Technical Support Document 

Reducing Emissions to Support Reasonable Progress Goals

in New York’s Regional Haze State Implementation Plan

Air Programs Branch, EPA Region 2

April 2012

INTRODUCTION

Technical Support Document

This Technical Support Document (TSD) describes EPA’s supporting documentation for its 

proposed actions on the reasonable progress section of New York’s Regional Haze State 

Implementation Plan (SIP). In addition, EPA should propose approval of New York’s 

Subchapter 249, which required eligible facilities to evaluate the need for Best Available Retrofit 

Technology. EPA reviewed the application of Subchapter 249 by New York in our evaluation of 

BART requirements for BART-eligible sources in New York. Evaluations of New York’s 

BART determinations are found in EPA’s docket for this action. 

Overview of New York’s State Implementation Plan for Regional Haze

Regional Haze State Implementation Plans (SIPs) are required by the Clean Air Act to reduce the 

effects of anthropogenic pollution on scenic views in areas designated at the Clean Air Act as 

Class I areas, at major National Parks and wilderness areas. 

The point of having a Regional Haze Plan is to show that each state is doing its share toward

improving these scenic views. New York does not have a Class I in its state, but, according to 

the list in its SIP, New York’s emissions impact protected areas in nearby states:

Lye Brook Wilderness Area, VT

Brigantine Wildlife Refuge, NJ

Presidential Range-Dry River Wilderness Area and Great Gulf Wilderness Area, NH

Roosevelt-Campobello International Park, 

Acadia National Park, ME

Moosehorn Wildlife Refuge, ME,

Shenandoah National Park, VA

The techniques used to determine if New York’s emissions impact Class I areas is discussed later 

in this section and some of the models used are in the section that reviews the use of air quality

models in the SIP.

The states and tribes in the northeastern United States worked together as the MidAtlantic/Northeast Visibility Union (MANE-VU) to determine the amount of emission 

reductions needed in the first ten year period ending in 2018. The amount of reductions needed 

by 2018 was calculated based on the need to insure steady progress toward the goal of no 

anthropogenic impairment of visibility in Class I areas by 2064. MANE-VU states agreed to a 

set of reasonably implementable emission reduction programs that, when modeled with other 

existing measures, are forecast to meet the projected visibility improvement target by 2018. 
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New York’s SIP includes emission controls measures that will reduce pollutants that impair the 

view at National Parks and wilderness areas in nearby states. Some of these emission controls 

are part of its Regional Haze SIP and other controls listed in the SIP were recently adopted 

separately from this SIP or already existed in other plans. Air quality models show that many of 

these measures also reduce haze. This portion of the TSD evaluates whether New York adopted 

the measures that the modeling shows will reduce impairments to visibility at protected areas. 

Material Submitted by New York

New York’s Department of Environmental Conservation (DEC) prepared the Regional Haze SIP, 

which the Commissioner submitted for the State. The main submittal was on March 15, 2010, 

containing the main document, Appendices A through X. The SIP was automatically declared 

complete six months after New York’s submittal. New York submitted its Part 249 rule for 

BART-eligible sources to determine BART controls on August 10, 2010. New York provided 

additional information about its BART sources on March 2, 2011. The public hearing on the SIP 

was held on January 5, 2010 and New York provided EPA with records from the hearing and 

associated comment period.

As of April 16, 2011, New York had not submitted the permit modifications needed for federal 

approval of its BART determinations. From discussions with the staff of the New York State 

Department of Environmental Conservation, EPA understood that New York had planned to 

submit a letter to EPA describing how it would enforce its sulfur-in-fuel legislation and a 

commitment to expand its sulfur-in-fuel limits via regulation. The upcoming regulation would 

complete New York’s effort to meet the sulfur-in-fuel limits specified in the measures MANEVU agreed to in order to achieve reasonable progress toward improving visibility in Class I 

areas. New York also planned to provide the BART permits that it had finalized to this point, but 

they have not arrived either.

The MANE-VU states showed, using models that combine meteorology, mathematics and 

emissions, that existing measures and emission reductions adopted for this Regional Haze SIP

will provide adequate progress toward the 2064 Clean Air Act goal of no anthropogenic 

impairment to visibility in protected parks and wilderness areas. The specific measures to be 

adopted by the states include: implementing Best Available Retrofit Technology (BART) per 

EPA guidelines on old sources, reducing emissions from 167 Electric Generating Units by an 

average of ninety percent or more, and implementing a geographically-specified program 

reducing sulfur in fuel oil. 

Specifically, New York’s Plan reduced emissions from its sub-set of the 167 EGUs by a small 

amount less than ninety percent for its set of EGUs. New York’s legislature enacted a sulfur-infuel reduction program for number 2 fuel oil that takes effect in 2012. New York has proposed 

to the public, and in some cases, taken final action on, control of sources subject to BART

requirements. Overall, these measures, combined with other reductions in emissions, provide a 

sufficient quantity of reduction of visibility-impairing pollutants to meet its contribution to 

improving visibility at Class I areas affected by New York’s emissions.

 

Background Information on the Nature of Regional Haze

Regional haze is visibility impairment that is produced by a multitude of sources and activities 

which are located across a broad geographic area. These sources emit fine particles (PM2.5) (e.g., 

sulfates, nitrates, organic carbon, elemental carbon, and soil dust) and their precursors (e.g., 

sulfur dioxide (SO2), nitrogen oxides (NOx), and in some cases, ammonia (NH3) and volatile 

organic compounds (VOC)). Fine particle precursors react in the atmosphere to form fine 

particulate matter which impairs visibility by scattering and absorbing light. Visibility
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impairment reduces the clarity, color, and visible distance that one can see. PM2.5 can also cause 

serious health effects and mortality in humans and contributes to environmental effects such as 

acid deposition and eutrophication. 

The average visual range1in many Class I areas (i.e., national parks and memorial parks, 

wilderness areas, and international parks meeting certain size criteria) in the eastern United 

States, is less than 30 kilometers or about one-fifth of the visual range that would exist under 

estimated natural conditions (64 FR 35714, July 1, 1999). In section 169A of the 1977 

Amendments to the Clean Air Act (the Act), Congress created a program for protecting visibility

in the nation’s national parks and wilderness areas. This section of the Act establishes as a 

national goal the “prevention of any future, and the remedying of any existing, impairment of 

visibility in mandatory Class I Federal areas2 which impairment results from manmade air 

pollution.” On December 2, 1980, the Environmental Protection Agency (EPA) promulgated 

regulations to address visibility impairment in Class I areas that is “reasonably attributable” to a 

single source or small group of sources, i.e., “reasonably attributable visibility impairment” (45 

FR 80084). These regulations represented the first phase in addressing visibility impairment. 

