in order to achieve established goals, the 

Department will provide to the EPA Administrator a negative declaration that 

further revision of the SIP is not needed at this time.

2) If the Department in its five-year progress report determines that the existing SIP 

is or may be inadequate to ensure reasonable progress due to emissions from 

another States which participated in the regional planning process, the 

Department will provide notification to the EPA Administrator and the other 

States that participated in the regional planning process and will collaborate with 

the other states through the regional planning process to address the SIP’s 

deficiencies.

3) If the Department in its five-year progress report determines that the existing SIP 

is or may be inadequate to ensure reasonable progress due to emissions from 

another country, the Department will provide notification and available 

information to the EPA Administrator.

4) If the Department in its five-year progress report determines that the existing SIP 

is or may be inadequate to ensure reasonable progress due to emissions from 

sources within Pennsylvania, the Department will revise its SIP within one year to 

address the plan’s deficiencies.
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13.0. Public and FLM Comment Process

13.1. Public Comment Period 

Requirements for a public comment process are set forth in Section 110(a)(2) of the CAA 

and 40 CFR § 51.102(d). The Department provided public notice of the opportunity to 

comment on the SIP revision and provided public notice of public hearing on October 9, 

2010. The Department held public hearings regarding the SIP on November 9th and 

November 10th, 2010. The Department did not receive any comments during the public 

comment period; therefore a Comment and Response document is not included in this 

final SIP revision. 

13.2. FLM Comments

Comments the Department received from the FLMs on the draft proposed Regional Haze 

SIP revision during the mandated 60-day consultation period were addressed. The 

FLM’s comments and the Department’s responses are included in Appendix AA.