### 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) describe s EPA’s supporting documentation for its proposed actions on the reasonable progress section of New York ’s Regional Haze State Implementation Plan (SIP)
. Inaddition, 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 b y New York in our evaluation of BART requirements for BART
- eligible sources in New York . Evaluations of New York’s BART dete rminations 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 b y the Clean Air Act to reduce the effects of anthropogenic polluti on on s cenic views in areas designated at the Clean Air Act as Class Iareas, at major Nati onal 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 protect ed areas in nearb y s tates: Lye Brook Wilderness Area, VT Brigantine Wildlife Refuge, NJ Presidential Range
- Dry

River Wilderness Area and Gr eat 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 Iareas 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 Mid
Atlantic/Northeast Visibility Union (MANE
- VU) to determi ne the amount of emission reductions needed in the first ten y ear 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 Cla ss I areas b y 2064. MANE - VU states agreed to a set of reasonabl y implementable emission reduction programs that, when modeled with other existing measures, are forecast to meet the projected visibility improvement target by

2018.2

New York’s SIP include s 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 SI P and other controls listed in the SIP were recently ado pted separately from this SIP or already

exist ed 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) p repared the Regional Haze SIP, which the Commissioner submitted for the State
. The main submittal was on March 15, 2010 , contai ning 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 24 9 rule for BART - eligible sources to determine BART controls on August 10, 2010. New York pro vided 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 d escribing 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 MANE
VU 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 mo dels 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 pr otected parks and wilderness areas. The specific measures to be adopted b y the states include: implementing Best Available Retrofit Technology (BART) per EPA guidelines on old sources, reducing emissions from 167 Electric Generating Units b y an average o f ninet y percent or more, and implementing a geographicall y - specified program reducing sulfur in fuel oil
. Specificall y , 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
- in
fuel 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 In formation**  **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 (PM 2.5 ) (e.g., sulfates, nitrates, organic carbon, elemental carbon, and soil dust) and their precursors (e.g., sulfur dioxide (SO 2 ), nitrogen oxides (NO x ), and in some cases, ammonia (NH 3 ) and volatile organic compounds (VOC)). Fine particle precursors react in the atmosphere to form fin e particulate matter which impairs visibility by scattering and absorbing light. Visibility3

impairment reduces the clarity , color, and visible distance that one can see. PM 2.5 can also cause serious health effects and mortality in humans and contributes to environmental effects such as acid deposition and eutrophication. The average visual range 1 in 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 fo r 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 remed yi ng of any existing, impairment of visibility in mandatory

Class IFederal are as 2 which impairment results from manmade air pollution.” On December 2, 1980, the Environmental Protection Agency (EPA) promulgated regulations to address visibility impairment in Class Iareas that is “reasonably attributable” to a single source or smal l 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 toward s the national goal of achieving natural visibility conditions in Class Iareas. 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 Technol ogy (BART) controls for the purpose of eliminating or reducing visibility impairment. **Determination that**  **New York State Impact**  **s Visibility in Class I Areas**  New York State listed the Class Iareas where its emissions have an impact based on the anal ys es i n the report Contributions to Regional Haze in the Northeast and Mid
- Atlantic United States prepared b y NESCAUM (Northeast States for Coordinated Air Use Management). The report used a variety

of techniques, listed below, for determin ing the relative contributions of its states to visibility

impairment in Class Iareas . Since s ulfate t ypicall y accounts for 70

– 82 percent of estimated particle
- induced light extinction at northeastern and mid
- Atlantic Class Isites, the report used the effect of each state ’s emissions on sulfat e concentrations in the Class Iarea as a surrogate for transported pollutants that impair visibility . Using sulfates as an indicator of effect on visibility in Class Iareas is acceptable in this

1 Visual range is the greatest distance, in kilometers or miles, at which a dark object can be viewed against the sky
. 2 Areas designated as mandatory Class I Federal areas consist of nationa l 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 wit h 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 ‘‘mandato ry 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, w e mean a “mandatory Class I Federal area.” 3 Albuquerque/Bernalill o County in Ne w 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).4