The requirement to submit a regional haze SIP applies to all 50 states, the District of Columbia, 

and the Virgin Islands.3 Section 51.308(b) requires states to submit the first implementation plan 

addressing regional haze visibility impairment no later than December 17, 2007. Regional haze 

SIPs must assure reasonable progress towards the national goal of achieving natural visibility

conditions in Class I areas. Section 169A of the CAA and EPA’s implementing regulations 

require states to establish long-term strategies for making reasonable progress toward meeting 

this goal. Implementation plans must also give specific attention to certain stationary sources 

that were in existence on August 7, 1977, but were not in operation before August 7, 1962, and 

require these sources, where appropriate, to install Best Available Retrofit Technology (BART) 

controls for the purpose of eliminating or reducing visibility impairment. 

Determination that New York State Impacts Visibility in Class I Areas

New York State listed the Class I areas where its emissions have an impact based on the analyses 

in the report Contributions to Regional Haze in the Northeast and Mid-Atlantic United States

prepared by NESCAUM (Northeast States for Coordinated Air Use Management). The report

used a variety of techniques, listed below, for determining the relative contributions of its states 

to visibility impairment in Class I areas.

Since sulfate typically accounts for 70–82 percent of estimated particle-induced light extinction 

at northeastern and mid-Atlantic Class I sites, the report used the effect of each state’s emissions

on sulfate concentrations in the Class I area as a surrogate for transported pollutants that impair 

visibility. Using sulfates as an indicator of effect on visibility in Class I areas is acceptable in this 

 

1Visual range is the greatest distance, in kilometers or miles, at which a dark object can be viewed against the sky.

2Areas designated as mandatory Class I Federal areas consist of national parks exceeding 6000 acres, wilderness 

areas and national memorial parks exceeding 5000 acres, and all international parks that were in existence on 

August 7, 1977. 42 U.S.C. 7472(a). In accordance with section 169A of the CAA, EPA, in consultation with the 

Department of Interior, promulgated a list of 156 areas where visibility is identified as an important value (44 FR 

69122, November 30, 1979). The extent of a mandatory Class I area includes subsequent changes in boundaries, 

such as park expansions. 42 U.S.C. 7472(a). Although states and tribes may designate as Class I additional areas 

which they consider to have visibility as an important value, the requirements of the visibility program set forth in 

section 169A of the CAA apply only to ‘‘mandatory Class I Federal areas.” Each mandatory Class I Federal area is 

the responsibility of a ‘‘Federal Land Manager.’’ 42 U.S.C. 7602(i). When we use the term “Class I area” in this 

action, we mean a “mandatory Class I Federal area.”

3Albuquerque/Bernalillo County in New Mexico must also submit a regional haze SIP to completely satisfy the 

requirements of section 110(a)(2)(D) of the CAA for the entire State of New Mexico under the New Mexico Air 

Quality Control Act (section 74-2-4).
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round of visibility improvement because states agreed to measures that focused on removing 

sulfates from emissions. The methods for attributing state effects on Class I areas used

emissions, distance from the Class I area and the effects of weather patterns. The report found a 

high level of overall consistency among the different methods listed here. 

Technical approaches for attributing state contributions to observed sulfate in MANE-VU 

Class I areas:

Analytical technique Approach

Emissions divided by distance Empirical

Incremental probability Lagrangian trajectory technique

Cluster-weighted probability Lagrangian trajectory technique

Emissions times upwind probability Empirical/trajectory hybrid

Source apportionment approaches Receptor model/trajectory hybrid

REMSAD tagged species Eulerian source model

CALPUFF with MM5-based meteorology Lagrangian source dispersion model

CALPUFF with observation-based meteorology Lagrangian source dispersion model

New York is ranked in the top five states for several of these approaches and contributes a large 

percentage of visibility-impairing sulfate to several Class I areas, making control if its 

contributions essential to reducing impairment to visibility at Class I areas in the northeast and 

mid-atlantic states. 

STATE’S SUBMITTAL

The SIP revision addresses regional haze for the first implementation period, ending in 2018. 

New York’s emissions affect air quality in Class I areas in nearby states. But since New York 

does not have a Class I areas within its borders, it uses the baseline and natural visibility

conditions and reasonable progress goals established by states with the Class I area. These goals 

were developed by states with Class I areas, in consultation with states that affect visibility in the 

Class I areas. It follows that New York also does not have to address monitoring requirements,

or meeting RAVI requirements for Class I areas. But, New York is responsible for developing a 

regional haze SIP that addresses its impact on nearby Class I areas, with a long-term emission 

strategy, describing its role in the consultation processes, and how the SIP meets the other 

requirements in EPA’s regional haze regulations. 

Measures Adopted to Address Long-Term Strategy (LTS)

The LTS is a compilation of state-specific control measures relied on by the state to obtain its 

share of emission reductions to support the RPGs established the Class I states. New York’s

LTS for the first implementation period addresses the emissions reductions from federal, state, 

and local controls that take effect in the State from the baseline year of 2002 until the end of the 

first period in 2018. 

The LTS was developed by Class I states in coordination with other states working together as 

the Mid-Atlantic NorthEast Visibility Union (MANE-VU), as they identified emission controls 

that were reasonable and addressed the goal of meeting the RPG in Class I areas across the 

northeastern United States. 

On June 20, 2007, the MANE-VU states agreed to adopt emission control strategies that MANEVU modeled to determine the amount of progress that the MANE-VU states would make toward 

improving visibility by the end of the first control period, ending in 2018. 
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By adopting all the measures identified in the MANE-VU analysis and applying BART to 

eligible sources, New York LTS would achieve its share of emissions reductions that are 

reasonable and, according to the results of atmospheric modeling, will achieve the reasonable 

progress goals for the nearby Class I areas. The following chart compares measures adopted by 

New York with the measures agreed to by the MANE-VU states (often referred to as the MANEVU ‘ask’). 

MANE-VU ‘Ask’ Measures* Measures Adopted or Action Taken by New York

Timely implementation of BART on 

all sources identified as BART –

eligible

Implementing BART on all eligible sources, except those that do 

not meet BART eligibility or have emission limits less than the 

250 tons per year BART eligibility thresholds in their permits.

Low sulfur fuel oil strategy: for NY:

distillate oil to 0.05% (500pmm) 

sulfur by 2012 and to 15ppm by 2016, 

#4 residual oil to 0.25% sulfur no later 

than 2012, #6 residual oil to 0.3 to 

0.5% by 2012 

New York State Law: No. 2 reduced to 15 ppm by 2012

New York City has adopted:

No. 2: 15 ppm by 2012 (following state law)

No. 4: 0.15 percent by 2012

No. 5, No. 6 & heavier: 0.30 percent by 2012.

All lower sulfur targets to be met well before 2018. 

NYS planned to enact statewide limits on number 4 and 6 oil in 

upcoming regulations.

