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### New Hampshire Regional Haze SIP Revision

Summaries of Conference Calls with Federal Land Man agers

August 28, 2008, and September 18, 2008

Conference calls with the Federal Land Managers (FL Ms) were arranged on two separate dates to discuss New Hampshire’s draft Regional Haze SIP. The first conference call covered all aspects of the plan except BART. The second confer ence call focused on New Hampshire’s BART analyses.

Conference Call – August 28, 2008

Attendees :

USDOI, National Park Service – Bruce Polkowsky, Hol ly Salazer USDOI, Fish and Wildlife Service – Tim Allen USDA, Forest Service – Anne Acheson, Scott Copeland USEPA – Anne Arnold, Anne McWilliams NHDES – Andy Bodnarik, Charlie Martone, Jeff Underh ill

Notes :

On August 27, 2008, the day before the conference c all, NHDES received preliminary comments on the draft SIP by email from the U.S. De partment of the Interior (DOI), National Park Service (NPS) and U.S. Fish and Wildlife Servi ce (FWS). On the day of the call, NHDES received preliminary comments by email from the U.S . Department of Agriculture, U.S. Forest Service (USFS). The ensuing discussion during the call indicated the consensus of the FLMs that the draft SIP was well written and comprehensi ve but needed some “slight adjustments.”

The call began with a general discussion of the ove rall SIP process with special reference to the vacatur of CAIR. All parties agreed that the vacat ur was a major issue that needed to be

addressed in the SIP but was not sufficient reason to delay moving toward completion of the SIP. It was noted that New Hampshire’s draft plan was heavily dependent on implementation of CAIR by upwind states, even though New Hampshire was not a CAIR state itself.

It was suggested that New Hampshire’s SIP make refe rence to CAIR up front, address the uncertainty created by the vacatur, and include a c ommitment to review the situation as it evolves. The review would include an updating of e mission inventories, a check of other

states’ SIPs to determine whether the MANE-VU “Ask” (or equivalent measures) was incorporated, a comparison of “where we are now ver sus where we thought we would be,” and appropriate revisions to the SIP by the first progr ess report due in 2012.

The remainder of the call was devoted to specific p oints raised by the FLMs in their emailed preliminary comments. New Hampshire’s responses to these comments are provided in the accompanying document, “New Hampshire Regional Haze SIP Revision: Response to Federal Land Managers’ Comments.” Some additional points a rising from the conference call were as

follows:

• It was suggested that 1996 and 1999 national emissi ons inventory data were extraneous

and could be removed from the SIP.

• A VISTAS report on smoke emissions (from prescribed fires and woodstoves) was available and might serve as a useful reference to New Hampshire.Page 2 of 2

• CALMET and CALPUFF were not modeled by MANE-VU exac tly per EPA guidance. This distinction should be explained in the text.

• The SIP includes no contingency plan for discontinu ance of monitoring sites. In the event of reduced federal funding or other cause, Ne w Hampshire should consult with

the FLMs on what actions could be taken to avoid lo ss of monitoring data.

• It should be noted in the SIP that Prevention of Si gnificant Deterioration and regional haze planning are complementary programs.

• Final comments from USDA would be delayed perhaps 9 0 days.

Conference Call – September 18, 2008

Attendees :

USDOI, National Park Service – Bruce Polkowsky, Hol ly Salazer USDOI, Fish and Wildlife Service – Sandra Silva USDA, Forest Service – Scott Copeland

USEPA – Anne McWilliams NHDES – Andy Bodnarik, Charlie Martone, Gary Milbur y, Jeff Underhill

Notes :

This conference call was reserved for discussion of New Hampshire’s BART analyses. NHDES received draft comments on the BART analyses from the National Park Service by email on September 16, 2008. Discussion during the conference call adhered closely to, and reiterated points contained in, the written comment s. As a general comment, it was stated that New Hampshire’s BART analyses needed more documenta tion and fine-tuning, with greater detail in the description of sources. It was reque sted that New Hampshire submit draft permits

for the BART sources to the FLMs when the drafts be come available.

The parties acknowledged that the latest projected costs of SO 2 scrubber controls for Merrimack Station were very high at around $1,000/kW – about triple what they were when first estimated

in 2003. NPS has found that SO 2 scrubbers for other BART-eligible facilities typic ally have cost half this amount or less, but costs have been rising sharply. It was suggested that the BART analyses focus not just on incremental costs.

Some recent BART analyses conducted elsewhere have evaluated the project costs in terms of dollars per deciview of visibility improvement. BA RT control costs have been reported to be on the order of $10-15 million per deciview.

New Hampshire’s responses to specific points raised by the FLMs in their emailed comments may be found in the accompanying document, “New Ham pshire Regional Haze SIP Revision: Response to Federal Land Managers’ Comments.”

Postscript :

The day after September 18 conference call, Don She pherd sent an email to NHDES providing technical information and costs on BART proposals f or facilities in other parts of the country.

NHDES received final comments from DOI – NPS in a l etter dated September 26, 2008. The final comments were not substantially changed from the preliminary comments received earlier.