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 Iarea and the effects of weather patterns. The report found a high level of ov erall 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 In cremental pr obability Lagrangian trajectory technique Cluster
- weighted probability Lagrangian trajectory technique Emissions times upwind probability Empirical/trajectory hy brid Source apportionment approaches Receptor model/trajectory hy brid REMSAD tagg ed 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 appr oaches and contributes a large percentage of visibility
- impairing sulfate to several Class Iareas, making control if its contributions essential to reducing impairment to visibility at Class I areas in the northeast and mid
- atlantic states. **STATE’S SUB MITTAL**  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 Iarea. These goals were developed b y states with Class Iareas, in consultation with states that affect visibility in the Class Iareas. 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 area s , with a long
- ter m emission strategy , describing its role in the consultation processes, and how the SI P 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 c ontrol 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 i dentified 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 MANE
VU 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 2018.5

By adopting all the measures identified in the MANE
- VU anal ys is and applying BART to el igible sources, New York LTS would a chieve its share of emissions reductions that are reasonable and , according to the results of atmospheric mo deling , will achieve the reasonable progress goals for the nearb y C lass I area s . The following chart compares m easures adopted b y New York with the measures agreed to b y the MANE
- VU states (often referred to as the MANE
VU ‘ask’). **MANE -**  **VU ‘As**  **k ’**  **Measures** ***** **Measures Adopted or Action Taken by New York**  Timely implementation of BART on all sources identified as BA RT

– eligible Implementing BART on all eligible sources, except those that do not meet BART eligibility or have emission limits less than the 250 ton s per y ear BART eligibility thresholds in their permits
. Low sulfur fuel oil strategy : for N Y: distillate o il 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 201 2 New York Cit y has adopted: No. 2: 15 ppm by

2012 (fo llowing state law) No. 4: 0. 1 5 percent by

201 2 No. 5, No. 6 & h eavier: 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 R eductions 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 efficienc y, 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 specifi call y modeled and are not binding commitments on the part of NYS : • The revisions for RACT for major sources of PM2.5 greater than 100 t ons 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 Electricit y Demand Day Units, • Emission reductions resulting from consent orders, and • The continued evaluation of other control measures including energy efficiency , alte rnative 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 Iareas reaching reasonable progress goals by 2018.6

**• BART Controls**  A more d etailed 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 twent y sources that could be subject to BART . Thirteen sources were EGUs and seven were other major source s. 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. Onl y 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 no t sent its finalized permits for these sources, as the permits with the reductions need to be submitted to EPA as SI P revisions to become effective. EPA is discussing the potential approvability of these SI P revisions in the proposed action, based on publ ic notices on the permits. Since New York has ye t 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 SI P 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 SI P. **• Electric Ge**  **nerating 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 goal s for the five Class Iareas 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 b y sources under CAIR. So, New York chose to evaluate c ontrol s 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 SO 2 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 n inety 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 8 3 percent. This means that 9,110 tons per y ear of sulfur emissions must be available, above and bey ond the reductions required for other parts of the Regional Haze SIP , to fulfill this MANE
VU 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, w ill be shutdown. The MANE
- VU modeling included the estimate of BART redu ctions 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 in formation for these two sources, from the MANE
- VU final modeling. i Kodak unit U15 was estimated to emit 14,216 tons of sulf ur dioxide after BART controls. After further anal ys is, 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 ye ar eliminated. At LaFarge Building Materials, 4,400 tons per y ear of sulf ur were to be emitted in the estimated BART analy sis used in the modeling. LaFarge will cease operations. Therefore, the additional reductions bey ond the BART reductions already in the model total 11,195 tons per year from Kodak and L aFarge combined . Th ese reductions are bey ond 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 so urce sulfur e missions. 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 originall y 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 poi nt 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 -2,074.68