90% or more reduction in SO2 

emissions from 167 stacks or 

alternative measures

Reductions of sulfur emissions at New York’s nineteen out of the 

167 stacks, plus additional reductions on two non-EGU BART 

sources

Continued evaluation of other 

measures, including energy efficiency, 

alternative clean fuels, reduce SO2 

and NOx from coal units by 2018 and 

NSPS for wood combustion if 

reasonable and cost-effective

Emission reductions included in ozone and particulate matter 

SIPs (included in modeling). These strategies were not 

specifically modeled and are not binding commitments on the 

part of NYS:

• The revisions for RACT for major sources of PM2.5 greater 

than 100 tons per year

• New Source Review in Nonattainment Areas and Ozone

Transport Region (revisions adopted January 15, 2009),

• MACT under Section 112 of the 1990 CAA Amendments,

• NOx RACT measures for High Electricity Demand Day Units,

• Emission reductions resulting from consent orders, and

• The continued evaluation of other control measures including 

energy efficiency, alternative clean fuels, and other approaches.

*Measures agreed-to by MANE-VU states and tribes on June 20, 2007 and included in the modeling that 

predicted visibility in Class I areas reaching reasonable progress goals by 2018.
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• BART Controls 

A more detailed review of New York’s implementation of BART is found in documents in 

EPA’s docket on this proposed action.

In summary, New York identified twenty sources that could be subject to BART. Thirteen 

sources were EGUs and seven were other major sources. All these sources were included in the 

regional haze modeling, but since New York had not identified its BART-eligible sources at that 

time, the reduced emissions due to BART controls were not included in the modeling for the 

2018 future case. (EGUs that are part of the 167 sources were modeled with 90 percent 

reductions. Only two BART sources in New York, both non-EGUs had their potential BART 

controls included in the modeling.) 

As of the date of the signed Federal Register notice, New York had not sent its finalized permits 

for these sources, as the permits with the reductions need to be submitted to EPA as SIP 

revisions to become effective. EPA is discussing the potential approvability of these SIP 

revisions in the proposed action, based on public notices on the permits. Since New York has 

yet to submit these permits as SIP revisions, and EPA was compelled to take action at that time, 

EPA has proposed that the appropriate pollution control measures as part of a Federal 

Implementation Plan (FIP) for New York. If New York submits these permits as SIP revisions 

in time for EPA to review and process before the final action is needed on this SIP by August 16, 

2012, EPA may be able to approve these measures as part of New York’s SIP. 

• Electric Generating Units 

New York is home to nine of the 105 power plants that make up the 167 EGU stacks identified 

when MANE-VU states set the 2018 reasonable progress goals for the five Class I areas in 

MANE-VU. New York has addressed emission changes from these nine sources, with nineteen 

stacks, in Table 9-4 in Section 9 of its Regional Haze Plan. 

EPA proposed that states could use their involvement under the Clean Air Interstate Rule to 

fulfill their commitment to implementing controls on EGUs for sulfur and nitrogen. While New 

York adopted CAIR, it chose to insure that the modeled improvement in visibility would occur 

even in case of emissions trading by sources under CAIR. So, New York chose to evaluate 

controls on each of its EGUs, outside of EPA’s CAIR. Thus the court remand of CAIR, and 

EPA’s development of an improved transport rule to replace CAIR, does not affect the amount of 

control that New York implemented for its sources and has no negative impact on New York’s

efforts to meet the visibility Progress Goals. 

The key issue is to determine if New York’s controls on its share for 167 EGU stacks amounts to 

the ninety percent SO2 emission reduction agreed to in the MANE-VU ‘ask’. The MANE-VU set 

of control measures are important because modeling shows that they produce an improvement in 

visibility that puts the Class I areas in the MANE-VU domain on the path to reaching the 2064 

goal of no anthropogenic interference with visibility.

The calculations that document New York’s ability to reach the ninety percent emission 

reduction target are found in the spreadsheet below. Based on data from the MANE-VU 

modeling, and New York’s commitments to implement controls on these sources, EPA can 

calculate the total percent sulfur reductions from its share of the 167 sources to be about 83

percent. This means that 9,110 tons per year of sulfur emissions must be available, above and 

beyond the reductions required for other parts of the Regional Haze SIP, to fulfill this MANEVU agreement for ninety percent control of these EGU emissions.
7

Additional reductions are available to New York. The two non-EGU sources eligible for BART 

controls, and modeled at estimated BART levels of control, will be shutdown. The MANE-VU 

modeling included the estimate of BART reductions for those two non-EGU sources in New 

York State, Kodak and LaFarge Cement. Table 9-6 of New York’s Haze SIP includes this 

information for these two sources, from the MANE-VU final modeling.i Kodak unit U15 was 

estimated to emit 14,216 tons of sulfur dioxide after BART controls. After further analysis, with 

changes to a number of sources in the Kodak complex, this unit is planned to be shut down, with 

another 6,745 tons per year eliminated. At LaFarge Building Materials, 4,400 tons per year of 

sulfur were to be emitted in the estimated BART analysis used in the modeling. LaFarge will 

cease operations. Therefore, the additional reductions beyond the BART reductions already in 

the model total 11,195 tons per year from Kodak and LaFarge combined. These reductions are 

beyond the emission reductions from New York State’s sources used in the MANE-VU 

modeling for the Class I areas. These reductions can be used to supplement and complete New 

York’s State’s quest for a ninety percent reduction in major source sulfur emissions. As seen in 

this spreadsheet’s calculations, NYSDEC overall reduction in sulfur emissions from the nineteen 

stacks plus the sources with emission controls beyond the originally planned BART is 2,074 tons 

per year more than needed to meet the ninety percent requirement. Thus, New York’s emissions 

of sulfur dioxide from point sources exceed their contribution to meeting the reasonable progress 

requirement. 

Source 2002mm5 2002vtdec 2002 base EI MANE-VU EI 2018

Control info from 2018 

MANE-VU EI and Table 9-

4 NYSDEC Haze SIP and 

updated information

Revised 2018 

Emissions

CR Huntley 25,343.0 25,320.0 25,343.0 7,085.0

80%; 14,169 for Huntley 

and Dunkirk together 7,085.0

CR Huntley 12,317.0 12,317.0 "

CR Huntley "

Dunkirk 30,151.0 30,125.0 30,151.0 7,085.0 " 7,085.0

Roseton 3,817.0 3,817.0 3,817.0

Reductions from BART 

analysis 1.0% S fuel 2,936.2

Roseton 2,840.0 2,840.0 2,840.0 " 2,184.6

Danskammer 7,720.0 7,720.0 763.5 763.5

Goudey/Westover 14,929.0 14,929.0 1,921.1

Plant destroyed in 

flooding 0.0

Goudey/Westover 1,921.1 0.0

Goudey/Westover 3,856.1 0.0

Greenidge 12,650.0 12,650.0 605.0 605.0

Northport 7,359.0 7,359.0 7,359.0

NYSDEC SIP says new 

plant to be constructed 

(shutdown) 0.0

Oswego 1,747.0 1,747.0 1,747.0 1,747.0

Rochester 7 14,086.0 14,086.0 200.0

NYSDEC SIP says 

shutdown 0.0

Total emissions: 132,959.0 39,199.8 22,406.3

Total percent 

control for all of 

NYS's subset of 167 

sources: 70.5% 83.1%

90% of base: 13,295.9 Additional needed: 119,663.1

Additional needed, based 

on updates> 9,110.4

Kodak reductions beyond 

modeled BART> 6,745.0

LaFarge reductons 

beyond modeled BART> 4,440.0

Net -2,074.6
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• Sulfur in Fuel Oil 

Under the MANE-VU agreement to reduce emissions of sulfur in fuel oil, Phase 1 of the 

proposed standards establishes limits of:

0.05 percent sulfur by weight (500 ppm) for distillate oil (No. 2 and lighter);

0.25 percent sulfur by weight (2,500 ppm) for No. 4 residual oil; 

and between 0.3 and 0.5 percent sulfur by weight (3,000 to 5,000 ppm) for No. 6 residual oil. 

These standards are to go into effect no later than 2012. 

In addition, the MANE-VU strategy provides for a phase two reductions for distillate oil (No. 2 

and lighter) to 15 ppm by 2016. 

The lower sulfur limits in New York’s sulfur-in-fuel law are effective in 2012. 

New York State’s Environmental Conservation Law, section 19-0325: Sulfur reduction 

requirements: limits the sulfur content of number two heating oil to fifteen parts per million by

2012. This requirement is one portion of the control strategies agreed to by the MANE-VU 

states. However, the final modeling included reductions in number four and six oil to .25% and 

.6%, respectively. These reductions are not in place statewide, except for limits of 0.15% to be 

effective in New York City by 2012. 

EPA estimates a reduction in sulfur emissions from the sulfur-in-fuel program in section 9.4.2 of 

the Haze Plan and the MANE-VU modeling inventory. The MANE-VU modeling included a 

reduction of sulfur emissions in New York State of 91,701 tons per year for BART and 

implementing the MANE-VU sulfur-in-fuel agreement, combined. Since the BART emission 

reduction, from the two non-EGU BART-eligible sources, was 19,942 tons per year of sulfur, the 

emission reductions expected from the sulfur-in-fuel program is 71,759 tons. From the data in 

New York’s SIP, EPA calculates that the new sulfur-in-fuel law will reduce emissions by 54,090 

tons per year. That would leave 17,669 tons per year for New York to obtain through expansion 

of its limits on lower sulfur oil. 

There are at least two ways that the need to include 17,669 tons in this plan can be addressed. 

First of all, when New York State adopts the rest of its sulfur-in-fuel program to meet the 

MANE-VU ask, its emission reductions would be the same tonnage as in the MANE-VU 

modeling, since New York’s program would be the same as modeled by MANE-VU. Second, 

MANE-VU modeling, after modeling the ‘ask’ and all its measures, put back 23,100 tons of New 

York’s sulfur emissions into the emissions inventory to better approximate the results of EPA’s 

transport rule programs. Even with the 23,100 tons returned to the atmosphere, MANE-VU’s 

model predicted that the Class I areas in the northeast and mid-atlantic states would still meet the 

progress goal set for visibility in 2018. This 23,100 tons of sulfur emissions, is more than the 

17,699 tons expected from the expansion of New York’s sulfur in fuel rule that has not been 

adopted yet. 

EPA should propose that, based on calculations from the MANE-VU modeling inventory, and 

because New York has a sulfur-in-fuel law that is in force for New York State and adopted as 

regulation in New York City, EPA should approve this portion of New York’s Haze Plan as 

sufficient to reduce haze in the affected Class I areas in the region by the amount specified in the 

MANE-VU modeling.

• Additional Measures 
9

The following additional measures also are part of New York’s Regional Haze Plan, but were not 

adopted specifically for the Plan. The following list is excerpted from New York’s Regional 

Haze Plan, February 2010:

• The revisions to 6 NYCRR Part 227 that will require RACT for major sources of PM2.5 (those 

greater than 100 tpy),

• Part 231: New Source Review in Nonattainment Areas and Ozone

Transport Region (revisions adopted January 15, 2009),

• MACT under Section 112 of the 1990 CAA Amendments,

• NOx RACT measures for High Electricity Demand Day Units,

• Emission reductions resulting from consent orders, and

• The continued evaluation of other control measures including energy efficiency, alternative 

clean fuels, and other approaches.

Emissions Inventory for 2018 with Federal and State Control Requirements 

The emissions inventory used in the regional haze technical analyses was developed by MidAtlantic Regional Air Management Association (MARAMA) for MANE-VU with assistance 

from the MANE-VU states. The 2018 emissions inventory was developed by projecting 2002 

emissions, assuming emissions growth due to projected increases in economic activity, as well as 

applying reductions expected from federal and state regulations affecting the emissions of VOC 

and the visibility-impairing pollutants NOx, PM10, PM2.5, and SO2. The BART guidelines direct 

states to exercise judgment in deciding whether VOC and NH3 impair visibility in their Class I 

area(s). MANE-VU demonstrated that anthropogenic emissions of sulfates are the major 

contributor to PM2.5 mass and visibility impairment at Class I areas in the Northeast and MidAtlantic region. It was also determined that the total ammonia emissions in the MANE-VU 

region are extremely small. In addition, VOC emissions are aggressively controlled through New 

York’s ozone SIPs. Therefore, the pollutants New York considered under BART are NOx, PM10, 

PM2.5, and SO2. 

New York’s emission inventory for its Haze SIP was taken from the MANE-VU emissions 

inventory used for the modeling analysis for regional haze and ozone and particulate matter SIP. 

The inventory was used for, and approved for New York’s ozone modeling and particulate 

matter SIP, is approvable for use in the regional haze SIP.

However, there was a typo in the original table in New York’s SIP. New York used the 

opportunity to make some minor changes to the inventory to bring it more in line with the 

changes in emissions from planned reductions due to its sulfur-in-fuel legislation and New 

York’s planned sulfur-in-fuel rule.