**• Sulfur in Fuel Oil**  Under the MANE
- VU agree ment to reduce emissions of sulfur in fuel oil, Phase 1 of the proposed standards establish es limits of: 0.05 percent sulfur b y 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
. T hese standards are to go into effect no later than 2012. In addition, the MANE
- VU strategy provides for a phase two reductions f or 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. N ew York State’s Environmental Conservation Law, section 19
- 0325: Sulfur reduction requirements : limits the sulfur content of number two heating o il to fifteen parts per million by 2012. T his requirement is one portion of the control strategies agreed to b y the MANE
- VU states. However, the final modeling included reductions in number four and six oil to .25% and .6%, respectively . These reduction s 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 M ANE - VU modeling included a reduction of sulfur emissions in New York State of 91,701 tons per ye ar 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 SI P, EPA calculates that the new sulfur
- in
- fuel law will reduce emissions by 54,090 tons per y ear. Th at would le ave 17,66 9 tons per year for New York to obtain through expansion of its limits on lower sulfur oil. There are at least two ways that th e need to include 17,669 tons in this plan can be addressed. First of all, when New York State adopt s the rest of it s 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 it s 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 b een 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 p ortion 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 Haz e Plan, but were not adopted specificall y 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 tp y), • 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 Electricit y Demand Day Units, • Emission reductions res ulting 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 analy ses was developed by Mid
Atlantic 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 NO x , PM 10 , PM 2.5 , and SO 2 . The BART gu idelines direct states to exercise judgment in deciding whether VOC and NH 3 impair visibi lity in their Class I area(s). MANE - VU demonstrated that anthropogenic emissions of sulfates are the major contributor to PM 2.5 mass and visibility impairment at Clas s Iareas in the Northeast and Mid
Atlantic region. It was also determined that the total ammonia emissions in the MANE
- VU region are extremely

small. In addition , VOC emissions are aggressivel y controlled through New York’s ozone SIP s . Therefore, the po llutants New York considered under BART are NO x , PM 10 , PM 2.5 , and SO 2 . New York’s emission inventory for its Haze SIP was taken from the MANE
- VU emissions inventory used for the modeling anal ys is 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 t yp o in the original table in New York’s SI P. New York used the opportunity

to mak e 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
- f uel legislation and New York’s planned sulfur
- in
- fuel rule. **M odeling to Support the L**  **ong Term Strategy and**  **to Deter**  **mine 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 anal ys is is a complex technical evaluation that began with selection of the modeling sy stem. M ANE - VU used the following modeling s ys tem:  Meteorological Model: The Fifth
- Generation Pennsylvania State University /National Center for Atmospheric Research (NCAR) Mesoscale Meteorological Model (MM5) version 3.6 is a nonhy drostatic, prognostic meteorological model routinel y used for urban
- and regional
- scale photochemical, PM 2.5 , and regional haze regulatory modeling studies.10

 Emissions Model: The Sparse Matrix Operator Kernel Emissions (SMOKE) version 2.1 modeling s y stem is an emissions modeling sy stem 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 Multisc ale Air Quality (CMAQ) version 4.5.1 and REMSAD modeling s ys tem 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 anal ys is.  Air Quality

Model: The California Puff Model (CAL PUFF), version 5 is a non
- stead y state 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 PM 2.5 modeling platform that all member states could use to model their L TSs to demonstrate reasonable progress by 2018 in meeting the ultimate go al of natural visibility conditions by

2064. The New York State Department of Environmental Conservation (NYSDEC) was the lead agency for coordinating and running the m odeling platform used b y the MAN E - VU RPO. Modeling centers responsible for running the platform included the NYSDEC, the Universit y 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 PM 2.5 and PM 2.5 precursors and a sophisticated meteor ological model (The Pennsylvania State University /National Center for Atmospheric Research Mesoscale Meteorological Model) to produce speciated PM 2.5 concentrations over the eastern United States. The meteorological data used in the meteorological model w as for the 2002 base year. The photochemical grid model was run with the base ye ar meteorology and base ye ar 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 b y changing meteorology
. **Conceptual Description of the**  **Modeling Situation** A conceptual model describes how weather patterns affect the formation and transport of PM 2.5 , accounting for emissions and photochemistry
. In the case of regional haze, emissions of sulfur, nitrogen and carbon, especiall y 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 vi sibility 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
. App endix A is a document prepared b y MANE - VU that includes numerous methods that provide informati on about how haze occurs in the northeast United States and the sources of haze. The11