Modeling to Support the Long Term Strategy and to Determine Visibility Improvement for 

Uniform Rate of Progress

MANE-VU performed modeling for the regional haze LTS for the 11 Mid-Atlantic and 

Northeast states and the District of Columbia. The modeling analysis is a complex technical 

evaluation that began with selection of the modeling system. MANE-VU used the following 

modeling system:

 Meteorological Model: The Fifth-Generation Pennsylvania State University/National 

Center for Atmospheric Research (NCAR) Mesoscale Meteorological Model (MM5) 

version 3.6 is a nonhydrostatic, prognostic meteorological model routinely used for 

urban- and regional- scale photochemical, PM2.5, and regional haze regulatory modeling 

studies.
10

 Emissions Model: The Sparse Matrix Operator Kernel Emissions (SMOKE) version 2.1 

modeling system is an emissions modeling system that generates hourly gridded 

speciated emission inputs of mobile, non-road mobile, area, point, fire and biogenic 

emission sources for photochemical grid models.

 Air Quality Model: The EPA’s Models-3/Community Multiscale Air Quality (CMAQ) 

version 4.5.1 and REMSAD modeling system is a photochemical grid model capable of 

addressing ozone, PM, visibility and acid deposition at a regional scale. 

 Air Quality Model: The Regional Model for Aerosols and Deposition (REMSAD), 

version 8 is a Eulerian grid model used for a source apportionment analysis.

 Air Quality Model: The California Puff Model (CALPUFF), version 5 is a non-steadystate Lagrangian puff model used to access the contribution of individual states’ 

emissions to sulfate levels at selected Class I receptor sites.

The MANE-VU was tasked with the assignment of preparing a PM2.5 modeling platform that all 

member states could use to model their LTSs to demonstrate reasonable progress by 2018 in 

meeting the ultimate goal of natural visibility conditions by 2064. The New York State 

Department of Environmental Conservation (NYSDEC) was the lead agency for coordinating 

and running the modeling platform used by the MANE-VU RPO. Modeling centers responsible 

for running the platform included the NYSDEC, the University of Maryland at College Park 

(UMD), the Northeast States for Coordinated Air Use Management (NESCAUM), the New 

Jersey Department of Environmental Protection (NJ DEP), and the Virginia Department of 

Environmental Quality (VA DEQ). Each modeling center was responsible for installing the 

modeling platform, conducting diagnostic tests and completing a benchmark run to ensure 

accurate, consistent results. 

 

MANE-VU used the CMAQ version 4.5.1 as its photochemical grid model. The model uses 

simulations of chemical reactions, emission of PM2.5 and PM2.5 precursors and a sophisticated 

meteorological model (The Pennsylvania State University/National Center for Atmospheric 

Research Mesoscale Meteorological Model) to produce speciated PM2.5 concentrations over the 

eastern United States. The meteorological data used in the meteorological model was for the 

2002 base year. The photochemical grid model was run with the base year meteorology and base 

year emissions to determine if the model performance was satisfactory. Once the model 

performance was determined to be adequate, PM 2.5 concentrations were modeled by running the 

model with projected emissions for 2018 and the original 2002 meteorology. The meteorology

was held constant so that the results of changing the emissions would not be influenced by 

changing meteorology.

Conceptual Description of the Modeling Situation

A conceptual model describes how weather patterns affect the formation and transport of PM2.5, 

accounting for emissions and photochemistry. In the case of regional haze, emissions of sulfur, 

nitrogen and carbon, especially sulfur, react in the atmosphere to form fine particles that are 

large enough to scatter visible light. This scattering reduces the contrast of distant objects and 

makes them less visible.

New York’s SIP includes, in Section 1.1, a description of how reduced visibility occurs in New 

York and how it affects its wilderness and scenic areas. Section 1.3 lists the areas that affect 

visibility at Class I locations in MANE-VU and Section 1.4 lists the Class I areas where New 

York’s emissions affect visibility. 

Appendix A is a document prepared by MANE-VU that includes numerous methods that provide 

information about how haze occurs in the northeast United States and the sources of haze. The 
11

methods include emissions information (and the distance to sources), trajectory analyses, and 

impacts predicted by dispersion and various grid models. Monitoring data is used to show that 

sulfates are the predominate species that reduce visibility at the Class I areas in MANE-VU. 

The various models support the hypothesis that many sources across a wide range of states in the 

eastern United States contribute to haze in New York and at areas in MANE-VU where visibility

is a protected value. 

Modeling Platforms

Two regional-scale air quality models were evaluated and used by NESCAUM to perform air 

quality simulations. These are the Community Multi-scale Air Quality modeling system 

(CMAQ; Byun and Ching, 1999) and the Regional Modeling System for Aerosols and 

Deposition (REMSAD; SAI, 2002). CMAQ was developed by EPA, while REMSAD was 

developed by ICF Consulting/Systems Applications International (ICF/SAI) with EPA support. 

CMAQ has undergone extensive community development and peer review (Amar et al., 2005) 

and has been successfully used in a number of regional air quality studies (Bell and Ellis, 2003;

Hogrefe et al., 2004; Jimenez and Baldasano, 2004; Mao and Talbot, 2003; Mebust et al., 2003). 

REMSAD has also has been peer reviewed (Seigneur et al., 1999) and used by EPA for 

regulatory applications ( www.epa.gov/otaq/regs/hd2007/frm/r00028.pdf and 

www.epa.gov/clearskies/air_quality_tech.html) to study ambient concentrations and deposition 

of sulfate and other PM species.

Five modeling centers worked collectively to maximize efficiency of computing resources in 

MANE-VU for SIP modeling. These centers include NY DEC, NJ DEP/Rutgers, VA DEQ, 

UMD, and NESCAUM. 

Use of Air Quality Models: Contribution Assessment

The 1999 Regional Haze Rule requires States and Tribes to submit State Implementation Plans to 

EPA for approval by January 2008 at the latest. The haze SIPs must include a “contribution 

assessment” to identify those states or regions that may be influencing specially protected federal 

lands known as Federal Class I areas.4These states or regions would then be subject to the 

consultation provisions of the Haze Rule. The Haze Rule also requires a “pollution 

apportionment” analysis as part of the long-term emissions management strategy for each site.

As described in the Conceptual Description portion of this TSD, sulfate alone accounts for 

anywhere from one-half to two-thirds of total fine particle mass on the 20 percent haziest days at 

MANE-VU Class I sites. 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.

Use of Air Quality Models: Area of Influence for MANE-VU Class I Areas 

 

4

The Class I designation applies to national parks exceeding 6,000 acres, wilderness areas and national memorial 

parks exceeding 5,000 acres, and all international parks that were in existence prior to 1977. In the MANE-VU area, 

this includes: Acadia National Park, Maine; Brigantine Wilderness (within the Edwin Wilderness, Vermont; 

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

Refuge), New Jersey; Great Gulf Wilderness, New Hampshire; Lye Brook Presidential Range – Dry River 

Wilderness, New Hampshire; and Roosevelt Campobello International Park, New Brunswick.
12

States with Class I areas calculate the baseline and natural visibility for their Class I areas, and 

the determination of reasonable progress goals. 

Class I States calculate baseline visibility conditions for the period between 2002 and 2004. The 

average impairment for the most and least impaired days are determined for each calendar year 

and compiled into the average of three annual averages (40 CFR 51.308 (d)(2)(i)). The natural 

visibility conditions are determined for the same baseline period with the most and least impaired 

days determined by available monitoring data or an appropriate data analysis technique (40 CFR 

51.308 (d)(iii-iv)). 

There are seven Class I areas located in the Mid-Atlantic and Northeast. In order to identify

states whose emissions are most likely to influence visibility in MANE-VU Class I areas, 

MANE-VU prepared the Contributions to Regional Haze in the Northeast and Mid-Atlantic 

United States (Contribution Assessment). The full report can be found in Appendix A of the New 

York Regional Haze SIP. 

Based on that work, MANE-VU concluded that it was appropriate to define an “Area of 

Influence” (AOI) including all of the states participating in MANE-VU plus other states outside 

MANE-VU for which modeling indicated they contributed at least two percent (2%) of the 

sulfate ion in MANE-VU Class I areas in 2002. The Visibility Improvement State and Tribal 

Association of the Southeast (VISTAS)5also conducted an AOI analysis, which used a level of 

one percent (1%) to assess whether an upwind state significantly contributed. The VISTAS AOI 

did not show New York to be a contributor to any VISTAS Class I area. 

The primary contribution assessment tool used for the New York Regional Haze SIP was the 

Regional Modeling System for Aerosols and Deposition (REMSAD) (SAI, 2002). 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 CMAQ SIP 

modeling platform, described earlier in this TSD, 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. A more in-depth description of the REMSAD modeling used for 

contribution assessment can be found in Appendix A of New York’s SIP.

The REMSAD contribution assessment modeling used for New York’s Regional Haze SIP

conforms to EPA modeling requirements and is acceptable to EPA. 

Use of Air Quality Models: REMSAD Contribution Assessment Results

MANE-VU States decided that any state or region that contributed at least 2 percent of total 

sulfate observed on 20 percent worst visibility days in 2002 is contributing significantly to the 

haze problem in that particular Class I area. With respect to sulfate, the Contribution 

Assessment estimated emissions from within MANE-VU in 2002 were responsible for about 25-

 

5

VISTAS is comprised of the following states: Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, 

South Carolina, Tennessee, Virginia, West Virginia, the Eastern Band of Cherokee Indians, and Knox County, TN 
13

30 percent of the sulfate at Class I areas located within and nearby to the MANE-VU region. The 

contribution of sulfate at these Class I areas from other regions, Canada, and outside the 

modeling domain were also significant. 

Use of Air Quality Models: CMAQ Modeling of Relative Contributions of Pollutants to

Visibility Impairment

An important step toward identifying reasonable progress measures is to identify the key

pollutants contributing to visibility impairment at each Class I area. To understand the relative 

benefit of further reducing emissions from different pollutants, MANE-VU developed emission 

sensitivity model runs using CMAQ to evaluate visibility and air quality impacts from various 

groups of emissions and pollutant scenarios in the Class I areas on the 20 percent worst visibility

days. 

Regarding which pollutants are most significantly impacting visibility in the MANE-VU region, 

MANE-VU’s contribution assessment, demonstrated that sulfate is the major contributor to 

PM2.5 mass and visibility impairment at Class I areas in the Northeast and Mid-Atlantic region. 

Sulfate particles commonly account for more than 50 percent of particle-related light extinction 

at northeastern Class I areas on the clearest days and for as much as or more than 80 percent on 

the haziest days. In particular, for the Brigantine National Wildlife Refuge Class I area, on the 20 

percent worst visibility days in 2000 – 2004, sulfate accounted for 66 percent of the particle 

extinction. After sulfate, organic carbon (OC) consistently accounts for the next largest fraction 

of light extinction. Organic carbon accounted for 13 percent of light extinction on the 20 percent 

worst visibility days for Brigantine, followed by nitrate that accounts for 9 percent of light 

extinction. 

 

The emissions sensitivity analyses conducted by MANE-VU predict that reductions in SO2

emissions from EGU and non-EGU industrial point sources will result in the greatest 

improvements in visibility in the Class I areas in the MANE-VU region, more than any other 

visibility-impairing pollutant. 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. 

Use of CMAQ Modeling to Develop 2018 Control Case Predictions:

Meteorological Time Periods Used in the Modeling

All of 2002, which represents the baseline period from 2000 to 2004, was included in CMAQ 

modeling. 2002 was divided into five periods. UMD is responsible for modeling the period from 

January 1 to February 28; NJ DEP/Rutgers are responsible for the period from March 1 to May

14; NY DEC is responsible for the period from May 15 to September 30; VA DEQ is responsible 

for the period from October 1 to October 31; and NESCAUM is responsible for the period from 

November 1 to December 31. Each period uses a 15 day spin up run to minimize the impact of 

the default initial concentration fields. Each group performs CMAQ simulations on its period for 

a series of scenarios including 2002 Base Case, 2009 Base Case, 2018 Base Case, 2009 Control 

Case, and 2018 Control Case. All scenarios adopt the same meteorological field (2002) and 

boundary conditions, varying only emission inputs. To ensure consistency between modeling 

groups, a benchmark test was conducted by each group.

Meteorological Data Used in the CMAQ Air Quality Model
14

The MANE-VU states decided to use a prognostic meteorological model that provides life-like 

meteorological inputs to the photochemical grid model. The Pennsylvania State 

University/National Center for Atmospheric Research Mesoscale Meteorological Model version 

3.6 was chosen for the modeling analysis. The MM5 model provides a reasonable representation 

of weather conditions at the surface and aloft. 

Use of CMAQ Modeling to Develop 2018 Control Case Predictions:

Domain of the Model, Horizontal/Vertical Resolution and the Initial and Boundary 

Conditions

MANE-VU adopted the Inter-RPO domain description for its modeling runs. This 36-km 

domain covers the continental United States, southern Canada and northern Mexico. The 

dimensions of this domain are 145 and 102 cells in the east-west and north-south directions, 

respectively. A 12-km inner domain was selected to better characterize air quality in MANE-VU 

and surrounding RPO regions. This domain covers the eastern region, which includes the 

northeastern, central, and southeastern U.S., as well as southeastern Canada. It extends from 

66W - 94W in longitude and 29N - 50N in latitude with 172 × 172 grid cells.

 

Vertical resolution is the number of layers and the size of each layer in the model. The layers in 

the photochemical grid model were set up to be compatible with the model that produced 

weather conditions for the photochemical grid model. The vertical resolution used in the 

modeling exercise followed EPA’s modeling guidance and therefore adequately represents the 

atmosphere where PM2.5 is emitted, forms and is transported. 