methods include emissions information (and the distance to sources), trajec tory anal ys es, and impacts predicted b y dispersion and various grid models. Monitoring data is used to show that sulfates are the predominate species that reduce visibility at the Class I area s in MANE
- VU . The various models support the hy pothesis 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 N ESCAUM to perform air quality simulations. These are the Community Multi
- scale Air Qualit y modeling s ys tem (CMAQ; By

un and Ching, 1999) and the Regional Modeling Sy stem for Aerosols and Deposition (REMSAD; SAI, 2002). CMAQ was developed b y EPA, while REMSA D was developed b y IC F Consulting/Sy stems 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 stud ies (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/hd2 007/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 collective ly 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 Feder al Class Iareas. 4 These states or regions would then be subject to the consultation provisions of the Haze Rule. The Haze Rule also requires a “pollution apportionment” anal ys is as part of the long
- term emissions management strategy for each site. As des cribed in the Conceptual Description portion of this TSD, sulfate alone accounts for any where from one
- half to two
- thirds of total fine particle mass on the 20 percent haziest day s at MANE - VU Class I sites. As a result of the dominant role of sulfate in th e formation of regional haze in the Northeast and Mid
- Atlantic region, MANE
- VU concluded that an effective emissions management approach would rely heavil y on broad
- based regional SO 2 control efforts in the eastern United States. **Use of Air Quality Mode ls:**  **Area of Influence for MANE -**  **VU Class I Areas**

4 The Class I designatio n 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 Iareas calculat e the baseline and natural visibility for their Class Iareas, and the determination of reasonable progress goals. Class IStates calculate baseline visibility conditions for the period between 2002 and 2004. The average impairment for the most and least impaired day s are determined for each calendar y ear 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 day s determined by

available monitoring data or an appropriate data anal ys is technique (40 CFR 51.308 (d)(iii
- iv)). There are seven Class I areas located in the Mid
- Atlantic and No rtheast. In order to identify states whose emissions are most likely to influence visibility

in MANE
- VU Class Iareas, 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 SI P. Based on that work, MANE
- VU concluded that it was appropriate to define an “Area of In fluence” (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 Iareas in 2002. The Visibility Improvement State and Tribal Association of the Southeast (VISTAS) 5 also conducted an AOI anal ys is, 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 VI STAS Class I area. The primary

contribution assessment tool used for the New York Regional Haze SIP w as the Regional Modeling S ys tem for Aerosols and Deposition (REMSAD) (SAI , 2002). A significant feature of the REMSAD work used to evaluate regional contributions is that N ESCAUM reprocessed the SO 2 emission data from each state to take advantage of REMSAD ’s tagging capabilities. Thus, all SO 2 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 i n this TSD, REMSAD was used to simulate the annual average impact of each state’s SO 2 emis s ion sources on the sulfate fraction of PM 2.5 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 SI P. 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 Assessmen**  **t 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 significantl y to the haze problem in that particular Class I area. With re spect 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, TN13