Baseline and Future Year Emission Inventories for CMAQ Modeling 

Section 51.308(d)(3)(iii) of EPA’s Regional Haze Rule requires the States to identify the 

baseline emission inventory on which strategies are based. The baseline inventory is intended to 

be used to assess progress in making emission reductions. Based on EPA guidance entitled, 2002 

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

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

haze, MANE-VU and New York are using 2002 as the baseline year. Future year inventories 

were developed for the years 2009, 2012 and 2018 based on the 2002 base year. These future 

year emission inventories include emissions growth due to projected increases in economic 

activity as well as the emissions reductions due to the implementation of control measures. 

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

MARAMA then coordinated and quality assured the 2002 inventory data. The 2002 emissions 

from non-MANE-VU areas within the modeling domain were obtained from other Regional 

Planning Organizations for their corresponding areas. These Regional Planning Organizations 

included the Visibility Improvement State and Tribal Association of the Southeast (VISTAS), 

the Midwest Regional Planning Organization and the Central Regional Air Planning Association. 

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

Technical support documentation for the MANE-VU 2002 base inventory is presented in 

Technical Support Document for 2002 MANE-VU SIP Modeling Inventories, Version 3, which 

is Appendix H of the New York SIP. This document explains the data sources, methods, and 

results for preparing this version of the 2002 base year criteria air pollutant and ammonia 

emissions inventory. Documentation for the future year estimations of EGUs is presented in 

Appendix E of the SIP – MARAMA’s Development of Emission Projections for 2009, 2012, and 

2018 for Non-EGU Point, Area, and Nonroad Source in the MANE-VU Region Final Report, 

February, 2007. 
15

CMAQ Model Performance Evaluation

The modeling is described in MANE-VU Modeling for Reasonable Progress Goals, prepared by 

NESCAUM, listed as Appendix R of New York’s SIP. 

NESCAUM evaluated the 2002 annual 12 km resolution meteorological fields generated by 

MM5 using ENVIRON's METSTAT program. Model results of surface wind speed, wind 

direction, temperature, and humidity were paired with measurements from EPA’s Clean Air 

Status and Trends Network (CASTNET) and National Center for Atmospheric Research’s 

Techniques Data Laboratory (TDL) network by hour and by location and then statistically

compared. Based on this statistical comparison between model prediction and data from the two 

networks for wind speed, wind direction, temperature, and humidity, MM5 performs well. An 

acceptable small bias, high index of agreement and strong correlation with CASTNET and TDL 

data are shown. Since MM5 uses TDL data for nudging, the model predictions are in better 

agreement with TDL data than with CASTNET data. MM5 performs better in Midwest and 

Northeast than Southeastern US.

CMAQ modeling was conducted for year 2002 by cooperative modeling efforts from NYDEC, 

UMD, NJDEP, Rutgers, VADEP, and NESCAUM. CMAQ Performance for PM2.5 species and 

visibility was examined based on this CMAQ run on a 12 km resolution domain. Measurements 

from IMPROVE and STN networks were paired with model predictions by location and time for 

evaluation. The goal and the criteria for PM2.5 evaluation suggested by Boylan and Baker (2004) 

were adopted by every RPO for SIP modeling. The performance goals are: Mean Fractional 

Error (MFE) ≤ +50%, and Mean Fraction Bias (MFB) ≤ ±30%; while the criteria are proposed 

as: MFE ≤ +75%, and MFB ≤ ±60%. CMAQ prediction of PM2.5 species from 40 STN sites and 

17 IMPROVE sites within the MANE-VU Region were paired with measurements and 

statistically analyzed to generate MFE and MFB values. Considering CMAQ performance in 

terms of MFE and MFB goals, sulfate, nitrate, OC, EC, and PM2.5 all had the majority of data 

points within the goal curve, some were between the goal and acceptable criteria, and only a few 

were outside the criteria curve. Only fine soil has the majority of points outside the criteria curve, 

but there were some sites still within the goal. For the MANE-VU region, CMAQ performs best 

for PM2.5 sulfate, followed by PM2.5, EC, nitrate, OC, and then fine soil. Regional haze modeling 

also requires CMAQ performance evaluation for aerosol extinction coefficient (Bext) and the 

haze index. Modeled daily aerosol extinction at each improve site was calculated following the 

IMPROVE formula with modeled daily PM2.5 species concentration and relative humidity

factors from IMPROVE. The approach used natural background visibility estimates and the haze 

index following EPA Guidance. The modeled Bext showed a near 1:1 linear relationship (slope of 

0.78 and r2 of 0.46) with IMPROVE observed Bext. The regression excluded three points from 

July 7, 2002; the monitors were directly impacted by Canadian fires whose emissions were not 

modeled. 

How to Calculate Uniform Rate of Progress Goals

The key difference between SIPs from States with Class I areas and those States without Class I

areas, but may have sources that impact visibility on Class I areas, is the calculation of the 

baseline and natural visibility for their Class I areas and the determination of uniform rate of 

progress goals - expressed in deciviews - that provide for reasonable progress towards achieving 

natural visibility by 2064. It is the Class I states responsibility assess these calculations. The 

Class I States must also consult with those States, which may reasonably be anticipated to cause 

or contribute to visibility impairment in their Class I areas (40 CFR 51.308 (d)(1)(i-vi)). 

The baseline visibility conditions are calculated for the baseline period between 2002 and 2004. 

The average impairment for the 20 most and 20 least impaired days are determined for each 
16

calendar year and compiled into the average of three annual averages (40 CFR 51.308 (d)(2)(i)). 

The natural visibility conditions are determined for the same baseline period with the most and 

least impaired days determined by available monitoring data or an appropriate data analysis 

technique (40 CFR 51.308 (d)(iii-iv)). 

The calculations used to determine the natural conditions used as the 2064 visibility goal are 

described at the MANE-VU SIP Template document, June 10, 2004: Natural Background 

Visibility Conditions Considerations And Proposed Approach To The Calculation Of Natural 

Background Visibility Conditions At Mane-Vu Class I Areas, following EPA’s guidance at: U.S. 

EPA (2003). Guidance for Estimating Natural Visibility Conditions under the Regional Haze

Rule. EPA-454/B-03-005. September 2003.

EPA released guidance on June 7, 2007 to 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. The following figure illustrates an 

example of how Uniform Rate of Progress is calculated. 

 

Example Calculation of Uniform Rate of Progress

CMAQ Modeled Visibility Projections for 2018

The CMAQ air quality model was used to simulate base period emissions and future emissions. 

The modeling results for the base year period (2002) and the year representing the end of the first 

planning period (2018) are used to develop relative response factors (RRF) for each component 

of particulate matter identified previously in this TSD. The relative response factors are 

multiplied by the measured species concentration data during the base period (for the measured 

20% best and worst days). This results in daily future year species concentrations data. The 

projected concentrations are then used to derive daily visibility in deciviews and are averaged 

across all best and worst days to create the projected future visibility.
17

Brigantine in New Jersey is one of the Class I areas that New York affects. As an example, the 

results of this procedure are plotted along with the uniform progress glide slope below, and in 

Table 8.4 and Figure 8.1 in New Jersey’s SIP, taken from Figure 3-2, and 4-1B in 2018 Visibility

Projections, Appendix J-1 in New Jersey’s SIP.

Reasonable Progress Goals and Projected Future Visibility for the Brigantine 

Wilderness Area

Baseline 

Visibility

(2000-2004)

Natural Background 

Conditions for 2064

Reasonable Progress 

Goal for 2018 

2018 CMAQ 

Projections 

20% 

Worst 

Days 

29.0 12.2 25.1 25.1 

20% Best 

Days 

14.3 5.5 14.3 12.2 

(All values expressed as deciviews – lower deciviews means better visibility.) 

From: 2018 Visibility Projections (NESCAUM for MANE-VU States, May 2008), Appendix J-1 

in New Jersey’s SIP.

By interpolating between the base year of 2004 and the natural background year of 2064, the 

Progress Goal for 2018 is 25.1 deciviews, 3.9 deciviews lower than 29.0 deciviews starting 

point. State plans must adopt all reasonable controls, with the objective of improving visibility

to equal to, or better than, the Progress Goal. MANE-VU modeled the effects of reducing 

emissions on air quality and visibility. Based on the emission controls agreed-to by the MANEVU states, visibility at the Brigantine Class I area is forecast to improve to 25.1 deciviews in 

2018, meeting the Progress Goal. 

 

The modeling results presented in 2018 Visibility Projections, Appendix V in New York’s SIP, 

show all MANE-VU sites are projected to meet or exceed the uniform rate of progress goals for 
18

2018 on the 20 percent worst days. In addition, no site anticipates increases in visibility

impairment relative to the baseline on the 20 percent best days. 

Additional examples of the Rate of Progress tables and graphs for other Class I areas affected by

emissions from New York follow.
19

Summary of Photochemical Grid Modeling Results

In summary, the photochemical grid modeling, documented in New York’s Regional Haze SIP, 

follows EPA’s modeling guidance and is acceptable to EPA. All MANE-VU Class I area sites 

impacted by New York are projected to meet or exceed the uniform rate of progress goal for 

2018 on the 20 percent worst days. In addition, no site anticipates increased visibility impairment 

relative to the baseline on the 20 percent best days. 

Monitoring and Reasonably Attributable Visibility Impairment (RAVI)

Since New York does not have any Class I areas, the requirements to operate and maintain 

monitoring sites and assessing visibility impairment do not apply to New York.

Public Hearing and Response to Comments and Consultation with Federal Land Manager

New York State listed the Federal Land Manager’s concerns about New York’s Plan in their 

public notice of December 2, 2009. This notice also announced their public hearing on the plan, 

held January 5, 2010 at the New York State Department of Environmental Conservation’s offices 

in Albany, New York. Written comments were accepted though January 12, 2010. Comments 

were submitted by representatives of two power producing organizations. Comments and New 

York’s responses to those comments were submitted as part of its SIP submission as an 

attachment (unnumbered) to its letter of March 15, 2010 submitting the SIP.

Previously, New York held a hearing and responded to comments, as reported in Appendix B of 

New York’s Regional Haze SIP, where New York addressed the comments from the public, 

stakeholders, EPA and the Federal Land Manager. These actions were outlined in its letter of 

August 2, 2010.

On May 10, 2006, the MANE-VU State Air Directors adopted the Inter-RPO State/Tribal and 

FLM Consultation Framework that documented the consultation process within the context of 

regional phase planning, and was intended to create greater certainty and understanding among 

RPOs. MANE-VU states held ten consultation meetings and/or conference calls from March 1, 

2007 through March 21, 2008. In addition to MANE-VU members attending these meetings 

conference calls participants from VISTAS, Midwest RPO and relevant Federal Land Managers 

were also in attendance at many of these meetings and conference calls. In addition to the 

conference calls and meeting, the FLMs were given the opportunity to review and comment on 

each of the technical documents developed by MANE-VU. 

New York commits in section 10 of the Regional Haze SIP to ongoing consultation with the 

FLMs on Regional Haze issues throughout the implementation of the SIP as required in 40 CFR 

51.308(i)(4). 

Periodic SIP Revisions and Five-Year Progress Reports 

Consistent with the requirements of 40 CFR 51.308(g), New York committed to submitting a 

report on its contribution to reasonable progress (in the form of a SIP revision) to the EPA every

five years following the initial submittal of its regional haze SIP
20

CONCLUSIONS AND RECOMMENDED AGENCY ACTION

The overall reductions in emissions from New York’s Regional Haze SIP are sufficient to meet 

the requirements for New York’s contribution toward meeting the reasonable progress goals for 

Class I areas in the northeastern United States that are affected by New York’s emissions. Thus, 

EPA should approve New York Long Term Strategy to reduce regional haze for the first 

progress period ending in 2018. 

In order for EPA to give final approval to New York’s SIP, New York needs to submit the 

revised permits that include the appropriate levels of BART controls as described in the BART 

Technical Support Document. If New York does not submit its permits in a timely manner, EPA 

is proposing Federal Implementation Plans (FIPssss0 for these sources. Since EPA is including 

reductions from these sources in our potential FIP, these reductions will contribute to New 

York’s reaching its goal of meeting its contribution to reducing regional haze in the first 

planning period ending in 2018. 

EPA is also proposing alternative BART controls for two sources, as documented in materials in 

EPA’s docket for this proposed action. EPA is proposing to implement these controls, if in our 

final notice we believe they are appropriate, via a FIP. EPA should approve New York’s Part 

249, which it used to request BART analyses from sources in New York. EPA, in documents in 

the docket for this action, evaluates New York’s analysis of BART requirements for these 

sources, following EPA’s BART guidelines published at 70 FR 39158-39161; July 6, 2005.

In summary, the TSD recommends that EPA approve the portion of New York’s Regional Haze 

SIP that provides its contribution to meeting the reasonable progress goals for the affected Class 

I areas; and approve the BART determinations that meet the BART guidance if New York

submits final permits as revisions to the New York State Implementation Plan. In the alternative, 

EPA should prepare proposed FIPs in case New York does not finalize and submit their BARTaffected permits and propose FIPs for the two sources that EPA is proposing alternatives to New 

York’s BART recommendations. 

 

i

 NYSDEC SIP includes this table as Table 9-6, from the MANE-VU SIP Template: Long Term Strategy, Table 

10.4 in the July21, 2008 draft.