30 percent of the sulfate at Class Iareas located within and nearby to the MANE
- VU region. The contribution of sulfate at these Cla ss I areas from other regions, Canada, and outside the modeling domain were also significant. **Use of Air Quality Models: CMAQ Modeling of**  **R elative**  **C ontributions**  **of P**  **ollutants to**  **V isibility**  **I mpairment**  An important step toward identifying reasonable pro gress 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 usin g CMAQ to evaluate visibility and air quality

impacts from various groups of emissions and pollutant scenarios in the Class Iareas on the 20 percent worst visibility day s. Regarding which pollutants are most significantly impacting visibility in the MAN E - VU region, MANE - VU’s contribution assessment, demonstrated that sulfate is the major contributor to PM 2.5 mass and visibility

impairment at Class Iareas in the Northeast and Mid
- Atlantic region. Sulfate particles commonly account for more than 50 perce nt of particle
- related light extinction at northeastern Class I areas on the clearest day s and for as much as or more than 80 percent on the haziest day s. In particular, for the Brigantine National Wildlife Refuge Class Iarea, on the 20 percent worst visi bility

day s in 2000

– 2004, sulfate accounted for 66 percent of the particle extinction. After sulfate, organic carbon (OC) consistently accounts for the next largest f raction of light extinction. Organic carbon accounted for 13 percent of light extinctio n on the 20 percent worst visibility

day s for Brigantine, followed by nitrate that accounts for 9 percent of light extinction. The emissions sensitivity anal ys es conducted b y MANE - VU predict that reductions in SO 2 emissions from EGU and non
- EGU indus trial 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 rel y heavily on broad
- based regional SO 2 control efforts in the eastern United States. **Use of CMAQ Modeling to Develop 2018 Control Case Predict ions:**  **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 Feb ruary

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 f rom 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, varyingonl y emission inputs. To ensure consistency between modeling groups, a benchmark test was conducted b y 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 anal ys is. The MM5 model provides a reasonable representation of weather conditions at the surface and aloft. **Use of CMAQ Modeling to Develop 2018 Co ntrol 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, r espectivel y. A 12 - km inner domain was selected to better characterize air quality in MANE
- VU and surrounding RPO regions. This domai n 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 lay ers and the size of each lay er in the model. The lay ers 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 PM 2.5 is emitted, forms and is tran sported. **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 int ended 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 y ear for regional haze, MANE
- VU and New York are using 2002 as the baseline y ear. Future y ear inventories were developed for the years 2009, 2012 and 2018 based on the 2002 base year. These future ye ar 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 b y the individual states in the MANE
- VU area. MARAMA then coordinated and qualit y 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

I mp rovement 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 y ear 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 y ear estimations of EGUs is presented in Appendix E o f the SIP

– MARAMA’s Development of Emission Projections f or 2009, 2012, an d 2018 f or Non - EGU Point, Area, and Nonroad Source i n 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 b y NESCAUM , listed as Appendix R of New York ’s SI P. NESCAUM evaluated the 2002 annual 12 km resolution meteorological fields generated b y 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 T echniques 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 M M5 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 ye ar 2002 b y cooperative modeling efforts from NYDEC, UMD, NJDEP, Rutgers, VADEP, and NESCAUM. CMAQ Performance for PM 2.5 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 locat ion and time for evaluation. The goal and the criteria for PM 2.5 evaluation suggested b y Bo yl an and Baker (2004) were adopted b y every R PO 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 PM 2.5 species from 40 STN sites and 17 IMPROVE sites within the MANE
- VU Region were paired with measurements and statistically

anal yz ed to generate MFE and MFB values. Cons idering CMAQ performance in terms of MFE and MFB goals, sulfate, nitrate, OC, EC, and PM 2.5 all had the majority of data points within the goal curve, some were between the goal and acceptable criteria, and onl y a few were outside the criteria curve. Onl y 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 PM 2.5 sulfate, followed by PM 2.5 , EC, nitrate, OC, and then fine soil. Regional haze modeling a lso requires CMAQ performance evaluation for aerosol extinction coefficient (B ext ) and the haze index. Modeled daily aerosol extinction at each improve site was calculated following the IMPROVE formula with modeled daily PM 2.5 species concentration and re lative humidity factors from IMPROVE. The approach used natural background visibility estimates and the haze index following EPA Guidance. The modeled B ext showed a near 1:1 linear relationship (slope of 0.78 and r2 of 0.46) with IMPROVE observed B ext . The regression excluded three points from July 7, 2002; the monitors were directl y 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 Iareas an d those States without Class I areas, but may

have sources that impact visibility on Class Iareas, 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 dec iviews
- that provide for reasonable progress towards achieving natural visibility

by 2064. It is the Class I states responsibility assess these calculations. The Class IStates must also consult with those States, which may reasonabl y be anticipated to c ause 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 day s are determined for each16

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 day s determined by available monitoring data or an appropriate data anal ys is 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 IAreas , 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 day s, and ensure no degr adation in visibility for the least impaired day s over the S IP period. The following f igure illustrates an example of how Uniform Rate of Progress is calculated.

**Example C**  **alculat ion of Uniform Rate of Progress**  **CMAQ Modeled Visibility Projections for 2018**  The CMAQ air qualit y m odel was used to simulate base period emissions and future emissions. The modeling results for the base ye ar period (2002) and the ye ar representing the e nd 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 day s). This results in daily future y ear species concentrations data. The projected concentrations are then used to derive daily visibility in deciviews and are averaged across all best and worst day s 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 SI P, taken from Figure 3
- 2, and 4
- 1B in 2018 Visibility Projections, Appendix J
- 1 in New Jersey ’s SI P.

**Reasonable Progress Goals and Projected Future Visibility for the Brigantine Wilderness Area**  Baseline Visibility (2000
- 200 4) Natural Background

Conditions for 2064 Reasonable Progress Goal for 2018 2018 CMAQ

Projections 20% Worst Day s 29.0 12.2 25.1 25.1 20% Best Day s 14.3 5.5 14.3 12.2 (All values expressed as deciviews

– lower deciviews means better visibili ty. )

From: 2018 Visibility Projections (NESCAUM for MANE
- VU States, May 2008), Appendix J
- 1 in New Jersey’s SIP. By interpolating between the base y ear of 2004 and the natural background y ear 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 quali ty

and visibility . Based on the emission controls agreed
- to by the MANE
VU 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 for18

2018 on the 20 percent worst day s . In addition, no site anticipates increases in visibility impairment relative to the baseline on the 20 percent best day s. 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 , follow s EPA’s modeling guidance and is acceptable to EPA. All MANE
- VU Class Iarea sites impacted b y New York are projected to meet or exceed the uniform rate of progress goal for 2018 on the 20 percent worst day s. In addition, no site anticipates increase d visibility impairment relative to the baseline on the 20 percent best days. **Monitoring and Reasonably Attri**  **butable Visibility Impairment (RAVI)** Since New York does not have an y Class I areas, the requirements to operate and maintain monitoring sites and assessing visibility impairment do not apply to New York. **P ublic Hearing and Response to Comments and Consu**  **ltation 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 announc ed 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 b y 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 H aze 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/Trib al and FLM Consultation Framework that documented the consultation process within the context of regional phase planning, and was intended to create greater certaint y and understanding among RPOs. MANE - VU states held ten consultation meetings and/or conf erence calls from March 1, 2007 through March 21, 2008. In addition to MANE
- VU members attending these meetings conference calls participants from VI STAS, Midwest RPO and relevant Federal Land Managers were also in attendance at many of these meetings and conference call s . Inaddition to the conference calls and meeting, the FLMs were given the opportunity to review and comment on each of the technical documents developed b y M ANE - VU. New York commits in section 10 of the Regional Haze SIP to ongoing c onsultation 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 committ ed to submitting a report on its contribution to reasonable progress (in the form of a SIP revision) to the EPA every five y ears following the initial submittal of its regional haze SIP20

**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 Iareas in the northeastern United States that are affected b y 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 SI P, 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 th ese 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 so urces, 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 reque st BART analy ses from sources in New York. EPA, in documents in the docket for this action , evaluates New York’s analy sis of BART requirements for these sources, following EPA’s BART guidelines published at 70 FR 39158 - 39161; July 6, 2005. In summary , the TSD recommend s 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 submit s 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 BART
affected 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 Ju ly21, 2008 draft.